WikiLeaks bills itself as:
a non-profit media organization dedicated to bringing important news and information to the public. We provide an innovative, secure and anonymous way for independent sources around the world to leak information to our journalists. We publish material of ethical, political and historical significance while keeping the identity of our sources anonymous, thus providing a universal way for the revealing of suppressed and censored injustices.
National News media have focused mostly on diplomatic leaks and potential legal and criminal issues. Less attention has been given to insect issues. A big buzz surrounds an EPA memo from November 2, 2010 regarding the insecticide clothianidin. The full memo (100+ pages) courtesy of WikiLeaks can be seen here.
In a previous post, I discussed some of the issues surrounding the pesticide clothianidin and toxicity to bees. The EPA memo (available from WikiLeaks) discloses that
1. US EPA is well aware of these issues
2. US EPA is asking for more testing to be done
3. US EPA is revising its evaluation of previous submitted tests.
Quoting from Page 2 of the EPA memo:
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. Although EFED does not conduct RQ based 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. An incident in Germany already illustrated the toxicity of clothianidin to honeybees when allowed to drift off-site from treated seed during planting.
A previous field study 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.
The incident that led to suspension of clothianidin in Germany is found on Page 46:
beekeepers in Baden-Wurttemberg region of Germany had reported that two-thirds of their bees died in May 2008 following the application of a pesticide called clothianidin. Tests on dead bees showed that almost all of those examined had a build-up of clothianidin. The chemical, produced by Bayer CropScience, is sold in Europe under the trade name Poncho. The seeds were treated in advance of being planted or were sprayed while in the field. The company said an application error by the seed company, which failed to use the glue like substance (“stickers”) that sticks the pesticide to the seed, led to the chemical being dispersed into the air. Clothianidin is a systemic chemical that works its way through a plant and attacks the nervous system of any insect it comes into contact with and it is highly toxic to honeybees. The German Office for Consumer Protection and Food Safety has ordered the immediate suspension of the approval for eight seed treatment products including clothianidin as well as the related neonicotinoid ingredients imidacloprid and thiamethoxam, and the carbamate methiocarb. Germany temporarily pulled the registration for these seed treatments because of these incidents and the result of their studies. Investigations of bee kills determined that use of a particular type of pneumatic drilling equipment with treated seeds was causing a high exposure to bees. It appears that poorly applied corn seed treatments, together with physical abrasion of the treated seed by the pneumatic planters, led to dust clouds of pesticides being formed. These dust clouds drifted onto neighboring crops where bees were foraging.
The US EPA has a mandate to weigh the costs and benefits of insecticides. Part of its mandate is to protect the health and safety of the public and to protect the environment. The neonicotinoids (clothianidin is a neonicotinoid pesticide) are noted for being selectively much more toxic to insects than to humans and other mammals. Clothianidin has a much lower human toxicity and is much less of a health risk than many of the OP insecticides it replaces. From strictly a human health perspective, replacing OPs with neonicotinoids is a move in the right direction.
However, bee toxicity is an issue that must be addressed, either through use patterns or formulations. If those steps cannot protect bees, then cancellation of the offending insecticide may be the only recourse.
Pesticides are the most extensively tested class of chemicals on the planet. Pesticides receive even more testing than pharmaceuticals. Pesticides receive the same mammalian safety testing that pharmaceuticals do and also are tested for effects on the environment and non-target plants and animals. EPA may require over 140 tests to register a pesticide. The testing (which is paid by the company that produces the pesticide) provides factual information as the basis for regulation of its the pesticide use. In this case, Bayer does not help their case with the lack of attention to detail with regard to bee studies. The lack of data creates a great deal of uncertainty. When uncertainty is high, decisions must be based on estimates and the door is wide open to criticism based on speculation.
The current firestorm of criticism from beekeepers and environmentalists reinforces the importance of extensive pesticide testing and transparency of information. EPA is placed in the situation of making a decision (involving a lot of money) with many unanswered questions, a large degree of uncertainty and less than adequate information.