Neil Carman, a Sierra Club staff person from Austin Texas, was interviewed for this article.--Tom

 

Quote: The EPA did not clarify what is meant by "imminent hazard" and why the death of honeybees does not qualify.
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http://www.salon.com/env/feature/2009/05/18/bees_pesticides/
Pesticides indicted in bee deaths
Agriculture officials have renewed their scrutiny of the world's
best-selling pest-killer as they try to solve the mysterious collapse
of the nation's hives.
By Julia Scott
   
May 18, 2009 | Gene Brandi will always rue the summer of 2007. That's
when the California beekeeper rented half his honeybees, or 1,000
hives, to a watermelon farmer in the San Joaquin Valley at pollination
time. The following winter, 50 percent of Brandi's bees were dead.
"They pretty much disappeared," says Brandi, who's been keeping bees
for 35 years.
Since the advent in 2006 of colony collapse disorder, the mysterious
ailment that continues to decimate hives across the country, Brandi
has grown accustomed to seeing up to 40 percent of his bees vanish
each year, simply leave the hive in search of food and never come
back. But this was different. Instead of losing bees from all his
colonies, Brandi watched the ones that skipped watermelon duty
continue to thrive.

Brandi discovered the watermelon farmer had irrigated his plants with
imidacloprid, the world's best-selling insecticide created by Bayer
CropScience Inc., one of the world's leading producers of pesticides
and genetically modified vegetable seeds, with annual sales of $8.6
billion. Blended with water and applied to the soil, imidacloprid
creates a moist mixture the bees likely drank from on a hot day.

Stories like Brandi's have become so common that the National Honeybee
Advisory Board, which represents the two biggest beekeeper
associations in the U.S., recently asked the U.S. Environmental
Protection Agency to ban the product. "We believe imidacloprid kills
bees -- specifically, that it causes bee colonies to collapse," says
Clint Walker, co-chairman of the board.

Beekeepers have singled out imidacloprid and its chemical cousin
clothianidin, also produced by Bayer CropScience, as a cause of bee
die-offs around the world for over a decade. More recently, the same
products have been blamed by American beekeepers, who claim the
product is a cause of colony collapse disorder, which has cost many
commercial U.S. beekeepers at least a third of their bees since 2006,
and threatens the reliability of the world's food supply.

Scientists have started to turn their attention to both products,
which are receiving new scrutiny in the U.S., due to a disclosure in
December 2007 by Bayer CropScience itself. Bayer scientists found
imidacloprid in the nectar and pollen of flowering trees and shrubs at
concentrations high enough to kill a honeybee in minutes. The
disclosure recently set in motion product reviews by the California
Department of Pesticide Regulation and the EPA. The tests are
scheduled to wrap up in 2014, though environmentalists, including the
Sierra Club, are petitioning the EPA to speed up the work.

For over a decade, Bayer CropScience has been forced to defend the
family of insecticides against calls for a ban by beekeepers and
environmentalists. French beekeepers succeeded in having imidacloprid
banned for use on several crops after a third of the country's bees
died following its use in 1999 -- although the French bee population
never quite rebounded, as Bayer is quick to point out. Germany banned
the use of clothianidin and seven other insecticides in 2008 after
tests implicated them in killing up to 60 percent of honeybees in
southwest Germany.

Imidacloprid and clothianidin are chloronicotinoids, a synthetic
compound that combines nicotine, a powerful toxin, with chlorine to
attack an insect's nervous system. The chemical is applied to the seed
of a plant, added to soil, or sprayed on a crop and spreads to every
corner of the plant's tissue, killing the pests that feed on it.

Pennsylvania beekeeper John Macdonald has been keeping bees for over
30 years and recently became convinced that imidacloprid is linked to
colony collapse disorder. It's the only explanation he can find for
why his bees, whose hives border farmland that uses the pesticide,
started dropping dead a few years ago.

"There's the pernicious toxic effect -- it does everything nicotine
does to our nervous system," says Macdonald. "There's the pathological
effect, the interference with basic functions. They get lost, they get
disoriented. They fall to the ground. They get paralyzed and their
wings stick out. I can't think of anything in the environment that's
changed other than farming, and virtually every farmer is using
treated seeds now."

Bayer CropScience spokesman Jack Boyne says his company's pesticides
are not to blame. "We do a lot of research on our products and we feel
like we have a very good body of evidence to suggest that pesticides,
including insecticides, are not the cause of colony collapse
disorder," he says. "Pesticides have been around for a lot of years
now and honeybee collapse has only been a factor for the last few
years." (Imidacloprid has been approved for use in the U.S. since 1994
and clothianidin has been used since 2003.)

Scientists continue to investigate the causes of colony collapse
disorder. Leading theories suggest a combination of factors that
include parasitic mites, disease, malnutrition and environmental
contaminants like pesticides, insecticides and fungicides. The current
EPA review will provide further insight into the role of pesticides,
as it will uncover whether honeybees sickened by exposure to
imidacloprid spread it around by bringing contaminated nectar and
pollen back to the hive.

