Saturday 18 December 2010

CATCH THE BUZZ - Both Bayer and EPA Have it wrong

CATCH THE BUZZ

Flawed Study Must Be Redone

In the opinion of some members of The National Honey Bee Advisory Board and the other groups invested in the registration issues surrounding clothiandin, both EPA and Bayer are avoiding or misstating  the facts to avoid responsibility for the registration issues with clothianidin.

 

It is felt by some that posting Bayer's response in the BUZZ gives voice to their agenda.

 

Of course it does.

 

How else does information become known? Below is additional information on the chronology of this event. We urge you to read it fully, and if still not satisfied on the culpability of both EPA and Bayer CropScience in this registration process event, again read the original request.

 

Too, you may contact Heather Pilatic, Pesticide Action Network

cell: 415.694.8596

Jay Feldman, Beyond Pesticides

202.543.5450, ext 15

 

For additional information.

 

And recall the Penn State position of Dr. Frazier…

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.

 

Chronology of a core required study for clothianidin 2003-2010

Beyond Pesticides and Pesticide Action Network North America

 

Response to EPA’s initial media statement on 12.9.10

 

It is clear the EPA, when issuing a conditional registration for clotlhianidin in 2003 established a requirement for a field study that it considered core and essential to the issuance of the continued registration of the chemical. EPA develops requirements such as these in accordance with guidance when determined necessary. In this case, as EPA stated in 2003, “The possibility of toxic chronic exposure to nontarget pollinators through the translocation of clothiandin residues in nectar and pollen has prompted EFED to require field testing (141-5) that can help in evaluating this uncertainty. In order to fully evaluate the possibility of this long term toxic effect, a complete worker bee life cycle study must be conducted. . .” At this point, the study requirement became “core” to the registration.

 

Bayer conducted these studies. EPA accepted Bayer’s study in November 2007. In November 2010, however, EPA changed its position on this “core” study in a memorandum “Clothianidin Registration of Prosper T400 Seed Treatment on Mustard Seed and Poncho/Votivo Seed Treatment on Cotton,” November 2, 2010 (see pp. 2, 4). In that memo, it is stated that, “A previous field study (MRID 46907801/46907802) investigated the effects of clothianidin on whole hive parameters and was classified as acceptable. However, after another review of this field study in light of additional information, deficiencies were identified that render the study supplemental.

 

It does not satisfy the guideline 850.3040, and another field study is needed to evaluate the effects of clothianidin on bees through contaminated pollen and nectar.”

 

It is clear in that document that the “required” study for “Honey Bee Field Testing for Pollinators” is not acceptable to support the registration of clothianidin, and as a result “more data is needed” (see p27). While the study may contain “some” useful information, as stated by EPA, it does not contain “required” information necessary to registration.

 

The issue here is not whether one can attribute one pesticide as the cause of colony collapse disorder (CCD). That claim has not been made by anyone. The critical issue is that we know that this is a highly toxic pesticide to bees and, given the EPA’s inability to identify the cause(s) of CCD, it must not and does not have the legal authority to allow a pesticide to be used without “required” data that enables the agency to answer this critical question relating to the health of honeybees.

 

Supporting Documentation

EPA Addendum to February 2003 Risk Assessment...PAGE 2

 “Since this compound is persistent (field dissipation ½ life = 277 – 1,386 days), toxic to honeybees, and has the potential for expression in pollen and nectar of flowering crops, EFED also concluded that there was a potential for long term toxicity to these pollinators.

The possibility of toxic chronic exposure to nontarget pollinators through the translocation of clothiandin residues in nectar and pollen has prompted EFED to require field testing (141-5) that can help in evaluating this uncertainty. In order to fully evaluate the possibility of this long term toxic effect, a complete worker bee life cycle study must be conducted, as well as an evaluation of exposure to the queen. Because of this concern, EFED suggested that the following honeybee label statement be included:

 

This compound is toxic to honey bees. The persistence of residues and the expression of clothianidin in nectar and pollen suggests the possibility of chronic toxic risk to honey bee larvae and the eventual stability of the hive.

 

However, after further consideration, EFED would like to suggest that the registrant be given conditional registration that is contingent on their conducting the chronic honey bee study that evaluates the sublethal effects of clothianidin to the hive over time. EFED will therefore defer the requirement for this bee labeling statement until after the chronic study has been reviewed.”

