Wednesday, September 24, 2014
Risk Policy Report - 07/31/2012

Democrats Urge EPA To Speed Neonicotinoid Review, Citing Pollinator Risk

Posted: July 30, 2012

Three Senate Democrats are urging EPA to expedite pesticide registration reviews of neonicotinoid pesticides over concerns about their possible contribution to the widespread deaths of honeybees and other pollinators, a request that adds to the pressure EPA faces from activists who have asked the agency to bar pesticides with the neonicotinoid clothianidin.

The request to complete the reviews in 2013, five years earlier than the 2018 date the senators say EPA is on track for, comes after EPA on July 17 partially rejected a petition from environmentalists to suspend clothianidin -- one of the neonicotinoids whose registrations the Democrats want EPA to review faster -- but left some questions unanswered pending additional study (Risk Policy Report, July 26).

But if EPA grants the request, the agency may have to grapple with whether it can conduct the required ecological risk assessments of the neonicotinoids using a new risk assessment procedure it is drafting for quantitatively estimating pollinator risks from pesticides, or if it will have to rely on its current procedures that beekeepers and others have called inadequate. EPA is still working on the procedure but has said it plans to take a proposal to a panel of scientific advisors in mid-September.

Neonicotinoids have been cited as among the potential contributors to colony collapse disorder (CCD), whose exact causes are still not fully understood despite efforts by environmentalists and others to tie it to pesticides' uses. But the agency, citing the accumulation of information on the substances' hazards and risks to pollinators, has said it is reviewing the neonicotinoid pesticides as a group as part of the registration review, moving many of them ahead in the schedule so that all the relevant regulatory dockets will be open by the end of fiscal year 2012.

"Therefore, among other refinements to ecological risk assessment during registration review, the Agency will consider potential effects of the neonicotinoids to honeybees and other pollinating insects," EPA told its Pesticide Program Dialogue Committee (PPDC) on May 4.

But stakeholders have expressed concern that EPA would not finish the registration reviews until 2018, which they believe is too late given the nature of their concerns. Led by Sen. Kirsten Gillibrand (D-NY), who sits on the Senate agriculture and environment committees, the Democrats cite the ongoing uncertainty and potential seriousness of the risks in arguing for faster reviews of clothianidin as well as a range of other neonicotinoids.

"It would be far too risky to wait [until 2018] given the seriousness of the concerns raised," Gillibrand, Sen. Sheldon Whitehouse (RI) and Sen. Patrick Leahy (VT) wrote in the July 26 letter to EPA Administrator Lisa Jackson. "We believe it would be more appropriate to establish an expedited deadline for completing the reviews. We expect that by the end of 2013, the EPA will be able to come to a consensus on all neonicotinoids and if it is found necessary to protect honey bees and other pollinators, the EPA will act quickly to remove them from the market." The letter is available on (Doc ID: 2405971)

The senators' plea adds to pressure from environmental groups such as Center for Food Safety (CFS) and beekeepers. In a March 21 petition, activists and beekeepers called for EPA to start cancellation proceedings for clothianidin and to suspend the registration pending the proceedings' outcome, arguing that the pesticide poses an "imminent hazard," one criterion that is sufficient under the Federal Insecticide, Fungicide & Rodenticide Act (FIFRA) to warrant a suspension.

But EPA, in its July 17 partial-response letter to CFS, rejects most of the petitioners' claims, reiterating the agency's recent assertions that evidence is lacking that clothianidin is contributing to rapid, widespread bee deaths. EPA concludes that while recent science shows clothianidin is toxic to honeybees, petitioners failed to explain why the pesticide poses an "imminent hazard." The agency, however, leaves unanswered the petitioners' argument that the requirements for the pesticide's conditional registration were never fulfilled because a key field study is still missing.

Additionally EPA's planned incorporation of pollinator risks into the ecological risk assessments during the registration review will come as the agency prepares a new quantitative risk assessment process for pollinators that the agency says will draw on recommendations from a 2011 international workshop on pollinator risk assessment. EPA has said it will take a draft proposal for a new risk assessment process for pollinators to its FIFRA Scientific Advisory Panel (SAP) for peer review in mid-September.

But it is not immediately clear whether EPA, if it decides to expedite the reviews, can finish that procedure and implement it in time to meet the 2013 timeline that the senators request.

Activists and beekeepers have argued that EPA's current risk assessment process fails to adequately account for the way in which systemic pesticides -- a relatively new class of chemicals that are absorbed into the leaves and stem of plants, may contribute to bee mortality -- despite studies suggesting that a joint infection from two pathogens could be to blame for the collapse of honeybee colonies.

The procedure is expected to draw on a global workshop that met in 2011 at a Society of Environmental Toxicology and Chemistry meeting to craft advice on improving risk assessments to mitigate threats to bees and other pollinators. The Pellston workshop recommendations for a risk assessment procedure include a tiered system that tailors the risk assessment for a pesticide to its exposure routes.

In the short term EPA is working on implementing recommendations from its PPDC, which has suggested increased use of best-management practices to reduce pollinator exposure to pesticides; making language on pesticide labels more consistent; and boosting training and educational resources for applicators and others who rely on pesticides (Risk Policy Report, May 8). -- Puneet Kollipara

Risk Policy Report - 07/31/2012, Vol. 19, No. 31