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Beekeepers Ask EPA to Remove Pesticide Linked to Colony Collapse Disorder, Citing Leaked Agency Memo

For immediate release: December 8, 2010


Heather Pilatic, Pesticide Action Network
cell: 415.694.8596

Jay Feldman, Beyond Pesticides
202.543.5450, ext 15

Beekeepers Ask EPA to Remove Pesticide Linked to Colony Collapse Disorder,
Citing Leaked Agency Memo

Pesticide Already Illegal in Germany, Italy & France Based on Scientific Findings

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SAN FRANCISCO and WASHINGTON, D.C – Beekeepers and environmentalists today called on EPA to remove a pesticide linked to Colony Collapse Disorder (CCD), citing a leaked EPA memo that discloses a critically flawed scientific support study. The November 2nd memo identifies a core study underpinning the registration of the insecticide clothianidin as unsound after EPA quietly re-evaluated the pesticide just as it was getting ready to allow a further expansion of its use. Clothianidin (product name “Poncho”) has been widely used as a seed treatment on many of the country’s major crops for eight growing seasons under a “conditional registration” granted while EPA waited for Bayer Crop Science, the pesticide’s maker, to conduct a field study assessing the insecticide’s threat to bee colony health.

Bayer’s field study was the contingency on which clothianidin’s conditional registration was granted in 2003. As such, the groups are calling for an immediate stop-use order on the pesticide while the science is redone, and redesigned in partnership with practicing beekeepers. They claim that the initial field study guidelines, which the Bayer study failed to satisfy, were insufficiently rigorous to test whether or not clothianidin contributes to CCD in a real-world scenario: the field test evaluated the wrong crop, over an insufficient time period and with inadequate controls.

According to beekeeper Jeff Anderson, who has testified before EPA on the topic, “The Bayer study is fatally flawed. It was an open field study with control and test plots of about 2 acres each. Bees typically forage at least 2 miles out from the hive, so it is likely they didn’t ingest much of the treated crops. And corn, not canola, is the major pollen-producing crop that bees rely on for winter nutrition. This is a critical point because we see hive losses mainly after over-wintering, so there is something going on in these winter cycles. It’s as if they designed the study to avoid seeing clothianidin’s effects on hive health.”

Clothianidin is of the neonicotinoid family of systemic pesticides, which are taken up by a plant’s vascular system and expressed through pollen, nectar and gutation droplets from which bees then forage and drink. Scientists are concerned about the mix and cumulative effects of the multiple pesticides bees are exposed to in these ways. Neonicotinoids are of particular concern because they have cumulative, sublethal effects on insect pollinators that correspond to CCD symptoms – namely, neurobehavioral and immune system disruptions.

According to James Frazier, PhD., professor of entomology at Penn State’s College of Agricultural Sciences, "Among the neonicotinoids, clothianidin is among those most toxic for honey bees; and this combined with its systemic movement in plants has produced a troubling mix of scientific results pointing to its potential risk for honey bees through current agricultural practices. Our own research indicates that systemic pesticides occur in pollen and nectar in much greater quantities than has been previously thought, and that interactions among pesticides occurs often and should be of wide concern." Dr. Frazier said that the most prudent course of action would be to take the pesticide off the market while the flawed study is being redone.

Clothianidin has been on the market since 2003. With a soil half-life of up to 19 years in heavy soils, and over a year in the lightest of soils, commercial beekeepers are concerned that even an immediate stop-use of clothianidin won’t save their livelihoods or hives in time.

“We are losing more than a third of our colonies each winter; but beekeepers are a stubborn, industrious bunch. We split hives, rebound as much as we can each summer, and then just take it on the chin – eat our losses. So even these big loss numbers understate the problem,” says 50-year beekeeper, David Hackenberg. “What folks need to understand is that the beekeeping industry, which is responsible for a third of the food we all eat, is at a critical threshold for economic reasons and reasons to do with bee population dynamics. Our bees are living for 30 days instead of 42, nursing bees are having to forage because there aren’t enough foragers and at a certain point a colony just doesn’t have the critical mass to keep going. The bees are at that point, and we are at that point. We are losing our livelihoods at a time when there just isn’t other work. Another winter of ‘more studies are needed’ so Bayer can keep their blockbuster products on the market and EPA can avoid a difficult decision, is unacceptable.”  