 

November, 2007 EPA memo…PAGE 5

In its memo entitled “Review of Data Package DP336888 for Clothianidin,” EPA accepted the following study: Cutler, C. 2006. An Investigation of the Potential Long Term Impact of Clothianidin Seed Treated Canola on Honey Bees, Apis mellfeva L. Laboratory Report JD: 2005-CSD-EBTIX064. MRID 46907801 (with addendum 46907802). According to the memo,

 

“This study was submitted to provide data on the toxicity of clothianidin to honeybees in a field test for the purpose of chemical registration (new use). Specifically, the test was conducted in response to a request by the Canadian PMRA and the U.S. EPA; as a condition for Poncho@ registration in these countries, Bayer Cropscience was asked to investigate the long-term toxicity of clothianidin-treated canola to foraging honey bees.”

 

November, 2010 EPA memo...PAGE 2

“A previous field study (MRID 46907801/46907802) investigated the effects of clothianidin on whole hive parameters and was classified as acceptable. However, after another review of this field study in light of additional information, deficiencies were identified that render the study supplemental.

 

It does not satisfy the guideline 850.3040, and another field study is needed to evaluate the effects of clothianidin on bees through contaminated pollen and nectar. Exposure through contaminated pollen and nectar and potential toxic effects therefore remain an uncertainty for pollinators.“

 

November, 2010 EPA memo...PAGE 4 “Field Test for Pollinators (850.3040): The possibility of toxic exposure to nontarget pollinators through the translocation of clothianidin residues that result from seed treatments has prompted EFED to require field testing (850.3040) that can evaluate the possible chronic exposure to honey bee larvae and queen. In order to fully evaluate the possibility of this toxic effect, a field study should be conducted and the protocol submitted for review by the Agency prior to initiation. Another study had been submitted to satisfy this guideline requirement. While it had originally been classified as acceptable, after recent reevaluation it is classified as supplemental, and a field study is still being needed for a more refined risk assessment.”

 

 

Central Beekeepers Alliance : NB Agriculture Website is Updated, Better for Beekeepers

Central Beekeepers Alliance : NB Agriculture Website is Updated, Better for Beekeepers


NB Agriculture Website is Updated, Better for Beekeepers

Posted: 17 Dec 2010 10:10 AM PST

The New Brunswick Department of Agriculture, Aquaculture and Fisheries has launched a major update to its website. Beyond a clean new look, the revised website makes it easier to find information published by the department, including forms and regulations. For beekeepers, there is a separate page all about bees, which serves as a “one-stop shop” for beekeeping information.

So far, in addition to information about alfalfa leafcutter bees and the native bumblebees that pollinate blueberries, and sidebar links to NBDAAF programs, agricultural research, events and maps, the Bees page on the government website contains:

  • a link to the beekeeper registration form that all New Brunswick beekeepers are required by law to complete each year;
  • information on evaluating, managing and protecting honeybee hives; and
  • under the Integrated Pest Management heading , information on the control of varroa mites.

Visitors can enter the main NBDAAF website at http://www.gnb.ca/0027/index-e.asp, the Agriculture division at http://www.gnb.ca/0027/Agr/index-e.asp, or the dedicated section on bees at http://www.gnb.ca/0027/Agr/0013/index-e.asp.

NB Agriculture Website is Updated, Better for Beekeepers was written and published by the Central Beekeepers Alliance - Honey Bees & Beekeeping in New Brunswick, Canada. For more information, please visit http://cba.stonehavenlife.com.

Friday 17 December 2010

CATCH THE BUZZ - 2010 USDA CCD Report

CATCH THE BUZZ

USDA Releases 2010 Honey Bee Colony Collapse Disorder Progress Report

By Kim Kaplan
December 17, 2010

WASHINGTON -- The U.S. Department of Agriculture has released the 2010 Colony Collapse Disorder (CCD) Progress Report highlighting current research on this still mysterious disease affecting the nation's honey bees.

The report, which was mandated by Congress in 2008, summarizes research by federal agencies, state departments of agriculture, universities and private organizations to find the cause of CCD and how to stop or mitigate its impact. The report was produced by USDA's Agricultural Research Service (ARS) and National Institute of Food and Agriculture.

"Honey bees are critical to U.S. agriculture, with about 130 crops depending on pollination to add more than $15 billion in crop value annually. It is vital that we find a way to deal with CCD," said ARS Administrator Edward B. Knipling. "This report is an important measure of what we are learning about this serious problem."

CCD, a syndrome characterized by the sudden disappearance of all adult honey bees in a colony, was first recognized in 2006. Since then, surveys of beekeepers indicate that the industry is suffering losses of more than 30 percent annually. Before the appearance of CCD, losses averaged 15-20 percent annually from a variety of factors such as varroa mites and other pests and pathogens.

