Main Office: 660 Pennsylvania Ave., S.E., Suite 302, Washington, D.C. 20003  Phone: 202

- 547

- 9359  Fax: 202

- 547

- 9429

Californ ia Office: 303 Sacramento Street, Second Floor, San Francisco, CA 94111  Phone: 415

- 826

- 2770  Fax: 415

- 826

- 0507

Email: info@centerforfoodsafety.org  www.centerforfoodsafety.org  www.foodsafetynow.org May 3, 2012 United States Environmental Protection Agency Office of Chemical Safety and Pollution Prevention c/o Marianne Lewis and Kimberly Nesci Sent via email to: Lewis.Maria nne@epamail.epa.gov and Nesci.Kimberly@epamail.epa.gov Attn: Docket No. EPA

- HQ

- OPP

- 2012

- 0334

Re: SUPPLEMENTAL FILING for Emergency Petition for Suspension of R egistration

– Clothianidi n , 3/20/1 2
Dear Ms. Lewis and Ms. Nesci, The following information is submitted as a supplemental filing in support of the above

- referenced Petition. This consists of information that came to light after the Petition was filed but that directly supports the argum ents in it.

- A new Xerces Society report, Are Neonicotinoids Killing Bees ? A Review of Research into the Effects of Neonicotinoid Insecticides on Bees, with Recommendations for Action issued on Mar. 26, available at this link: http://www.xerces.org/wp

- content/uploads/2012/03/Are

Neonicotinoids

- Killing

- Bees_Xerces

- Society1.pdf Authors: Jennifer Hopwood, Mace Vaughan, Matthew Shepherd, Davi d Biddinger, Eric Mader, Scott Hoffman Black, Celeste Mazzacano Their key findings and recomme n dations bolster the Petition, in particular at p. 26: Applications of neonicotinoids should be limited until we have data on how neonicoti noid use on a specific plant may be managed to provide pest protection without exposing beneficial insects to sublethal or lethal levels in nectar and pollen. Without clear evidence that they are not causing long

- term harm to non

- target species such as pollinators, the use of neonicotinoids should be restricted to applications that will not affect these vital insects.

- Two new Science articles, issued on March 29: Neonicotinoid Pesticide Reduces Bumble Bee Colony Growth and Queen Production Autho rs: Penelope R. Whitehorn , Stephanie O ’Connor , Felix L. Wackers , Dave Goulson2

http://www.sciencemag.org/content/early/2012/03/28/science.1215025.abstract Science DOI:10.1126/science.1215025

Abstract: Growing evidence for declines in bee populations has c aused great concern due to the valuable ecosystem services they provide. Neonicotinoid insecticides have been implicated in these declines as they occur at trace levels in the nectar and pollen of crop plants. We exposed colonies of the bumble bee Bombu s terrestris in the lab to field

- realistic levels of the neonicotinoid imidacloprid, then allowed them to develop naturally under field conditions. Treated colonies had a significantly reduced growth rate and suffered an 85 percent reduction in producti on of new queens compared to control colonies. Given the scale of use of neonicotinoids, we suggest that they may be having a considerable negative impact on wild bumble bee populations across the developed world.

A Common Pesticide Decreases Foragin g Success and Survival in Honey Bees Authors: Mickaël Henry

, Maxime Beguin , Fabrice Requier , Orianne Rollin , Jean

- François Odoux , Pierrick Aupinel , Jean Aptel , Sylvie Tchamitchian , Axel Decourtye http://www.sciencemag.org/content/early/2012/03/28/science.1215039 Science DOI : 10.1126/science.1215039

Abstract: Nonlethal exposure of honey bees to thiamethoxam (neonicotinoid systemic pesticide) causes high mortality due to homing failure at levels that could put a colony at risk of collapse. Simulated exposure events on fre e - ranging foragers labeled with an RFID tag suggest that homing is impaired by thiamethoxam intoxication. These experiments offer new insights into the consequences of common neonicotinoid pesticides used worldwide.

