Recent declines in honeybee populations and the impact on food crops should trigger the EPA to immediately suspend the use of neonicotinoid pesticides and to investigate a possible link between the use of these common pesticides and reductions in the honeybee population. Honey bees are responsible for pollination of approximately one third of the United States’ crop species, including such species as almonds, peaches, soybeans, apples, pears, cherries, raspberries, blackberries, cranberries, watermelons, cantaloupes, cucumbers and strawberries. Bee pollination contributes an estimated $15 billion in additional crop yields.
Recent research has found that certain members of a group of related pesticides, known as neonicotinoids, may be jeopardizing bee populations and with them important food crops and jobs. France, Germany and Italy have banned neonicotinoids based on indications that the insecticides could be linked to honey bee Colony Collapse Disorder (“CCD”). Internal EPA reports dating back to 2003 show that EPA scientist have raised serious concerns about the use of neonicotinoids. While these warnings are very specific in the EPA’s internal documents, both USDA and EPA have avoided targeting neonicotinoids in their published documents, instead calling for “further study” rather than any restrictions on use. The Union asks that Congress direct the EPA:
- To immediately suspend the use of neonicotinoids (“NN”) – a class of neuro-active insecticides chemically related to nicotine, with a common mode of action that affects the central nervous system of insects, causing paralysis and death – until such time as the Agency can definitively state that NNs are not the cause or a contributory cause of CCD.
- To investigate the impacts of this class of pesticides on honeybees and other pollinators.
- To report on the steps the Agency has taken to ensure there is sufficient scientific evidence to make informed decisions about the impacts of neonicotinoids on pollinators.
- To report what additional steps the Agency intends to take to limit or restrict the use of these pesticides and reduce the impact on bee populations.
The development of the class of neonicotinoids began with work in the 1980s. They were developed in large part because they show reduced toxicity compared to previously used organophosphate and carbamate insecticides. Most neonicotinoids show much lower toxicity in mammals than insects, but some breakdown products are toxic. The neonicotinoid imidaclopridis currently the most widely used insecticide in the world. Available neonicotinoid insecticides include – Acetamiprid; Clothianidin; Dinotefuran; Imidacloprid; Nitenpyram; Thiacloprid; and Thiamethoxam; Trade names include – Actara, Platinum, Helix, Cruiser, Adage, Meridian, Centric, Flagship, Poncho, Titan, Clutch, Belay, Arena, Confidor, Merit, Admire, Ledgend, Pravado, Encore, Goucho, Premise, Assail, Intruder, Adjust and Calypso.
Honeybee Colony Collapse Disorder
Colony collapse disorder (“CCD”) is a phenomenon in which worker bees from a beehive or European honey bee colony abruptly disappear. (It is important to note that honey bees are not native to the Americas.) The first report of CCD was in mid-November 2006 by a Pennsylvania beekeeper overwintering in Florida. By February 2007, large commercial migratory beekeepers in several states had reported heavy losses associated with CCD. Their reports of losses varied widely, ranging from thirty to ninety percent (30% to 90%) of their bee colonies; in some cases beekeepers reported loss of nearly all of their colonies with surviving colonies so weakened that they might no longer be viable to pollinate or produce honey. Losses were reported in migratory operations wintering in California, Florida, Oklahoma and Texas. Some larger non-migratory beekeepers in the mid- Atlantic and Pacific Northwest regions also reported significant losses of more than 50%. Colony losses also were reported in five Canadian provinces, several European countries, and countries in South and Central America and Asia. In 2010, the USDA reported that data on overall honey bee losses for the year indicate an estimated 34% loss, which is statistically similar to losses reported in 2007, 2008, and 2009; in 2011 the loss was 30%.
Colony collapse is significant economically because many agricultural crops worldwide are pollinated by bees; and ecologically due to the major role that bees play in the reproduction of plant communities. Honey bees are responsible for pollination of approximately one third of the United States’ crop species, including such species as almonds, peaches, soybeans, apples, pears, cherries, raspberries, blackberries, cranberries, watermelons, cantaloupes, cucumbers and strawberries. Bee pollination contributes an estimated $15 billion in additional crop yields.
European beekeepers observed similar phenomena in Belgium, France, the Netherlands, Greece, Italy, Portugal, and Spain, and initial reports have also come in from Switzerland and Germany, albeit to a lesser degree while the Northern Ireland Assembly received reports of a decline greater than 50%. Several European countries have suspended the use of certain pesticides in response to incidents involving acute poisoning of honey bees. For example:
- France – Sunflower and corn seed treatments of imidacloprid are suspended.