During the past three years, numerous causes for CCD have been proposed and investigated. Although the cause or causes of CCD are still unknown, research summarized in the report supports the hypothesis that CCD may be a syndrome caused by many different factors, that work individually or in combination. The sequence and combination may not even be the same in every case, explained Kevin Hackett, ARS national program leader for pollination and co-chair of the USDA CCD Steering Committee.

The 2010 CCD Progress Report is available online at:
http://www.ars.usda.gov/is/br/ccd/ccdprogressreport2010.pdf .

More information about CCD can be found at http://www.ars.usda.gov/CCD .


Read an EXCLUSIVE CHAPTER from Tom Seeley’s new book Honey Bee Democracy, only on Bee Culture’s web page Here!

Build an entire bee hive with just a table saw.

Go to Garreson Publishing. Books by Peter Sieling. Find out What Is New At Mann Lake right Here

Protein feeding pays off with better health, better survival, better production, and better wintering. Learn More.  

FREE - Kelley Bees Modern Beekeeping Monthly Newsletter

 

Quality Top Bar Hives by Gold Star Honeybees - good for you, good for your bees, good for the planet. Check us out at www.goldstarhoneybees.com.

 Subscribe to Malcolm Sanford’s Apis Newsletter right here for a comprehensive listing of beekeeping events around the country and around the globe, check out Bee Culture’s Global Beekeeping Calendar

This message brought to you by Bee Culture, The Magazine Of American Beekeeping, published by the A.I. Root Company.

 

 

 

 

CATCH THE BUZZ - Bayer CropScience Responds

Importance of Honey Bee Health
CATCH THE BUZZ

Bayer Responds To Critical Study Claims

Bayer CropScience was recently made aware of an unauthorized release from within the Environmental Protection Association (EPA) of a document regarding the seed treatment product, clothianidin, which we sell in the United States corn market. In response to this document, some environmental groups made claims against clothianidin with regard to the honey bee population. We believe these claims are incorrect and unwarranted.

Clothianidin is the leading seed treatment on corn in the United States and has been used extensively for more than six years without incident to honey bees. In fact, the long-term field study referenced in the EPA document was conducted with clothianidin-treated seed and showed that there were no effects on bee mortality, weight gain, worker longevity, brood development, honey yield and over-winter survival.


Bayer CropScience stands behind the science and safety of our products and the benefit of seed treatments as a technology for growers to providing healthy and affordable food. And we are working with EPA to address this situation and ensure accurate information is shared with the public.


We published a statement on our website today in response to this issue (see attached). We've also developed the below fact sheet about clothianidin and honey bees that we encourage you to read at your convenience.


Thank you for your support.

WEB PAGE STATEMENT

Bayer CropScience Responds to Honey Bee Concerns

 

12/14/2010 Bayer CropScience LP announced that the claims by

some environmental groups against one of its products are incorrect

and unwarranted with regard to honey bee concerns.

Bayer CropScience was recently made aware of an unauthorized

release from within the Environmental Protection Association (EPA)

of a document regarding the seed treatment product, clothianidin,

which is sold in the United States corn market. Bayer CropScience

disagrees with the claims by some environmental groups against this

product and we believe these are incorrect and unwarranted with

regard to honey bee concerns.

 

The study referenced in the document is important research,

conducted by independent experts and published in a major peer reviewed

scientific journal. The long-term field study conducted in

accordance with Good Laboratory Practices (GLP) by independent

experts using clothianidin-treated seed showed that there were no

effects on bee mortality, weight gain, worker longevity, brood

development, honey yield and over-winter survival. The EPA

reviewed and approved the study protocol prior to its initiation and it

was peer-reviewed and published in the Journal of Economic

Entomology*. Upon reviewing the results of the long-term trial, the

Agency noted the study as “scientifically sound and satisfies the

guideline requirements for a field toxicity test with honey bees.

 

Clothianidin is the leading seed treatment on corn in the United

States and has been used extensively for over six years without

incident to honey bees. Innovative seed treatment technology represents an environmentally sound approach to crop protection. Treating the seed provides a targeted and effective means of application that helps increase yields, safeguard our environment and ensure a sustainable means of crop

production.

 

NOTE: More information on Bayer CropScience and honey bees can

be found at:

http://www.bayercropscience.com/bcsweb/cropprotection.nsf/id/EN_Bee_Health_Crop_Protection_2010

 

*Clothianidin Honey Bee Field Study: Journal of Economic

Entomology, 100(3): pages 765-772

 

BAYER FACT SHEET

Bayer CropScience has an inherent interest in helping to ensure the existence of robust agricultural systems around the world. Pollinators are an essential component of these systems. We understand the importance of thoroughly researching the causes of bee health problems and support efforts in finding remedies.

