BEE HEALTH

USDA and EPA 

Should Take 

Additional Actions to 

Address Threats to 

Bee Populations

Report to Congressional Requesters

February 2016

GAO-16-220

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-16-220, a report to 

congressional requesters

February 2016

BEE HEALTH

USDA and EPA Should Take Additional Actions to 

Address Threats to Bee Populations

Why GAO Did This Study

Honey bees and other managed and 

wild, native bees provide valuable 

pollination services to agriculture worth 

billions of dollars to farmers. 

Government and university

researchers have documented 

declines in some populations of bee 

species, with an average of about 29 

percent of honey bee colonies dying 

each winter since 2006. A June 2014 

presidential memorandum on 

pollinators established the White 

House Pollinator Health Task Force, 

comprising more than a dozen federal 

agencies, including USDA and EPA.

GAO was asked to review efforts to 

protect bee health. This report 

examines (1) selected USDA agencies’ 

bee-related monitoring, research and 

outreach, as well as conservation 

efforts, and (2) EPA’s efforts to protect 

bees through its regulation of 

pesticides. GAO reviewed the White 

House Task Force’s national strategy 

and research action plan, analyzed 

data on USDA research funding for 

fiscal years 2008 through 2015, 

reviewed EPA’s guidance for 

assessing pesticides’ risks to bees, 

and interviewed agency officials and 

stakeholders from various groups 

including beekeepers and pesticide 

manufacturing companies. 

What GAO Recommends

GAO recommends, among other 

things, that USDA coordinate with 

other agencies to develop a plan to

monitor wild, native bees, and evaluate 

gaps in staff expertise in conservation 

practices, and that EPA identify the 

most common mixtures of pesticides 

used on crops. USDA and EPA 

generally agreed with the 

recommendations.

What GAO Found

The U.S. Department of Agriculture (USDA) conducts monitoring, research and 

outreach, and conservation that help protect bees, but limitations in those efforts 

hamper the department’s ability to protect bee health. For example, USDA has

increased monitoring of honey bee colonies managed by beekeepers to better 

estimate losses nationwide but does not have a mechanism in place to 

coordinate the monitoring of wild, native bees that the White House Pollinator 

Health Task Force’s May 2015 strategy directs USDA and other federal agencies 

to conduct. Wild, native bees, which also pollinate crops, are not managed by 

beekeepers and are not as well studied. USDA officials said they had not 

coordinated with other agencies to develop a plan for monitoring wild, native 

bees because they were focused on other priorities. Previous GAO work has

identified key practices that can enhance collaboration among agencies, such as 

clearly defining roles and responsibilities. By developing a mechanism, such as a 

monitoring plan for wild, native bees that establishes agencies’ roles and 

responsibilities, there is better assurance that federal efforts to monitor bee 

populations will be coordinated and effective. Senior USDA officials agreed that 

increased collaboration would improve federal monitoring efforts.

USDA also conducts and funds research and outreach on the health of different 

categories of bee species, including honey bees and, to a lesser extent, other 

managed bees and wild, native bees. Consistent with the task force strategy and 

the 2008 Farm Bill, USDA has increased its conservation efforts on private lands

to restore and enhance habitat for bees but has conducted limited evaluations of 

the effectiveness of those efforts. For example, a USDA-contracted 2014 

evaluation found that agency staff needed additional expertise on how to 

implement effective habitat conservation practices, but USDA has not defined 

those needs through additional evaluation. By evaluating gaps in expertise, 

USDA could better ensure the effectiveness of its efforts to restore and enhance 

bee habitat plantings across the nation. USDA officials said that increased 

evaluation would be helpful in identifying where gaps in expertise occur.

The Environmental Protection Agency (EPA) has taken steps to protect honey 

bees and other bees from risks posed by pesticides, including revising the label 

requirements for certain pesticides, encouraging beekeepers and others to report 

bee deaths potentially associated with pesticides, and urging state and tribal 

governments to voluntarily develop plans to work with farmers and beekeepers to 

protect bees. EPA also issued guidance in 2014 that expanded the agency’s 

approach to assessing the risk that new and existing pesticides pose to bees. 

The task force strategy also calls for EPA to develop tools to assess the risks

posed by mixtures of pesticide products. EPA officials agreed that such mixtures 

may pose risks to bees but said that EPA does not have data on commonly used 

mixtures and does not know how it would identify them. According to 

stakeholders GAO interviewed, sources for data on commonly used or 

recommended mixtures are available and could be collected from farmers, 

pesticide manufacturers, and others. By identifying the pesticide mixtures that 

farmers most commonly use on crops, EPA would have greater assurance that it 

could assess those mixtures to determine whether they pose greater risks than

the sum of the risks posed by individual pesticides.

View GAO-16-220. For more information, 

contact Steve D. Morris at (202) 512-3841 or 

morriss@gao.gov. 
Page i GAO-16-220 Protecting Bee Health

Letter 1

Background 7

Selected USDA Agencies Conduct Monitoring, Research and 

Outreach, and Conservation to Protect Bees, but Limitations 

Exist within Those Efforts 15

EPA Has Taken Some Steps to Address Pesticide Threats to 

Bees, but Potential Threats Remain 32

Conclusions 51

Recommendations for Executive Action 54

Agency Comments and Our Evaluation 55

Appendix I Objectives, Scope, and Methodology 59

Appendix II Stakeholders’ Views on Efforts USDA and EPA Should Make to 

Further Protect Bees 64

Appendix III Bee Health Stakeholders We Interviewed 71

Appendix IV Comments from the Department of Agriculture 74

Appendix V Comments from the Environmental Protection Agency 78

Appendix VI GAO Contact and Staff Acknowledgments 83

Table

Table 1: Stakeholders’ Views on Efforts U.S. Department of 

Agriculture (USDA) and Environmental Protection Agency 

(EPA) Should Make to Further Protect Bees 64

Contents
Page ii GAO-16-220 Protecting Bee Health

Figure

Figure 1: Estimated Acreage of Crops Pollinated by Managed 

Bees in the United States 9

Abbreviations

APHIS Animal and Plant Health Inspection Service

ARS Agricultural Research Service

CRIS Current Research Information System

CRP Conservation Reserve Program

CSP Conservation Stewardship Program

EIIS Ecological Incident Information System

EQIP Environmental Quality Improvement Program

EPA Environmental Protection Agency

FIFRA Federal Insecticide, Fungicide, and Rodenticide Act

FSA Farm Service Agency

Interior Department of the Interior

IPM Integrated Pest Management

NASS National Agricultural Statistics Service

NIFA National Institute of Food and Agriculture

NRCS Natural Resources Conservation Service

OECD Organization for Economic Cooperation and Development

OMB Office of Management and Budget

OPP Office of Pesticide Programs

PCA Plant Conservation Alliance

PRIA Pesticide Registration Improvement Act

SAFE State Acres for Wildlife

SFIREG State-FIFRA Issues, Research, and Evaluation Group

USDA U.S. Department of Agriculture

USGS U.S. Geological Survey

This is a work of the U.S. government and is not subject to copyright protection in the 

United States. The published product may be reproduced and distributed in its entirety 

without further permission from GAO. However, because this work may contain 

copyrighted images or other material, permission from the copyright holder may be 

necessary if you wish to reproduce this material separately.
Page 1 GAO-16-220 Protecting Bee Health

441 G St. N.W.

Washington, DC 20548

February 10, 2016

The Honorable Barbara Boxer

Ranking Member

Committee on Environment and Public Works

United States Senate

The Honorable Kirsten Gillibrand

Ranking Member

Subcommittee on Livestock, Marketing, and Agriculture Security

Committee on Agriculture, Nutrition, and Forestry

United States Senate

The Honorable Dianne Feinstein

United States Senate

Bees play a vital role in agriculture by pollinating crops that are worth 

billions of dollars to farmers, while also providing environmental value to 

other landowners and natural ecosystems by pollinating flowering plants. 

The health of bee populations, therefore, is important to the nation’s wellbeing. In recent years, beekeepers, farmers, scientists, and others have 

been increasingly concerned about the health of European honey bees 

that are commercially managed for honey production and pollination 

services; other managed bees; and wild, native bees.1 Annual surveys of 

U.S. beekeepers since 2006 indicate that, on average, about 29 percent 

 

1

The scientific name of the European honey bee is Apis mellifera. Hereafter, in this report, 

we refer to them as honey bees. Other managed bees include orchard mason bees 

(Osmia lignaria), alfalfa leafcutting bees (Megachile rotundata), and bumble bees 

(Bombus spp.). Orchard mason bees and some bumble bees are native to the United 

States, while alfalfa leafcutting bees are not. In this report, wild, native bees refer to 

unmanaged bees that are native to the United States. There are an estimated 4,000 or 

more species of wild, native bees in the United States. We acknowledge that nonnative 

bees, including honey bees, may also be unmanaged, i.e., wild.

Letter
Page 2 GAO-16-220 Protecting Bee Health

of honey bee colonies have been dying over the winter.2 Government and 

academic researchers have documented long-term declines for some 

populations of other bee species, including bumble bees, but little is 

known about trends for populations of the estimated 4,000 or more 

species of wild, native bees in the United States.

A June 2014 presidential memorandum on pollinators established the 

White House Pollinator Health Task Force, comprised of more than a 

dozen federal agencies and co-chaired by the Secretary of Agriculture 

and the Administrator of the Environmental Protection Agency (EPA).3 In 

response to direction in the memorandum, the task force issued a May 

2015 national strategy for protecting bees and other pollinators from a 

range of possible threats, including pests and pathogens, reduced 

habitat, lack of nutritional resources, and exposure to pesticides.4 The 

task force’s strategy contains three overarching goals, two of which relate 

to bees: (1) reducing honey bee colony losses during winter to no more 

than 15 percent within 10 years; (2) increasing the Eastern population of 

the monarch butterfly to 225 million butterflies occupying an area of 

approximately 15 acres in the overwintering grounds in Mexico, through 

domestic and international actions and public-private partnerships, by 

2020; and (3) restoring or enhancing 7 million acres of land for pollinators 

over the next 5 years through federal actions and public-private 

partnerships.5 The White House Task Force also issued the Pollinator 

Research Action Plan in May 2015, which it described as a road map for 

 

2

The Bee Informed Partnership’s national survey of managed honey bee annual colony 

losses, carried out in cooperation with the U. S. Department of Agriculture (USDA) and the 

Apiary Inspectors of America, is a survey of beekeepers. Despite efforts to reach out to 

beekeepers nationwide, the partnership’s colony loss data cannot be generalized to 

beekeepers who did not participate in the survey. The partnership is a collaboration of 

efforts across the country from research laboratories and universities in agriculture and 

science. It is supported by USDA’s National Institute of Food and Agriculture.

3

The White House, Presidential Memorandum – Creating a Federal Strategy to Promote 

the Health of Honey Bees and Other Pollinators, Office of the Press Secretary (2014). 

4

White House Pollinator Health Task Force, National Strategy to Promote the Health of 

Honey Bees and Other Pollinators, May 19, 2015. 

5

We do not discuss the second goal in this report. 
Page 3 GAO-16-220 Protecting Bee Health

federally-supported pollinator health research, contingent upon available 

funding.6

The U.S. Department of Agriculture (USDA) and EPA have several 

programs that contribute to protecting bee health. USDA’s National 

Agricultural Statistics Service (NASS) surveys beekeepers to document 

the number of active managed colonies of honey bees and honey 

production levels. USDA’s programs for research and outreach are 

primarily conducted or funded by its two largest research agencies, the 

Agricultural Research Service (ARS) and the National Institute of Food 

and Agriculture (NIFA).7 USDA’s Farm Service Agency (FSA) and Natural 

Resources Conservation Service (NRCS), which oversee conservation 

programs for private lands, provide financial and technical support to 

landowners to encourage habitat conservation, including conservation 

intended to provide bees and other pollinators with forage8 and nesting 

areas.9 EPA plays a role in protecting bees as part of its regulation of 

pesticides under the Federal Insecticide, Fungicide, and Rodenticide Act 

(FIFRA).10 EPA makes regulatory decisions that affect pesticides used by 

farmers and other landowners, as well as pesticides used by beekeepers 

 

6

White House Pollinator Health Task Force, Pollinator Research Action Plan, May 19, 

2015. 

7

We use the term outreach in this report to mean efforts to communicate with and educate 

stakeholders about bees. This includes communication and education performed by 

USDA’s Cooperative Extension System. The Cooperative Extension System is a 

partnership between land-grant universities and USDA. Established by the Morrill Act of 

1862, the Land-Grant University System is composed of more than 100 colleges and 

universities around the country. These institutions receive federal support and are 

required to provide relevant information to the public through the extension system.

8

Forage refers to the food or nesting materials gathered by bees for themselves or their 

offspring.

9

Other USDA agencies and programs may also affect bee health but are not primarily 

responsible for addressing it and, therefore, are not covered by the scope of this report. 

For example, this report does not address research by USDA’s Economic Research 

Service or Forest Service; efforts by the Forest Service to provide bee habitat; or 

monitoring of bee pests and diseases by the Animal and Plant Health Inspection Service

(APHIS). 

10Under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), EPA registers 

pesticides for distribution, sale, and use in the United States and prescribes labeling and 

other regulatory requirements to prevent unreasonable adverse effects on the 

environment. To obtain a registration, a company or person (registrant) must provide data 

in support of registration, including tests and results, flagging any potential adverse effects 

to human health or the environment. 
Page 4 GAO-16-220 Protecting Bee Health

to combat pests that infest bee hives.11 In particular, EPA determines 

whether pesticides may cause unreasonable adverse effects to the 

environment, including bees and other organisms, when used in 

accordance with widespread and commonly recognized practice.12

In this context, you asked us to review specific USDA and EPA efforts to 

protect bee health. Our objectives were to evaluate (1) the bee-related 

monitoring, research and outreach, and conservation efforts of selected 

USDA agencies; and (2) EPA’s efforts to protect bees through its 

regulation of pesticides.

To examine USDA’s monitoring, research and outreach, and conservation 

efforts with respect to bees, we selected five USDA agencies: NASS, 

ARS, NIFA, NRCS, and FSA, because they have been most involved in 

addressing bee health issues. We reviewed the methodology of the NIFAfunded Bee Informed Partnership’s national survey of commercial 

beekeepers on their honey bee colony losses, to assess the reliability of 

the survey and determined that, while the data are not generalizable to 

the nation, they illustrate the experiences of the respondents with respect 

to colony losses. We analyzed the methodology that NASS used in a 

2015 survey of beekeepers about honey bee colony losses and the 

efforts within USDA to monitor wild, native bees. We also reviewed our 

prior body of work on interagency collaboration, as agencies within USDA 

carry out work related to bee monitoring in conjunction with other 

agencies; from that work, we selected practices that were related to 

 

11Pesticides include, among other substances, herbicides (i.e., weed killers), plant growth 

regulators (i.e., chemicals used to alter the expected growth, flowering, or reproduction 

rate of plants), insecticides (i.e., chemicals used to kill insects and other arthropods), 

insect growth regulators (i.e., chemicals used to disrupt the molting, maturity from pupal 

stage to adult, or other life processes of insects), miticides (i.e., chemicals used to kill 

mites that feed on plants and animals), fungicides (i.e., chemicals used to kill fungi, 

including blights, mildews, molds, and rusts), and nematicides (i.e., chemicals used to kill 

nematodes—microscopic, worm-like organisms that feed on plant roots). 

12Under FIFRA, EPA must take into account both the costs and benefits of the use of any 

pesticide. 
Page 5 GAO-16-220 Protecting Bee Health

challenges that we or agency officials identified and used the practices to 

assess interagency collaboration at USDA concerning bee monitoring.13

We analyzed funding data for ARS and NIFA from fiscal year 2008 

through fiscal year 2015 and fiscal year 2008 through fiscal year 2014, 

respectively, to document the agencies’ support for bee-related research 

and outreach. We selected fiscal year 2008 as the starting point to reflect 

2008 Farm Bill initiatives;14 data from fiscal years 2015 and 2014 were the 

most recent data available for ARS and NIFA, respectively. We assessed 

the reliability of ARS and NIFA funding data by comparing agencyprovided data with data found in USDA’s Current Research Information 

System (CRIS) and reviewing the agencies’ management controls and 

determined that these data were sufficiently reliable for the purpose of 

reporting on bee-related research projects. We reviewed how ARS and 

NIFA categorize research data in USDA’s CRIS database and compared 

the CRIS categories to those used in the task force strategy and research 

action plan. We also reviewed an evaluation of NRCS’s technical 

assistance efforts and examined the agency’s response to conclusions 

about the level of bee habitat conservation expertise within the agency. 

Further, we examined the data FSA and NRCS collect from their bee 

habitat conservation efforts to determine the extent to which the data 

could be used to evaluate the agencies’ progress in meeting the task 

force strategy’s goal to restore and enhance pollinator habitat. To assess 

the reliability of these data, we reviewed management controls over the 

information systems that maintain the data and found them sufficiently 

reliable for our reporting purposes. We interviewed USDA officials 

regarding all of these activities.

To examine EPA’s efforts to protect bees, we gathered information on its 

regulation of pesticides under FIFRA. Specifically, we reviewed the 

agency’s 2011 interim and 2014 final guidance for assessing the risk that 

 

13GAO, Results-Oriented Government: Practices That Can Help Enhance and Sustain 

Collaboration among Federal Agencies, GAO-06-15 (Washington, D.C.: Oct. 21, 2005); 

Managing for Results: Key Considerations for Implementing Interagency Collaborative 

Mechanisms, GAO-12-1022 (Washington, D.C.: Sept. 27, 2012); Managing for Results: 

Implementation Approaches Used to Enhance Collaboration in Interagency Groups, 

GAO-14-220 (Washington, D.C.: Feb. 14, 2014).

