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!
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
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
The document [PDF], leaked to
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.
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
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,
In a memo [PDF], an EFAD scientist explained the decision:
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
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
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
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
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
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 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.
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:
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:
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
But as concern mounts -- from her own staff and elsewhere -- that clothianidin is harming honeybees, there's no excuse for