Honey Bee Hazards

Honey bees are subjected to many sources of health hazards. These come from naturally-occurring factors, such as predators, parasites and diseases, but can come from other causes, such as inadequate food supplies, habitat disruption, colony manipulation, exposure to environmental toxicants and lack of genetic diversity.


Colony Collapse Disorder

Unlike many well-known honey bee maladies, Colony Collapse Disorder (CCD) is a more recent term used to describe the sudden disappearance of worker honey bees from a colony, with an apparently healthy queen and brood left behind. Although recent reports have highlighted fears about CCD, reports of similar colony collapses, or die-offs have been documented many times in previous years, as early as 1896.


The Cause of CCD

CCD has been linked to a combination of parasitic mites and honey bee pathogens. Despite some claims in the media, there is no evidence linking pesticides, including neonicotinoids, to CCD. Current research on bee health indicates that honey bees are facing significant stress from multiple factors, including parasites, diseases, lack of genetic diversity, climate change, pesticides, and stress-induced impacts (such as colony transport).


Neonicotinoid Insecticides

Neonicotinoids are one of the more modern classes of pesticides and are noted for their effectiveness in controlling harmful pests and relatively favorable environmental impact. Some neonicotinoids, such as clothianidin, the leading seed treatment on corn, are highly toxic to honey bees. Despite its acute toxicity, clothianidin may be used without causing harm to honey bee colonies by following the label directions.


Field Studies on Clothianidin and Honey Bees

A long-term field study conducted by independent researchers using clothianidin-treated seed showed that there was no effect on bee mortality, weight gain, worker longevity, brood development, honey yield and over-winter survival when compared to bees observed in untreated controls. This study was peer-reviewed and published in the Journal of Economic Entomology, 100(3): pages 765-772 (2007).


Commercial Use of Clothianidin

Actual commercial use of clothianidin supports the conclusions of controlled field studies. Clothianidin is the leading corn seed treatment insecticide and has been used extensively for over 6 years without incident to honey bees in the United States.


Need for Seed Treatments

Innovative seed treatment technology represents an environmentally compatible approach toward crop protection. Treating the seed provides a targeted and effective means of application that helps increase yields, safeguard our environment and ensure a sustainable means of crop prod


This message brought to you by Bee Culture, The Magazine Of American Beekeeping, published by the A.I. Root Company.

 Read an EXCLUSIVE CHAPTER from Tom Seeley’s new book Honey Bee Democracy, only on Bee Culture’s web page Here!

Build an entire bee hive with just a table saw. Go to Garreson Publishing. Books by Peter Sieling.

Find out What Is New At Mann Lake right Here

Protein feeding pays off with better health, better survival, better production, and better wintering. Learn More.  

FREE - Kelley Bees Modern Beekeeping Monthly Newsletter

 

Quality Top Bar Hives by Gold Star Honeybees - good for you, good for your bees, good for the planet. Check us out at www.goldstarhoneybees.com.

 

Subscribe to Malcolm Sanford’s Apis Newsletter right here for a comprehensive listing of beekeeping events around the country and around the globe, check out Bee Culture’s Global Beekeeping Calendar

 

 

uction

Wednesday 15 December 2010

CATCH THE BUZZ - Honey Locator Better Than Ever

CATCH THE BUZZ

The National Honey Board’s ‘HoneyLocator.com’ Offers

Honey Varietal Information, Inspiration to Foodservice Professionals

 

FIRESTONE, Colo. – Dec. 10, 2010 – Bearing a new look and enhanced features, the National Honey Board’s Honey Locator website (www.honeylocator.com) is the top honey varietal information resource and “one-stop shop” for foodservice professionals.  Easy one-click searches allow use rs to find honey varietals and their suppliers by state or region, or source honey varietals of their choosing from anywhere in the United States.

Pure, one-ingredient honey comes in more than 300 varietals in the U.S. alone.   Each varietal has a distinct flavor profile, aroma and color, based on the floral source visited by the producing honey bees.  Varietals range from the ubiquitous Clover honey to regional specialties like Lehua honey from Hawaii and Tupelo honey from northern Florida.  Popular varietals for foodservice applications (largely based on availability) include:  Buckwheat, Eucalyptus, Orange Blossom, Sage, Sourwood and Wildflower. 