EPA critics suggest that the agency allowed economic considerations to
take precedence over the well-being of honeybees when it approved
imidacloprid for sale in the U.S. 15 years ago. "I think the EPA and
USDA [U.S. Department of Agriculture] have been covering up for Bayer,
and now they're scrambling to do something about it," says Neil
Carman, a plant biologist who advises the Sierra Club on pesticides
and other issues. "This review should have been done 10 years ago.
It's been found to be more persistent in the environment than was
reported by Bayer."

Imidacloprid was approved with knowledge that the product, marketed as
Gaucho, Confidor, Admire and others, was lethal to honeybees under
certain circumstances. Today the EPA's own literature calls it "very
highly toxic" to honeybees and other beneficial insects. Its
workaround was to slap a label on the product, warning farmers not to
spray it on a plant when bees were foraging in the neighborhood.

In its 2007 studies, Bayer applied standard doses of imidacloprid to
test trees, including apple, lime and dogwood. Its scientists found
imidacloprid in nectar at concentrations of up to 4,000 parts per
billion, a dose high enough to kill several bees at once. (Honeybees
can withstand a dose of up to 185 ppb, the standard amount it would
take to kill 50 percent of a test population.) What caught the
attention of California agricultural officials was that the test trees
contained the same amount of deadly imidacloprid as the citrus and
almond groves regularly sprayed by farmers, and pollinated by bees.
(California's almond industry has increased its use of imidacloprid by
a factor of 300 in the past five years.) Agricultural officials were
also surprised to learn that the imidacloprid can persist in the
leaves and blossoms of a plant for more than a year.

The Bayer results don't surprise University of California at Davis
professor Eric Mussen, a well-known entomologist and one of the
country's leading experts on colony collapse disorder. Mussen has seen
a variety of unpublished studies with similar results, including one
at U.C. Riverside that found imidacloprid in the nectar of a
eucalyptus tree bloom at concentrations of 550 ppb a full year after
it was applied.

"From some of the data on the trees, it appears as though there are
situations where honeybees can get into truly toxic doses of the
material," says Mussen, who avoids spraying imidacloprid on his own
demonstration fields at U.C. Davis. "This the first time that we've
had something you put in a tree that could stay there for a long
time."

But Mussen isn't convinced imidacloprid is a primary cause of the
honeybee die-off. He explains that some bees settle on fields of
sunflowers and canola treated with the chemical and then "fly right
through to next year." So imidacloprid is not the only story. "Could
it be part of the story?" he asks. "I'm sure. I think any of the
pesticides the bees bring back to the beehive is hurting the bees."

Mussen adds that ongoing research into chronic exposure to
insecticides will be crucial. It's likely, he says, that exposure to
even low doses acts like a one-two punch: It can weaken the bees until
a parasite or pathogen moves in to finish them off.

As the EPA begins its pesticide studies this year, skeptics wonder
whether the agency can conduct an unbiased review. Back in 2003, they
point out, the EPA reported that clothianidin was "highly toxic to
honeybees on an acute contact basis," and suggested that chronic
exposure could lead to effects on the larvae and reproductive effects
on the queen. Although the EPA asked Bayer for further studies of its
effects on honeybees, it nevertheless authorized the chemical for
market.

"If the EPA had sufficient concern about harm to bees that they would
insist on other studies, it seemed unwise to approve it anyway and ask
for research after the fact," says Aaron Colangelo, an attorney with
the Natural Resources Defense Council. "The EPA's job is to make a
decision about whether a chemical is safe or not."

Colangelo envisions a similar scenario in coming years. The EPA has
announced it will review clothianidin and other chemicals in the same
family, but not until 2012. In the meantime, there's nothing stopping
the agency from approving the insecticides for use on new crops based
on existing policies. In the end, Colangelo has little confidence the
federal agency will bring a hammer down on the agribusiness giant. The
EPA, he explains, often keeps its test results confidential for
proprietary reasons at a company's request. As a consequence, it's
unclear where gaps or discrepancies occur until a company makes a
disclosure similar to Bayer's.

"They're not making decisions about whether the pesticide can be put
on the market based on impacts to bees, no matter how much evidence of
harm there is," Colangelo says. "The EPA will just approve it anyway
and put a warning label on the product."

Halting the sale of pesticides, though, would be no mean task. Over
120 countries use imidacloprid under the Bayer label on more than 140
crop varieties, as well as on termites, flea collars and home garden
landscaping. And the product's patent expired a few years ago, paving
the way for it to be sold as a generic insecticide by dozens of
smaller corporations. In California alone, imidacloprid is the central
ingredient in 247 separate products sold by 50 different companies.

In a statement, the EPA says that before banning a pesticide, it "must
find that an 'imminent hazard' exists. The federal courts have ruled
that to make this finding, EPA must conclude, among other things, that
there is a substantial likelihood that imminent, serious harm will be
experienced from use of the pesticide." The EPA did not clarify what
is meant by "imminent hazard" and why the death of honeybees does not
qualify.

As Mussen points out, though, a few million dead honeybees may be the
cost of doing business. "If they didn't register products that were
toxic to honeybees, there wouldn't be a lot of products on the market
that were available for pest control."
All the more reason to start taking the world's most ubiquitous
insecticide off the market and invent a safer one, argues Walker, of
the National Honeybee Advisory Board. "It's on every golf course, it's
on every lawn. It's not just an agricultural product. There's really
not one part of our lives it's not touching."