14The Food, Conservation, and Energy Act of 2008, Pub. L. No. 110-246, 122 Stat.1651. 
Page 6 GAO-16-220 Protecting Bee Health

pesticides posed to bees.15 We also reviewed a 2012 document 

containing comments from EPA’s FIFRA Scientific Advisory Panel 

regarding the agency’s risk assessment framework. We examined how 

EPA has applied the new guidance to particular pesticides. We reviewed 

data and interviewed agency officials about the status of EPA’s pesticide 

registration and registration review programs. In particular, we gathered 

information about pesticides that have been associated with bee kill 

incidents, as indicated by EPA’s Ecological Incident Information System 

(EIIS). To assess the reliability of the EIIS data, we discussed with EPA 

officials the methods by which the agency collects and assesses the EIIS 

data and determined that, while the data had limitations that are 

discussed in the report, they were sufficiently reliable for the purpose of 

identifying pesticides potentially associated with bee kills. We also 

reviewed documents and interviewed agency officials regarding EPA’s 

efforts to encourage states to develop voluntary managed pollinator 

protection plans.

In addition, to address both objectives, we gathered stakeholders’ views 

on what efforts, if any, USDA and EPA could make to protect bee 

health. Specifically, we interviewed a nonprobability sample of 

stakeholders from 35 of the following types of organizations, identified 

through interviews with agency officials and other interested parties: farm 

groups, including those generally representing conventional or organic 

farming and commodity groups whose crops are largely pollinated by 

managed bees, e.g., apple and almond growers; groups representing 

commercial beekeepers; pesticide manufacturing companies; state 

government; universities; and conservation and environmental 

groups.16 USDA and EPA reviewed the stakeholder list and made 

suggestions. We also obtained advice from a member of the National 

Academy of Sciences with extensive experience on bee and pollinator 

 

15Interim Guidance on Honey Bee Data Requirements, EPA Office of Pesticide Programs, 

Environmental Fate and Effects Division, October 2011. Guidance for Assessing Pesticide 

Risks to Bees, co-authored by the Office of Pesticide Programs, United States 

Environmental Protection Agency, Washington, D.C.; the Health Canada Pest 

Management Regulatory Agency, Ottawa, ON, Canada; and the California Department of 

Pesticide Regulation, Sacramento, CA, June 19, 2014. 

16In a nonprobability sample, some units in the population have no chance, or an

unknown chance, of being selected. In nonprobability sampling, a sample is selected 

based on knowledge of the population’s characteristics or from a subset of a population. 

This kind of sample is not designed to produce estimates of the entire population; that is, it 

is not generalizable. 
Page 7 GAO-16-220 Protecting Bee Health

research about how to achieve a balanced list of stakeholders with varied 

expertise and knowledge. We interviewed the stakeholders using a data 

collection instrument and conducted a content analysis of the 

stakeholders’ responses, whereby we organized their comments into 

relevant categories. In particular, we asked stakeholders about their 

familiarity with agency efforts to protect bee health, as well as their views 

on any suggestions for efforts the agencies should make to further protect 

bee health. Because we used a nonprobability sample of stakeholders, 

their views cannot be generalized to all such stakeholder organizations 

but can be illustrative. In addition, the views expressed by the 

stakeholders do not represent the views of GAO. Further, we did not 

assess the validity of the stakeholders’ views on what efforts USDA and 

EPA should make to protect bee health. For more detail on our 

objectives, scope, and methodology, see appendix I. We incorporated 

relevant stakeholders’ views into our discussion of USDA and EPA efforts 

to protect bees and present a more comprehensive summary of their 

views in appendix II.

We conducted this performance audit from October 2014 to February

2016 in accordance with generally accepted government auditing 

standards. Those standards require that we plan and perform the audit to 

obtain sufficient, appropriate evidence to provide a reasonable basis for 

our findings and conclusions based on our audit objectives. We believe 

that the evidence obtained provides a reasonable basis for our findings 

and conclusions based on our audit objectives.

This section provides information on the role and economic value of bees, 

bee population trends, factors affecting bee health, effects of bee losses 

on agriculture and ecosystems, and the roles and responsibilities that 

USDA’s ARS, FSA, NASS, NIFA, and NRCS, and EPA have played with 

respect to addressing bee health issues.

Pollinators—including honey bees, other managed bees, and wild, native 

bees—are critical to our nation’s economy, food security, and 

environmental health.17 Honey bees—nonnative insects introduced to the 

United States in the 1620s by early settlers—are the most recognizable 

 

17A variety of animals, such as bees, wasps, flies, butterflies, moths, bats, beetles, and 

birds, serve as pollinators. This report focuses on bees only.

Background

The Role and Economic 

Value of Bees
Page 8 GAO-16-220 Protecting Bee Health

pollinators of hundreds of ecologically and economically important crops 

and plants in North America. In 2014, USDA reported that crops 

pollinated by honey bees directly or indirectly account for up to one-third 

of the U.S. diet.18 The most recent study on the value of pollinators to

U.S. food and agriculture was published in 2012 and estimated that, as of 

2009, the total value of crops that were directly dependent on honey bee 

pollination, including almonds, apples, and cherries, was almost $12 

billion.19 The study estimated that, also as of 2009, the total value of 

crops that were indirectly dependent20 on bees, such as hay, sugar beets, 

asparagus, and broccoli, was more than $5 billion.21 In addition, 

according to a 2015 USDA-NASS report, honey bees produced more 

than $385 million worth of honey in 2014.22

Approximately 1,500 to 2,500 commercial U.S. beekeepers manage 

honey bee colonies, according to an estimate by the American 

Beekeeping Federation.23 Many commercial beekeepers travel across the 

country to provide pollination services for farmers’ crops and to support 

honey production. According to the 2014 USDA report, in 2012, almonds, 

sunflowers, canola seed, apples, cherries, and watermelons were among 

the top crops that were sources of pollination service fee revenue for 

beekeepers.24 About 1.6 million honey bee colonies—approximately 60 to 

 

18USDA Economic Research Service, Fruit and Tree Nuts Outlook: Economic Insight – 

U.S. Pollination-Services Market, FTS-357SA (Washington, D.C.: Sept. 26, 2014).

19N.W. Calderone, “Insect Pollinated Crops, Insect Pollinators, and U.S. Agriculture: Trend 

Analysis of Aggregate Data for the Period 1992–2009.” PLoS ONE 7(5) (2012): e37235. 

Adjusting only for inflation between 2009 and 2015, we estimate the value of the crops 

that were directly dependent on honey bee pollination in 2009 to be about $13.03 billion in 

constant 2015 dollars (adjusted by the Consumer Price Index). 

20Crops that indirectly depend on pollination do not require pollination but are grown from 

seeds that result from pollination.

21Calderone (2012). The estimated value of crops indirectly dependent on honey bee 

pollination in 2009 is about $6.01 billion in constant 2015 dollars (adjusted by the 

Consumer Price Index).

22NASS, Honey Report, March 2015. 

23The American Beekeeping Federation classifies beekeepers based on the number of 

honey bee colonies they maintain: small-scale (less than 25 colonies), sideliner (25 to 300 

colonies), and commercial (more than 300 colonies and deriving most or all of their 

income from beekeeping).

24USDA Economic Research Service (2014). 
Page 9 GAO-16-220 Protecting Bee Health

75 percent of all U.S. commercial honey bee colonies—provide pollination 

services to California’s almond orchards early each spring.25 Figure 1 

shows the estimated acreage of crops for which beekeepers provide 

pollination services and the location of summer feeding grounds for 

commercially managed bees. 

Figure 1: Estimated Acreage of Crops Pollinated by Managed Bees in the United States

 

25The Almond Board of California and USDA Economic Research Service (2014). 
Page 10 GAO-16-220 Protecting Bee Health

In addition to honey bees, certain managed bees and wild, native bees 

also provide valuable pollination services. Whereas honey bees comprise 

an estimated 98 percent of managed bees in the United States, other 

managed bee species—including bumble bees, alfalfa leafcutting bees, 

and orchard mason bees—comprise the remaining 2 percent, according 

to a representative of the Pollinator Stewardship Council.26 These other 

managed bees pollinate alfalfa, almonds, apples, cherries, and tomatoes. 

Wild, native bee species may also pollinate agricultural crops. In 2009, 

crops directly and indirectly dependent on pollination by other managed 

bees; wild, native bees; and other insects were valued at almost $10 

billion according to the 2012 study of the value of pollinators to U.S. food 

and agriculture.27 In addition, a 2007 National Research Council study 

found that wild, native bees provide most of the pollination in natural plant 

communities, which contributes to valuable ecosystem services, including 

water filtration and erosion control.28

According to the White House Task Force’s 2015 Pollinator Research 

Action Plan, in 2006, some beekeepers in the United States began to 

notice unusually high mortality among their honey bee colonies over the 

winter months. From 2006 to 2014, beekeepers who responded to the 

Bee Informed Partnership’s nongeneralizable national survey of managed 

honey bee colony losses reported that an average of about 29 percent of 

their bee colonies died each winter. Those losses exceeded the 

approximately 13 to 19 percent winter loss rate that beekeepers indicated 

in the surveys were acceptable. Furthermore, when winter losses are 

combined with losses at other times of the year, total annual losses can 

be higher. For example, a preliminary report from the Bee Informed 

Partnership indicated that beekeepers who responded reported total 

 

26The mission of the Pollinator Stewardship Council is to defend managed and native 

pollinators vital to a sustainable and affordable food supply from the adverse impact of 

pesticides.

27Calderone 2012. Adjusting only for inflation from 2009 to 2015, we estimate that the 

value of crops directly dependent on bees and insects other than honey bees in 2009 to 

be about $3.84 billion in constant 2015 dollars (adjusted by the Consumer Price Index). In 

addition, we estimate the value of crops indirectly dependent on bees and insects other 

than honey bees in 2009 to be about $7.15 billion in constant 2015 dollars (adjusted by 

the Consumer Price Index). 

28National Research Council, Status of Pollinators in North America, National Academies 

Press (Washington, D.C., 2007).

Bee Population Trends
Page 11 GAO-16-220 Protecting Bee Health

annual losses of more than 40 percent of colonies from April 2014 

through March 2015. Whereas nongeneralizable data on short-term 

losses in honey bee colonies are available, the status of other managed 

bees and most of the wild, native bee species in the United States is less 

well-known.29

According to the White House Task Force’s strategy and research action 

plan, intensive public and private research in the United States and 

abroad over the past 8 years has shown that no single factor is 

responsible for the general problems in pollinator health, including the 

loss of honey bee colonies or declines in other bee populations. The task 

force stated that bee health problems are likely caused by a combination 

of stressors.30 Some of these stressors, in no particular order, include

• habitat loss, degradation, and fragmentation, including reduced 

availability of sites for nesting and breeding;

• poor nutrition, due in part to decreased availability of high quality and 

diverse forage;

• pests (e.g., the mite Varroa destructor31) and disease (e.g., viral, 

bacterial, and fungal diseases);

• pesticides and other environmental toxins; and

• migratory stress from long-distance transport.

Continued losses of honey bees; other managed bees; and wild, native 

bees threaten agricultural production and the maintenance of natural 

plant communities. Commercial beekeepers are concerned that honey 

bee colony losses could reach an unsustainable level for the industry. 

According to a 2014 USDA report, the cost of honey bee almond 

pollination services is believed to have risen in connection with the 

 

29Pollinator trends are generally tracked by comparing current population levels to 

historical population levels. While assessments of honey bee status are measured in part 

by examining the number of managed hives registered for honey production, assessments 

of native bee status rely on disparate historical collection data and limited contemporary 

surveys.

30In addition to the impacts of each individual stressor, stressors interact and, in some 

cases, act together to impair pollinator health.

31The Varroa mite is an external parasite that feeds on honey bee blood.

Factors Affecting Bee 

Health

Effects of Bee Losses on 

Agriculture and 

Ecosystems
Page 12 GAO-16-220 Protecting Bee Health

increased cost of maintaining hives in the midst of industry-wide 

overwintering losses.

32 Officials we interviewed from a commercial 

beekeeping organization said that, for beekeepers, meeting the growing 

demand for pollination services in agricultural production has become 

increasingly difficult, particularly as a result of bee colony losses. 

Although the number of managed honey bee colonies has been relatively 

consistent since 1996, ranging from about 2.4 to 2.7 million colonies, the 

level of effort by the beekeeping industry to maintain colony numbers has 

increased, according to the White House Pollinator Health Task Force’s 

strategy.33 For example, beekeepers face increasing production costs, 

which include sugar, protein, medications, and miticides (chemicals that 

kill the mites that can infest bee hives). Furthermore, when winter colony 

losses are high, beekeepers may compensate for these losses by splitting 

one colony into two, supplying the second colony with a purchased queen 

bee and supplemental food to build up colony strength. Using this 

method, the commercial honey beekeeping industry has generally been 

able to replenish colonies lost over the winter, but at a cost. These 

increased maintenance costs can result in increased rental fees for 

farmers renting the hives.

Five USDA agencies within the scope of our review—NASS, ARS, NIFA, 

FSA, and NRCS—as well as EPA have specific roles and responsibilities 

with respect to addressing bee health issues.

USDA has surveyed beekeepers in the United States since the late 1930s 

to determine the number of honey bee colonies and the amount of honey 

produced. The survey, now conducted by NASS, is called the Bee and 

Honey Inquiry. NASS maintains a list of beekeeping operations in the 

nation and has been surveying beekeepers in all states except Alaska 

since the 1970s to gather data on honey bee colonies, including the 

number of colonies producing honey, total pounds of honey produced, 

and total value of production by state for a production year.

ARS, USDA’s largest research agency, conducts research within several 

of its laboratories that could protect bee health. NIFA, USDA’s primary 

 

32USDA Economic Research Service (2014). 

33White House Pollinator Health Task Force, National Strategy to Promote the Health of 

Honey Bees and Other Pollinators, May 19, 2015.

Specific Roles and 

Responsibilities of USDA 

and EPA in Addressing 

Bee Health Issues
Page 13 GAO-16-220 Protecting Bee Health

agency providing research grants to universities, provides competitive 

grants to conduct research related to bee health and to disseminate the 

results through the Cooperative Extension System. CRIS, which is 

managed by NIFA, contains information on ARS and NIFA research and 

outreach. CRIS provides documentation and reporting for agricultural, 

food science, human nutrition, and forestry research, education and 

extension activities for USDA, including those related to bee health.

FSA and NRCS oversee conservation programs that, among other things, 

help provide habitat for bees. FSA administers the Conservation Reserve 

Program (CRP), which implements long-term rental contracts with 

farmers to voluntarily remove certain lands from agricultural production 

and to plant species that will improve environmental health and quality, 

such as improving forage plantings for bees and other pollinators. The 

long-term goal of the program is to reestablish valuable land cover to help 

improve water quality, prevent soil erosion, and reduce loss of wildlife 

habitat. NRCS administers the Environmental Quality Improvement 

Program (EQIP), which implements short- to long-term contracts with 

farmers to voluntarily implement practices to conserve natural resources 

and deliver environmental benefits, such as created wildlife habitat, which 

may benefit bees. In addition, NRCS administers components of the 

Agricultural Conservation Easement Program, in which plantings may 

benefit bees or other pollinators.34 NRCS has primary responsibility for 

providing to landowners the technical assistance needed to plant the 

pollinator-friendly habitats. NRCS assists farmers through a network of 

staff at headquarters, state, and county offices. In addition to supporting 

overall pollinator habitat across the nation, FSA and NRCS are focusing 

CRP and EQIP pollination resources on five upper Midwest states 

(Michigan, Minnesota, North Dakota, South Dakota, and Wisconsin) that 

are home to a significant percentage of honey bee colonies during the 

summer months.

Under FIFRA, EPA is responsible for regulating pesticides, including 

those used on crops and other plants and those used by beekeepers to 

 

34The Agricultural Conservation Easement Program provides financial and technical 

assistance to help protect wetlands, agricultural uses, and grazing and related 

conservation values on eligible lands. Under the Agricultural Land Easements component, 

NRCS helps American Indian tribes, state and local governments, and nongovernmental 

organizations protect agricultural lands by limiting nonagricultural uses on the land. Under 

the program’s Wetlands Reserve Easements component, NRCS helps to restore, protect, 

and enhance enrolled wetlands.
Page 14 GAO-16-220 Protecting Bee Health

combat bee pests. As part of this responsibility, EPA reviews applications 

from pesticide manufacturers seeking to obtain a registration for new 

pesticides or new uses of existing pesticides. Under FIFRA, pesticide 

registrants are required to report to EPA any information related to known 

adverse effects to the environment caused by their registered 

pesticides.35 In addition, the Food Quality Protection Act of 1996 

amended FIFRA to require that EPA begin a review of the registrations of 

all existing pesticide active ingredients. As further amended in 2007 by 

the Pesticide Registration Improvement Renewal Act, FIFRA requires all 

reviews be completed by October 2022. According to EPA’s website, the 

FIFRA requirement applies to about 1,140 pesticides. EPA has chosen to 

review the registration of all of these pesticides in about 740 “cases.” A 

case may cover more than one pesticide active ingredient that are closely 

related in chemical structure and toxicological profile. The Pesticide 

Registration Improvement Act of 2003 (PRIA) amended FIFRA to require 

that EPA issue annual reports containing a review of its progress in 

carrying out its responsibilities for reviewing new and registered 

pesticides.

Other agencies, including some within USDA, also have programs related 

to bee health. For example, USDA’s Forest Service has conducted some 

research and monitoring and conserves habitat to protect bee 

populations. The U.S. Geological Survey (USGS) within the Department 

of the Interior (Interior) has monitored wild, native bee populations.36

Interior’s National Park Service and the National Science Foundation 

have also funded research on bee health, and Interior’s Bureau of Land 

Management is making changes to land-management programs by 

incorporating native, pollinator-friendly plants in its management 

practices.37

 

35In 1994, EPA created EIIS, its database on adverse pesticide incidents, to store 

information extracted from incident reports from pesticide registrants and others.

36The U.S. Geological Survey is an agency within the Department of the Interior that 

provides scientific information on, among other things, the health of the U.S. environment 

and ecosystems.