“Honey varietals can add depth and interest to foodservice recipes across the menu – from beverages and appetizers to main courses and desserts,” explains Emily Manelius, communications specialist at the National Honey Board.  “In addition, the use of honey varietals to add a regional flavor and flair to recipes is of growing interest.”

“We are pleased to offer the Honey Locator as a unique and comprehensive resource to foodservice professionals,” adds Ms. Manelius.  “We believe the newly updated website will inspire innovative, new honey varietal recipes on menus nationwide.”   

The National Honey Board’s 2010 “Honey Trends Survey” confirms that honey usage is on the rise among foodservice operators, with survey respondents attributing the growth primarily to “new menu items” (34%) and “greater demand” (22%).  Interestingly, only 31% of respondents to the survey were aware of the scope of honey varietals available.  Additional survey results will be released later this month.

The National Honey Board is a federal research and promotion board under USDA oversight that conducts research, marketing and promotion programs to help maintain and expand markets for honey and honey products. These programs are funded by an assessment of one cent per pound on domestic and imported honey.


 

Subscribe to Malcolm Sanford’s Apis Newsletter right here for a comprehensive listing of beekeeping events around the country and around the globe, check out Bee Culture’s Global Beekeeping Calendar

 This message brought to you by Bee Culture, The Magazine Of American Beekeeping, published by the A.I. Root Company.

 Read an EXCLUSIVE CHAPTER from Tom Seeley’s new book Honey Bee Democracy, only on Bee Culture’s web page Here!

Build an entire bee hive with just a table saw. Go to Garreson Publishing. Books by Peter Sieling.

Find out What Is New At Mann Lake right Here

Protein feeding pays off with better health, better survival, better production, and better wintering. Learn More.  

FREE - Kelley Bees Modern Beekeeping Monthly Newsletter

 

Quality Top Bar Hives by Gold Star Honeybees - good for you, good for your bees, good for the planet. Check us out at www.goldstarhoneybees.com.

 

 

 

Monday 13 December 2010

CATCH THE BUZZ - Being in a hurry

CATCH THE BUZZ

Of course, we were not implying that Georgia has two more cases of American Foulbrood (AFB) but two more hives of African Honey Bees...AHB. It's late, we goofed. Sorry, Georgia.

Kim Flottum, Editor.

CATCH THE BUZZ - More AFB Found in Georgia

CATCH THE BUZZ

More African Honey Bees Found In Georgia

ALBANY, GA -- Two more colonies of Africanized “killer” honeybees have been found in Dougherty County near the area where a man died from an attack in October.

Since 73-year-old Curtis Davis’ death, the Georgia Department of Agriculture has monitored swarms and tested suspect bees. 90 samples were tested, confirming two more colonies in Southwest Georgia.

The Department of Agriculture is still unsure of how the Africanized honeybees arrived in Dougherty County.

Both newly discovered colonies have been destroyed.

Africanized honeybees are occasionally found on cargo ships that come from South or Central America.

Beekeepers are the best defense Georgians have against Africanized honeybees, according to the Department of Agriculture and the University of Georgia.

State agriculture officials say budget cuts have affected the Georgia Department of Agriculture’s ability to offer services but that they are evaluating how to best monitor for Africanized honeybees in 2011. The department plans to resume trapping in middle to late February when the bees become more active.


Quality Top Bar Hives by Gold Star Honeybees - good for you, good for your bees, good for the planet. Check us out at www.goldstarhoneybees.com.

Subscribe to Malcolm Sanford’s Apis Newsletter right here for a comprehensive listing of beekeeping events around the country and around the globe, check out Bee Culture’s Global Beekeeping Calendar

 This message brought to you by Bee Culture, The Magazine Of American Beekeeping, published by the A.I. Root Company.

 Read an EXCLUSIVE CHAPTER from Tom Seeley’s new book Honey Bee Democracy, only on Bee Culture’s web page Here!

Build an entire bee hive with just a table saw. Go to Garreson Publishing. Books by Peter Sieling.

Find out What Is New At Mann Lake right Here

Protein feeding pays off with better health, better survival, better production, and better wintering. Learn More.  

FREE - Kelley Bees Modern Beekeeping Monthly Newsletter

Quality Top Bar Hives by Gold Star Honeybees - good for you, good for your bees, good for the planet. Check us out at www.goldstarhoneybees.com.

.