In sum, these reports and studies s how field

- relevant levels of EPA

- approved neonicotinoid pesticides, ( includ in g clothianidin ’ s precur sor and close chemical relative, thiamethoxam) are causing severe harm to honey bee colonies and bumble bee hives as well. They represent the type of p ollinator field studies that Bayer and EPA have failed to see completed for clothianidin, as the Petition documents in detail. Petitioners also bring to EPA’s attention some informative quotes from leading experts as reported in the extensive media on the two Science articles, appended below. These are not exhaustive of all of the articles or all of the experts who made statements, but they provide a good sampl e
. ( The excerpts below in some cases leave out intervening portions of the articles; the full articles are at th e links provided. ) On the whole the se excerpts underline the point that numerous experts have publicly stat ed serious concerns about the risks of these EPA

- registered insecticides. Thank you for your attention to this Supplemental Filing. Please contact me if you have an y questions. Sincerely,

/s/____________________________ Peter T. Jenkins, Attorney for Petitioners3

Center for Food Safety and International Center for Technology Assessment 660 Pennsylvania Ave., SE Suite 302 Washington, DC 20003 Phone: (202) 547

- 93 59 Email: PJenkins@icta.org

CC: all Petitioners

--------------------------------------------------
APPENDIX Study: Disorientation from pesticides a clue to bee disorder 30 March 2012, by Dan Vergano (USA Today) http://www.usatoday.com/tech/science/environment/story/2012

- 03

- 28/pesticide

- bee

- navigation

colony

- collapse

- disorder/53868646/1 "Ironically, we have moved to neonic otinoids because they are safer for people. We may be seeing unintended consequences of a solution to an earlier problem," says entomologist James Frazier of Penn State University in State College, Pa. 2 Studies Point to Common Pesticide as a Culprit in D eclining Bee Colonies 29 March 2012, by Carl Zimmer (NY Times) http://www.nytimes.com/2012/03/30/science/neocotinoid

- pestic ides

- play

- a - role

- in

- bees

- decline

- 2

- studies

- find.html?_r=2 “I personally would like to see them not being used until more research has been done,” said David Goulson , an author of the bumblebee paper who teaches at the University of Stirling, in Scotland. “If it confirms what we’ve found, then they certainly shouldn’t be used when they’re going to be fed on by bees.” “I thought it was very well designed,” said May Berenbaum , an entomologist at the University of Illinois at Urbana

- Champaign. Jeffery Pettis , a bee expert at the United States Department of Agriculture, called Dr. Goulson’s study “alarming.” He said he suspected that other types of wild bees would be shown to suffer similar effects. Dr. Pettis is also convinced that neonicotinoids in low doses make bees more vulnerable to disease. He and other researchers have recently published experiments showing that neonicotinoids make honeybees more vulnerable to infections from parasitic fungi. “Three or four years ago, I was much more cautious about how much pesticides were contributing to the problem,” Dr. Pettis said. “Now more and more evidence points to pesticides being a consistent part of the problem.” Controversial Pesticide Linked to Bee Collapse 29 March 2012, by Brandon Keim (Wired Science) http://www.wired.com/wiredscience/2012/03/neonicotinoids

- bee

- collapse/4

“It’s pretty damning,” said David Goulson , a bee biologist at Scotland’s University of Stirling. “It ’s clear evidence that they’re likely to be having an effect on both honeybees and bumblebees.” “Bees’ ability to navigate is very important. When they leave their nest, they fly miles to gather food. Anything that makes them even a little bit worse at na vigating or learning could be a disaster in those circumstances,” said Goulson. “The research suggested effects on their learning ability, but it was all done in confined situations. What we and the French group did is something more natural.”

Penn State entomologist James Frazier , who was not involved in the study, called it “the best study to date” on neonicotinoids’ real

- world effects on foraging. “Nests have annual cycles. They start with a single queen, and the nest grows through the season. If it do esn’t get big enough, it doesn’t have the resources to pour into rearing queens,” Goulson said. “The French study shows that exposure to neonicotinoids make honeybees less likely to find their nest. That’s likely the mechanism that led to our nests growing more slowly.” Vaughn [ Mace Vaughn , pollinator program director at the Xerces society] said they could be used differently. “I would call for a ban on their use without a demonstrated pest threat. If you have corn rootworm, and need to address that, then use neonicotinoid

- coated seeds,” he said. “But if it’s a vague threat that you haven’t identified, you shouldn’t be using them. Maybe it makes you a few bucks, and certainly makes the seed companies a lot of money, but it’s potentially killing bees across the country.” Studies Show Why Insecticides Are Bad News for Bees 29 March 2012, by Dan Charles (NPR) http://www.npr.org/blogs/thesalt /2012/03/29/149614689/studies

