CATCH THE BUZZ
These comments, submitted by the National Honey Bee Advisory Board to EPA concerning the registration of imidacloprid, a systemic pesticide produced by Bayer Chemical Company, have been edited here because of length. But the stories have not been changed or altered. The NHBAB consists of beekeepers from both the AHPA and the ABF, and represents most of the nation’s commercial beekeepers. EPA now must act on these and other comments regarding this compound. At the same time, this group of beekeepers and Bayer are meeting to discuss continued research with this compound. Time will tell if increased regulation, or more precise research improve the situation.
Beekeepers from around the
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Imidacloprid is only one of six product formulations in the broader class of “systemic neonicotinoids.” Although only imidacloprid is currently ‘up’ for public comment, all six of these products in this class are of great concern to beekeepers. Much attention has been given to the seed treatments such as Gaucho, a trade name for a formulation of imidacloprid.
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Farmers, pesticide applicators, and beekeepers all look to EPA to provide guidance on safe and unsafe ways to apply these economic poisons. We will quote the public comment of Roger Haldenby (Plains Cotton Growers, Inc. tracking number 808bfe56, February 23, 2009) on Imidacloprid: “There are reports of imidacloprid toxicity to bees, birds, earthworms, and some fresh water crustaceans. The impact of imidacloprid on these organisms can be mitigated by proper application of the insecticide in accordance with label instructions.”
Systemic pesticides, like imidacloprid, work on a different principal. The chemical is taken up into the plant tissue, and becomes systemic. Active chemical is moved throughout the plant including the nectar and pollen of the treated crop plant, or inadvertently treated weed. Once the chemical is in the nectar and pollen of the plant, no protective means can be employed to protect the pollinator who gathers the poisoned food. There is no “label warning” currently to protect pollinators from imidacloprid tainted nectar and pollen. EPA does not have “safe label” instructions for imidacloprid.
In an advertisement for Premise 200SC, an imidacloprid product for termite control, Bayer states, “Premise 200SC interferes with (the) instinctive social behavior (of termites), contributing to the termites’ demise. Low doses of Premise 200 SC disorientate the termites and cause them to cease their natural grooming behavior. Grooming is important for termites to protect them against pathogenic soil fungi. When termites stop grooming, the naturally occurring fungi in the soil attack and kill termites. Premise 200SC makes fungi 10,000 times more dangerous to termites. Nature assists Premis in giving unsurpassed control.” (Bayer
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Major incidents have been reported by beekeepers linked to imidacloprid. EPA is aware that their incident reporting database of pesticide effects on honeybees is not working. At the December 2, 2008 meeting between US EPA Office of Pesticide Programs and Beekeepers, the beekeepers explained how the incident reporting system, which utilizes state departments of agriculture and chemical manufacturing companies, is not reporting beekeeper field incidents with pesticides. The beekeepers at the meeting presented a wall chart showing all incidents reported to EPA and then detailed how their own personal incidents, as well as incidents of colleagues not there. Providing a mechanism for reporting bee incidents was one of the eight “action items” listed as coming out of that meeting.
Recognizing that EPA is not aware of beekeeper incidents related to pesticides, we would like to provide you with a partial list of our own. Many beekeepers will be reporting their individual incidents independently. The list below by no means should be considered as complete; it only attempts to showcase a few of the most prominent incidents. Many commercial beekeepers have had problems related to the use of imidacloprid.
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The largest incident involved seven beekeepers in
Clint Walker relates his experience with imidacloprid and cotton in
By In January of 2007 we began to see a significant portion of our nearly 2000 hives begin to collapse with Colony Collapse Disorder (CCD) symptoms. As we searched for an explanation to our losses, a disturbing pattern emerged: All of the collapsing hives had been in
Dave Hackenberg tells his story of CCD on the East coast. In 2004, when our bees were first exposed to imidacloprid, we saw things happen in our bees that we have never seen before. Good colonies of bees run through pollinations and honey crops over the summer that we now know were exposed to Assail in Apple pollination and Admire in pumpkin pollination, by fall when no new food was coming into the hives, began to collapse at a rapid pace, leaving nothing but a queen and a few bees in the boxes. The farmers that I work with are sensitive to using anything that would hurt my bees because they recognize how important good pollination is to the success of their crops. They were told by their chemical suppliers that these ‘new’ pesticides were ‘safer’ for honeybees and they could even apply them during bloom without damage to the bees. We did not see any dead bees in front of our hives while they were in these pollinations. In the fall, it was clear that the bees that had been on honey locations were OK with normal mortality of 10 to 15% loss, while the pollination hives had 75 to 80% loss. The ‘surviving’ pollination hives were not healthy and they failed to build properly in the spring. We saw this same problem with pollination hives in 2005 and 2006. It was in the fall of 2006 that we began to associate these losses with summer pollination exposure. Since then we have communicated to our growers some of our concerns and the losses have gotten better in apple pollination where the grower had ‘options’ to use other products. In pumpkin pollination, the growers have not had such luck since there are few other ‘approved’ products available to them.
Gene Brandi tells his story of watermelon pollination in
Dave Mendes tells his story of orange orchards in
Imidacloprid, a systemic insecticide, moves through the treated plant to the nectar and pollen. The chemical remains persistent in soils for several years, can be taken up by subsequent plantings and weeds, and expressed in their pollen and nectar. No mechanism exists to protect honeybees from this exposure. Due to the vitally important nature of pollinators we recommend that imidacloprid be removed from use in the
The reader may ask how did we find ourselves at the point where an extremely dangerous chemical compound has come into such widespread use, threatening the very existence and viability of the pollination framework of the country. The answer is simple. Deregulation, the same concept which precipitated our financial collapse, has precipitated an environmental collapse no less serious. At the same time that financial institutions were being given a free reign to regulate themselves on the naive assumption that industry knew best, pesticide regulation was being turned over from EPA to industry on the same assumption.
US EPA used to do pesticide screening in honeybees, do pesticide toxicity study themselves, but today industry directs and funds the critical toxicity studies to determine product safety themselves. The studies are shown to EPA for registration purposes, then filed away as “proprietary information” far from the scrutiny of the public eye. Enforcement actions are not taken by EPA; instead these critically important functions are delegated to individual state departments of agriculture, under an arrangement ironically called a “primacy agreement.”
The problems faced by the beekeeping industry are not limited to one single chemical compound. They are in fact linked to a pervasive regulatory failure. When the EPA was first set up, it was in response to environmental challenges of an unprecedented nature. At that time the country was using 200,000,000 pounds of active ingredient chemical pesticides. Today that number is over 5,000,000,000 pounds of active ingredient. Simply put, the country is drowning in chemicals. These very “economic poisons” are doing their job too well, and because of the deregulation process we are faced with a perfect storm today capable of destroying our countries pollinator base which will carry with it agricultural and environmental catastrophe.
The fundamental change which is necessary is to return to a system at EPA which independently tests chemical compounds before they are released for widespread use. Precaution and prevention are words which need to return to environmental protection. Massive field experiments, such as what has occurred with the neonicotinoid class of systemic insecticides is just too high risk of a behavior. Environmental catastrophe such as global warming, and our current pollinator crisis are big flashing warning lights. These warning lights are there to tell us something, they are telling us to take action before it is too late.
The message brought to you by Bee Culture, The Magazine Of American Beekeeping
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