 

 

 

 

 

Wednesday 8 December 2010

CATCH THE BUZZ - Clothianidin's Faulty Registration

 

CATCH THE BUZZ

Press Release

 

In the July issue of Bee Culture Magazine there appeared an article by Tom Theobald detailing the fallacy of clothianidin registration in the U.S. That story is below. This article instigated several investigations by various concerned groups. The following Press Release is one result.

 

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

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."

 

Tom Theobald’s  Article - Do We Have A Pesticide Blowout?

Bee Culture Magazine, July, 2010

(This story is available on Bee Culture’s web page here.)

You can listen to a PBS interview about this with Tom here)

I doubt that there are many readers who have escaped reports of the oil well blowout - the explosion and collapse of the Deepwater Horizon drilling platform and the subsequent environmental disaster that has ensued.

Evidence is mounting that the blowout of the Deepwater Horizon was brought on by a climate of lax oversight by the federal agency responsible for 'insuring the safety and environmental protection of offshore drilling operations,' the Mineral Management Service, or MMS. As I’ve listened to the news and read the articles describing events leading up to the explosion I’m struck by the parallel to what has been occurring in the beekeeping world over the past several years.

In May of 2008 there were massive bee kills in the Baden-Wurttemberg region of Germany, with two thirds of the colonies there killed. The damage was quickly traced to one of the pesticides in the controversial family of neonicotinoids produced by the German corporation Bayer. Planting of corn seed coated with clothianidin, by way of pneumatic planters, supposedly resulted in fugitive clothianidin dust which caused the disaster. Within two weeks Germany banned clothianidin on corn and several other crops, but the damage was done.

Clothianidin is just one of a number of pesticides in the family of neonicotinoids. Neonicotinoids are systemic pesticides, which means that they become incorporated into the system of the plant when the seed germinates. In the United States clothianidin was given a conditional registration by the EPA in 2003. Originally approved for use as a seed coating on corn and canola, it is now being approved for a growing list of other crops as well.

The German bee kill came as no surprise to the beekeeping community, which had been concerned about clothianidin since its registration in the U.S. in 2003, and in Germany in 2004. For four years those concerns were met with repeated assurances of safety, until finally disaster struck in Germany. Even in the aftermath of this huge bee kill the assurances continued. Bayer’s explanation was that the bee kill was caused by '. . . an application error by the seed company which failed to use the glue-like substance that sticks the pesticide to the seed . . . It is an extremely rare event and has not been seen anywhere else in Europe . . .' This is reminiscent of the finger pointing in the oil industry over the past several weeks.

It appears that two years later we have now had a repeat of this 'rare event,' this time here in the United States. This bee kill occured in Indiana in April, reported by two entomologists at Purdue University in an article written for the Indiana Beekeepers Association newsletter and circulated widely. Titled 'Pesticide Kill at the Purdue Bee Lab?' it reports a significant bee kill across Indiana, again believed to have come from fugitive dust from pneumatic corn planters.

According to these two entomologists 'Every corn seed that goes into the ground in Indiana these days has a coating of clothianidin on it. It has been a dry spring. We have had very warm, windy weather this week. As I watched my neighbor planting, I could see huge clouds of dust being stirred up.' As researchers at a major university, the authors had the resources to do some immediate analysis that would have been beyond the reach of most beekeepers, and they found high levels of clothianidin in the dead bees and the incoming pollen.

Along with other beekeepers, I have been concerned about clothianidin for some time, in part because it is not the first neonicotinoid to cause problems. Imidacloprid, the first, was registered in the U.S. in 1994 and was soon implicated in widespread bee kills. Several commercial beekeepers in North Dakota filed suit because of damage from imidacloprid used on sunflowers and similar damage in France from use on sunflowers led to a ban there in 1999. However it is still used without change in the U.S. France declined to even register clothianidin.

I became concerned about clothianidin in 2007 as the possible cause of a break in the Fall brood cycle I was seeing in my bees and in early 2008 I began digging into the facts surrounding its approval. That story is instructive and cause for great concern I believe.

The first record I found on the consideration of clothianidin comes in the form of an EPA memo dated February 23, 2003, titled 'Risk Assessment for Seed Treatment of Corn and Canola.' To their credit, EPA scientists raised serious concerns in that document and called for strong label language if clothianidin was to be approved for use. They cited the experience in France with imidacloprid as the basis for extreme caution and called for label language which would highlight the dangers. Quite responsibly, they called for a field test of the dangers prior to registration:

'The possibility of toxic exposure to nontarget pollinators through the translocation of clothianidin residues that result from seed treatment (corn and canola) has prompted EFED [Environmental Fate and Effects Division] to require field testing that can evaluate the possible chronic exposure to honey bee larvae and queen. In order to fully evaluate the possibility of this toxic effect, a complete worker bee life cycle study must be conducted, as well as an evaluation of exposure and effects to the queen.'

and they called for strong label language as well:

'This compound is toxic to honey bees. The persistence of residues and the expression of clothianidin in nectar and pollen suggests the possibility of chronic toxic risk to honey bee larvae and the eventual stability of the hive.'