- show

- why

- insecticides

- are - bad

news - for

- bees The neonicotinoids appear to be "so toxic to bees, really the only safe number is zero," says Christian Krupke , one of the authors of the Purdue study. Pesticides suspected in mass die

- off of bees 29 March 2012, by Eryn Brown (LA Times) http://www. latimes.com/news/science/la

- sci

- bees

- pesticides

- 20120330,0,4969345.story "If it's blundering around and can't return to the hive ... the bee might as well be dead," said Christian Krupke , an entomologist at Purdue University in West Lafayette, Ind., who was not involved in either study. By the end of the study period, the bees that ate the insecticide produced 85% fewer queens per colony, on average. The queens lay the eggs that produce the members of the colony for the next year. "If that went on for years, the consequences could be pretty dramatic," Goulson [ David Goulson , biologist at the Univ. of Stirling in Scotland] said. Pesticides hit queen bee numbers 29 March 2012, by Richard Black (BBC News)5

http://www.bbc.co.uk/news/science

- environment

- 17535769 "I wouldn't say this proves neonicotinoids are the sole cause of the problems bees face," said Dr Goulson [David Goulson , Univ. of Stirling], "but it does suggest they're likely to be one of the causes, and possibly a significant one. "The use of these pesticides is so widespread that most bee colonie s in areas of arable farming are likely to be exposed to them, so there is potential for them to be playing a significant role in suppression of bee populations on a pretty staggering scale."

Dr Henry [Mickael Henry , French National Institute for Agricult ural Research] told BBC News that it was time for authorities to re

- design the safety tests that pesticides have to pass. "To date, the tests mostly require that the doses found in nature do not kill bees," he said. "But those authorisation processes ignor e possible consequences for the behaviour of bees, and we hope the people in charge will be more careful." May Berenbaum , head of entomology at the University of Illinois and one of the leading US experts on CCD, said the chemicals should be used more car efully. "There is no question that neonicotinoids are being used recklessly, for want of a better word," she said. "Fifty years of experience should have taught us that overuse of a single class of compounds is an inherently unsustainable practice, and tha t pre

- treating seeds when pest problems might not even be present is colossally unwise. Pesticides linked to honeybee decline 29 March 2012, by Damian Carrington (The Guardian) http://www.guardian.co.uk/environment/2012/mar/29/crop

- pesticides

- honeybee

- decline "People had found pretty trivial effects in lab and greenhouse experiments, but we have shown they can translate into really big effects in the field. T his has transformed our understanding," said Prof David Goulson , at the University of Stirling and leader of one of the research teams.
Prof Mickaël Henry , at INRA in Avignon , France, who led a separate research team, said: "Under the effects we saw from the pesticides, the population size would decline disastrously, and make them eve n more sensitive to parasites or a lack of food." "There was a staggering magnitude of effect," said Goulson . "This is likely to have a substantial population

- level impact."
Goulson dismissed as "nonsense" Little's [Julian Little, Bayer CropScience spok esman] suggestion that the doses given to the bees were higher than in reality. Both Bayer and Defra suggested other field studies had shown no harmful effects to bees. Goulson said: "If they have done these studies, where are they? They are not in the pub lic domain and therefore cannot be scrutinised. That raises the question of just how good they are." A Pasco County beekeeper knows why bees are dying and colonies are collapsing 31 March 2012, by Dan DeWitt (Tampa Bay Times) http://www.tampabay.com/news/environment/wildlife/a

- pasco - county

- beekeeper

- knows

- why

- bees

are - dying

- and

- colonies

- are/12228806

"It's still a comb ination of factors," said James Frazier , an entomology professor at Penn State University. "But the position of pesticides on the list of those factors has gone from last to first or maybe second." Government to reconsider nerve agent pesticides 31 March 2012, by Michael McCarthy (The Independent) http://www.independent.co.uk/environment/nature/government

- to

- reconsider

- nerve - agent

pe sticides

- 7604121.html The Government is to reconsider its refusal to ban neonicotinoid pesticides, the nerve

- agent chemicals blamed for the collapse of bee colonies worldwide, the chief scientist at the Department of the Environment, Sir Robert Watson , to ld The Independent

