Follow the honey: Smoking bees makes them less mad when you move them, but leaked EPA documents might have the opposite effect.Photo: Kris FrickeIt's
not just the State and Defense departments that are reeling this month
from leaked documents. The Environmental Protection Agency now has some
explaining to do, too. In place of dodgy dealings with foreign leaders,
this case involves the German agrichemical giant Bayer; a pesticide
with an unpronounceable name, clothianidin; and an insect species
crucial to food production (as well as a food producer itself), the
honeybee. And in lieu of a memo leaked to a globetrotting Australian, this
one features a document delivered to a long-time Colorado beekeeper.
All
of that, plus my favorite crop to fixate on: industrial corn, which
blankets 88 million acres of farmland nationwide and produces a bounty
of protein-rich pollen on which honeybees love to feast.
It's The Agency Who Kicked the Beehive, as written by Jonathan Franzen!
Hive talking
An
internal EPA memo released Wednesday confirms that the very agency
charged with protecting the environment is ignoring the warnings of its
own scientists about clothianidin, a pesticide from which Bayer racked up €183 million (about $262 million) in sales in 2009.
Clothianidin
has been widely used on corn, the largest U.S. crop, since 2003.
Suppliers sell seeds pre-treated with it. Like other members of the
neonicotinoid family of pesticides, clothianidin gets "taken up by a
plant's vascular system and expressed through pollen and nectar,"
according to Pesticide Action Network of North America (PANNA), which
leaked the document along with Beyond Pesticides. That effect makes it
highly toxic to a crop's pests -- and also harmful to pollen-hoarding
honeybees, which have experienced mysterious annual massive die-offs
(known as "colony collapse disorder") here in the United States at least
since 2006.
The
colony-collapse phenomenon is complex and still not completely
understood. While there appears to be no single cause for the annual
die-offs, mounting evidence points to pesticides,
and specifically neonicotinoids (derived from nicotine), as a key
factor. And neonicotinoids are a relatively new factor in ecosystems
frequented by honeybees -- introduced in the late 1990s, these systemic
insecticides have gained a steadily rising share of the seed-treatment
market. It does not seem unfair to observe that the health of the
honeybee population has steadily declined over the same period.
According
to PANNA, other crops commonly treated with clothianidin include
canola, soy, sugar beets, sunflowers, and wheat -- all among the most
widely planted U.S. crops. Bayer is now petitioning the EPA to register
it for use with cotton and mustard seed.
The document [PDF], leaked to Colorado beekeeper Tom Theobald, reveals that EPA
scientists have declared essentially rejected the findings of a study conducted on behalf of Bayer
that the agency had used to justify the registration of clothianidin.
And they reiterated concerns that widespread use of clothianidin
imperils the health of the nation's honeybees.
On
Thursday, I asked an EPA press spokesperson via email if the
scientists' opinion would inspire the agency to remove clothianidin from
the market. The spokesperson, who asked not to be named but who
communicated on the record on behalf of the agency, replied that
clothianidin would retain its registration and be available for use in
the spring.
Wimpy watchdogging
Before
we dig deeper into the leaked memo, it's important to understand the
sorry story of how an insecticide known to harm honeybee populations
came to blanket a huge swath of U.S. farmland in the first place. It's
nearly impossible not to read it as a tale of a key public watchdog
instead heeling to the industry it's supposed to regulate.
In
the EPA's dealings with Bayer on this particular insecticide, the
agency charged with protecting the environment has consistently made
industry-friendly decisions that contradict the conclusions of its own
scientists -- and threaten to do monumental harm to our food system by
wiping out its key pollinators.
According to a time line provided by PANNA, the sordid story begins when Bayer first applied for
registration of clothianidin in 2003. (All of the documents to which I
link below were provided to me by PANNA.) By 2003, U.S. beekeepers were
reporting difficulties in keeping hives healthy through the winter, but
not yet on the scale of colony collapse disorder. In February of this
year, the EPA's Environmental Fate and Effects Division (EFED) withheld
registration of clothianidin, declaring that it wanted more evidence
that it wouldn't harm bee populations.
In a memo [PDF], an EFAD scientist explained the decision:
The possibility of toxic exposure to nontarget pollinators [e.g., honeybees] through the translocation of clothianidin residues that result from seed treatment (corn and canola) has prompted EFED to require field testing that can evaluate the possible chronic exposure to honeybee larvae and the queen. In order to fully evaluate the possibility of this toxic effect, a complete worker bee life cycle study (about 63 days) must be conducted, as well as an evaluation of exposure to the queen.
So,
no selling clothianidin until a close, expert examination of how pollen
infused with it would affect worker bees and Her Majesty the queen.
