Beekeeper Tom Theobald, courtesy of Barbara Theobald
Though worldwide honey bee health has been on the decline since the 1980's, it wasn't until the fall of 2006 that beekeepers nation wide began noticing honey bee colonies disappearing in large numbers without known reason. This syndrome, named Colony Collapse Disorder or CCD, is characterized by the inexplicable disappearance of the hive's worker bees, leaving the newborns to fend for themselves.
Researchers globally have been trying to pin down the cause or causes of this mysterious ailment. Most entomologists believe a combination of factors are involved: exposure to pesticides, urbanization, disruption of habitat, water pollution, climate change, the Israeli Acute Paralysis Virus, the Varroa mite and literally trucking bee hives around the world to pollinate crops. However, more and more evidence is pointing to sub-lethal pesticide exposures as critical contributing factors.
Beekeepers and environmentalists today called on EPA to remove the pesticide Clothianidin, 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.
Pesticide Action Network and Beyond Pesticides joined forces with beekeepers from around the country to call 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. The pesticide is already illegal in Germany, Italy and France based on scientific findings.
"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," said Jeff Anderson, experienced beekeeper and owner of California Minnesota Honey Farms, a farm and beekeeping operation of just under 3000 bee colonies. "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 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. We 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, Co-Chair of the National Honey Bee Advisory Board.
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.
A letter was sent to EPA Administrator, Lisa Jackson, from Steve Ellis, National Honey Bee Advisory Board, Kenneth Haff, President American Honey Producers Association, Heather Pilatic, Co-Director Pesticide Action Network North America, Jay Feldman, Director Beyond Pesticides, David Mendes, President American Beekeeping Foundation and Justin Augustine, staff attorney at Center for Biological Diversity.
The letter asked, "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... 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."
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.
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.
Unfortunately, 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.
"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 who began beekeeping after working with IBM. "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."