> ... so common sense tells
> me Bayer has reason to believe
Hi Paul
> ... so common sense tells
> me Bayer has reason to believe the potential problems
> for pollinators are not serious and can be mitigated,
> if necessary, via adjusting the formula or application
> doses / techniques.
To many, that will sound far too weak and trusting.
> What documented field evidence do the regulators have
> of serious harm to pollinators?
This document (and I apologise for the length of this cut-and-paste job) was being circulated recently around beekeepers here. It seems to come from Bee Culture. Of course, I can't comment on the veracity of all the claims made in it, but it does seem to be based in part on lab determinations and field observations in real beekeeping situations. It documents claims made to the EPA in December last year. I have been telling beekeepers that imidacloprid is unlikely to be a major determinant in CCD and UK winter losses - but reading this below has made me stop doing so, at least until better studies emerge.
all the best
Gavin
Beekeepers from around the United
States , and around the world, have had persistent
problems associated with the use of the systemic pesticide
imidacloprid. Since the first uses of imidacloprid in France in 1994 on
sunflowers beekeepers reported problems. Soon the condition was given a
name in France : “mad bee disease.” Problems
reported by beekeepers, combined with mounting independent scientific data,
caused the French Minister of Agriculture to suspend the use of imidacloprid on
sunflowers in January of 1999. In February 2004, France extended the suspension
to include uses on corn. At the same time they further broadened the
ban on systemic insecticides to include the chemical fipronil.
In Europe the debate goes on, important data
from toxicity studies is being produced. Conclusions from this data
vary. The chemical manufacturers continue to maintain that the systemic
compound imidacloprid is safe for use around honeybees, native pollinators,
birds, and does not pose an unreasonable risk to the environment. Reports
from the field, however, are telling a different story. The recent
dramatic increase in use of imidacloprid on a greatly expanded list of cropland,
rangeland, forest, residential, and recreational (golf courses and parks), has
greatly increased exposure of pollinators to contaminated nectar and pollen
expressed from flowering crops and weeds.
Imidacloprid is only one of six product formulations in the broader
class of “systemic neonicotinoids.” Although only imidacloprid is
currently ‘up’ for public comment, all six of these products in this class are
of great concern to beekeepers. Much attention has been given to the seed
treatments such as Gaucho, a trade name for a formulation of imidacloprid.
Recent data from Penn State on crab apple trees, although
unpublished, and not yet replicated is extremely concerning. Two controls,
and two treated trees were used in the experiment. After three weeks no
imidacloprid was detected. However the next spring pollen samples from
pollen sacs and anthers tested over 900 ppb combined Imidacloprid and 2
principal degradants: 5- hydroxe and olefin. In nectaries the combined
number was 1,450 ppb. Although further research is required for this study
to be properly concluded, the initial data raises questions about how
imidacloprid is stored and translocated in woody plants, like fruit trees.
Farmers, pesticide applicators, and beekeepers all look to EPA
to provide guidance on safe and unsafe ways to apply these economic
poisons. We will quote the public comment of Roger Haldenby (Plains Cotton
Growers, Inc. tracking number 808bfe56, February 23, 2009) on
Imidacloprid: “There are reports of imidacloprid toxicity to bees, birds,
earthworms, and some fresh water crustaceans. The impact of imidacloprid
on these organisms can be mitigated by proper application of the insecticide in
accordance with label instructions.”
Systemic pesticides, like imidacloprid, work on a different
principal. The chemical is taken up into the plant tissue, and becomes
systemic. Active chemical is moved throughout the plant including the
nectar and pollen of the treated crop plant, or inadvertently treated
weed. Once the chemical is in the nectar and pollen of the plant, no
protective means can be employed to protect the pollinator who gathers the
poisoned food. There is no “label warning” currently to protect pollinators
from imidacloprid tainted nectar and pollen. EPA does not have “safe
label” instructions for imidacloprid.