Citing the imminent economic and environmental hazards posed by the continued use of clothianidin, the National Honey Bee Advisory Board, Beekeeping Federation, Beyond Pesticides, Pesticide Action Network, North America and Center for Biological Diversity are asking EPA administrator Lisa Jackson to exercise the Agency’s emergency powers to take the pesticide off the market.

"The environment has become the experiment and all of us – not just bees and beekeepers – have become the experimental subjects," said Tom Theobald, a 35-year beekeeper. "In an apparent rush to get products to the market, chemicals have been routinely granted "conditional" registrations. Of 94 pesticide active ingredients released since 1997, 70% have been given conditional registrations, with unanswered questions of unknown magnitude. In the case of clothianidin those questions were huge. The EPA's basic charge is "the prevention of unreasonable risk to man and the environment" and these practices hardly satisfy that obligation. We must do better, there is too much at stake."



Letter to the EPA (appended)
Clothianidin & CCD Fact Sheet (appended)
Timeline of the clothianidin decision (available)
Copy of the November 2nd memo, as well as other relevant EPA documentation (available)


Available for interviews

Tom Theobald,  [email protected], 303.652.2266
Beekeeper and owner of the Niwot Honey Farm for 35 years. One of the founders of the Boulder County Beekeepers' Association and its president for 30 years, he began beekeeping after 10 years with IBM. In addition to operating a commercial beekeeping operation he has at different times been a boatman on western whitewater and Montana trout rivers, a hunting guide and horse packer, volunteer fire chief in his home town, and for the past 20 years, a freelance writer. Tom was the last County Bee Inspector in the state of Colorado, a position created in 1891 and retired in 2000.
Jeff Anderson,  [email protected], 209.847.4731
Beekeeper, with 34 years experience. He owns California Minnesota Honey Farms a family owned and run operation of just under 3000 bee colonies. Jeff is currently a member of the National Honey Bee Advisory Board, a joint board formed by the two National beekeeping organizations, The American Beekeepers Federation, and the American Honey Producers organization to deal with pesticide issues at the National level. 

David Hackenberg,  [email protected], 813.713.1239
Beekeeper who first discovered a mysterious disappearance of honeybees now known as Colony Collapse Disorder (CCD). He is featured in the films Vanishing of the Bees and  Nicotine Bees, as well as this 60 Minutes segment. Mr. Hackenberg founded Hackenberg Apiaries in 1962 as a high school vo-ag project. Today, he and his son operate approximately 3,000 hives of bees in 5 states for pollination and honey. David has served as president of the American Beekeeping Federation. He currently sits as co-chair on the National Honey Bee Advisory Board.

James Frazier, Ph.D, professor of entomology at Penn State's College of Agricultural Sciences
[email protected], 814-863-7345
Dr. Frazier works at the Center for Pollinator health at Penn State, where his research focuses on synergistic and sublethal effects of multiple pesticides on the chemical senses and chemically mediated behaviors of honeybees in relation to honeybee health and CCD in collaboration with Chris Mullin and Maryann Frazier. He also researches chemical ecology: specifically, the structure and function of insect chemosensory systems and the impact of sensory systems on chemically mediated behavior. Penn State's Pollinator health center is a leading institution in research on rapid pollinator population decline.


Clothianidin & CCD :: Fact Sheet

by Pesticide Action Network, North America & Beyond Pesticides


What is Colony Collapse Disorder? Colony Collapse Disorder, or CCD, is the name given to the mysterious decline of honeybee populations around the world beginning around 2006. Each winter since, one-third of the U.S. honeybee population has died off or disappeared (more than twice what is normal). While CCD appears to have multiple interacting causes including a mix of pathogens, a range of evidence points to sub-lethal pesticide exposures as important contributing factors. Neonicotinoids are a particularly suspect class of insecticides, especially in combination with the dozens of other pesticides found in honeybee hives. Key symptoms of CCD include: 1) inexplicable disappearance of the hive’s worker bees; 2) presence of the queen bee and absence of invaders; 3) presence of food stores and a capped brood.


