Main Office: 660 Pennsylvania Ave., S.E., Suite 302, Washington, D.C. 20003  Phone: 202-547-9359  Fax: 202-547-9429

California 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.Marianne@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 Registration – Clothianidin, 3/20/12

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 arguments 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/AreNeonicotinoids-Killing-Bees_Xerces-Society1.pdf

Authors: Jennifer Hopwood, Mace Vaughan, Matthew Shepherd, David Biddinger, Eric Mader, 

Scott Hoffman Black, Celeste Mazzacano

Their key findings and recommendations bolster the Petition, in particular at p. 26:

Applications of neonicotinoids should be limited until we have data on how neonicotinoid 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

Authors: Penelope R. Whitehorn, Stephanie O’Connor, Felix L. Wackers, Dave Goulson
2

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 caused 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 Bombus 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 

production 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 Foraging 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 free-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 show field-relevant levels of EPA-approved neonicotinoid pesticides, 

(including clothianidin’s precursor and close chemical relative, thiamethoxam) are causing severe harm 

to honey bee colonies and bumble bee hives as well. They represent the type of pollinator 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 sample. (The excerpts

below in some cases leave out intervening portions of the articles; the full articles are at the links 

provided.) On the whole these excerpts underline the point that numerous experts have publicly stated 

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 any questions.

Sincerely,

/s/____________________________

Peter T. Jenkins, Attorney for Petitioners 
3

Center for Food Safety and International Center for Technology Assessment

660 Pennsylvania Ave., SE Suite 302

Washington, DC 20003

Phone: (202) 547-9359

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-navigationcolony-collapse-disorder/53868646/1

"Ironically, we have moved to neonicotinoids 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 Declining Bee Colonies

29 March 2012, by Carl Zimmer (NY Times)

http://www.nytimes.com/2012/03/30/science/neocotinoid-pesticides-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 navigating 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 doesn’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-badnews-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 colonies 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 Agricultural 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 ignore 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 carefully. "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 that 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. This 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 even 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 spokesman] 

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 public 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-beesare-dying-and-colonies-are/1222880
6

"It's still a combination 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-agentpesticides-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, told 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 bees". 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 bee 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 Research

30 March 2012, by Rudy Ruitenberg (Bloomberg)

http://www.bloomberg.com/news/2012-03-30/france-to-study-withdrawing-syngenta-pesticide-afterbee-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 Kaufman (Washington Post)

http://www.washingtonpost.com/national/health-science/new-bee-research-details-harm-frominsecticide/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 

bees,” 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 results 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 pointed 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 bumblebee 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 neonicotinoids 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/Pesticidedosed_bees_lose_future_royalty%2C_way_home

Ecotoxicologist David Fischer of Bayer CropScience, which markets imidacloprid products, notes 

that earlier research (with 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.

Honeybee research on whether pesticide exposure interferes with daily foraging could be 

relevant to other species, Goulson says. “If that is also happening in bumblebees, which is a 

reasonable guess, that could precisely explain our results.” If exposed bumblebees 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,” Goulson 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-askepa-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 between clothianidin and colony collapse has not been established, 

more studies are needed.