Again,
that was in February of 2003. But in April of that year, just two
months later, the agency backtracked. "After further consideration," the
agency wrote in another memo,
the EPA has decided to grant clothianidin "conditional registration" --
meaning that Bayer was free to sell it, and seed processors were free
to apply it to their products. (Don't get me started on the EPA's habit
of granting dodgy chemicals "conditional registration," before allowing
their unregulated use for years and even decades. That's another story.)
The
EPA's one condition reflected the concerns of its scientists about how
it would affect honeybees: that Bayer complete the "chronic life cycle
study" the agency had already requested by December of 2004. The
scientists minced no words in reiterating their concerns. They called
clothianidin's effects "persistent" and "toxic to honeybees" and noted
the the "potential for expression in pollen and nectar of flowering
crops."
These
concerns aside and "conditional registration" in hand, Bayer
introduced clothianidin to the U.S. market in spring 2003. Farmers
throughout the corn belt planted seeds treated with clothianidin, and
billions -- if not trillions -- of plants began producing pollen rich
with the bee-killing stuff.
A bee does what it does best -- thankfully, not in a corn field.Photo: PurplekeyIn March of 2004, Bayer requested an extension on its December deadline for delivering the life-cycle study. In a March 11 memo [PDF], the EPA agreed, giving the chemical giant until May 2005 to
complete the research. Clothianidin continued flowing from Bayer's
factories and from corn plants into pollen.
But
the EPA also relayed a crucial decision in this memo: It granted Bayer
the permission it had sought to conduct its study on canola in Canada,
instead of on corn in the United States. The EPA justified the decision
as follows:
[Canola] is attractive to bee [sic] and will provide bee exposure from both pollen and nectar. An alternative crop, such as corn, which is less attractive to bees as a forage crop, would provide exposure from pollen, only.
Bee experts cite three problems with this decision:
- Corn produces much more pollen than does canola;
- its pollen is more attractive to honey bees; and
- canola is a minor crop in the United States, while corn is the single most widely planted crop.
What
happened next was ... not much. Bayer let the deadline for completing the
study lapse; and the EPA let Bayer keep selling clothianidin, which
continued to be deposited into tens of millions of acres of farmland.
Not until August of 2007, more than a year after its deadline, did Bayer deliver its study. In a November 2007 memo [PDF], EPA scientists declared the study "scientifically sound," adding
that it, "satisfies the guideline requirements for a field toxicity
test with honeybees."
Beeing and nothingness
So what were the details of that study, on which the health of our little pollinator friends depended?
Well,
the EPA initially refused to release it publicly, prompting a Freedom
of Information Act by the Natural Resources Defense Council. When the
EPA still refused to release it, NRDC filed suit in response. Eventually, the study was released. Here it is [PDF].
Prepared
for Bayer by researchers at Canada's University of Guelph, the study is
a bit of a joke. The researchers created several 2.47-acre fields
planted with clothianidin-treated seeds and matching untreated control
fields, and placed hives at the center of each. Bees were allowed to
roam freely. The problem is that bees forage in a range of 1.24 to 6.2
miles -- meaning that the test bees most likely dined outside of
the test fields. Worse, the test and control fields were planted as
closely as 968 feet apart, meaning test and control bees had access to
each other's fields.
Not
surprisingly, the researchers found "no differences in bee mortality,
worker longevity, or brood development occurred between control and
treatment groups throughout the study."
Tom
Theobald, the Colorado beekeeper who obtained the leaked memo, assessed
the study harshly on the phone to me Thursday. "Imagine you're a
rancher trying to figure out if a noxious weed is harming your cows," he
said. "If you plant the weed on two acres and let your cows roam free
over 50 acres of lush Montana grass, you're not going to learn much
about that weed."
James Frazier, professor of entomology at Penn State, concurred.
Frazier has been studying colony-collapse disorder since 2006. "When I
looked at the study," he told me in a phone interview, "I immediately
thought it was invalid."
Meanwhile,
Bayer continued selling clothianidin under its conditional
registration. Then, on April 22 of this year, the EPA finally ended
clothianidin's long period of "conditional" purgatory -- by granting it full registration.
The
agency gifted the bee-killing pesticide with its new status quietly; to
my knowledge, the only public acknowledgment of it came through the
efforts of Theobald, who is extremely worried about the fate of his own
bee-keeping business in Colorado's corn country. Theobald forwarded me a
Nov. 29 email exchange with Meredith Laws, the acting chief of the
EPA's herbicide division in the Office of Pesticide Programs, to whom
he'd written to enquire about clothianidin's registration status. Laws'
reply is worth quoting in its entirety:
Clothianidin was granted an unconditional registration for use as a seed treatment for corn and canola on April 22, 2010. EPA issued a new registration notice, [but] there is no document that acknowledges the change from conditional to unconditional. This was a risk management decision based on the fulfillment of data requirements and reviews accepting or acknowledging the submittal of the data.
So, the EPA gave Bayer and its dubious pesticide a full pass without even bothering to let the public know.