This level of concern expressed by EPA scientists in February of 2003 wasn’t to last however. In the next memo just two months later, dated April 10, 2003 - an Addendum to the Risk Assessment - EFED retreated. They stuck to their guns on the label language, sort of, but they appear to have been handed their heads by an EPA management that would brook no interference with corporate objectives. 'However, after further consideration …' is what the scientists had to say after having their attitudes adjusted:

'However, after further consideration, EFED would like to suggest that the registrant be given a conditional registration that is contingent on their conducting the chronic honey bee study that evaluates the sublethal effects of clothianidin over time. EFED will therefore defer the requirement for this bee labeling statement until after the chronic study has been reviewed.'

Bayer was given eight months, until December of 2003, to complete the study, but clothianidin was released to the market and the horses were out of the barn.

It is here, with the April memo,  that the regulatory process begins to unravel. The condition of registration, the [chronic] life cycle field study, would go undone for years. 'After further consideration…' meant that the real field test was to take place across the farmlands of America, without control and with serious concerns as to the safety of this pesticide unanswered.

The next memo, which established the final protocols for the field study, is dated March 11, 2004. The original deadline for the field study, upon which the conditional registration had been granted, had already passed three months before. Bayer requested and was granted, retroactively, an extension to complete the field study by May of 2005. All the while however clothianidin would be out on the market and useage would increase rapidly. This has become a common tactic in the corporate playbook, get these products out there by whatever means possible, get agriculture hooked, and then convince farmers they can’t live without them.

Previously EPA scientists had clearly stated that any study should be done in the United States, but Bayer was given permission to do it in Canada instead. More significantly, rather than require that the field study be done on both crops, corn and canola, Bayer was allowed to test only canola, while corn was dismissed with a single sentence. This is significant because in the United States canola is a relatively minor crop, with less than a million acres grown. Corn on the other hand accounts for about 88 million acres. Further, we had just seen a decade of enormous damage to bees from a product called encapsulated methyl parathion, where contaminated corn pollen had been the major vector of damage and EPA scientists were well aware of this. I knew the biologist who signed off on the March, 2004 memo which dismissed corn so casually and he most certainly would have known of the dangers cor n pollen could represent, yet Bayer was given a pass and was allowed to disregard corn.

Since clothianidin becomes part of the plant it is expressed in all parts of the plant, thus any insect which chews or sucks on the plant ingests the pesticide and dies. Don’t worry though, we were told, it only affects the bad bugs. Besides, it’s one of the new 'green' pesticides, derived from a natural substance, nicotine (this is a whole other story, because like many other 'green' pesticides it is a product of heavy chemistry, not nature). It also reduces the need for the application of other, supposedly more toxic pesticides we’re told. Neonicotinoids have come under increasing criticism however, not the least of which has been leveled by the beekeeping industry and others for the alleged detrimental effects on honey bees and other pollinators.

The word 'alleged' could start the fight I suppose, because critics believe the case against the neonicotinoids is complete and compelling. On the other hand, Bayer, and apparently the EPA, would have us believe otherwise. Much of the evidence is in the public arena now, and with the publication of this article, the conduct of the EPA, revealed through its own documents, will be as well. The readers can judge the evidence for themselves and draw their own conclusions. I’m presenting my view of the goings on and that can be part of your consideration. Obviously, I’m not without my own opinions in these matters.

The official life cycle study was to languish for years. In March of 2004 the initial deadline for the study had passed and the EPA granted Bayer an extension, until May of 2005, allowing further that if accurate data could not be produced in the summer of 2004, the study might be extended yet again, through the 2005 growing season. According to its own records, dated March 11, 2004, the EPA says 'EFED wants usable data to decide the potential adverse effects to bees from clothianidin’s seed treatment use and opposes rushing the study and having deficient information.'

While this may seem to evidence concern, you must remember that this would mean a pesticide with serious questions as to its environmental consequences could then have been on the market and in wide use for three full growing seasons without any answers to those questions. While there may have been concern about rushing the study, there seemed to be no comparable concern about rushing an untested pesticide onto the market. These tests should have been completed before clothianidin was ever registered, as EPA scientists had initially recommended.

