The copy of the EPA memorandum (all 101 pages) is at http://www.panna.org/sites/default/files/Memo_Nov2010_Clothianidin.pdf.  I have not read the whole document, but the following is from the executive summary.  

--------------------------------------------

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.

---------------------------------------

A previous field study (MRID 46907801/46907802) 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.

------------------------------------------------

There is also an interesting article on the leaked document at http://www.grist.org/article/food-2010-12-10-leaked-documents-show-epa-allowed-bee-toxic-pesticide-/?ref=se.  It has a number of useful links.

I am far from the expert on the subject, but the last line in the quote from EPA's own document - toxic effects therefore remain an uncertainty for pollinators - bothers me greatly.

Larry Krengel



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