In an advertisement for Premise 200SC, an imidacloprid product for termite
control, Bayer states, “Premise 200SC interferes with (the) instinctive
social behavior (of termites), contributing to the termites’ demise. Low doses
of Premise 200 SC disorientate the termites and cause them to cease their
natural grooming behaviour. Grooming is important for termites to protect
them against pathogenic soil fungi. When termites stop grooming, the
naturally occurring fungi in the soil attack and kill termites. Premise
200SC makes fungi 10,000 times more dangerous to termites. Nature assists
Premis in giving unsurpassed control.” (Bayer Premise SC Brochure)
Major
incidents have been reported by beekeepers linked to imidacloprid. EPA is
aware that their incident reporting database of pesticide effects on honeybees
is not working. At the December 2, 2008 meeting between US EPA Office of
Pesticide Programs and Beekeepers, the beekeepers explained how the incident
reporting system, which utilizes state departments of agriculture and chemical
manufacturing companies, is not reporting beekeeper field incidents with
pesticides. The beekeepers at the meeting presented a wall chart showing all
incidents reported to EPA and then detailed how their own personal incidents, as
well as incidents of colleagues not there. Providing a mechanism for
reporting bee incidents was one of the eight “action items” listed as coming out
of that meeting.
Recognizing that EPA is not aware of beekeeper incidents related to
pesticides, we would like to provide you with a partial list of our own.
Many beekeepers will be reporting their individual incidents
independently. The list below by no means should be considered as
complete; it only attempts to showcase a few of the most prominent
incidents. Many commercial beekeepers have had problems related to the use
of imidacloprid.
The largest incident involved seven beekeepers in North Dakota and Minnesota with Gaucho, a product formulation of
Imidacloprid seed treatment on canola. The seven beekeepers
initiated legal action against Bayer Crop Science in Federal Court. Private
laboratory tests performed on the beekeepers’ wax comb and honey in
barrels. “ADPEN analyzed the material for imidacloprid, carbofuran,
dichlotvos and coumaphos. They found residues of imidacloprid in all of
the samples. The levels of imidacloprid found ranged from 22 to 671
ppb. These levels are much higher than the LD50 and are certainly killing
honeybees and causing sub lethal effects” (Mayer sworn and notarized DOC
dated 12th January 2007). Chris Charles explained that placing
these boxes on top of his hives would cause an immediate die off of the fie ld
bees. Concerns about this lethal mix in his wax combs caused him to
replace his entire comb with new. He observed that his bees
recovered after being given new fresh wax.
Clint Walker relates his experience with imidacloprid and cotton in Texas . “In the summer of 2006 we
shipped 500 bee hives to the cotton fields of West
Texas . It was a drought year where the only green plants were
under irrigation. During the active bloom phase of the cotton it was
treated with aerial and ground applications of imidacloprid (Gaucho and Admire)
for aphids. All of our 500 hives received sustained exposure to this chemical
with no immediate ill effects. Our crop was short due to the
drought. As we relocated the bees back to our home territory ( Central Texas ) in the early fall, the bees were strong and
apparently healthy.”
By In January of 2007 we began to see a significant portion of our
nearly 2000 hives begin to collapse with Colony Collapse Disorder (CCD)
symptoms. As we searched for an explanation to our losses, a disturbing
pattern emerged: All of the collapsing hives had been in West Texas four months earlier. We saw no CCD in the Central Texas bee colonies. This was the only difference in the
cultural practice of the bees that collapsed and those that were healthy.”
Dave Hackenberg tells his story of CCD on the East coast. In
2004, when our bees were first exposed to imidacloprid, we saw things happen in
our bees that we have never seen before. Good colonies of bees run through
pollinations and honey crops over the summer that we now know were exposed to
Assail in Apple pollination and Admire in pumpkin pollination, by fall
when no new food was coming into the hives, began to collapse at a rapid pace,
leaving nothing but a queen and a few bees in the boxes. The farmers that
I work with are sensitive to using anything that would hurt my bees because they
recognize how important good pollination is to the success of their crops.
They were told by their chemical suppliers that these ‘new’ pesticides were
‘safer’ for honeybees and they could even apply them during bloom without damage
to the bees. We did not see any dead bees in front of our hives while they
were in these pollinations. In the fall, it was clear that the bees that
had been on honey locations were OK with normal mortality of 10 to 15% loss,
while the pollination hives had 75 to 80% loss. The ‘surviving’
pollination hives were not healthy and they failed to build properly in the
spring. We saw this same problem with pollination hives in 2005 and
2006. It was in the fall of 2006 that we began to associate these losses
with summer pollination exposure. Since then we have communicated to our
growers some of our concerns and the losses have gotten better in apple
pollination where the grower had ‘options’ to use other products. In
pumpkin pollination, the growers have not had such luck since there are few
other ‘approved’ products available to them.