What are “conditional registrations”?Clothianidin was given a conditional registration in 2003. EPA is supposed to license ("register") pesticides only if they meet standards for protection of environment and human health. But pesticide law allows EPA to waive these requirements and grant a "conditional" registration when health and safety data are lacking in the case of a new pesticide, allowing companies to sell the pesticide before EPA gets safety data. The company is supposed to submit the data by the end of the conditional registration period. Conditional registrations account for 2/3 of current pesticide product registrations. It is a common practice for the EPA’s Office of Pesticide Programs, to afford rapid market access for products that remain in use for many years before they are tested. According to the Natural Resources Defense Council, of the 16,000 current product registrations: 11,000 (68%) have been conditionally registered; almost 8,200 products have been conditionally registered (“CR status”) since 2005; approximately 5,400 products have had CR status since 2000; and over 2,100 products have had CR status since 1990.


European examples:France:Imidacloprid has been banned as a seed dressing for sunflowers in France since 1999, after a third of French honeybees died following its widespread use. Five years later it was also banned as a sweetcorn treatment. In 2008, French authorities declined to register clothianidin. French beekeepers report hive recovery as a result of the bans. Germany: In May 2008 German authorities banned seed treatment with neonicotinoids following a large bee kill in the Baden-Württemberg region of Germany which was linked to clothianidin use. Italy: As a precautionary measure, Italy’s agriculture ministry suspended neonicotinoids in 2008. In 2009, Italy's neonicotinoid-free corn sowing resulted in no cases of widespread bee mortality in apiaries around the crops. This had not happened since 1999.


Pesticide questions:

            Neonicontinoids: Clothianidin is of the neonicotinoid family of systemic pesticides, which are taken up by a plant’s vascular system and expressed through pollen, nectar and gutation droplets from which bees then forage and drink. Neonicotinoids kill sucking and chewing insects by disrupting their nervous systems. Beginning in the late 1990s, these systemic insecticides began to take over the seed treatment market. Clothianidin is Bayer’s successor product to imidacloprid, which recently went off patent. Both are known to be toxic to insect pollinators, and are lead suspects as causal factors in CCD. Together, the two products accounted for over a billion dollars in sales for Bayer Crop Science in 2009. Imidacloprid is the company’s best-selling product and among the most widely used insecticides in the U.S. Starting in about 2004, seed companies in the U.S. began to market seeds treated with a 5-X rate of neonicotinoids (1.25mg/seed, compared with the traditional 0.25 mg/seed).

            “Chemical cocktail” effect – or synergistic and cumulative pesticide exposures: EPA regulates on a chemical-by-chemical basis, but interacting chemicals can have synergistic effects at very low levels — where a “chemical cocktail” of multiple interacting chemicals combine to have greater effects than would be predicted by traditional toxicological models. Traditional toxicological models proceed from the 16th century maxim that “the dose makes the poison.” Pesticides can also have a cumulative "toxic loading" effect both in the immediate and long term. Neonicotinoids are known to persist in the soil for years and to accumulate on neurotransmitters over time. U.S. environmental regulation remains behind current toxicological science in accounting for synergistic and cumulative chemical effects.


Crop questions:

Why is corn relevant? Bees don’t pollinate corn. Because corn is wind pollinated it must produce pollen in abundance and bees exploit this rich protein source, bringing in more than their daily need and storing large surpluses for later use. Many commercial honeybees also feed on corn syrup over the winter. Corn covers 88 million acres of U.S. farmland. Despite the fact that honeybees aren’t used to pollinate corn, by virtue of its sheer prevalence, this crop accounts for a large portion of honeybee nutrition and exposure, and nearly all U.S. corn is treated with systemic insecticides.