37Other agencies within the White House Pollinator Health Task Force may also have 

taken actions to protect bee health. However, these agencies were generally not the focus 

of this review.
Page 15 GAO-16-220 Protecting Bee Health

Five selected USDA agencies conduct monitoring, research and 

outreach, and conservation to protect bees, but limitations within those 

efforts hamper the agencies’ ability to protect bee health. In 2015, USDA 

agencies increased honey bee colony monitoring to better estimate honey 

bee colony losses nationwide, but as a co-chair of the White House 

Pollinator Health Task Force with EPA, the department has not worked 

with task force partners to coordinate a native bee monitoring plan. In 

addition, USDA has conducted and funded research and outreach, 

primarily by ARS and NIFA, on the health of different categories of bees, 

including honey bees and, to a lesser extent, other managed and wild, 

native bees, but CRIS, which tracks USDA-funded research and 

outreach, is not currently designed to enable tracking or searching of 

projects by bee category. Furthermore, USDA’s FSA and NRCS have 

increased funding and taken other actions to promote bee habitat, but 

neither agency has a method to count all of the acres that landowners 

have restored or enhanced to benefit bees and other pollinators, and 

limitations in their evaluation of those actions may hinder their 

conservation efforts.

USDA agencies have taken some actions to increase monitoring of honey 

bees, other managed bees, and wild, native bees, but USDA, which cochairs the White House Pollinator Health Task Force with EPA, has not 

worked with its partners on the task force to coordinate a native bee 

monitoring plan.

In April 2015, NASS, which conducts USDA bee surveys, initiated colony 

loss surveys to provide quarterly estimates of honey bee colony losses in 

the United States. NASS officials told us that the results of these surveys 

will improve data on colony losses from prior USDA-funded surveys. 

According to the task force’s strategy, federal agencies plan to use data 

from these surveys to assess progress toward the strategy’s goal of 

reducing winter honey bee colony losses to no more than 15 percent by 

2025.38 USDA has conducted surveys of beekeepers in the United States 

 

38The Task Force stated it will develop additional goal metrics for summer and total 

annual colony losses. 

Selected USDA 

Agencies Conduct 

Monitoring, Research 

and Outreach, and 

Conservation to 

Protect Bees, but 

Limitations Exist 

within Those Efforts

USDA Agencies Increased 

Honey Bee Colony 

Monitoring in 2015 but 

Have Not Worked with 

Federal Partners to 

Coordinate a Native Bee 

Monitoring Plan

Monitoring Honey Bees
Page 16 GAO-16-220 Protecting Bee Health

to track the number of honey bee colonies in the country since the late 

1930s, but those surveys have not gathered beekeepers’ observations or 

data about bee health problems.

Before NASS’s new surveys, NIFA provided most of the funding for the 

Bee Informed Partnership to survey beekeepers about colony losses and 

honey bee health from 2006 through 2015. The surveys showed that, on 

average, about 29 percent of respondents’ honey bee colonies have been 

dying over the winter, but the results cannot be generalized beyond the 

survey respondents. The partnership has used a variety of methods to 

reach out to all beekeepers in the country and in recent years received 

responses from over 6,000 beekeepers.39 However, the partnership has 

not calculated or estimated response rates to the surveys and has not 

reported whether nonrespondents might differ from the respondents in 

terms of survey answers. Because of this, the results cannot represent 

beekeepers in general.

In a letter to the Office of Management and Budget (OMB) commenting 

on the new NASS survey, the partnership stated that NASS is wellequipped to take over the honey bee colony loss surveys with its new 

quarterly and annual surveys. According to NASS officials, improvements 

will be possible in the new NASS surveys in part because NASS 

maintains a comprehensive list of beekeepers from which it can select a 

random sample. According to an agency document and official, the 

quarterly survey will capture data from beekeeping operations with five or 

more colonies, and operations with fewer than five colonies will receive 

one annual survey in December. NASS officials said that their estimates 

of U.S. colony losses during 2015 will be available in May 2016. NASS 

has also added questions to the annual Bee and Honey Survey on the 

costs associated with colony maintenance, which may include costs 

associated with colony losses.

In addition, USDA’s Animal and Plant Health Inspection Service (APHIS) 

has coordinated a national survey of honey bee pests and diseases 

annually since 2009 with the University of Maryland and ARS. However, 

that survey does not provide estimates of colony losses in the United 

States.

 

39In the 2012-2013 survey, for example, the partnership sent e-mail invitations using a 

variety of e-mail lists and placed advertisements and notices in beekeeping journals and 

social media. 
Page 17 GAO-16-220 Protecting Bee Health

According to NASS officials, NASS does not conduct surveys to estimate 

populations or colony losses of other managed bees, such as bumble 

bees, alfalfa leafcutting bees, and orchard mason bees, because NASS 

does not consider them to be within the scope of their responsibilities for 

farm livestock commodities. USDA’s ARS and NIFA conduct and fund 

limited monitoring activities in agricultural settings to estimate populations 

and health issues for these other types of managed bees. However, the 

research action plan established as a priority engaging NASS in collecting 

data on the commercial sales of nonhoney bee pollinators to understand 

the economic value of alternative pollinators. To address this priority, 

NASS included in a new survey on the cost of pollination—which largely 

focuses on honey bees—questions on the cost to agricultural producers 

for products such as wildflowers and pollination by other managed bees 

and native bees. NASS began data collection for this new survey in 

December 2015. 

USDA agencies, including ARS and NIFA, have conducted and supported 

limited monitoring of wild, native bees, according to USDA documents 

and officials. For example, one NIFA-funded project at Pennsylvania 

State University begun in 2010 seeks to establish baseline biodiversity 

and abundance data for native bees in and adjacent to Pennsylvania 

orchards, determine which species are pollinators, and quantify their 

relative significance and economic importance, according to the project 

summary in CRIS. In addition, in 1997, ARS’s laboratory in Logan, Utah, 

began monitoring wild, native bees in parks, forests, and other areas in 

the United States as part of their efforts to develop alternative pollinators 

for U.S. agriculture, according to ARS scientists. In one project, ARS has 

annually conducted surveys of bumble bee populations for 5 to 8 years at 

five sites in Nevada, Oregon, and Utah. The goal is to provide insight into 

natural population dynamics of native bees in native habitat and identify 

bumble bee population trends by species on the basis of 10 years of 

surveys. According to the project description, bumble bee declines have 

been documented over the last decade, but long-term studies of bumble 

bee community dynamics are lacking, and such monitoring will help 

determine whether a fluctuation in a bumble bee population is a natural 

cycle or something unusual.

In its 2007 report on the status of pollinators, the National Research 

Council stated that wild, native bees are arguably the most important and 

Monitoring Other Managed 

Bees

Monitoring Wild, Native Bees
Page 18 GAO-16-220 Protecting Bee Health

least studied groups of pollinators.40 The report recommended 

establishing a baseline for long-term monitoring, and a coordinated 

federal approach with a network of long-term pollinator-monitoring 

projects that use standardized protocols and joint data-gathering 

interpretation. The report also stated that pollinator monitoring programs 

in Europe have effectively documented declines in pollinator abundance, 

but there is no comparable U.S. monitoring program. Stakeholders from 

pesticide manufacturing, university research, and 

conservation/environmental groups we interviewed said that USDA 

should take additional actions to monitor wild, native bees because 

current monitoring is insufficient and will not facilitate provision of trends 

in these bee populations. Stakeholders from some groups suggested that 

USDA and other agencies, such as USGS, should coordinate federal 

monitoring efforts. A stakeholder from a university said that USDA should 

develop a coordinated assessment policy for native bees to provide 

information on their status because, without such a policy, agencies will 

not know which species are declining, endangered, or extinct.

The 2014 presidential memorandum on pollinators called for the White 

House Task Force to assess the status of native bees and other 

pollinators. The subsequent White House Task Force strategy and 

research action plan state that native bees are affected by habitat loss 

and degradation, and that there is strong evidence, for some species, that 

such factors have led to population declines. For example, the research 

action plan states that collapses in bumble bee species have been 

statistically documented, but little is known about trends for wild, native 

bees, most of which are solitary, rather than social, bees. The research 

action plan also states that (1) the scope of native bee monitoring is 

limited by available funding, (2) assessments of native bees’ status rely 

on disparate historical collection data and limited contemporary surveys, 

and (3) a survey of bees in various ecosystems is needed to determine 

the status of native pollinators.

The White House Task Force’s research action plan identified several 

priority actions, with corresponding lead and support agencies 

responsible for different aspects of the monitoring. For example, the 

research action plan identifies ARS, USGS, and the Fish and Wildlife 

 

40National Research Council, Status of Pollinators in North America, National Academies 

Press (Washington, D.C., 2007).
Page 19 GAO-16-220 Protecting Bee Health

Service as three of the lead agencies for the priority actions to develop 

baseline status data and to assess trends in pollinator populations. And 

the research action plan identifies NIFA, NASS, the National Science 

Foundation, the Forest Service, and the National Park Service as primary 

support agencies for these priority areas. Although the research action 

plan identifies which agencies have responsibility for monitoring 

pollinators, it does not identify the development of a mechanism, such as 

a monitoring plan, to coordinate the efforts of those agencies related to 

native bees. As of September 2015, USDA did not have plans to work 

with task force members to coordinate development of such a mechanism 

for wild, native bees. Some officials said that USDA has not coordinated 

with other task force agencies to develop a wild, native bee monitoring 

plan because they were developing the broader task force strategy. The 

research action plan also does not define and articulate the common 

outcome or identify specific roles and responsibilities for each lead or 

support agency. Key practices for agency collaboration that we identified 

in an October 2005 report call for agency staff to work together across 

agency lines to define and articulate the common federal outcome or 

purpose they are seeking to achieve that is consistent with their 

respective agency goals and mission. Another key practice we identified 

calls for collaborating agencies to work together to define and agree on 

their respective roles and responsibilities, including how the collaborative 

effort will be led.41

In addition, we identified, in a February 2014 report, key practices for 

agency collaboration that call for establishing shared outcomes and goals 

that resonate with, and are agreed upon, by all participants and are 

essential to achieving outcomes in interagency groups.42 Furthermore, 

although the research action plan mentions stakeholders and 

partnerships, it does not articulate how they will be included in addressing 

priority actions related to monitoring native bees. In September 2012, 

another key practice we identified calls for ensuring that the relevant 

stakeholders have been included in the collaborative effort. This 

collaboration can include other federal agencies, state and local entities, 

and private and nonprofit organizations.43 By developing a mechanism, 

 

41GAO-06-15. 

42GAO-14-220. 

43GAO-12-1022. 
Page 20 GAO-16-220 Protecting Bee Health

such as a monitoring plan for wild, native bees that would (1) establish 

roles and responsibilities of lead and support agencies and their shared 

outcomes and goals and (2) obtain input from relevant stakeholders, 

there is better assurance that a coordinated federal effort to monitor bee 

populations will be effective. One senior USDA official stated that 

coordinating with the other task force agencies to develop a wild, native 

bee monitoring plan would be very important for gathering data to show 

the status of wild, native bees in the future. Key USDA and USGS officials 

with bee-related management responsibilities agreed that developing 

such a monitoring plan would help them establish a consistent approach 

across their agencies. The officials also said that USDA and other 

agencies should establish a team of federal scientists to coordinate the 

development of a federal monitoring plan for wild, native bees that would 

establish monitoring goals and standard methods and involve state and 

other stakeholders. Some USDA and USGS officials said that without a 

team to coordinate a monitoring plan, individual agency efforts may be 

ineffective in providing the needed information on trends in wild, native 

bees in the United States.

USDA has conducted and funded research and outreach, primarily by 

ARS and NIFA, on the health of different categories of bees, including 

honey bees and, to a lesser extent, other managed and wild, native bees, 

but CRIS, which tracks USDA-funded research and outreach, does not 

currently facilitate tracking or searching of projects by bee category.44

ARS’s honey bee projects have focused on projects for many health 

concerns. For example, the ARS laboratory in Baton Rouge, Louisiana, 

has focused for many years on breeding honey bees that are resistant to 

Varroa mites. Also, ARS’s laboratory in Beltsville, Maryland, has 

conducted research to develop management strategies for diagnosing 

and mitigating disease, reducing the impacts of pesticides and other 

environmental chemicals, and improving nutrition. ARS’s laboratory in 

Logan, Utah, is identifying how farmers may use different pollinators, 

including managed and wild, native bees. This research includes 

 

44According to USDA officials, other USDA agencies, such as the Forest Service, have 

not conducted as much research on bees as ARS and NIFA. According to Forest Service 

officials, the agency conducts research on agroforestry, forestry, ecological, full life-cycle, 

and landscape-scale factors of bee sustainability. However, our review did not examine 

Forest Service research activities.

USDA Bee Research and 

Outreach Have Focused 

Primarily on Honey Bee 

Health, but Limitations in 

Its Research Information 

System Hinder Efforts to 

Track Research Projects
Page 21 GAO-16-220 Protecting Bee Health

developing methods for mass production, use, and disease control for a 

selection of bees.

ARS scientists have regularly disseminated the results of their research at 

national, regional, state, and local bee-related conferences and events. 

ARS officials have also conducted outreach at meetings to provide 

information to commodity growers, such as the Almond Board of 

California. One ARS scientist noted that he had attended 27 state and 

other types of beekeeper meetings over the past 5 years. Another ARS 

scientist told us that he spends about 25 percent of his time conducting 

outreach with beekeepers. In addition, ARS scientists have published

dozens of articles summarizing their research results in scientific journals.

From fiscal year 2008 through fiscal year 2015, ARS obligated $88.5 

million for projects focused on bee health and $1.6 million for projects on 

the effect of pollination by different types of bees on crop or plant 

production.45 Of the $88.5 million obligated, our analysis determined that 

$72.6 million was for projects primarily focused on honey bee health, an 

additional $6.3 million was for projects with a combined focus on the 

health of honey bees and other bees, and $9.6 million was for projects 

focused only on other managed bees or wild, native bees.46 According to 

ARS officials, all ARS funding for research on wild, native bees has been 

for the purpose of developing new uses for managed bees in commercial 

agriculture.

Unlike ARS, which itself conducts research, NIFA provides funds for 

research through grants. For fiscal years 2008 through 2014, NIFA’s 

competitive grants for research on bee health were largely focused on 

honey bees, with some efforts focused on managed and wild, native 

 

45Research on pollinator effectiveness examines the effect of pollination by different types 

of bees on crop or plant production. ARS also obligated $1.7 million to other bee-related 

research topics, including the effect bees have on gene flow from genetically modified 

plants to other plants.

46We analyzed ARS projects to determine whether they addressed bee health or pollinator 

effectiveness. We then determined whether the projects on bee health addressed (1) 

honey bees only, (2) honey bees and other bees, or (3) other managed bees and wild, 

native bees. See appendix I for details of our methodology.
Page 22 GAO-16-220 Protecting Bee Health

bees.47 For example, NIFA obligated funds for a 2012 grant to a team of 

scientists and outreach specialists at Michigan State University, the 

University of California-Davis, and other institutions that works with 

growers to develop best practices for pollinator habitat enhancement and 

farm management practices to bolster managed and wild, native bee 

populations. The project is examining the performance, economics, and 

farmer perceptions of different pollination strategies in various fruit and 

vegetable crops, according to the project website. These strategies 

include complete reliance on honey bees, farm habitat manipulation to 

enhance suitability for native bees, and use of managed, native bees 

alone or in combination with honey bees.

For fiscal years 2008 through 2014, NIFA obligated $29.9 million on 

competitive grant projects focused primarily or partially on bee health, and 

$11.6 million on projects focused on pollination effectiveness.48 Of the 

$29.9 million, our analysis of individual grant project objectives and 

descriptions determined that NIFA provided $16.7 million to projects on 

honey bee health, $9.8 million to projects on the health of honey bees 

and other bees, and $3.4 million to projects on the health of wild, native 

bees.49

In addition to funding competitive grants, NIFA provides support for bee 

research at land-grant institutions through capacity grants to the states on 

 

47NIFA offers competitive grants to institutions and other entities to enable USDA to (1) 

attract a wide pool of applicants to work on agricultural issues of national interest and (2) 

select the highest quality applications submitted by highly qualified individuals, institutions, 

or organizations.

48NIFA also provided $1.0 million for research on other bee-related issues, including the 

effect of bees on gene flow from genetically modified plants to other plants. 

49We analyzed NIFA-funded projects to determine whether they addressed bee health or 

pollinator effectiveness. We then determined whether the projects on bee health 

addressed (1) honey bees only, (2) honey bees and other bees, or (3) other managed 

bees and wild, native bees. Because NIFA’s database does not identify what percentage 

of the obligations the agency directed to each project topic, the obligations were for 

projects that primarily or partially addressed these topics and categories of bees, so some 

of these projects included nonbee-related research. See appendix I for details of our 

methodology.
Page 23 GAO-16-220 Protecting Bee Health

the basis of statutory formulas.50 From fiscal year 2008 through fiscal year 

2014, these institutions expended $10.7 million in NIFA grants for 

research related to bees. Furthermore, state institutions have used NIFA 

capacity grants to support bee-related extension and education activities 

through the Cooperative Extension System, such as teaching best 

management practices to beekeepers, according to an agency budget 

official. However, because NIFA and its partners do not track capacity 

grant funding related to extension activities by subject, we were not able 

to determine the amount of extension funding dedicated to bee-related 

activities. In addition, according to estimates by the Economic Research 

Service, overall research funding has declined in inflation-adjusted 

dollars, from 1980 to 2014, which may have resulted in a reduction in the 

number of cooperative extension bee specialists.51 According to NIFA 

officials, about 28 bee specialists are currently supported by the 

Cooperative Extension System in the United States and its territories. 