Just bee very careful, please
Now we get to the leaked memo [PDF]. It is dated Nov. 2 -- three weeks before Laws' reply to Theobald.
It relates to Bayer's efforts to expand clothianidin's approved use into
cotton and mustard. Authored by two scientists in the EPA's
Environmental Fate and Effects Division -- ecologist Joseph DeCant and
chemist Michael Barrett -- the memo expresses grave concern about
clothianidin's effect on honeybees:
Clothianidin's major risk concern is to nontarget insects (that is, honey bees).
Clothianidin is a neonicotinoid 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. Although EFED does not conduct ... risk assessments on non-target insects, information from standard tests and field studies, as well as incident reports involving other neonicotinoids insecticides (e.g., imidacloprid) suggest the potential for long term toxic risk to honey bees and other beneficial insects.
The real kicker is that the researchers essentially invalidated the Bayer-funded study -- i.e., the study on which the EPA based clothianidin's registration as an fully registered chemical. Referring to the pesticide, the authors write:
A previous field study [i.e., the Bayer study] investigated the effects of clothianidin on whole hive parameters and was classified as acceptable. However, after another review of this field study in light of additional information, deficiencies were identified that render the study supplemental. It does not satisfy the guideline 850.3040, and another field study is needed to evaluate the effects of clothianidin on bees through contaminated pollen and nectar. Exposure through contaminated pollen and nectar and potential toxic effects therefore remain an uncertainty for pollinators. [Emphasis mine.]
So,
here we have EPA researchers explicitly invalidating the study on which
clothianidin gained registration for corn. But as I wrote above,
despite this information's being made public, the EPA has signaled that
it has no plans to change the chemical's status.
In
the 2011 growing season, tens of millions of acres of farmland will
bloom with clothianidin-laced pollen -- honeybees, and sound science, be
damned.
Now,
in my correspondence with the EPA, the agency has denied that the
downgrading of the Bayer study from "acceptable" to "supplemental" meant
that the agency should be compelled to clothianidin's approval. In a
Thursday email to me, the agency delivered a limp defense of the Bayer
study, contradicting its own scientists and addressing none of the
critiques of it:
EPA's evaluation of the study determined that it contains information useful to the agency's risk assessment. The study revealed the majority of hives monitored, including those exposed to clothianidin during the previous season, survived the over-wintering period.
And
it downplayed the study's importance to Bayer's application to register
clothianidin: The study in question is "not a 'core' study for EPA as
claimed," the agency insisted. "It is not a study routinely required to
support the registration of a pesticide."
I
ran that response by Jay Feldman of Beyond Pesticides, the group that
collaborated with PANNA in publicizing the leaked document. "I find the
EPA response either misinformed or misleading," he told me. "The paper
trail on this is clear. We're talking about a bad study required by EPA
[that is central] to the registration of this chemical."
Feldman's
assessment appears to bear out. He pointed me back to the above-linked
Nov. 27 document in which EPA originally accepted the Bayer study.
There, on page 5, we find this statement:
Specifically, the test was conducted in response to a request by the Canadian PMRA [Pesticides and Pest Management Agency] and the U.S. EPA; as a condition for Poncho@ [clothianidin] registration in these countries, Bayer CropScience was asked to investigate the long-term toxicity of clothianidin-treated canola to foraging honey bees.
So evidently, the discredited Bayer study does
lie at the heart of clothianidin's acceptance. (I have requested an
interview with an EPA official who can talk knowledgeably and on the
record about these matters; the anonymous-by-request spokesperson is, at
the time of publication, still looking for the "right person," I was
informed via email.)
A stinging assessment
At
the very least, we have ample evidence that the EPA has been ignoring
the warnings of its own staff scientists and green-lighting the mass
deployment of a chemical widely understood to harm pollinators -- at a
time when honeybees are in grave shape.
But why?
Tom Theobald, the Colorado beekeeper who broke this story, ventured an
answer. "It's corporatism, the flip side of fascism," he said. "I'm not
against corporations, I think they have a good model. But they're like
children -- we have to rein them in or they get out of hand. The EPA's
supposed to do that."
When
regime change came to Washington in 2008, many of us hoped that an EPA
under Barack Obama would be a better parent. EPA Director Lisa Jackson inherited quite a mess from her predecessor, and she faces the Herculean challenge of regulating greenhouse gases against fierce Republican and industry opposition.
But
as concern mounts -- from her own staff and elsewhere -- that
clothianidin is harming honeybees, there's no excuse for Jackson's
agency to keep coddling Bayer. Frazier, the Penn State entomologist, put
it to me like this: "If the Bayer study is the core study the EPA used
to register clothianidin, then there's no basis for registering it." He
urged the EPA to withdraw registration to avoid unnecessary risk to a
critical player in our ecosystem
-- as have the governments of Germany, France, Italy, and Slovenia.
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