Are neonicotinoids necessary for corn production? Bayer claims that their seed treatments increase yields by 6-8 bushels per acre, but corn yields in Europe have not experienced an equivalent decline after banning the products. According to Dr. Benbrook, in the U.S., corn was a leading crop in terms of Integrated Pest Management (IPM)practices in the early 1990s. At that time, 1/3 to 1/2 of corn acres were not treated with any insecticide. Pest threats were managed with crop rotations and other IPM practices. Since 2000 however, virtually all conventional corn seed has been treated with one or more insecticide seed treatments. The average acre of corn contains plants with three systemic insecticides moving through them – two Bt toxins manufactured in the plant, and a neonicotinoid such as clothianidin or imidacloprid. So while it is difficult to find untreated corn seed, the crop itself is not reliant.




The Honorable Lisa P. Jackson Administrator
U.S. Environmental Protection Agency
Ariel Rios Building, MC 1101A 1200
Pennsylvania Avenue NW Washington DC 20004

Dear Administrator Jackson:

            National Honey Bee Advisory Board American Beekeeping Federation American Honey Producers Association Beyond Pesticides Pesticide Action Network North America Center for Biological Diversity

In light of new revelations by your agency in a November 2, 2010 memorandum that a core registration study for the insecticide clothianidin has been downgraded to unacceptable for purposes of registration, we are writing to request that you take urgent action to stop the use of this toxic chemical. Clothianidin is a widely used pesticide linked to a severe and dangerous decline in pollinator populations. As we are sure you appreciate, the failure of the agency to provide adequate protection for pollinators under its pesticide registration program creates an emergency with imminent hazards: Food production, public health and the environment are all seriously threatened, and the collapse of the commercial honeybee-keeping industry would result in economic harm of the highest magnitude for U.S. agriculture.

            The debate on clothianidin and the neonicotinoid pesticides is not new to the agency, but the recognition of the past failure of the Office of Pesticide Program’s (OPP) 2007 scientific review, now acknowledged, requires immediate action to stop use while new studies are conducted. We refer you to the memorandum entitled “Clothianidin Registration of Prosper T400 Seed Treatment on Mustard Seed and Poncho/Votivo Seed Treatment on Cotton,” November 2, 2010 (see pp. 2, 4). The science that the agency has, and the independent literature find that clothianidin-contaminated pollen and nectar presents an imminent hazard. Because the hazards to honeybee health are present within registered use parameters, it is clear that label changes alone will not offer adequate protection. The issue is not one of application error, in other words. We therefore urge the agency to issue a stop use order immediately. Our nation cannot afford, and the environment cannot tolerate another growing season of clothianindin use.

            In addition, because this problem reflects an overuse of the conditional registration program in OPP, we urge you to set an immediate moratorium on the use of such registrations until the program is fully evaluated for compliance with its underlying statutory responsibilities. The conditional registration of clothianidin in 2003 with outstanding data critical to its safety assessment represents a failure that could and should have been avoided. Clearly, the impacts on pollinators were not adequately evaluated prior to the issuance of the conditional registration, despite knowledge of “chronic toxic risk to honey bee larvae and the eventual instability of the hive.” This is the case with pollinator protection and a host of other issues that have direct bearing on environmental protection and public health.

            In redoing the clothianidin study and evaluating the causes of Colony Collapse Disorder and the larger issue of the pollinator decline crisis, we urge you to establish protocol that fully assesses the complexities that come together to threaten the honeybees. To be fully protective of bees, reviews must consider multiple chemical and cumulative exposures, persistence, and synergistic effects. We can no longer rely on studies of individual chemicals in isolation.

Thank you for your attention to the pollinator crisis and efforts to stem the tide of contamination and poisoning. We look forward to your reply.



National Honey Bee Advisory Board

Steve Ellis, Secretary


American Honey Producers Association

Kenneth Haff, President


Pesticide Action Network North America

Heather Pilatic, Co-Director


American Beekeeping Federation

David Mendes, President


Beyond Pesticides

Jay Feldman, Executive Director


Center for Biological Diversity

Justin Augustine, Staff Attorney


cc Steve Owens, Assistant Administrator, Office of Steven Bradbury, Director, Office of Pesticide Programs Chemical Safety and Pollution Prevention

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