Then in May of 2008 we have the German incident – two thirds of the colonies in the Baden-Wurttemberg region killed, with 99% of the dead bees showing high levels of clothianidin. Within two weeks of this incident Germany had suspended the registration for clothianidin and this action was soon followed by bans in Italy and Slovenia. And what came from regulators in the U.S.? Silence. Worse than silence actually, because it soon began to appear that the EPA was going into hiding.

It was in the Spring of 2008, before the German incident, that I began investigating clothianidin. I did so because the previous Fall I had discovered that there was a break in the Fall brood cycle in nearly all of my colonies, and when I tried to match the symptoms to some known or suspected cause, the trail led to clothianidin.

I wasn’t the only one who was concerned about pesticides. In the Fall of 2006 Pennsylvania beekeeper David Hackenberg had broken the story of huge bee losses, what would come to be called Colony Collapse Disorder, or CCD. Dubbed the great mystery by many researchers, over time more and more beekeepers began to believe that there was little mystery and that pesticides were a major ingredient in CCD.

The Natural Resources Defense Council had begun questioning the safety of clothianidin and subsequent to the incident in Germany asked the EPA to provide the long awaited life cycle study, which was by now four years overdue. The EPA failed to respond so the NRDC filed a Freedom of Information Act request. The EPA failed to respond once more and on August 18, 2008 the NRDC filed suit for the study.

It was just prior to the NRDC suit that I discovered the infamous missing study; the internet can be an amazing resource if you just keep digging and prying. Within a month of my discovery the EPA had put their review and approval of the study on their web site, apparently flushed out by the NRDC lawsuit. What the review does and doesn’t reveal is disturbing.

Let me first put the study in a more agricultural context, and then look at it more closely. Let’s say you had a noxious weed that was affecting your cattle and you wanted to assess the dangers. So you plant two and a half acres of the suspect weed in the middle of 2000 acres of lush Wyoming grassland and put four cows on the test plot. The cows aren’t fenced in, however, and are free to roam over the entire 2000 acres. What do you think is going to happen? How long do you think your four cows are going to stay on your dinky little test plot? How significantly is that noxious weed going to be represented in their diet? I think you know the answers.

Here’s what the life cycle study of bees and canola consisted of: four colonies of bees were set in the middle of one hectare (2½ acres) of canola planted from treated seed, with the bees free to forage over thousands of surrounding acres in bloom with untreated canola, which they most surely did. What do you think the results were? They were exactly what Bayer wanted of course.

Why was the chronic life cycle study and the EPA’s review unavailable? Was it ineptitude? Perhaps it was simply embarrassment, because the study had been completed on August 1, 2006, already long overdue, and yet despite all the controversy had not been reviewed by the EPA until November 16, 2007, nearly a year and a half later, after clothianidin had been on the market for five full growing seasons.

Perhaps it was because in the opening paragraph of its review the EPA states unequivocally 'This study is scientifically sound and satisfies the guideline requirements for a field toxicity test with honeybees (OPP Gdln. No. 141-5; OPPTS 850.3040).' Scientifically sound? If you’re in 4th grade perhaps, but certainly not if you have a Phd after your name. They should be embarrassed, this makes a mockery of science.

Further concerns are emerging as a consequence of the Indiana bee kill. High levels of atrazine were found in the dead bees and pollen along with clothianidin. This suggests that dust alone may be a vector, with the atrazine contamination coming from airborn soil. We now find evidence, again from the EPA’s own documents, that clothianidin can be persistent in the soil, remaning for years in some cases, and that it may accumulate from successive uses of treated seed, a common practice in the corn belt. Has the soil itself become a source of toxicity as a consequence of clothianidin use? Only further tests will give us answers to those questions.

What are we to do with circumstances like these? It is simply nuts, and yet this bogus science has now been used as justification to approve the use of clothianidin on a rapidly growing roster of other crops while there is mounting evidence of problems coming from around the globe. The EPA still seems to lack any sense of urgency and says it will not review clothianidin until 2012.

I still believe that most of the working level people at the EPA want to do things right, but there seems to be a serious management failure and nobody seems to be stepping in to get the ship back on course. Some very spooky chemicals are coming onto the market without proper testing and once out are virtually unregulated. We are seeing the legacy of more than a decade of deregulation and self regulation and it has not worked.

This is the Deepwater Horizon in agriculture. America’s farmland is awash in these questionable chemicals as surely as the shorelines of the Gulf Coast are awash in crude oil, and for many of the same reasons.

The bees are telling us something. We need to start listening before it’s too late.