That number has declined from an estimated 40 extension bee specialists 

in 1986, largely due to funding reductions. In addition, according to NIFA 

officials, the reduction in extension funding may have reduced expertise 

in related areas, including Integrated Pest Management (IPM), which 

focuses on long-term prevention of pests or their damage through a 

combination of techniques, such as biological control, habitat 

manipulation, modification of cultural practices, and use of resistant 

varieties, paired with monitoring to reduce unnecessary pesticide 

applications. IPM extension agents routinely advise farmers on 

alternatives to pesticides and pesticide application methods that reduce 

risk to bees and other pollinators. 

 

50Through several program authorities, NIFA provides funds for research and extension to 

land-grant colleges and universities, schools of forestry, and schools of veterinary 

medicine. These are known as capacity grants. Capacity funding helps ensure that the 

land-grant university system and other partners maintain the capacity to conduct research, 

education, and extension activities. Local or regional university leaders decide which 

specific projects are to be supported by an institution’s formula grant allotment. The 

institutions receiving the funding determined how much of their capacity funds they 

wanted to expend for bee-related projects. The institutions categorized these projects as 

bee-related, and NIFA confirmed the categorization. 

51Sun Ling Wang, “Cooperative Extension System: Trends and Economic Impacts on U.S. 

Agriculture,” Choices, Agricultural & Applied Economics Association, 1st Quarter of 2014. 

The author, an economist with USDA’s Economic Research Service, used the service’s 

research price index as the deflator and updated her findings through 2014 for GAO.
Page 24 GAO-16-220 Protecting Bee Health

USDA’s CRIS provides overall funding data and descriptions of beerelated research and outreach but does not facilitate tracking projects and 

funding by the categories of bees addressed by the White House Task 

Force’s strategy and research action plan. In addition, the research action 

plan identifies key research needed to fill knowledge gaps for honey 

bees; other managed bees; wild, native bees; and other pollinators. 

However, the three categories for bees and other pollinators used in 

CRIS to code USDA projects are “honey bees,” “bees, honey and other 

pollinators,” and “other pollinators,” so that bee-related research projects 

that could help fill the identified knowledge gaps may not be easily 

identified in CRIS. For example, NIFA guidance on reviewing certain 

competitive grant applications states that national program leaders must 

check CRIS to determine if the proposed work has already been funded 

by NIFA or ARS and to ensure that it is not unnecessarily repeating work 

not yet published. In addition, ARS guidance directs the agency’s 

scientists to search CRIS for potentially duplicative projects when 

preparing project plans. Because projects may have multiple objectives, it 

would be time-consuming to readily identify and track completed and 

ongoing bee-related research by category of bee. Both the NIFA staff and 

the researchers would have to search the codes for the up to three 

different CRIS categories and then review the descriptions and the 

multiple objectives for all projects with those codes.

By updating the categories of bees in CRIS to reflect the categories of 

bees discussed in the White House Task Force’s strategy and research 

action plan, USDA could increase the accessibility and availability of 

information about USDA-funded research on bees. Senior USDA officials 

said that CRIS would be more useful within the department and to others 

seeking to identify bee-related research projects and project funding by 

topic if USDA revised it to indicate the categories of pollinators that are 

consistent with the research action plan. ARS and NIFA officials agree 

improvements to CRIS could help managers track research spending 

over time by the categories of bees identified in the research action plan. 

One NIFA official estimated that revisions to CRIS could be done costeffectively using minimal staff time.
Page 25 GAO-16-220 Protecting Bee Health

FSA and NRCS have taken many actions to promote bee habitat 

conservation since 2008, but limitations in research, tracking of pollinator 

habitat, and evaluation of the agencies’ conservation efforts could hinder 

those efforts.

The Farm Bill of 2008 authorized USDA to encourage the use of 

conservation practices that benefit native and managed pollinators and 

required that USDA review conservation practice standards to ensure the 

completeness and relevance of the standards to, among other things, 

native and managed pollinators. In August 2008, and again in May 2015, 

NRCS in partnership with the Xerces Society and San Francisco State 

University published guidance identifying several conservation 

programs,52 including CRP, EQIP, and NRCS’s Conservation 

Stewardship Program (CSP)53 that could be used to promote pollinators 

on working lands.54 This guidance identified 37 practices to create or 

enhance pollinator habitat by providing more diverse sources of pollen 

and nectar, and shelter and nesting sites, among other things.

According to FSA and NRCS officials, CRP and EQIP are the largest 

USDA private land conservation programs benefiting pollinators. 

Participants voluntarily sign up or enroll in FSA or NRCS conservation 

programs and in specific practices within those programs. As of August 

2015, FSA had over 132,000 acres enrolled in pollinator-specific CRP 

practices, with a remaining allocation of 67,000 acres that could be 

 

52The Xerces Society for Invertebrate Conservation is a nonprofit organization that 

protects wildlife through the conservation of invertebrates and their habitat. The 

organization partners with NRCS to support pollinator conservation efforts.

53Through CSP, participants take additional steps to improve resource condition including 

soil quality, water quality, water quantity, air quality, and habitat quality, as well as energy. 

CSP provides two types of payments through 5-year contracts: annual payments for 

installing new conservation activities and maintaining existing practices; and supplemental 

payments for adopting a resource-conserving crop rotation.

54NRCS, the Xerces Society for Invertebrate Conservation, and San Francisco State 

University, Using Farm Bill Programs for Pollinator Conservation, August 2008. This 

information was updated in 2015; NRCS, the Xerces Society for Invertebrate 

Conservation, and San Francisco State University, Using Farm Bill Programs for Pollinator 

Conservation, May 2015.

FSA and NRCS Have 

Taken Actions That 

Promote Bee Habitat 

Conservation, but 

Limitations Could Hinder 

the Agencies’ 

Conservation Efforts

FSA and NRCS Have Taken 

Many Actions That Promote 

Bee Habitat Conservation
Page 26 GAO-16-220 Protecting Bee Health

enrolled under these practices. In 2014, FSA announced an additional $8 

million in incentives to enhance CRP cover crops to make them more 

pollinator-friendly. FSA is offering incentives to CRP participants in the 

five states that are home to most honey bee colonies during the 

summer—Michigan, Minnesota, North Dakota, South Dakota, and 

Wisconsin—to establish pollinator habitat. According to an FSA official, 

because CRP participants began to implement habitat enhancements in 

fiscal year 2015, FSA does not yet have information on the number of 

acres of habitat established. Also, within CRP, the State Acres for Wildlife 

(SAFE) initiative allows agricultural producers to voluntarily enroll acres in 

CRP contracts for 10 to 15 years. In exchange, producers receive annual 

CRP rental payments, incentives, and cost-share assistance to establish, 

improve, connect, or create higher-quality habitat. As of November 2015, 

the SAFE initiative was providing pollinator habitat in Michigan, Ohio, and 

Washington. For example, the goal of the Michigan Native Pollinators 

SAFE project is to enroll 2,500 acres of enhanced habitat over the next 5 

years to benefit native pollinators.

In addition, in fiscal year 2014, NRCS provided more than $3.1 million in 

technical and financial assistance to EQIP participants in the five states 

that are home to most honey bee colonies during the summer to 

implement conservation practices that would provide pollinator habitat. 

This funding led to over 220 contracts with participants to establish about

26,800 acres of pollinator habitat, according to NRCS data. NRCS made 

$4 million available in fiscal year 2015 through EQIP for honey bee 

habitat. NRCS also funds other conservation programs that can benefit 

bees and other pollinators. For example, the CSP provides financial and 

technical assistance for participants whose operations benefit pollinators. 

From 2012 through 2014, 17,500 acres were enrolled in one beneficial 

CSP practice intended to improve habitat for pollinators and other 

beneficial insects. Another CSP practice for grazing management may 

benefit pollinators, but the acreage that benefits pollinators is unknown, 

according to an NRCS official. In addition, NRCS offices in several states, 

including Montana and South Dakota, seek to benefit pollinators with 

upland habitat restoration funded by the Wetlands Reserve Program.

NRCS and FSA have taken steps to provide information to field offices, 

agricultural producers, and others that is useful for pollinator habitat 

conservation programs. For example, in collaboration with the Xerces 

Society and academic partners, NRCS has revised and expanded lists of 

plants that benefit bees and technical guidance for conserving pollinator 

forage. The NRCS Conservation Innovation Grants program has 

supported several projects across the country designed to demonstrate 
Page 27 GAO-16-220 Protecting Bee Health

the value of habitat for pollinators, as well as to expand and improve 

NRCS’s capacity to establish and monitor high-quality bee forage sites. 

The task force’s strategy notes that FSA is working collaboratively with 

NRCS to promote the use of more affordable, pollinator-friendly seed 

mixes on CRP land. Some NRCS Plant Materials Centers—which 

evaluate plants for conservation traits and make them available to 

commercial growers who provide plant materials to the public—have 

pollinator forage demonstration field trials under way to determine and 

demonstrate the effectiveness of forage planted for pollinators. In 

addition, FSA, NRCS, and Interior’s USGS and Fish and Wildlife Service 

have funded a website that provides information on plant-pollinator 

interactions to help agencies improve pollinator seed mixes for programs 

such as CRP and EQIP, according to a USGS official. USGS manages 

this website, known as the Pollinator Library, to provide information on the 

foraging habitat of pollinating insects with the goal of improving their 

habitat.55 The Pollinator Library is to help users determine which flowers 

that various insects, including native bees, prefer. The website includes a 

search feature so users can determine, for example, what types of 

pollinators have been found on different plant species, by state and land 

type (such as CRP land). Knowing which flowers pollinators prefer is 

useful to agencies creating seed mixes for CRP and EQIP habitat 

enhancement efforts.

While USDA agencies have taken steps to improve bee habitat, 

according to USDA officials and documents, limitations related to (1) 

research on bee habitat and forage, (2) tracking acres of restored or 

enhanced pollinator habitat, and (3) evaluating NRCS and FSA 

conservation efforts, could hinder conservation efforts.

Research on Habitat and Forage

As part of the task force’s strategy and research action plan, federal 

officials evaluated completed research and determined that additional 

research on bee forage and habitat is needed to support NRCS, FSA, 

and other entities’ conservation efforts. The task force’s research action 

plan notes that there is much more to learn about the relationships 

between plants and pollinators, including

 

55 www.npwrc.usgs.gov/pollinator. 

Limitations in Research, 

Tracking Acres of Pollinator 

Habitat, and Evaluation Could 

Hinder the Agencies’ 

Conservation Efforts
Page 28 GAO-16-220 Protecting Bee Health

• identifying habitat with the greatest potential for pollinator benefits;

• developing locally-adapted plant mixes to provide resources for 

pollinators throughout the year;

• designing a means for properly collecting, processing, storing, and 

germinating sufficient seeds for restoration; and

• developing new concepts and techniques to understand how to 

establish a broad mix of plants required for restoration based on 

different factors—e.g., cost-effectiveness and site properties.

In addition, the research action plan identifies priority research actions for 

federal agencies. For example, one priority action is developing a 

science-based plant selection decision support tool to assist land 

managers. According to the research action plan, this tool would help 

land managers use the most effective and affordable plant materials 

currently commercially available for pollinator habitat in wildland, 

agricultural, or urban areas. The strategy for carrying out this action in 2 

to 3 years, according to the research action plan, is to identify existing 

science capacity to produce the decision-support tool. The research 

action plan identifies ARS, NRCS, and USGS as able to provide 

collaborative leadership for this action within the Plant Conservation 

Alliance (PCA).

56 Another priority action is developing a system for 

monitoring the use of native plant materials.57 According to the research 

action plan, the strategy for this action is within 2 years to develop an 

interagency, online, searchable database to collect and analyze relevant 

data efficiently (e.g., species, plant material type, location, acreage, year, 

establishment, impacts on pollinators) to evaluate the use of native plant 

materials. The research action plan identifies ARS and NRCS as sharing 

 

56The research action plan identifies USDA and Interior as members of the Plant 

Conservation Alliance (PCA), a collaborative partnership among 12 federal agencies and 

almost 300 nonfederal cooperators. PCA, through its proposed Interagency Seed 

Strategy, proposes similar research. According to the research action plan, research 

coordinated through the PCA framework could ensure focus, optimize resources, and 

enhance dissemination of results.

57According to the research action plan, the federal government currently lacks a 

mechanism for tracking deployment of native plants, the long-term success of those 

deployments, and their benefit(s) to pollinators on federally-managed (e.g., the Bureau of 

Land Management and the U.S. Forest Service) and federally-subsidized (e.g., CRP, 

EQIP) restoration projects. This missed opportunity to assess success and failure 

condemns land managers to repeat the same mistakes, according to the plan.
Page 29 GAO-16-220 Protecting Bee Health

collaborative leadership within the PCA for this action with the U.S. Forest 

Service and Interior’s USGS and Bureau of Land Management.

Tracking Acres of Restored and Enhanced Pollinator Habitat

In response to the June 2014 presidential memorandum on pollinators, 

the task force established an overarching goal on pollinator habitat 

acreage of restoring and enhancing 7 million acres of land for pollinators 

over the next 5 years through federal actions and public-private 

partnerships. Under the task force’s strategy, USDA agencies, including 

FSA and NRCS, are to contribute to this goal. FSA and NRCS are able to 

track acres of pollinator habitat restored and enhanced under pollinatorspecific initiatives and practices, according to agency officials. However, 

they are unable to track acres on which landowners implement practices 

for other conservation purposes, such as for erosion control, improved 

water quality, or wildlife habitat, that may also have an additional benefit 

for pollinators, according to agency officials. According to FSA and NRCS 

officials, developing a method for tracking most acres with conservation 

practices benefiting pollinators will be time-consuming and may require 

some form of estimation. For example, according to FSA officials, the 

agency may be able to estimate acres of pollinator habitat using 

information it has on the types of plants landowners have planted. 

Nevertheless, by developing an improved method, within available 

resources, to track conservation program acres that benefit pollinators, 

FSA and NRCS would be better able to measure their contribution to 

restoring and enhancing the acres called for by the task force strategy’s 

goal. Both agencies agreed that developing an improved method for 

tracking acres on which pollinator habitat has been restored or enhanced 

would provide valuable information. As of November 2015, the agencies 

had begun to discuss and consider methods they might use to track acres 

on which pollinator habitat has been restored or enhanced but had yet to 

develop an improved method.

Evaluating FSA and NRCS Conservation Efforts

USDA has funded two evaluations of the effectiveness of FSA and NRCS 

conservation efforts related to pollinator habitat. First, in 2013, FSA and 

NRCS began jointly supporting a USGS study to evaluate the effect of 

CRP and EQIP plantings on honey bee health and productivity in five 

Midwestern states—Michigan, Minnesota, North Dakota, South Dakota, 

and Wisconsin. According to a January 2015 USGS progress report, the 

monitoring will quantify the effect USDA conservation lands have on 

honey bee health and productivity. For example, USGS is comparing the 
Page 30 GAO-16-220 Protecting Bee Health

health of honey bee colonies in areas dominated by row crops with the 

health of colonies located in areas with significant CRP and pasture 

acreage. The evaluation has begun to show which weeks or months may 

have a shortage of blooming forage. USGS plans to expand this 

evaluation in 2016 to additional sites in Michigan and Wisconsin and add 

a demonstration project to monitor the effect of CRP and EQIP plantings 

on orchards, according to a USGS official. Information generated from 

this USGS evaluation will be used to improve pollinator seed mixes for 

CRP and EQIP, according to FSA and NRCS officials. Second, in 2014, 

the Pollinator Partnership,58 under a cooperative agreement with NRCS, 

issued an independent evaluation of how NRCS field offices were 

promoting, implementing, monitoring, and documenting pollinator habitat 

efforts in conservation programs in several states. This evaluation 

concluded, among other things, that NRCS field offices were eager to 

support pollinators, but agency staff needed additional expertise to advise 

landowners how to implement effective conservation practices. However, 

NRCS has not conducted an evaluation to show where there may be 

gaps in expertise and how they might be filled; for example, whether the 

gaps should be filled through additional formal training for staff or through 

the informal learning that occurs when field staff, using technical 

assistance funding, monitor the field work to determine which plants are 

thriving and attracting bees.

According to NRCS officials, headquarters’ evaluations of pollinator 

habitat have been limited, in part, because the agency has been focused 

on implementing the plantings. The NRCS National Planning Procedures 

Handbook directs an evaluation of the effectiveness of the implemented 

plan to ensure it is achieving its objectives.59 The officials said that 

increased evaluation would be helpful because, while each state office 

has a biologist and other conservation experts, including partner 

biologists from nonprofit organizations, there are gaps in technical 

expertise on pollinator habitat available to some field offices. As a result, 

some field offices have less ability to effectively plan and monitor 

pollinator habitat. One university stakeholder suggested that NRCS 

 

58The mission of the Pollinator Partnership, a nonprofit organization, is to promote the 

health of pollinators, critical to food and ecosystems, through conservation, education, and 

research.

59USDA, NRCS, Title 180—National Planning Procedures Handbook, Part 600—National 

Planning Procedures, Subpart C—NRCS Planning Process (November 2014). 
Page 31 GAO-16-220 Protecting Bee Health

ensure that each of the approximately 30 states with a significant need for 

pollinator habitat has a native bee expert. NRCS officials said an 

evaluation of field office efforts to restore or enhance bee habitat could 

help identify where expertise gaps occur. Another NRCS official said that 

the agency could survey its staff to gather their views on the need for 

additional training or expertise. In addition, one NRCS official said that 

on-site evaluation of the success of the pollinator habitat is important to 

understanding the effectiveness of the technical assistance.

