I agree with Tom Philpott. This is not a rebuttal at all. It is actually an admission that no such
rebuttal is forthcoming nor will be forthcoming.
The product has already been banned in key markets in Europe and you would surely expect to see Bayer on their
best game. Instead we have a weak ‘but
your agency approved it’ comment.
The present level of institutional integrity is so
undermined in terms of public confidence that such defenses no longer work, if
they ever did.
We have a problem Bayer, and the size of the market is
not big enough for you to bet the whole company trying to defend it. We all know that the EPA testing standards
are routinely skated around and that is plausibly permissible when there is no
creditable pathway to more serious harm.
Here the pathway is obvious and measurable. That the bee threshold
is way lower than originally hoped for is disappointing. A field proof using the entire US corn crop was a bit over the top, and it has
decimated the US
bee industry. From now on all losses are
accumulating to Bayer’s account in the inevitable class action suit. I suspect someone is trying to make it to retirement before the proverbial C### hits the fan.
The agro chemical industry is big enough to do this
right. It takes years to introduce a new
product for good reason. Large multi
year field tests are needed and I see that detailed biological studies are
needed in surrounding wilds and fields in order to assess impact.
That may still have missed colony collapse disorder but
it would pick up a lot of effects that are happening under the radar.
Update: Bayer
responds to criticism of its potentially bee-killing pesticide
BY Tom Philpott
20 DEC 2010 8:56 AM
I recently wrote about a study, funded by
the German chemical giant Bayer, purporting to show that Bayer's blockbuster
pesticide clothianidin doesn't harm honeybees when applied as a treatment to
seeds.
The EPA had required the study before it would
register clothianidin. Years before it finally got the study in 2007, the EPA
granted the neonicotinoid pesticide "partial registration," and
farmers promptly began to apply it to millions of acres of farmland across the
country. Meanwhile, a mysterious phenomenon called "colony collapse
disorder" arose -- across the nation, beekeepers were finding it
increasingly impossible to keep their hives alive.
To make a long story short, the EPA eventually accepted Bayer's study
and granted clothianidin full registration in early 2010. But as I reported
earlier, a leaked document (PDF) from November shows
that two EPA scientists had reviewed that Bayer study and found it wanting. The
study had "deficiencies," they wrote, that rendered it unacceptable.
The study was clearly flawed -- it appeared to
let test and control bees range widely and forage on both clothianidin-treated
and non-treated fields. "When I looked at the study," Penn State
entomologist James Frazier told me in a phone interview, "I immediately
thought it was invalid."
Well, Bayer has now responded to critiques of
the study on its website. Lamenting the "unauthorized release" of the
recent EPA memo, the agrichemical giant declared:
The study referenced in the document is important research, conducted
by independent experts and published in a major peer-reviewed scientific
journal. The long-term field study conducted in accordance with Good Laboratory
Practices (GLP) by independent experts using clothianidin-treated seed showed
that there were no effects on bee mortality, weight gain, worker longevity,
brood development, honey yield and over-winter survival. The EPA reviewed and
approved the study protocol prior to its initiation and it was peer-reviewed
and published in the Journal of
Economic Entomology*. Upon reviewing the results of the long-term trial,
the Agency noted the study as "scientifically sound and satisfies the
guideline requirements for a field toxicity test with honey bees.
"Independent experts," huh? Not
really -- Bayer paid for that study.
But here's the important thing about that
response: It contains no substantial defense of the methodology, and no attempt
to explain its obvious flaws. The response, essentially, is that the EPA
initially approved the study, therefore it is valid. Of course, in that
"unauthorized release," EPA scientists explicitly withdrew approval
citing "deficiencies"
-- and Bayer has no comment on those concerns.
For me, Bayer's hollow response actually
raises the level of alarm about what clothianidin is doing to our honeybees
rather than mutes it.
As I reported before, EPA continues to stand behind Bayer despite its
own scientists' concerns. If you want to let the agency's administrator, Lisa
Jackson, know what you think about that decision, check out Pesticide Action
Network's petition.
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I find it very suspicious that the military is now involved in the research on colony-collapse disorder. More than suspicious, really, frightening.
A number of years ago, Military Intelligence Officer Milton William Cooper exposed a secret plan by a government faction to gain total control over the country by engineering a nationwide emergency, which would allow for the suspension of the Constitution and the Bill of Rights. He speculated that an epidemic spread by bees could be the artificial crisis. After publishing his findings, he was shot to death by a government agent.
C.C.D. could provide the military with the perfect smokescreen for the introduction of a human-killing strain to honeybee populations. I hope someone is investigating this possible link.
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