- Germany – The use of a number of seed treatment pesticides was temporarily suspended following an incident in May 2008 in which many bees were inadvertently poisoned. However, after investigating the factors contributing to the situation, Germany lifted the suspensions with the exception of the neonicotinoid clothianidin.
- Holland – banned Imidaclprid completely in open-air situations. The product evidently leaves a residue in the soil that completely destroys the Earthworm population that is so important to soil conservation.
- Italy – Certain imidacloprid and other neonicotinoid seed treatment uses were suspended temporarily – this action was taken based on preliminary monitoring studies in northern and southern regions of Italy showing that bee losses were correlated with the application of seeds treated with these compounds.
- Slovenia – Neonicotinoid seed treatments for maize and oil seed rape (canola) were temporarily suspended. The suspension was based on poor seed treatment methods resulting in release of dust during the seed sowing process.
Risks Noted by EPA
Insecticide-treated seeds are covered with a sticky substance to control its release into the environment; however they are then coated with talc to facilitate machine planting, which is released into the environment in large amounts. The study found that the exhausted talc showed extremely high levels of the insecticides—up to about 700,000 times the lethal contact dose for a bee. “Whatever was on the seed was being exhausted into the environment. This material is so concentrated that even small amounts landing on flowering plants around a field can kill foragers or be transported to the hive in contaminated pollen. This might be why we found these insecticides in pollen that the bees had collected and brought back to their hives.” Acute toxicity studies show clothianidin is highly toxic on both a contact and an oral basis to bees.
- EPA reports dating back to 2003 suggest EPA and USDA may have downplayed warnings from EPA scientists about the impact of certain pesticides on bee colonies.
- As a result of the disclosure of an internal EPA memo linking health impacts on bees from the application of clothianidin and the widespread honeybee disappearance, the National Honey Bee Advisory Board and other organizations have requested the agency to remove clothianidin from the market. EPA officials have declined, contending that the organizations’ complaint and the subsequent press coverage of the flap make erroneous assertions.
A November 2, 2010, memorandum from the U.S. EPA Office of Chemical Safety and Pollution Prevention entitled, Clothianidin Registration of Prosper T400 Seed Treatment on Mustard Seed (Oilseed and Condiment) and Poncho/Votivo Seed Treatment on Cotton, summarized the Environmental Fate and Effects Division’s (“EFED”) screening-level Environmental Risk Assessment for clothianidin.
- Clothianidin is an insecticide that is both persistent and systemic. Acute toxicity studies to honey bees show that clothianidin is highly toxic on both a contact and an oral basis.
- Data suggest that neonicotinoid residues can accumulate in pollen and nectar of treated plants and may represent a potential exposure to pollinators.
- Adverse effects data as well as beekill incidents have also been reported, highlighting the potential direct and/or indirect effects of neonicotinoid pesticides.
- The memo goes on to say that “information from standard tests and field studies, as well as incident reports involving other neonicotinoid insecticides (e.g., imidacloprid) suggest the potential for long term toxic risk to honey bees and other beneficial insects.”
- In 2012, researchers announced findings that sublethal exposure to imidacloprid rendered honey bees significantly more susceptible to infection by the fungus Nosema, thereby suggesting a potential link to CCD, given that Nosema is increasingly considered to contribute to CCD.
- Also in 2012, researchers in Italy published findings that the pneumatic drilling machines that plant corn seeds coated with clothianidin and imidacloprid release large amounts of the pesticide into the air, causing significant mortality in foraging honey bees.
- A 2012 in situ study provided strong evidence that exposure to sub-lethal levels of imidacloprid in high fructose corn syrup (“HFCS”) used to feed honey bees when forage is not available causes bees to exhibit symptoms consistent to CCD 23 weeks post imidacloprid dosing. The researchers suggested that “the observed delayed mortality in honey bees caused by imidacloprid in HFCS is a novel and plausible mechanism for CCD, and should be validated in future studies”.
- In the March 29, 2012, issue of the journal Science, two separate studies found that neonicotinoids may interfere with bee’s natural homing abilities, causing them to become disoriented and preventing them from finding their way back to the hive.
- Congress should direct the EPA to investigate the impacts of this class of pesticides on honeybees and other pollinators.
- Congress should direct EPA to report on the steps the Agency has taken to ensure there is sufficient scientific evidence to make informed decisions about the impacts of neonicotinoids on bees and other pollinators.
- Congress should direct EPA to report (1) what steps the Agency has taken and (2) what more can the agency do to limit or restrict the use of these pesticides and reduce the impact on bee populations.