NRCS officials also said that additional evaluation is needed to determine 

if technical assistance funding is adequate to support conservation 

planning efforts for different pollinator habitats across the country. NRCS 

funding for technical assistance enables field staff to develop 

conservation plans for landowners and to assess the implementation of 

those plans. NRCS’s financial assistance funding to landowners helps 

pay to implement conservation plans. If technical assistance funding is 

too low, the effectiveness of conservation efforts may be compromised, 

according to NRCS officials. As total funding for NRCS conservation 

programs has increased, the percentage available for technical 

assistance has decreased relative to financial assistance. In 2014, 

funding for technical assistance was proportionally half of what it was in 

2002, relative to the amount of financial assistance that it supported in 

terms of conservation planning and monitoring. Specifically, according to 

NRCS officials, for every dollar provided for financial assistance in 2002, 

about $1.22 went to technical assistance. However, in 2014, for every 

dollar provided for financial assistance, about 59 cents was provided for 

technical assistance.60 According to USDA officials, the reduced 

percentage of funding devoted to technical assistance has resulted in 

NRCS field office staff having less time to plan for and ensure the quality 

of conservation efforts, including pollinator habitat, because the staff must 

spend more time in the office managing contracts and ensuring that all 

financial assistance dollars are obligated.61 By increasing evaluation of its 

habitat conservation efforts, including gaps in expertise and technical 

assistance funding available to field offices, USDA could better ensure 

 

60From fiscal year 2002 through fiscal year 2014, funding for NRCS’s conservation 

programs directed to technical assistance increased 156 percent from $976 million to 

about $1.5 billion, according to NRCS officials. During the same period, funding directed 

to financial assistance increased 321 percent from $801 million to $2.6 billion.

61The Secretary of USDA determines the relative proportion of financial assistance to 

technical assistance for mandatory programs, according to an NRCS official.
Page 32 GAO-16-220 Protecting Bee Health

the effectiveness of its efforts to restore and enhance bee habitat 

plantings across the nation.

EPA has taken steps to address pesticide threats to bees, but potential 

threats remain. Among other steps, in 2013, EPA revised the label 

requirements for certain pesticides and in 2015, proposed revisions for 

certain additional pesticides that are acutely toxic in an effort to reduce 

bees’ exposure. Since at least 2009, EPA has encouraged beekeepers 

and others to report bee kill incidents potentially associated with 

pesticides, but agency officials and others point to challenges to accurate 

reporting and data collection on these incidents. EPA has also 

encouraged state and tribal governments to voluntarily develop plans to 

work with farmers and beekeepers to protect bees from pesticides. EPA 

has revised its guidance for assessing the risks new and existing 

pesticides pose to bees, but there are limitations to the approach, 

including a lack of data on pesticides’ risks to nonhoney bees and risks 

that pesticide mixtures pose to bees. Changes to EPA’s risk assessment 

approach will likely extend its schedules for reviewing the registrations of 

some existing pesticides—including many that are known to be toxic to 

bees—as the agency gathers and reviews additional data on risks to 

bees. However, EPA has not revised the publicly available work 

schedules for pesticides currently under review.

EPA Has Taken Some 

Steps to Address 

Pesticide Threats to 

Bees, but Potential 

Threats Remain
Page 33 GAO-16-220 Protecting Bee Health

In August 2013, EPA directed the registrants of four pesticides in a class 

of chemicals known as neonicotinoids to submit an amendment to revise 

the labels of products containing those pesticides that were registered for 

outdoor use on plant foliage.62 Neonicotinoids are insecticides that affect 

the central nervous system of insects, causing paralysis and death. 

Pesticide labels contain directions for use and warnings designed to 

reduce exposure to the pesticide for people and nontarget organisms, 

including beneficial insects such as bees. It is unlawful to use any 

pesticide in a manner inconsistent with its labeling. In proposing the label 

changes, EPA cited the possible connection between acute exposure to 

particular pesticides and bee deaths. EPA called for the labels to have a 

pollinator protection box (also called a “bee advisory box”) and new 

language outlining the directions for the products’ use, in addition to any 

restrictive language that may already be on the product labels. The 

agency directed the registrants to submit revisions to their product labels 

with EPA’s prescribed language no later than September 30, 2013, and 

told the registrants that it anticipated that the new product labels would be 

in place in 2014.63

The new language for the pollinator protection box warns of the threat the 

pesticide poses to bees and other pollinators and instructs the user to 

follow the new directions for use. The directions for use restrict the use of 

the pesticide on crops and other plants at times when bees are foraging 

on those plants. More specifically, the directions generally prohibit foliar 

use, or use on leaves, until flowering is complete, and all petals have 

fallen from the plants. However, the new directions for use allow for 

exceptions to the prohibition under certain conditions, which vary, 

 

62A registrant is the company or individual holding a registration for a pesticide. The four 

registered nitroguanidine neonicotinoid pesticide active ingredients are clothianidin, 

dinetofuran, imidacloprid, and thiamethoxam. Another registered neonicotinoid pesticide—

acetamiprid—was not covered by EPA’s label changes. The registrant for an additional 

neonicotinoid—thiacloprid—voluntarily requested that its registration be canceled. EPA 

granted the request in August 2014 and allowed the registrant to sell and distribute 

existing stocks of products through February 8, 2016. According to EPA officials, 

acetamiprid and thiacloprid are considerably less toxic to bees than the other four 

neonicotinoid pesticides because they are readily metabolized, or chemically transformed, 

by bees.

63According to an EPA official in July 2015, while most of the subject products had been 

revised to include the new restrictions, some companies chose to delete the outdoor foliar 

use pattern, and a few chose to cancel their products.

EPA Revised the Label 

Requirements for Certain 

Pesticides and Has 

Proposed Revisions to 

Label Requirements for 

Additional Pesticides 

Known to Be Acutely Toxic
Page 34 GAO-16-220 Protecting Bee Health

depending on whether or not managed bees are on-site to provide 

contract pollination services.64

In November 2014, EPA staff told us the label changes to the four 

neonicotinoids had led to confusion for pesticide users and resentment by 

some stakeholder groups, but that the agency planned to address these 

concerns through additional label changes for those and other pesticides 

that are acutely toxic to bees. In particular, according to EPA officials, 

pesticide users found that new label language, in some instances, 

contradicted other parts of the label or was poorly defined. In May 2015, 

EPA requested public comments on a proposal to make label changes 

restricting the use of some products containing acutely toxic pesticides65

on pollinator-attractive crops when managed bees are present for the 

purpose of providing pollination services, saying that “clearer and more 

consistent mandatory label restrictions could reduce the potential 

exposure to bees from pesticides categorized as acutely toxic to bees.”66

The deadline for public comments on EPA’s proposal was June 29, 2015. 

Subsequently, that deadline was extended to August 28, 2015. According 

to EPA officials, as of October 2015, the agency was in the process of 

reviewing more than 100,000 comments on the label proposal; in part due 

 

64Under the contract pollination scenario, if an application must be made when managed 

bees are at the treatment site, the beekeeper providing the pollination services must be 

notified no less than 48 hours prior to the time of the planned application, so that the bees 

can be removed, covered, or otherwise protected prior to spraying. Under the scenario for 

food crops and ornamental plants not under contract for pollination services, the 

pesticides may be applied if one of several conditions is met, including (1) the application 

is made to the target site after sunset or (2) the application is made to the target site when 

temperatures are below 55 ̊F. (Bees are less active after sunset and when temperatures 

cool and are thereby less likely to be exposed.)

65EPA has classified as acutely toxic those pesticides with an acutely lethal dose to 50 

percent of the bees tested (abbreviated LD50) of less than 11 micrograms per bee.

66EPA’s proposed label language for the acutely toxic pesticides would read: “For Foliar 

Applications of this Product to Sites with Bees On-Site for Commercial Pollination 

Services: Foliar application of this product is prohibited from onset of flowering until 

flowering is complete when bees are on-site under contract, unless the application is 

made in association with a government-declared public health response. If site-specific 

pollinator protection/pre-bloom restrictions exist, then those restrictions must also be 

followed.” EPA’s proposal does not apply to pesticides used in seed treatments. The 

agency noted that “systemic pesticides that have prolonged residual toxicity may not be 

adequately addressed by the proposed mitigation discussed in this proposal.” EPA said 

that it would continue to use its registration and registration review programs to assess the 

risks of individual chemicals, including those used in seed treatments. 
Page 35 GAO-16-220 Protecting Bee Health

to the number of comments, the officials said they could not estimate 

when the agency will finalize the proposal.

Since at least 2009, EPA has encouraged beekeepers and others to 

voluntarily report bee kill incidents—that is, when bees in or near a hive 

are killed by a suspected exposure to a pesticide, according to agency 

officials. EPA records reports of bee kills that may have been associated 

with pesticide use in its Ecological Incident Information System (EIIS) 

database on adverse pesticide incidents. When EPA receives reports of 

bee kill incidents, according to agency officials, it considers a range of 

evidence to evaluate the probability that a specific pesticide was the 

cause. The evidence could include information about pesticide use near 

the incident, the known toxicity of the pesticides used in the area, and 

physical or observational evidence associated with the affected bees. 

After considering the evidence, EPA categorizes the likelihood that a 

specific pesticide was associated with the bee kill as highly probable, 

probable, possible, unlikely, or unrelated.67 In total, the EIIS data include 

306 unique bee kill incidents occurring from 1974 through 2014 and 

another 90 incidents with no associated year.68 Of this total of 396 

incidents, EPA found sufficient evidence to categorize 201 as highly 

probable or probable. The 201 incidents were associated with 42 

pesticides. (The EIIS data show that 3 bee kill incidents were highly 

probable or probable but name no specific pesticide.)

According to agency officials, EPA encourages the public to report 

incidents to their state lead agency (typically the state’s department of 

agriculture) so that such incidents can be properly investigated.

Recognizing that some members of the public may not feel comfortable 

 

67EPA’s user’s manual for the EIIS database contains definitions for each category. They 

are: Highly probable: pesticide was confirmed as the cause through residue analysis or 

other reliable evidence, or the circumstances of the incident along with knowledge of the 

pesticide’s toxicity or history of previous incidents give strong support that this pesticide 

was the cause. Probable: circumstances of the incident and properties of the pesticide 

indicate that this pesticide was the cause, but confirming evidence is lacking. Possible: 

The pesticide possibly could have caused the incident, but there are possible explanations 

that are at least as plausible. Often used when organisms were exposed to more than one 

pesticide. Unlikely: Evidence exists that a stressor other than exposure to this pesticide 

caused the incident, but that evidence is not conclusive. Unrelated: Conclusive evidence 

exists that a stressor other than exposure to the given pesticide caused the incident.

68According to an EPA document, the baseline year for the EIIS database is “about 1970.” 

EPA Has Encouraged 

Beekeepers and Others to 

Report Bee Kill Incidents 

Potentially Associated with 

Pesticides
Page 36 GAO-16-220 Protecting Bee Health

with reporting to their state officials, EPA’s website and the “bee advisory 

boxes” added to certain pesticide labels identify additional options for the 

public to voluntarily report bee kill incidents. These include reporting 

through beekill@epa.gov, an e-mail address monitored by EPA’s Office of 

Pesticide Programs or to report incidents to the National Pesticide 

Information Center.69 In addition, EPA enters into cooperative agreements 

with states. Through these agreements, EPA may delegate certain 

authority to states to cooperate in enforcing FIFRA. One condition of the 

cooperative agreement is that states must report information on all known 

or suspected pesticide incidents involving pollinators to beekill@epa.gov

and send a copy to the relevant EPA regional office. EPA stores data on 

incident reports from the public, the National Pesticide Information 

Center, and the states in its EIIS database.

Several factors may contribute to underreporting of bee kill incidents, 

according to EPA staff and others we interviewed. According to officials 

from EPA and beekeeping and environmental organizations, beekeepers 

may be reluctant to report bee kills to state agencies or to EPA for one or 

more of three reasons. First, beekeepers may want to avoid conflicts with 

farmers with whom they have an arrangement for providing pollination 

services or for obtaining access to forage for honey production, even if 

the farmer’s pesticide application practices may have contributed to the 

incident. Second, beekeepers may want to avoid investigations that may 

suggest the beekeeper’s hive management practices—specifically, the 

use of miticides or other pesticides to combat hive pests—contributed to 

the incident. Third, according to a senior EPA official in the Office of 

Pesticide Programs, some beekeepers believe that submitting reports in 

the past has not resulted in a positive response from regulatory 

authorities and, therefore, is not worth the effort.

According to the senior EPA official, other challenges exist that may make 

bee kill incident reports inaccurate. For example, beekeepers may not be 

able to frequently monitor their colonies, so incidents may not be 

discovered for several days; the passage of time may hamper a 

conclusive investigation. Honey bees forage over an extensive range. 

Therefore, it may be difficult to determine to which crops and pesticides 

 

69According to its website, the National Pesticide Information Center provides objective, 

science-based information about pesticides and pesticide-related topics to enable people 

to make informed decisions about pesticides and their use. The center is funded by a 

cooperative agreement between Oregon State University and EPA.
Page 37 GAO-16-220 Protecting Bee Health

they have been exposed. Finally, according to the EPA official, the states 

have increasingly limited budgets to support bee colony inspection 

programs and pesticide incident inspection programs in general, and may 

not be able to fully investigate reported incidents.

In addition to the voluntary incident reports from beekeepers and others, 

FIFRA requires that pesticide registrants report factual information they 

are aware of concerning adverse effects associated with their products—

including the death of nontarget organisms such as bees.70 The 

information reported by a registrant is known as a FIFRA 6(a)(2) Incident 

Report. However, according to EPA staff, FIFRA 6(a)(2) reports are not 

particularly useful in providing details on bee kills because FIFRA and its 

implementing regulations do not require registrants to identify bees as the 

species harmed by a pesticide. Instead, bees are recorded within a larger 

category of “other nontarget” organisms. In addition, registrants do not 

need to report individual incidents involving “other nontarget” organisms 

when they occur. Instead, registrants can “aggregate” incidents that occur 

over a 90-day period and report those aggregated data to EPA 60 days 

after the end of the 90-day period. While these FIFRA reporting 

requirements apply generally to pesticide registrants, as we noted earlier, 

EPA modified its requirements for the registrants of four neonicotinoid 

pesticides. In its July 22, 2013, letter notifying the registrants of its plans 

to modify the pesticides’ labels to be more protective of bees, EPA also 

instructed the registrants to report bee kill incidents within 10 days of 

learning of the incident and that information on bee kills must not be 

aggregated, regardless of the number of individual pollinators involved in 

any incident.

 

70FIFRA Section 6(a)(2) states that “If at any time after the registration of a pesticide the 

registrant has additional factual information regarding unreasonable adverse effects on 

the environment of the pesticide, the registrant shall submit such information to the 

Administrator.” EPA’s regulations implementing section 6(a)(2) expressly require pesticide 

registrants to report adverse events that involve damage to nontarget organisms in 

addition to fish, wildlife, and plants. Nontarget organisms could include beneficial insects, 

which could include bees. EPA’s implementing regulations can be found in title 40 of the 

U.S. Federal Code of Regulations at part 159.
Page 38 GAO-16-220 Protecting Bee Health

In response to a directive from the June 2014 presidential memorandum 

on pollinators, EPA has encouraged state and tribal environmental, 

agricultural, and wildlife agencies to voluntarily develop managed 

pollinator protection plans (protection plans) that focus on improved 

communication between farmers and beekeepers regarding the use of 

pesticides and the proximity of managed bees. EPA is working with two 

organizations to encourage states and tribes to implement the protection 

plans: (1) the State-FIFRA Issues, Research, and Evaluation Group 

(SFIREG)71 and (2) the Tribal Pesticide Program Council.72 In December 

2014, SFIREG issued draft guidance for state lead agencies for the 

development and implementation of state protection plans. According to 

the guidance, the scope of the plans is limited to managed bees not 

providing contracted pollination services at the site of application. As 

such, the protection plans are intended to reduce pesticide exposure to 

bees that are adjacent to, or near a pesticide treatment site where bees 

can be exposed via drift or by flying to and foraging in the site of 

application. According to SFIREG’s draft guidance, many of the strategies 

to mitigate the risk of pesticide exposure to managed pollinators are also 

expected to reduce the risk to native bees and other pollinators. The 

voluntary protection plans would supplement EPA’s proposal to make 

label changes restricting the use of acutely toxic pesticides, described 

above, to protect managed bees that are under pollination contracts 

between farmers and beekeepers. According to the task force’s strategy, 

one of the key elements of the state protection plans are the metrics that 

will be used to measure their effectiveness in reducing honey bee losses. 

Those metrics, according to the strategy, may differ across states and 

tribes.

Because the development of the protection plans is voluntary, EPA will 

not approve or disapprove them, and measures of the plans’ 

effectiveness will be state- or tribe-specific, according to agency officials. 

According to EPA officials, as of January 2016, seven states had 

protection plans in place: Arkansas, California, Colorado, Florida, Iowa, 

Mississippi, and North Dakota, while all but a few of the other states had 

 

71The State-FIFRA Issues Research and Evaluation Group is a network of state officials 

interested in federal/state “co-regulation” of pesticides under FIFRA. It was established by 

the Association of American Pesticide Control Officials with financial support from EPA. 

72The council is a network of tribal representatives and intertribal consortia that serve as a 

tribal technical resource, program development and policy dialogue group focused on 

pesticide issues and concerns.

EPA Has Encouraged 

State and Tribal 

Governments to 

Voluntarily Develop Plans 

to Protect Managed Bees 

from Pesticides
Page 39 GAO-16-220 Protecting Bee Health

protection plans in some stage of development. In addition, EPA provided 

funding for a November 2015 training program to address tribal pollinator 

protection plans. Stakeholders we interviewed who commented on this 

topic generally supported EPA’s efforts to encourage pollinator protection 

plans. Stakeholders’ views on protection plans are summarized in 

appendix II.

In June 2014, EPA issued guidance advising the agency’s staff to 

consider requiring pesticide registrants to conduct additional studies on 

the risks that new or existing pesticides may pose to bees and bee 

colonies for pesticides going through the registration or registration review 

processes.73 The 2014 guidance formalized interim guidance issued in 

2011.74 EPA summarized the need for the risk assessment guidance in a 

2012 White Paper to the FIFRA Scientific Advisory Panel that noted that 

the lack of a clear, comprehensive and quantitative process for evaluating 

pesticide exposure and subsequent risk to bees from different routes of 

exposure was a major limitation.75 The guidance may result in registrants 

conducting additional studies on the toxicity of new and existing 

pesticides on honey bees. It also allows for several methods of 

characterizing pesticide risk. However, EPA’s 2014 risk assessment 

guidance relies largely on honey bees as a surrogate for other bee

species. In addition, the guidance does not call for EPA to assess the 

risks that pesticide mixtures may pose to bees.