Gene Brandi tells his story of watermelon pollination in California . “Another route of
imidacloprid exposure to which my bees have been subjected is by chemigation
with Admire on watermelons. Growers who chemigate with pesticides highly toxic
to bees are not required to notify registered beekeepers in California , so I was not aware until
after the fact that this practice was occurring. In the summer of 2007 I
pollinated watermelons with nearly one thousand colonies of my bees. After
approximately 50% of these colonies died during the following winter (compared
to an 18% winter loss in my colonies that did not pollinate watermelons), I
contacted the grower and discovered that the watermelons had been chemigated
with Admire. My colonies that were not in watermelon pollination were exposed to
other products, and yet did not sustain the same magnitude of w inter loss.
Although I do not have conclusive proof that exposure to imidacloprid was
the cause of this bee loss, the correlation of this loss to watermelon
pollination was enough for me to stop pollinating watermelons.
Dave
Mendes tells his story of orange orchards in Florida . “I am a commercial beekeeper operating 7500
hives for honey production and crop pollination in the states of Florida , California , Maine , and Massachusetts . I participated in a research project
organized through Penn State from March 2007 until January 2008 to follow a
group of beehives through a complete season to monitor several different
conditions in these hives to determine what factors may contribute to hive
mortality. I was one of three beekeepers in this study who
each selected 18 to 24 hives that would be sampled each time they were
moved to a new location. My hives were sampled 7 times during the test
period. I started the stud y with 18 hives and ended with 4 hives total
and only one of these was in good enough shape to produce honey or pollinate an
agricultural crop. The first samples taken while the bees were in Florida
citrus showed levels of 14 to 17 ppb of imidacloprid in the pollen inside the
hives. I spoke to the grove manager and found out that Admire Pro
had been applied to the younger trees in his grove (40,000 trees in a grove of
600,000 trees) in February as a ground application as the trees began to
bloom. The research on imidacloprid that I could find showed levels
of 3 to 5 ppb as the highest recorded levels in citrus nectar or pollen. I
inquired to Bayer Crop Science and the Florida pesticide regulatory people to find out
more about what effect these levels of imidacloprid could cause in my
beehives. I found very little information that addressed my concerns.
Imidacloprid, a systemic insecticide, moves through the treated plant
to the nectar and pollen. The chemical remains persistent in soils for
several years, can be taken up by subsequent plantings and weeds, and expressed
in their pollen and nectar. No mechanism exists to protect honeybees
from this exposure. Due to the vitally important nature of pollinators
we recommend that imidacloprid be removed from use in the United
States . Simply stated there is just no way to
protect bees from this danger.
The reader may ask how did we find ourselves at the point where an
extremely dangerous chemical compound has come into such widespread use,
threatening the very existence and viability of the pollination framework of the
country. The answer is simple. Deregulation, the same concept which
precipitated our financial collapse, has precipitated an environmental collapse
no less serious. At the same time that financial institutions were being
given a free reign to regulate themselves on the naive assumption that industry
knew best, pesticide regulation was being turned over from EPA to industry on
the same assumption.
US EPA used to do pesticide screening in honeybees, do pesticide
toxicity study themselves, but today industry directs and funds the critical
toxicity studies to determine product safety themselves. The studies are
shown to EPA for registration purposes, then filed away as “proprietary
information” far from the scrutiny of the public eye. Enforcement actions
are not taken by EPA; instead these critically important functions are delegated
to individual state departments of agriculture, under an arrangement ironically
called a “primacy agreement.”
The problems faced by the beekeeping industry are not limited to one
single chemical compound. They are in fact linked to a pervasive
regulatory failure. When the EPA was first set up, it was in response to
environmental challenges of an unprecedented nature. At that time the
country was using 200,000,000 pounds of active ingredient chemical
pesticides. Today that number is over 5,000,000,000 pounds of active
ingredient. Simply put, the country is drowning in chemicals.
These very “economic poisons” are doing their job too well, and because of the
deregulation process we are faced with a perfect storm today capable of
destroying our countries pollinator base which will carry with it agricultural
and environmental catastrophe.
The fundamental change which is necessary is to return to a system at
EPA which independently tests chemical compounds before they are released for
widespread use. Precaution and prevention are words which need to return to
environmental protection. Massive field experiments, such as what has occurred
with the neonicotinoid class of systemic insecticides is just too high risk of a
behaviour. Environmental catastrophe such as global warming, and our
current pollinator crisis are big flashing warning lights. These warning
lights are there to tell us something, they are telling us to take action before
it is too late.
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