. Even on Thursday, after the new studies were published, a spokesman for Defra said the new research did not change the Government's position, and that "the evidence shows that neonicotinoids do not pose an unacceptable risk to honey be es". But yesterday Sir Robert said: "The real Defra position is the following: we will absolutely look at the University of Stirling work, the French work, and the American work that came out a couple of months ago [a study by the US government's leading b ee researcher, Dr Jeffrey Pettis, which showed that exposure to microscopic doses of neonicotinoids weakened bees' resistance to disease]. We must look at this in real detail to see whether or not the current British position is correct or is incorrect. He added: "I want to get a really careful analysis of all three papers, and I've asked for a briefing on some ongoing work that we've been doing ourselves. I want this all reassessed, very, very carefully." France to Study Ban on Syngenta Pesticide on Bee R esearch 30 March 2012, by Rudy Ruitenberg (Bloomberg) http://www.bloomberg.com/news/2012

- 03

- 30/france

- to

- study

- withdrawing

- syngenta

- pesticide

- after

bee

- study.html “If the new scientific data are confirmed, the authorization to market Cruiser would be withdrawn,” the ministry [France’s Agriculture Ministry] wrote.
Bee research details harm from insecticides 29 March 2012, by Marc Kauf man (Washington Post) http://www.washingtonpost.com/national/health

- science/new

- bee

- research

- detail s - harm

- from

insecticide/2012/03/29/gIQAZrnGjS_story.html?hpid=z2 “People have asked me to sign petitions to ban or limit the use of the neonicotinoids for some time, but I never did because I really didn’t know if they were having a major impact on the be es,” said David Goulson of the University of Stirling in Britain, co

- author of one of the studies. “After seeing what we and the others found, I’m much more inclined to sign.” “So far, they mostly require manufacturers to ensure that doses encountered on the field do not kill bees, but they basically ignore the consequences of doses that do not kill them but may cause behavioral difficulties,” said Mickael Henry of the French National Institute for Agricultural Research (INRA) in Avignon, France.7

“The res ults were so dramatic that you just had to take notice,” Pettis [Jeffrey Pettis , USDA ARS lead researcher for bees] said. “I think that line of research will now drive a lot more of the discussion.” Bumblebee study co

- author Goulson also said the result p ointed to the need for action. “Bumblebees in the wild pollinate crops such as tomatoes, beans and cucumbers, as well as wildflowers,” he said. “This study shows that the use of neonicotinoid pesticides on flowering crops clearly poses a threat to their bu mblebee health, and urgently needs to be reevaluated.” Bee toxicity specialist May Berenbaum of the University of Illinois, who chaired a National Academy of Sciences study group on bee declines, said the studies were important in establishing that the ne onicotinoids are affecting wild bees as well as those used in controlled pollinations. “It’s easy to see the decline in honeybees kept for pollination, but much harder to see it in the wild bees with their nests underground and in trees,” she said. “Now we can say with more confidence that they are at risk as well.”

Pesticide

- dosed bees lose future royalty, way home 29 March 2012, by Susan Milius (ScienceNews) http://www.sciencenews.org/view/generic/id/339548/title/Pesticide

dosed_bees_lose_future_royalty%2C_way_home Ecotoxicologist David Fischer of Bayer CropScience, which markets imidacloprid products, notes that earlier research (w ith constrained rather than free

- flying bees) did not find a drop in young queens. Goulson [David Goulson , Univ. of Stirling] isn’t surprised that his bumblebees showed more of an impact. “Navigation isn’t important when you live in a box,” he says.
Honey bee research on whether pesticide exposure interferes with daily foraging could be relevant to other species, Goulso n says. “If that is also happening in bumblebees, which is a reasonable guess, that could precisely explain our results.” If exposed bumbleb ees aren’t as good at bringing home food, then colonies might not grow or reproduce as well. For common pesticides now on the market, “there are obviously big question marks as to whether the safety testing that was done on these was really adequate,” Gou lson says. Chronic effects may not show up without tests of free

- ranging bees confronting real

- world problems. Beekeepers ask EPA to ban pesticide, protect bees 21 March 2012, by Gosia Wozniacka (Associated Press) http://www.ksagland.com/index.php?option=com_content&view=article&id=6654:beekeepers

- ask

epa - to

- ban

- pesticide

- protect

- bees

- &catid=36:national

- ag - news&Itemid=84 "The EPA admits that their testing has not been adequate to determine the impact of this chemical on bees and pollinators," Frazier [Jim Frazier , entomologist at Penn State] said, adding that while a direct link betwe en clothianidin and colony collapse has not been established, more studies are needed.