 

73Guidance for Assessing Pesticide Risks to Bees, co-authored by the Office of Pesticide 

Programs, United States Environmental Protection Agency, Washington, D.C.; the Health 

Canada Pest Management Regulatory Agency, Ottawa, ON, Canada; and the California 

Department of Pesticide Regulation, Sacramento, CA, June 19, 2014. 

74The Director of EPA’s Environmental Fate and Effects Division issued a memorandum 

to staff titled Interim Guidance on Honey Bee Data Requirements in October 2011. 

According to EPA officials, the agency used the interim guidance until it issued the final 

guidance in June 2014. 

75Environmental Protection Agency, Health Canada Pest Management Regulatory 

Agency, and California Department of Pesticide Regulation, White Paper in Support of the 

Proposed Risk Assessment Process for Bees: Submitted to the FIFRA Scientific Advisory 

Panel for Review and Comment, September 2012. The FIFRA Scientific Advisory Panel is 

composed of biologists, statisticians, toxicologists, and other experts who provide 

independent scientific advice to EPA on a wide range of health and safety issues related 

to pesticides. 

EPA Has Revised Its 

Guidance for Assessing 

Risks to Bees Posed by 

New and Existing 

Pesticides, but Limitations 

Remain
Page 40 GAO-16-220 Protecting Bee Health

EPA’s June 2014 guidance calls for agency staff to consider requiring 

pesticide applicants or registrants to conduct additional studies on the 

toxicity of their pesticides to honey bees. The guidance applies to EPA’s 

review of new pesticide registration applications and its ongoing review of 

existing registrations. EPA has used, and continues to use, a three-tiered 

approach for assessing the risks that pesticides may pose to bees (and 

other organisms). That is, the agency may require additional studies—in 

Tiers II and III—from pesticide applicants or registrants, depending on the 

results of any Tier I studies that it required. Therefore, under the June 

2014 guidance, EPA staff are to consider a range of studies that examine 

different life stages of honey bees (adult and larval), different types of 

toxicity (acute and chronic), and different types of exposure to pesticides 

(contact and oral). Studies may be conducted in laboratories on individual 

bees (Tier I), as “semi-field” tests of small colonies (Tier II), or as field 

tests of whole colonies (Tier III). EPA may also consider other lines of 

evidence, including open scientific literature and incident reports.

Another aspect of assessing the risk of pesticides is deciding which 

chemicals within a pesticide product are to be studied. EPA’s June 2014 

guidance addresses this issue but leaves it to the discretion of agency 

staff. Specifically, EPA’s June 2014 guidance states that toxicity data 

using the end-use product may be needed if data suggest that a typical 

end-use product is potentially more toxic than the active ingredient, and 

bees may come directly in contact with the product.76 The guidance also 

calls for agency staff to consider the effects that systemic pesticides 

applied to seeds or in the soil may have on honey bees. Systemic 

pesticides applied to plants and soil can move through the plant to other 

plant tissues, potentially contributing to quantities of pesticide residues in 

pollen and nectar.

EPA regulations identify three honey bee studies as required, or 

conditionally required, and EPA’s 2014 guidance suggests additional bee 

toxicity studies that agency staff might consider requiring. EPA staff we 

interviewed acknowledged that additional steps are needed to establish 

 

76The end-use product may comprise the active ingredient and “inert ingredients” that help 

make the active ingredient more effective. The active ingredient is the chemical or 

substance component of a pesticide product that can kill, repel, attract, mitigate, or control 

a pest or that acts as a plant growth regulator, desiccant, or nitrogen stabilizer. Some inert 

ingredients are also toxic to organisms. Therefore, the toxicity of the end-use product may 

be greater than the active ingredient alone. 

EPA’s Risk Assessment 

Guidance Potentially Calls for 

More Study of the Effects of 

New and Existing Pesticides 

on Honey Bees
Page 41 GAO-16-220 Protecting Bee Health

study guidelines, but said that the agency has the authority under FIFRA 

to require and review any studies that it deems necessary to determine 

whether a pesticide will have unreasonable adverse effects. In addition, 

as of October 2015, EPA had not yet issued guidelines for the new types 

of studies that registrants may be required to submit. However, in July 

2015, EPA announced on its website that it was considering a proposal 

within 12 months that would update and codify the data requirements 

needed to characterize the potential risks of pesticides to bees and other 

pollinators. In the meantime, registrants may conduct three of the 

additional studies—acute adult oral toxicity, acute larval toxicity, and 

semi-field testing with whole colonies—using guidelines developed by the 

Organization for Economic Cooperation and Development (OECD).77

EPA officials told us that, as of October 2015, formal guidelines did not 

exist for chronic toxicity testing with adult bees and chronic toxicity testing 

with bee larvae but said that EPA is contributing to international efforts to 

develop formal guidelines, including draft guidelines on chronic toxicity 

with bee larvae. In addition, the task force’s strategy stated that 

standardized guidelines may not be developed for field studies (Tier III) 

because “these studies are intended to address specific uncertainties 

identified in lower tier tests.” Instead, according to agency officials, EPA 

will have to agree on specific Tier III protocols proposed by the pesticide 

applicant or registrant for particular pesticides.78

EPA’s June 2014 risk assessment guidance for honey bees allows the 

agency to use tiered studies in reviewing registration applications for new 

pesticides and new uses for existing pesticides. EPA’s review of 

registration applications for four pesticides—cyantraniliprole, oxalic acid, 

sulfoxaflor, and tolfenpyrad—provides examples of how the agency’s use 

of its 2011 interim and 2014 final guidance and its call for bee-related 

studies can vary. Because EPA’s risk assessment approach for this 

guidance is a tiered one, the agency staff uses its discretion when 

requiring registrants to conduct toxicity studies. For example, EPA 

 

77The mission of the OECD is to promote policies that will improve the economic and 

social well-being of people around the world. The OECD provides a forum in which 

governments can work together to share experiences and seek solutions to common 

problems. 

78In this context, according to EPA officials, a protocol is a test method developed by a 

pesticide applicant or registrant. The protocol should follow guidelines from EPA or the 

OECD if guidelines are available. If guidelines are not available, EPA would review the 

protocol to determine whether it meets the agency’s needs. 

EPA’s Risk Assessment 

Guidance Allows for Tiered 

Studies in Making Registration 

Decisions for New Pesticides 

and New Uses for Existing 

Pesticides
Page 42 GAO-16-220 Protecting Bee Health

approved oxalic acid for a new use as a miticide to combat Varroa mites 

in bee hives without requiring its own Tier II or Tier III studies. According 

to EPA staff, the agency relied on existing data from Canada that shows 

the pesticide has low acute toxicity and is effective at killing Varroa mites 

without harming bee colonies. For the other three pesticides, which were 

registered before the 2014 final guidance was issued, EPA reviewed 

varying numbers and types of studies but did not require all of the types 

of studies described in the new risk assessment guidance. However, EPA 

decided, on the basis of the studies that were done, to place restrictions 

on the pesticides’ use in order to reduce bees’ exposure. For example, 

EPA did not require Tier III studies for sulfoxaflor but used the results of 

Tier I and Tier II studies as the basis for reducing the amount of the 

insecticide that was allowed to be applied per acre under the pesticide’s 

2013 registration.79 In addition, cyantraniliprole and tolfenpyrad are 

among the acutely toxic pesticides covered by EPA’s May 2015 proposal 

to make label changes restricting the use of acutely toxic pesticides.

A finding from study results that a pesticide is toxic to bees (or other 

organisms) does not necessarily mean that EPA will disapprove an 

application for registration. Under FIFRA, throughout the tiered process, 

EPA considers whether mitigation measures (e.g., changes to application 

rates, the timing of applications, or the number of applications) are 

sufficient to reduce exposure to a level at which risk estimates are below 

levels for concern, while also taking the benefits from using the pesticide 

into consideration.

While EPA’s June 2014 pesticide risk assessment approach provides for 

the inclusion of data on additional bee species where available, it relies 

primarily upon data from honey bees as a surrogate for all bee species.

However, other bee species may be affected differently by pesticides. 

EPA acknowledges in its guidance that there are limitations to using 

honey bees as surrogates but maintains that honey bees can provide 

information relevant to other species, and that adequate, standardized 

 

79In 2013, commercial beekeeping organizations filed a lawsuit against EPA concerning 

the agency’s decision to register sulfoxaflor. In September 2015, the United States Court 

of Appeals for the Ninth Circuit vacated EPA’s unconditional registration of sulfoxaflor and 

remanded for EPA to obtain further studies and data regarding the effects of sulfoxaflor on 

bees. On November 12, 2015, EPA issued a cancellation order for all previously 

registered sulfoxaflor products. In comments on a draft of this report, EPA said that the 

registrant is conducting additional studies to address uncertainties regarding the effects of 

sulfoxaflor on bees. 

EPA’s 2014 Risk Assessment 

Guidance Relies Largely on 

Honey Bees as a Surrogate for 

Other Bee Species
Page 43 GAO-16-220 Protecting Bee Health

tests are not yet available for other species. EPA is involved in 

international efforts to develop standardized tests for other bee species 

and has been directed by the task force’s strategy with researching risk 

assessment tools for nonhoney bee species. However, EPA does not 

have a schedule for expanding the risk assessment process to other bee 

species. Stakeholders we interviewed from farming, commercial 

beekeeping, university, and conservation/environmental groups said EPA 

should expand its risk assessment process to include testing the effects 

of pesticides on pollinators other than the honey bee, including other 

commercial, or managed, and wild, native bees. Several of these 

stakeholders specified that EPA should develop testing models and 

guidelines for other types of bees, such as solitary and bumble bees.

EPA’s September 2012 White Paper attributed the agency’s focus on 

honey bees to two factors: (1) honey bees are considered the most 

important pollinator in North America from a commercial and ecological 

perspective and (2) standardized tests on the effects of chemicals are 

more developed for honey bees than for other managed bee species, 

such as the alfalfa leafcutting and orchard mason bees. However, the 

White Paper also noted that there are an estimated 4,000 species of wild, 

native bees in North America and more than 20,000 worldwide. These 

wild, native bees also provide important pollination services. Other 

managed and wild, native bee species may be exposed to pesticides 

through different routes, at different rates, or for different durations than 

honey bees, all of which may influence the effects of pesticides. The 

White Paper concluded that there was a clear need for a process to 

assess risks to species other than honey bees, owing to potential 

differences in sensitivity and exposure compared to honey bees. While 

noting the importance of assessing risks to diverse bee species, the 

White Paper also cited a 2012 European Food Safety Authority 

conclusion that published laboratory, semi-field, and open field test 

methods for other species (i.e., bumble bees, orchard mason bees,

leafcutting bees, and alkali bees) needed further development.80

In its December 2012 review of EPA’s White Paper, the FIFRA Scientific 

Advisory Panel recommended that EPA require testing on at least one 

 

80EFSA Panel on Plant Protection Products and their Residues (PPR), Scientific Opinion 

on the Science Behind the Development of a Risk Assessment of Plant Protection 

Products on Bees (Apis mellifera, Bombus spp. and Solitary Bees). May 2012.
Page 44 GAO-16-220 Protecting Bee Health

additional species to address the goal of protecting diversity.81 The FIFRA 

panel stated that alfalfa leafcutting bee and orchard mason bees are the 

easiest to include for Tier I testing, adding that these bees are 

commercially available in large numbers and would be fairly easy to use 

for higher-tiered tests. In addition, the panel noted that bumble bees are 

also available commercially, and considerable research is available on 

how to raise them, so they would be useful for Tier II tests, although with 

limitations. EPA’s June 2014 risk assessment guidance stated that, as the 

science evolves, methods and studies using other bee species may be 

considered and incorporated into risk assessments.

The task force’s strategy stated that uncertainty is created by relying on 

honey bees as a surrogate and stated the agency was working with 

regulatory counterparts through the OECD to ensure the development of 

standardized testing methods to address this uncertainty. In that regard, 

the task force’s research action plan directs EPA to develop appropriate 

assessment tools for sublethal effects of pesticides, adjuvants,82 and 

combinations of pesticides on the fitness, development, and survival of 

managed and wild pollinators (i.e., honey bees and other bees). The task 

force’s strategy states that a metric for progress in meeting the strategy’s 

directives will be the extent to which standardized guidelines are 

developed and implemented for evaluating potential risks to bees other 

than honey bees. According to the strategy, these studies will be critical 

for determining the extent to which honey bees serve as reasonable 

surrogates for other species of bees. However, the strategy and the 

research action plan do not identify how or when EPA is to ensure that 

adequate test protocols are incorporated into the risk assessment 

process. According to EPA officials, it would not be reasonable for the 

strategy to dictate a timeline or for EPA to commit to one given the 

absence of appropriations to support the development of test guidelines. 

Instead, these officials said that EPA is working with the OECD and other 

international bodies to develop test guidelines for other species of bees. 

 

81FIFRA Scientific Advisory Panel, A Set of Scientific Issues Being Considered by the 

Environmental Protection Agency Regarding Pollinator Risk Assessment Framework 

September 11–14, 2012.

82An adjuvant is generally broadly defined as any substance separately added to a 

pesticide product (typically as part of a spray tank mixture) that will improve the 

performance of the pesticide product. Since pesticide adjuvant products don’t make 

pesticidal claims, they are not pesticides, and the components of adjuvants are, therefore, 

not pesticide inert ingredients.
Page 45 GAO-16-220 Protecting Bee Health

According to OECD documents, progress has been made in developing 

guidelines to assess the acute contact and oral toxicity of pesticides to 

individual bumble bees. The documents state that the results of validation 

testing for the guidelines (known as ring tests) are expected to be 

reported by late 2015 or early 2016. However, it is not clear when EPA 

could incorporate them into its risk assessment process, and guidelines 

for other bee species would take additional time to develop. Regardless, 

EPA has the authority under FIFRA to require pesticide registrants to 

submit data on the toxicity of pesticides on other bee species using 

methods that meet the agency’s approval. By developing a plan for 

obtaining data from pesticide registrants on the effects of pesticides on 

nonhoney bee species, including other managed or wild, native bees, into 

its risk assessment process, EPA could increase its confidence that it is 

reducing the risk of unreasonable harm to these important pollinators, 

consistent with the task force’s strategy and research action plan.

EPA’s June 2014 risk assessment guidance calls for the agency to 

assess the risks that individual pesticides may pose to bees but not for 

the assessment of the risks from combinations of pesticide products or 

combinations of pesticide products with other chemicals. Farmers 

sometimes mix pesticide products for a single application to reduce the 

number of times they have to spray their fields. These combinations of 

pesticide products are known as tank mixtures. Beekeepers have raised 

concern that these mixtures of pesticide products may have synergistic 

effects on bees, meaning that the effect of the combination is greater than 

the sum of the effects of the individual pesticides. The Pollinator 

Stewardship Council reported on its website in 2014 that beekeepers 

attributed bee kill incidents to pesticides that acted in combination with 

each other to increase their collective toxicity. In addition, farmers may 

mix pesticide products with adjuvants, or chemicals to enhance the 

pesticides’ effectiveness. University researchers have also reported that 

combining certain pesticide products with other products can 

synergistically increase the overall toxicity to bees.83 Stakeholders we 

interviewed from commercial bee groups, universities, and conservation/ 

environmental groups suggested that EPA require companies to conduct 

 

83See RM Johnson, L Dahlgren , BD Siegfried, and MD Ellis (2013) Acaricide, Fungicide 

and Drug Interactions in Honey Bees (Apis mellifera). PLoS ONE 8(1): 

e54092.doi:10.1371/journal.pone.0054092; F Sanchez-Bayo, K Goka (2014) Pesticide 

Residues and Bees – A Risk Assessment. PLoS ONE 9(4): e94482. 

doi:10.1371/journal.pone.0094482. 

EPA’s June 2014 Guidance 

Does Not Call for the Agency 

to Assess the Risks That 

Pesticide Mixtures May Pose 

to Bees
Page 46 GAO-16-220 Protecting Bee Health

toxicity studies on pesticide tank mixtures as part of its risk assessment 

process. According to agency officials, EPA has taken some steps to 

expand the scope of its risk assessment to include mixtures of pesticides, 

but challenges remain, as discussed below.

EPA registers an individual pesticide after assessing the risks the 

pesticide poses to human health or the environment when used according 

to its directions for use.84 EPA also assesses the risks posed by 

combinations of pesticides that the applicant intends to be used as a 

registered combination.85 Otherwise, EPA does not assess the risks of 

tank mixtures of pesticides or combinations of pesticides and other 

chemicals such as adjuvants that farmers or others may use. According 

to EPA officials, the use restrictions that apply to tank mixtures of 

pesticides are, instead, based on the most restrictive elements of the 

individual pesticides’ labels.

In EPA’s September 2012 White Paper, the agency stated that “with 

respect to mixtures, while multiple stressors and the interactive effects of 

pesticides and/or other environmental stressors are important issues, 

they will not be examined at this time.” However, the task force’s strategy 

recognized the risks that pesticide mixtures may pose and called for EPA 

to develop appropriate tools to assess the sublethal effects of pesticides, 

adjuvants, and combinations of pesticides with other products on the 

fitness, development, and survival of managed and wild pollinators.

Senior EPA officials told us in October 2015 that they agreed that tank 

mixtures of registered pesticides pose potential risks to bees. However, 

they said that there was no reliable process for assessing mixtures and 

that, given the number of possible permutations that may occur in tank 

mixing, it was difficult to imagine how EPA could reasonably commit to 

such an effort. EPA officials also said that the use of tank mixes may 

change over time and by location as farmers respond to different pest 

outbreaks, and that the agency does not know how it would identify 

commonly used mixtures. However, according to stakeholders we 

interviewed, sources for data on commonly used or recommended 

 

84A registrant may use a registered pesticide in multiple products. Each product would 

have its own label with specific use restrictions. 

