Excerpt from "EPA’s Final Work Plan (FWP) for the registration review of imidacloprid"

> During the public comment period, the Agency received over 12,000 comments. The 
majority of those comments were received as a result of a letter writing campaign 
organized by Natural Resources Defense Council (NRDC) voicing concern that imidacloprid 
presents unacceptable risks to pollinators. The Agency received similar comments, i.e., 
concern over the risk to  pollinators, from private citizens, honey beekeeper interests 
represented by the National Honey Bee Advisory Board (NHBAB), and environmental 
advocacy groups like Beyond Pesticides, NRDC, and Sierra Club.


Excerpts from the Office of Pesticide Programs Response to the Sierra Club:

As OPP's Director, I appreciate the opportunity to address the issues you raise and 
respond to your request that EPA suspend use of nicotinyl insecticides. OPP has been 
actively involved in pollinator protection, and we share your concern that pesticides may 
have a role in Colony Collapse Disorder (CCD). 

For more than five years, EPA has required studies to evaluate sub-lethal effects of 
nicotinyl pesticides on bees as a requirement for registration. We have evaluated the 
potential for a variety of sub-lethal effects in these studies, such as behavioral effects 
and incidence of disease, that could cumulatively affect the functioning of hives. 

These studies and information available in the open literature to date do not demonstrate 
a link between these effects and severe adverse impacts to bees, such as the incidence of 
CCD, that you identify in your letter. 

Specifically, a survey of beekeepers conducted by the U.S. Department of Agriculture 
(USDA) shows no consistent link between the use of neonicotinics or pesticides in general 
on the frequency or location of bee colony losses attributed to CCD. 

Additionally, acute and chronic effects thus far demonstrated for most pesticides, 
including the neonicotinics, in both registrant submitted data and open literature, are not 
consistent with the sudden disappearance of bees that is considered diagnostic for CCD. 

While the current battery of guideline toxicity tests on pollinators focuses on adult forage 
bees initially, higher tier testing (field pollinator tests) examines potential effects on adult 
bees and their brood. In each tier of testing, however, sublethal behavioral effects are 
monitored. None of these tests thus far have provided any evidence of adult bees 
abandoning the hive and leaving no trace of their whereabouts, as has been observed 
with CCD. 

Our discussions with academic and government researchers studying this problem 
reaffirm that there is currently no evidence directly linking pesticides, including the 
neonicotinoid insecticides, to CCD or other serious impacts to colonies where they have 
become more susceptible to disease.

http://www.regulations.gov/
Docket Detail EPA-HQ-OPP-2008-0844

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