Sierra Club: New research should nail the coffin lid shut on a toxic bee-killing pesticide - Entire food chain found to be contaminated, from soil to pollen to dead bees

The Sierra Club, with over 1.3 million members and supporters, calls on the U.S. Environmental Protection Agency (EPA) to immediately suspend the registration of the insecticide clothianidin, based on new scientific evidence of extensive contamination in bees and soil. Last week (January 3, 2012) scientists at Purdue University documented major adverse impacts from clothianidin, used as a seed treatment in corn, on honey bee health. The results showed clothianidin present in foraging areas long after treated seed has been planted. The study raises questions about the long term survival of this major pollinator. "This research should nail the coffin lid shut on clothianidin", says Laurel Hopwood, Sierra Club's Chairwoman of the Genetic Engineering Action Team. "Despite numerous attempts by the beekeeping industry and conservation organizations to persuade the EPA to ban clothianidin, the EPA has failed to protect the food supply for the American people."

Tom Theobald, a founding member of the Boulder County Beekeeper's Association explains, "In 2010, I got hold of an EPA document revealing that the agency has been allowing the widespread use of this bee-toxic pesticide, against evidence that it's highly toxic to bees. Clothianidin has failed to meet the requirements for registration. It's continued use is in violation of the law."

Upon learning of the EPA's failures, the National Honey Bee Advisory Board, the American Beekeeping Federation and The American Honey Producer's Association urged the agency in a 12/8/2010 letter to cancel the registration of this pesticide. Yet despite the fact that clothianidin had failed a critical life cycle study which was required for registration, the agency responded in a 2/18/2011 letter stating "At this time, we are not aware of any data that reasonably demonstrates that bee colonies are subject to elevated losses due to chronic exposure to this pesticide. EPA does not intend at this time to initiate suspension or cancellation actions against the registered uses of clothianidin. If scientific information shows a particular pesticide is posing unreasonable risk to pollinators, we stand ready to take the necessary regulatory action."

Neil Carman, PhD, scientific advisor to Sierra Club, is troubled by EPA's complacency. "A huge shoe has dropped. U.S. researchers have documented major adverse impacts from clothianidin seed treatments in corn on honey bee health." Carman further explains "Because of the vital role played by honey bees in crop pollination, honey bee demise threatens the production of crops that produce one-third of American diets, including nearly 100 fruits and vegetables. The value of crops pollinated by bees exceeds $15 billion in the U.S. alone."

Hopwood exclaims, "The time is now for EPA to quit dodging the illusion of oversight and instead, cancel this bee- killing pesticide. If we travel too far down our current path, we could create conditions in our food system much like those that brought down the financial system."

Contact Laurel Hopwood, 216-371-9779 (EST)
Tom Theobald 303-652-2266 (MST)
Neil Carman, PhD. 512-288-5772 / cell 512-663-9594 (CST)

Read an article in Scotland's Sunday Herald of 15 January, 2012 on the Purdue University study:
http://www.heraldscotland.com/news/environment/scientists-link-mass-dea…
An EPA memo dated September 28, 2005 (attached) summarizes the Environmental Fate and Effects Division’s (EFED) screening-level Environmental Risk Assessment for Clothianidin:

- Clothianidin is expected to dissipate very slowly under terrestrial field conditions, based on the results of five bare ground field experiments conducted in the US and Canada. Half-lives of clothianidin, based on residues in the 0-15 cm soil depth, were 277 days (Wisconsin sand soil, incorporated), 315 days (Ohio silt loam soil, not incorporated), 365 days (Ontario silt loam soil, incorporated), and 1,386 days (North Dakota clay loam soil, not incorporated), and could not be determined at a fifth site due to limited dissipation during the 25-month study (Saskatchewan silty clay loam soil, incorporated). Incorporation did not appear to be a significant factor in determining the rate of dissipation. Clothianidin was generally not detected below the 45 cm soil depth except at one site, where it moved into the 45-60 cm depth. No degradates were detected at >10% of the applied, and degradates were generally only detected in the 0-15 cm soil layer. However, in many cases most of the parent remained untransformed at the close of the study; further accumulation of degradates could have occurred. Two studies were conducted to investigate leaching of clothianidin under field conditions. These studies were conducted in the Federal Republic of Germany and were apparently designed to fulfill certain European regulatory requirements. In these monolith lysimeter studies, 42 to 59% of the applied remained in the soil approximately 3 to 4 years following the first of two applications, and residues were primarily undegraded clothianidin.

- Direct contact and dietary exposure studies of honeybees indicate that clothianidin is highly toxic to honeybees (acute contact LD50 = 0.0439 µg/bee and acute oral LD50 = 0.0037 µg/bee). There is the potential for toxic exposure to honeybees, as well as other nontarget pollinators, through the translocation of clothianidin residues in nectar and pollen. In addition, studies indicate that clothianidin residues may affect foraging behavior. Data from studies determining the toxicity of residues on foliage indicate that clothianidin should not be applied to blooming, pollinating or nectar producing parts of plants because clothianidin will remain toxic to bees for days after a spray application. In honey bees, the effects of this toxic exposure may include lethal and/or sub-lethal effects in the larvae and reproductive effects to the queen. The field study EFED is requesting should resolve uncertainties dealing with clothianidin’s affects on bees. Clothianidin’s major risk concern is to nontarget insects (that is, honey bees). EFED expects adverse effects to bees if clothianidin is allowed to be sprayed on blooming, pollen-shedding, or nectar producing parts of plants. Although EFED does not conduct a risk quotient based risk assessment on non target insects, information from standard tests and field studies, as well as incident reports involving other neonicotinoids insecticides (e.g., imidacloprid) also suggest the potential for long term toxic risk to honey bees and other beneficial insects. Further studies may be needed to determine toxicity to honeybees from granular, seed treatment or foliar spray applications.
- The available data on clothianidin shows that the compound is relatively persistent to very persistent under most circumstances. Clothianidin is stable to hydrolysis at all pH's at environmental temperatures, moderately to highly stable under aerobic soil metabolism conditions (half lives range from 148 to 6,900 days).....Certain degradates appeared to accumulate in some soils under some conditions; over the very long term significant contamination of soil and water with these products might occur. The terrestrial field dissipation studies confirm the findings in the laboratory studies. Clothianidin was found to be persistent in the field (half lives of 277 days, 1,400 days, and too high to calculate).
- The Agency acknowledges that pesticides have the potential to exert indirect effects upon the listed organisms by, for example, perturbing forage or prey availability, altering the extent of nesting habitat, and creating gaps in the food chain