85Pesticide registrants may also get approval for label language stating that a pesticide 

should not be mixed with another pesticide.
Page 47 GAO-16-220 Protecting Bee Health

mixtures are available. These sources include the California Department 

of Pesticide Regulation—which has an extensive data base on pesticide 

use—the pesticide industry, farmers, pesticide application companies, 

and extension agents.

At the same time, EPA officials noted that the agency is working with the 

Fish and Wildlife Service and the National Marine Fisheries Service on 

assessing the risks of pesticides to threatened and endangered species 

such as salmon, including the risk posed by mixtures of pesticides. They 

said the agencies’ effort could eventually be relevant to EPA’s guidance 

for assessing pesticide risks to bees.86 EPA and the other agencies 

subsequently developed joint interim scientific approaches for assessing 

the risks of pesticides to threatened and endangered species.87 With 

respect to pesticide mixtures, the agencies’ document on interim 

approaches stated that risks associated with pesticide mixtures will 

largely be considered qualitatively rather than quantitatively. A related 

agency document states that long-term future work includes establishing 

a quantitative approach for assessing risks of mixtures but provides no 

time frames for doing so.88 We acknowledge that EPA’s work with other 

agencies on pesticide risks to threatened and endangered species may 

eventually contribute to its risk assessments for bees, but the effects of 

that work remain to be seen. By identifying the pesticide mixtures that 

farmers and pesticide applicators most commonly use on agricultural

crops, EPA would have greater assurance that it could assess those 

mixtures to determine whether they pose greater risks than the sum of the 

risks posed by the individual pesticides.

 

86To assist their effort to address threatened and endangered species, the agencies 

requested advice from a National Research Council committee of experts. In an April 2013 

report (National Research Council, Assessing Risks to Endangered and Threatened 

Species from Pesticides, April 2013), the committee noted the complexity of assessing the 

risks of pesticide mixtures but concluded that quantitative assessment of chemical joint 

action is warranted if adequate data are available on the exposures to and toxicities of the 

chemicals. The committee also said that challenges in assessing risks from mixtures 

include the lack of exposure data and an understanding of the potential for interactions 

among mixture components. 

87Interim Approaches for National-Level Pesticide Endangered Species Act Assessments 

Based on the Recommendations of the National Academy of Sciences April 2013 Report. 

88Interagency Approach for Implementation of National Academy of Sciences Report: 

Assessing Risks to Endangered and Threatened Species from Pesticides, Powerpoint 

slides dated November 15, 2013.
Page 48 GAO-16-220 Protecting Bee Health

According to senior EPA officials, if the agency has information about 

certain combinations being used regularly, it could require that pesticide 

registrants provide testing data on those combinations. If an assessment 

of commonly-used pesticide mixtures found synergistic effects on bees, 

FIFRA authorizes EPA to take regulatory actions to reduce risks, such as 

requiring label language warning of those effects.

Amendments to FIFRA require that EPA complete its reviews of all 

pesticide active ingredients registered as of October 1, 2007, by October 

2022. Applying EPA’s new risk assessment guidance to its review of 

registered pesticides will add time to the posted review schedules for 

some individual pesticides, and EPA has not revised these schedules.89

As discussed, EPA’s revised risk assessment guidance for bees calls for 

the agency to consider requiring registrants to conduct additional studies 

on their pesticide’s effect on bees. According to EPA documents and 

officials, the agency is now applying the new guidance to registered 

pesticides that are in the review process, as well as to new pesticides. 

Deciding what studies are needed, requesting the data from registrants, 

waiting for the studies to be conducted, and analyzing the study data will 

add time to EPA’s review of some pesticides’ risks to bees. The director 

of EPA’s Pesticide Re-Evaluation Division and other senior officials told 

us in April 2015, and confirmed in October 2015, that the agency was in 

the process of deciding what additional bee studies, if any, will be needed 

for specific individual pesticides. They could not estimate how long it will 

take to make those decisions but said a large number of pesticides for 

which EPA had begun a registration review prior to issuing its risk 

assessment guidance in June 2014 could require data on bees. The 

number of pesticides affected by the new risk assessment guidance is, 

therefore, likely to be substantial, according to EPA officials. In its annual 

PRIA implementation report, EPA reported to Congress in March 2015 

that by September 30, 2014, it had begun the review process for 528 

pesticide cases and prepared final work plans for 491 of those cases. The 

final work plans identify the studies the agency is requiring the registrant 

to conduct and show the agency’s estimated schedule for completing a 

registration review. Of the 491 cases with final work plans, EPA had 

issued registration review decisions for 105 cases by the end of fiscal 

 

89EPA maintains dockets on a federal website at www.Regulations.gov that contain 

information on the agency’s review of pesticide registrations. Included in the dockets are 

EPA’s work plans for completing the registration reviews.

Applying EPA’s New Risk 

Assessment Guidance Will 

Likely Extend the Agency’s 

Reviews of Registered 

Pesticides, and EPA Has 

Not Revised Review 

Schedules
Page 49 GAO-16-220 Protecting Bee Health

year 2014. According to EPA officials, as of September 30, 2015, the 

agency had increased the number of reviews begun to 612 pesticide 

cases, had prepared final work plans for 580 pesticides cases, and had 

issued 155 interim and final registration review decisions.90

According to the EPA division director, if EPA determines through 

registration review that additional data are necessary to make the 

necessary findings, the agency must obtain approval from the Office of 

Management and Budget (OMB) to request the data from registrants that 

use a particular active ingredient in their products. He added that, if EPA 

decides that registrants need to do additional studies on bees, it will need 

to obtain another approval from OMB for the new data. Once OMB 

approves the request, the required risk assessment studies on bees may 

take registrants from one to several years to conduct. The division 

director said that EPA was concerned that the number of pesticides 

needing new bee test data could overwhelm the supply of qualified testing 

laboratories, which could delay the start and completion of those studies.

In its written comments on a draft of this report, EPA said that it had more 

recently learned that laboratories are building capacity to conduct these 

studies. However, the conduct of honey bee studies is confined to a 

limited window within the year, typically from April through August. 

The final work plans for most of the pesticide cases for which EPA had 

begun registration review were developed and posted to the 

www.Regulations.gov website before EPA adopted its revised risk 

assessment guidance for bees in June 2014. According to EPA officials, 

those work plans may therefore not reflect the types of studies that are 

now called for by the new guidelines or the estimated schedules for 

completing the registration reviews. Work plans that EPA posted after the 

June 2014 risk assessment guidance, on the other hand, may better 

reflect the types of studies that are called for by the new guidance.

To examine the effect that EPA’s revised risk assessment guidance has 

had on its review of individual pesticide registrations, we selected eight 

 

90The agency may issue, when it determines it to be appropriate, an interim registration 

review decision before completing a registration review. Among other things, the interim 

registration review decision may require new risk mitigation measures, impose interim risk 

mitigation measures, identify data or information required to complete the review, and 

include schedules for submitting the required data, conducting the new risk assessment, 

and completing the registration review. 
Page 50 GAO-16-220 Protecting Bee Health

registered pesticides associated with bee kill incidents reported in EPA’s 

EIIS database.91 The work plans for these pesticides (amitraz, carbaryl, 

chlorpyrifos, coumaphos, malathion, and three neonicotinoid pesticides—

clothianidin, imidacloprid, and thiamethoxam)—could provide information 

on how EPA’s new risk assessment process will affect registration review, 

although we found the full effect is not yet clear. The director of the 

Pesticide Re-Evaluation Division explained that the work plans EPA has 

posted at www.Regulations.gov for amitraz, carbaryl, chlorpyrifos, 

coumaphos, and malathion are out of date because EPA has not yet 

decided what additional data on the effects of the pesticides on bees the 

agency will ask registrants to submit. However, EPA staff told us that the 

work plans for the three neonicotinoid pesticides—which predate the June 

2014 risk assessment guidance—more closely reflect the guidance and 

call for additional studies on bees.92 EPA staff said that they were aware 

of the need for more bee studies for those pesticides as the agency 

developed its 2014 guidance.

While the new guidance is likely to affect many pesticide reviews, EPA 

officials told us that the agency does not plan to revise the review 

schedules in work plans that have already been posted. The officials said 

that doing so would place a significant burden on agency staff and detract 

from their ability to conduct registration reviews. Instead, EPA officials 

said that the agency would annually announce for which pesticides it 

expected to have preliminary risk assessments available for public review 

in that year. In keeping with that plan, the May 2015 task force’s strategy 

included a list of 58 registration review preliminary risk assessments that 

EPA said would be open for public comments during 2015. Unlike the 

posted work plans for pesticides undergoing registration review, the 

 

91We selected the 10 pesticides shown by the EIIS data base to be associated with the 

largest number of bee kill incidents, weighted by EPA’s certainty index. However, 2 of the 

pesticides, parathion and methyl parathion, have been cancelled by their registrants, and, 

therefore, are no longer subject to EPA’s registration review process. See appendix I for 

more detail on our selection methodology.

92There are three other registered or formerly registered neonicotinoid pesticides that we 

did not examine in detail because, according to EPA’s EIIS database, they were not 

associated with a significant number of bee kill incidents. Two pesticides—dinotefuran and 

acetamiprid—are in the midst of registration review. According to EPA’s website, the

agency plans to issue a preliminary risk assessment and final risk assessment for 

dinotefuran in 2016 and 2017, respectively. Study data will be generated for acetamiprid 

through 2017, and EPA plans to complete the review process by 2019. The registration for 

the remaining neonicotinoid—thiacloprid—was voluntarily cancelled by the registrant, and 

EPA closed the registration review case in November 2014. 
Page 51 GAO-16-220 Protecting Bee Health

announcement in the strategy did not estimate when the reviews of the 58 

pesticides would be complete or identify what studies EPA has 

determined will be required. We understand that it may be challenging for 

agency staff to revise the review schedules in work plans that have 

already been posted. However, given that EPA is working to determine 

what studies will be required, it may soon be able to determine the 

studies it would require of registrants. By disclosing in its annual PRIA 

implementation reports which registration reviews have potentially 

inaccurate schedules and when it expected those reviews to be 

completed, EPA could provide Congress and the public with accurate 

information about the schedules for completing the registration reviews, 

thereby increasing understanding of EPA’s progress toward meeting the 

October 2022 deadline for completing all registration reviews.

As required by FIFRA as amended by PRIA and subsequent legislation, 

EPA’s PRIA implementation reports contain data on the number of cases 

opened and closed in a particular fiscal year and cumulatively since the 

start of registration review in 2007. EPA has reported on its website that it 

expects to open 70 or more new registration review dockets annually 

through fiscal year 2017. Although the reports do not estimate the number 

of reviews EPA expects to close each year as it moves toward the 2022 

deadline, the agency wrote in its fiscal year 2014 PRIA implementation 

report that it continued to open dockets for new registration review cases 

at the pace that must be maintained in order to finish reviews in 2022. 

EPA has estimated that the average time it will take to complete a 

registration review is about 6 years and that the agency has completed an 

average of less than 20 per year. However, the new risk assessment 

guidance for bees may increase the average time needed for reviews, 

raising questions about EPA’s ability to complete its registration reviews 

by 2022. EPA officials said that they are planning to assign additional 

agency staff to work on these registration reviews.

USDA and EPA have taken numerous actions to protect the health of 

honey bees and other species of bees, thereby supporting agriculture and 

the environment. Even with these efforts, honey beekeepers continue to 

report rates of colony losses that they say are not economically 

sustainable. Although data on the size of nonhoney bee populations 

(other managed bees and wild, native bees) are lacking, there is concern 

that these bee species also need additional protection. Finding solutions 

to address the wide range of factors that may affect bee health, including 

pests, disease, reduced habitat and forage, and pesticide exposure, will 

Conclusions
Page 52 GAO-16-220 Protecting Bee Health

be a complex undertaking that may take many years and require 

advances in science and changes in agricultural and land use practices. 

Monitoring honey bees and other bee species is critical to understanding 

their population status and threats to their health. The task force’s 

research action plan on bees and other pollinators identified monitoring of 

wild, native bees as a priority and directed agencies in USDA and the 

Department of the Interior to take leading and supporting roles. However, 

the research action plan did not establish a mechanism, such as a 

monitoring plan, that would establish participating agencies’ roles and 

responsibilities, establish common outcomes and goals, and obtain input 

from states and other stakeholders on native bees. By working with other 

key agency stakeholders, USDA can help agencies understand their 

respective roles, focus on the same goals and outcomes, and better 

solicit input from external stakeholders.

The task force’s strategy also includes a plan for extensive research on 

issues important to honey bees; other managed bees; wild, native bees; 

and other pollinators. USDA’s ARS and NIFA have funded and continue 

to fund research on these three categories of bees. While the ability to 

identify research projects by bee category is key to tracking projects 

conducted to implement the task force’s research action plan, USDA’s 

CRIS database does not currently reflect these categories. This limitation 

hinders users’ ability to search for or track completed and ongoing bee 

research. Updating the CRIS database to include the three bee 

categories would increase the accessibility and availability of information 

about USDA-funded research on all bees.

In addition, the task force’s strategy established a governmentwide goal 

of restoring and enhancing 7 million acres of habitat for bees and other 

pollinators. USDA’s NRCS and FSA are supporting efforts to improve 

habitat to help meet the strategy’s goal. It is not yet clear, however, how 

the agencies will determine which acres count toward this goal because 

USDA cannot currently track all acres on which conservation practices 

have restored or enhanced bee habitat as part of the effort to achieve the 

strategy’s goal. Without an improved method, USDA cannot accurately 

measure its contribution to the strategy’s goal. In addition, NRCS, which 

provides technical assistance to landowners implementing conservation 

practices, has conducted limited evaluation of the effectiveness of those 

efforts. NRCS’s National Planning Procedures Handbook calls for the 

agency to evaluate its conservation practices, including the technical 

assistance provided to landowners. According to one evaluation, agency 

staff need additional expertise to effectively advise landowners on how to 
Page 53 GAO-16-220 Protecting Bee Health

conserve pollinator habitat. However, NRCS has not evaluated which 

locations have gaps or identified methods for filling the gaps. Such 

methods could include providing additional training or time to conduct 

technical assistance through which staff can learn which practices are 

working and which are not. By increasing the evaluation of its habitat 

conservation efforts to include identifying gaps in expertise and technical 

assistance, USDA could better ensure the effectiveness of its efforts to 

restore and enhance bee habitat plantings across the nation.

Moreover, EPA has expanded its assessment of pesticides for their risks 

to honey bees. EPA generally uses data on pesticides’ risks to honey 

bees as a surrogate for risks to nonhoney bee species but stated that 

having data on those species would help meet the goal of protecting bee 

diversity. The task force’s research action plan calls for EPA to develop 

tools for assessing risks to a variety of bee species, including nonhoney 

bee species, such as other managed or wild, native bees. EPA is 

collaborating with international counterparts to develop standardized 

guidelines for how to study the effects of pesticides on other bee species. 

FIFRA authorizes EPA to require pesticide registrants to submit data from 

tests on nonhoney bee species using methods that meet EPA’s approval. 

By developing a plan for obtaining data from pesticide registrants on 

pesticides’ effects on nonhoney bee species until the standardized 

guidelines are developed, EPA could increase its confidence that it is 

reducing the risk of unreasonable harm to these important pollinators.

Furthermore, EPA does not assess the risks that mixtures of pesticides 

and other chemicals may pose to bees. Depending on the chemicals 

involved, a mixture may pose a greater risk to bees than the sum of the 

risks from exposure to individual pesticides. The task force’s research 

action plan generally called for research on the effects mixtures of 

pesticides can have on bees and, in particular, directed EPA to develop 

appropriate assessment tools for sublethal effects of pesticides, 

adjuvants, and combinations of pesticides with other products on the 

health of managed and wild pollinators. However, EPA does not have 

data on commonly used mixtures and does not know how it would identify 

them. By identifying the mixtures that farmers and pesticide applicators 

most commonly use on agricultural crops, EPA would have greater 

assurance that it could assess those mixtures to determine whether they 

pose greater risks than the sum of the risks posed by the individual 

pesticides and, if appropriate, take regulatory action.

As directed by FIFRA, EPA began a review of all pesticide active 

ingredients registered as of October 1, 2007, in fiscal year 2007 and is 
Page 54 GAO-16-220 Protecting Bee Health

required to complete it by October 2022. EPA’s review has been affected 

by the changes to its risk assessment process that call for pesticide 

registrants to submit additional bee-related data for some pesticides. As a 

result, the agency’s posted schedules for reviewing the registration of 

pesticides may be inaccurate because the schedules do not reflect 

requests for additional data. However, EPA has not posted revised 

schedules. Accurate information about the agency’s estimated schedule 

would help Congress and the public better understand EPA’s progress 

toward meeting the October 2022 deadline for completing all registration 

reviews.

We are making four recommendations to the Secretary of Agriculture and 

three recommendations to the Administrator of EPA.

To improve the effectiveness of federal efforts to monitor wild, native bee 

populations, we recommend that the Secretary of Agriculture, as a cochair of the White House Pollinator Health Task Force, coordinate with 

other Task Force agencies that have monitoring responsibilities to 

develop a mechanism, such as a federal monitoring plan, that would (1) 

establish roles and responsibilities of lead and support agencies, (2) 

establish shared outcomes and goals, and (3) obtain input from relevant 

stakeholders, such as states.

To increase the accessibility and availability of information about USDAfunded research and outreach on bees, we recommend that the 

Secretary of Agriculture update the categories of bees in the Current 

Research Information System to reflect the categories of bees identified 

in the White House Pollinator Health Task Force’s research action plan.

To measure their contribution to the White House Pollinator Health Task 

Force strategy’s goal to restore and enhance 7 million acres of pollinator 

habitat, we recommend that the Secretary of Agriculture direct the 

Administrators of FSA and NRCS to develop an improved method, within 

available resources, to track conservation program acres that contribute 

to the goal.

To better ensure the effectiveness of USDA’s bee habitat conservation 

efforts, we recommend that the Secretary of Agriculture direct the 

Administrators of FSA and NRCS to, within available resources, increase 

evaluation of the effectiveness of their efforts to restore and enhance bee 

habitat plantings across the nation, including identifying gaps in expertise 

and technical assistance funding available to field offices.

Recommendations for 

Executive Action
Page 55 GAO-16-220 Protecting Bee Health

To better ensure that EPA is reducing the risk of unreasonable harm to 

important pollinators, we recommend that the Administrator of EPA direct 

the Office of Pesticide Programs to develop a plan for obtaining data from 

pesticide registrants on the effects of pesticides on nonhoney bee 

species, including other managed or wild, native bees.

To help comply with the directive in the White House Pollinator Health 

Task Force’s strategy, we recommend that the Administrator of EPA 

direct the Office of Pesticide Programs to identify the pesticide tank 

mixtures that farmers and pesticide applicators most commonly use on 

agricultural crops to help determine whether those mixtures pose greater 

risks than the sum of the risks posed by the individual pesticides.

To provide Congress and the public with accurate information about the 

schedules for completing the registration reviews for existing pesticides 

required under FIFRA, we recommend that the Administrator of EPA 

disclose in its PRIA implementation reports, or through another method of 

its choosing, which registration reviews have potentially inaccurate 

schedules and when it expects those reviews to be completed.

We provided a draft of this report to USDA and EPA for review and 

comment. USDA and EPA provided written comments on the draft, which 

are presented in appendixes IV and V, respectively. In its written 

comments, USDA said that it agreed, in large part, with the four 

recommendations relevant to the department in the draft report and that 

progress with regard to the recommendations would improve protection 

for pollinators, especially bees. In its written comments, EPA said that it 

agreed with the three recommendations relevant to the agency in the 

draft report and that it has actions under way to implement the three

recommendations. 

In its written comments, USDA described actions it has taken or could 

take to implement our first recommendation that the Secretary of 

Agriculture, as a co-chair of the White House Pollinator Health Task 

Force, coordinate with other task force agencies that have monitoring 

responsibilities to develop a mechanism, such as a federal monitoring 

plan, that would (1) establish roles and responsibilities of lead and 

support agencies, (2) establish shared outcomes and goals, and (3) 

obtain input from relevant stakeholders, such as states. USDA noted that 

while it would be impossible to monitor all of the approximately 4,000 

species of bees in North America, it would be informative for agencies to 

survey changes in the distributions of a common set of sentinel, or 

Agency Comments 

and Our Evaluation
Page 56 GAO-16-220 Protecting Bee Health

indicator, bee species. The agency also described some of the monitoring 

methods that it plans to use or that could be used by USDA, the 

Department of the Interior, and other collaborators. In doing so, USDA 

noted that identifying native bee species can be very difficult (even to 

those trained in biology and museum curators) and that possible 

remedies will be explored, including the development of a universal field 

guide or apps that would facilitate bee identification efforts. 

USDA also described steps that it plans to take to implement our second 

recommendation that the Secretary of Agriculture update the categories 

of bees in CRIS to reflect categories of bees identified in the White House 

Task Force’s research action plan. USDA states that the discrepancy 

between the government-wide effort and current classifications needs to 

be reconciled to capture efforts of research, education, and extension 

projects as they work to address threats to bee health. While USDA 

states that the CRIS categories can be changed relatively quickly, it also 

states that the efficacy of the changes varies, depending on whether they 

are made for historical project data or for future project reports. USDA 

describes the additional staff time needed to analyze and recode projects 

manually in CRIS and that adding new classifications would affect current 

projects and would require analysis to determine if changes will affect 

trend reporting of the budget. USDA also states that a strategy will be 

needed to increase awareness of the new classifications for project 

directors and other scientists who may choose to change to the more 

specific bee classifications for their projects. The agency then describes 

the process by which changes are made to research classifications in 

CRIS, saying that if the CRIS Classification Board approves changes to 

CRIS when it meets in the spring of 2016, NIFA would address relevant 

changes at that time.

USDA generally agreed with our third recommendation that the Secretary 

of Agriculture direct the Administrators of FSA and NRCS to develop an 

improved method, within available resources, to track conservation 

program acres that contribute to the goal of restoring and enhancing 

habitat for pollinators. USDA said that since November 2015, FSA has 

had a method for estimating acres of pollinator habitat associated with 

Conservation Reserve Program practices. In addition, according to 

USDA, NRCS is exploring options to develop a method for tracking acres 

on which conservation practices are planned and applied to benefit 

pollinators.

USDA generally agreed with our fourth recommendation that the 

Secretary of Agriculture direct the Administrators of FSA and NRCS to, 
Page 57 GAO-16-220 Protecting Bee Health

within available resources, increase evaluation of the effectiveness of 

their efforts to restore and enhance bee habitat plantings across the 

nation, including gaps in expertise and technical assistance funding 

available to field offices. USDA said that it would expand and deepen its 

studies on the impact of conservation cover on honey bee and other 

pollinator health, diversity, and abundance as its budget allows.

EPA agreed with our first recommendation that the Office of Pesticide 

Programs develop a plan for obtaining data from pesticide registrants on 

the effects of pesticides on nonhoney bee species, including other 

managed or wild, native bees. In addition, EPA described actions that it is 

taking in collaboration with other parties to develop methods for testing 

the effects of pesticides on nonhoney bee species. We also noted many 

of these actions in the report. 

EPA agreed with our second recommendation that the Office of Pesticide 

Programs identify pesticide mixtures that farmers and pesticide 

applicators most commonly use on agricultural crops to help determine 

whether those mixtures pose greater risks than the sum of the risks 

posed by the individual pesticides. EPA noted that there is opportunity to 

identify some commonly used tank mixtures. At the same time, EPA 

commented on our use of the term “unregistered mixtures.” In our draft 

report, we intended for the term “unregistered mixtures” to mean 

combinations of registered pesticides that EPA has not registered for use 

in combination. However, we agree with EPA that the term “unregistered 

mixtures” might cause confusion and revised the draft, replacing that term 

with the term “tank mixtures.” 

EPA agreed with our third recommendation that the agency provide 

Congress and the public with accurate information about the schedules 

for completing the registration reviews for existing pesticides required 

under FIFRA. However, rather than agreeing to disclose this information 

in its PRIA implementation reports, EPA committed to creating a public 

website containing this information by April 2016. We agree that a public 

website could be a suitable method for accomplishing the intent of our 

recommendation. 

USDA and EPA also provided technical comments, which we 

incorporated as appropriate.

As agreed with your offices, unless you publicly announce the contents of 

this report earlier, we plan no further distribution until 30 days from the 
Page 58 GAO-16-220 Protecting Bee Health

report date. At that time, we will send copies to the appropriate 

congressional committees, the Secretary of Agriculture, the Administrator 

of EPA, and other interested parties. In addition, the report will be 

available at no charge on the GAO website at http://www.gao.gov. 

If you or your staff members have any questions about this report, please 

contact me at (202) 512-3841 or morriss@gao.gov. Contact points for our 

Offices of Congressional Relations and Public Affairs may be found on 

the last page of this report. GAO staff who made key contributions to this 

report are listed in appendix VI.

Steve D. Morris

Director, Natural Resources and Environment
Appendix I: Objectives, Scope, and 

Methodology

Page 59 GAO-16-220 Protecting Bee Health

This report examines (1) the bee-related monitoring, research and 

information dissemination, and conservation efforts of selected U.S 

Department of Agriculture (USDA) agencies and (2) the Environmental 

Protection Agency’s (EPA) efforts to protect bees through its regulation of 

pesticides.

To examine USDA’s monitoring, research and outreach, and conservation 

efforts with respect to bees, we focused on the National Agricultural 

Statistics Service (NASS), which surveys honey beekeepers; the 

Agricultural Research Service (ARS) and National Institute of Food and 

Agriculture (NIFA), which are the two largest USDA research agencies; 

and the Natural Resources Conservation Service (NRCS) and Farm 

Service Agency (FSA), which oversee conservation programs. To 

examine bee monitoring activities, we analyzed the methodology that 

NASS and the Bee Informed Partnership are using for their monitoring 

efforts related to their surveys of honey bee colony losses.1 We also 

reviewed the White House Task Force plans for wild, native bee 

monitoring by a variety of federal agencies to determine whether a means 

of federal coordination had been established. We also reviewed our prior 

body of work on interagency collaboration, as agencies within USDA 

carry out work related to bee monitoring in conjunction with other 

agencies; from that work, we selected practices that were related to 

challenges that we or agency officials identified and used the practices to 

assess interagency collaboration at USDA concerning bee monitoring.2 In 

addition, we reviewed ARS and NIFA documents related to monitoring 

projects and interviewed ARS and U.S. Geological Survey3 officials and 

university researchers participating in monitoring projects.

To examine bee-related research and outreach, we analyzed USDA 

project funding data for ARS and NIFA for fiscal years 2008 through 2015 

and for fiscal years 2008 through 2014, respectively, to identify the types 

of bees addressed by the projects. We selected fiscal year 2008 as the 

 

1

The Bee Informed Partnership is a collaboration of efforts across the country from 

research laboratories and universities in agriculture and science. It is supported by 

USDA’s National Institute of Food and Agriculture.

2

GAO-06-15; GAO-12-1022; and GAO-14-220. 

3

The U.S. Geological Survey is an agency within the Department of the Interior that 

provides scientific information on, among other things, the health of the U.S. environment 

and ecosystems.

Appendix I: Objectives, Scope, and 

Methodology
Appendix I: Objectives, Scope, and 

Methodology

Page 60 GAO-16-220 Protecting Bee Health

starting point to reflect 2008 Farm Bill initiatives; data from fiscal years 

2015 and 2014 were the most recent data available for ARS and NIFA, 

respectively. We evaluated the reliability of these data by comparing 

agency-provided data with data found in USDA’s website for its Current 

Research Information System (CRIS) and reviewing the agencies’ 

management controls to ensure the data’s reliability. We determined that 

the data are sufficiently reliable for the purposes of this report. We also 

reviewed how ARS and NIFA categorize research data in USDA’s CRIS 

database and compared the CRIS categories to those used in the task 

force strategy and research action plan. We interviewed ARS and NIFA 

officials in headquarters and in three bee laboratories regarding research 

and outreach projects being conducted and the usefulness of the CRIS 

bee categories.

To examine bee-related activities in two key USDA agencies with 

conservation programs, we collected data from NRCS and FSA on bee 

habitat acres established in 2014 and 2015 for two honey bee initiatives 

and associated agency funding. We evaluated the reliability of these data 

by reviewing the agencies’ management controls for the systems 

maintaining the data to ensure the data were sufficiently reliable for the 

purposes of this report. We also reviewed NRCS and FSA guidance and 

other documents on bee habitat, as well as evaluations of the NRCS 

technical assistance efforts. In particular, we reviewed an evaluation by 

the Pollinator Partnership of NRCS’s technical assistance efforts and 

examined the agency’s response to conclusions about the level of bee 

habitat conservation expertise within the agency.4 We interviewed FSA 

and NRCS officials to discuss strengths and weaknesses of their 

pollinator habitat efforts, particularly related to evaluation and technical 

assistance.

To examine EPA’s efforts to protect bees, we gathered information on its 

regulation of pesticides under the Federal Insecticide, Fungicide, and 

Rodenticide Act (FIFRA). In particular, we obtained documents from, and 

conducted interviews with, officials in EPA’s Office of Pesticide Programs 

(OPP). OPP carries out EPA’s responsibilities for regulating the 

manufacture and use of all pesticides (including insecticides, herbicides, 

 

4

Pollinator Partnership, Assessing the Effectiveness of NRCS Pollinator Programs, 

December 30, 2014. The mission of the Pollinator Partnership, a nonprofit organization, is 

to promote the health of pollinators critical to food and ecosystems through conservation, 

education, and research.
Appendix I: Objectives, Scope, and 

Methodology

Page 61 GAO-16-220 Protecting Bee Health

rodenticides, disinfectants, sanitizers, and more) in the United States. 

Specifically, we reviewed EPA’s decisions in 2014 to modify the labels of 

pesticide products containing neonicotinoid active ingredients. We also 

reviewed EPA’s 2015 proposal to modify the labels of pesticides the 

agency has determined to be acutely toxic to bees. We also gathered 

information about pesticides that have been associated with bee kill 

incidents from 1974 through 2014, as indicated by reports in EPA’s 

Ecological Incident Information System (EIIS). To assess the reliability of 

the EIIS data, we discussed with EPA officials the methods by which the 

agency collects and assesses the EIIS data and determined that, while 

they had limitations, they were sufficiently reliable for the purpose of 

identifying pesticides potentially associated with bee kills. Furthermore, 

we reviewed documents and interviewed agency officials regarding EPA’s 

efforts to encourage states to develop voluntary “managed pollinator 

protection plans.” 

In addition, we reviewed the agency’s 2011 interim and 2014 final 

guidance for assessing the risks that pesticides pose to bees and 

examined how the agency has applied the new guidance to particular 

pesticides.5 We also reviewed an EPA “White Paper” on risk assessment 

the agency submitted to the FIFRA Scientific Advisory Panel for 

comment, as well as the panel response.6 To learn more about how the 

agency has used its 2014 risk assessment guidance when reviewing the 

registration of existing pesticides, we selected 10 pesticides shown by 

EPA’s EIIS database to be associated with bee kills. When EPA receives 

reports of bee kill incidents, according to agency officials, it considers the 

evidence provided and categorizes the likelihood that a specific pesticide 

was associated with the bee kill as highly probable, probable, possible, 

unlikely, or unrelated. We assigned to those certainties a score of 4, 3, 2, 

1, or 0, respectively, and multiplied the number of incidents for each 

 

5

The director of EPA’s Environmental Fate and Effects Division issued a memorandum to 

staff titled Interim Guidance on Honey Bee Data Requirements in October 2011. In June 

2014, EPA issued Guidance for Assessing Pesticide Risks to Bees, co-authored by the 

Office of Pesticide Programs, United States Environmental Protection Agency, 

Washington, D.C.; the Health Canada Pest Management Regulatory Agency, Ottawa, ON, 

Canada; and the California Department of Pesticide Regulation, Sacramento, CA, June 

19, 2014. 

6

EPA, White Paper in Support of the Proposed Risk Assessment Process for Bees, 

September 11, 2012 and FIFRA Scientific Advisory Panel, A Set of Scientific Issues Being 

Considered by the Environmental Protection Agency Regarding Pollinator Risk 

Assessment Framework September 11 – 14, 2012. 
Appendix I: Objectives, Scope, and 

Methodology

Page 62 GAO-16-220 Protecting Bee Health

pesticide by the certainty score. Using the product of those calculations, 

we identified the 10 pesticides associated with the largest number of bee 

kill incidents and weighted by EPA’s degree of certainty. The 10 

pesticides, in alphabetical order, are amitraz, carbaryl, chlorpyrifos, 

clothianidin, coumaphos, imidacloprid, malathion, methyl parathion, 

parathion, and thiamethoxam. However, 2 of the pesticides, parathion 

and methyl parathion, have been cancelled by their registrants and, 

therefore, are no longer subject to EPA’s registration review process. For 

the remaining 8 pesticides, we reviewed EPA’s final work plans and other 

documents related to the agency’s registration review process and 

interviewed agency officials to determine what effect the new risk 

assessment guidance had on the registration review process.

We reviewed data and interviewed agency officials about the status of 

EPA’s pesticide registration and registration review programs. The data 

included the number of pesticide “cases” for which EPA had started the 

registration review process from the beginning of fiscal year 2007 through 

the end of fiscal year 2015, the number of cases with final work plans 

completed, and the number of case reviews that EPA has completed. We 

selected these time frames because EPA began the registration review 

process required by FIFRA in fiscal year 2007, and the most recent data 

available from the agency were through the end of fiscal year 2015. To 

assess the reliability of the data on registration reviews provided directly 

to us by EPA’s OPP, we compared them to data in EPA implementation 

reports to Congress required by FIFRA and found them sufficiently 

reliable for our reporting purposes.

To address both objectives, we gathered stakeholders’ views on what 

efforts, if any, USDA and EPA could take to protect bee health. 

Specifically, we interviewed stakeholders from the following types of 

organizations or entities: general farming, including conventional and 

organic farming; commodity farmers whose crops are pollinated by 

managed bees; commercial beekeepers; pesticide manufacturers; state 

governments; universities; and conservation/environmental protection. 

We developed a list of candidate stakeholders by asking for suggestions 

from knowledgeable federal officials and others knowledgeable about bee 

health and through our review of relevant literature. USDA and EPA 

officials reviewed our list of candidate stakeholders and made 

suggestions. We also obtained advice from a member of the National 

Academy of Sciences with extensive experience on bee and pollinator 

research about how to achieve a balanced list of stakeholders with varied 

expertise and knowledge. Appendix II presents a summary of 

stakeholders’ views on USDA and EPA efforts to protect bees.
Appendix I: Objectives, Scope, and 

Methodology

Page 63 GAO-16-220 Protecting Bee Health

We conducted 35 interviews with stakeholders. A total of 50 individuals 

participated in the interviews because, in some instances, more than one 

person represented a stakeholder organization. See appendix III for the 

names of the individuals we interviewed, their title, affiliation, and type of 

stakeholder organization.

To ensure we asked consistent questions among all the identified 

stakeholders, we developed an interview instrument that included 

questions about the stakeholders’ expertise and experience regarding 

bees, their knowledge of relevant USDA and EPA activities to protect bee 

health, and their views on suggestions for efforts, if any, (1) USDA’s ARS, 

NIFA, or NRCS should make with regard to bee-related research and 

information dissemination; (2) other USDA agencies should make to 

protect bee health; or (3) EPA should make to protect bee health. With 

the exception of the university research scientists, the stakeholders 

represented their organizations’ views. After completing the interviews, 

we conducted a content analysis of the stakeholders’ responses, whereby 

we organized their comments into relevant categories. Because we used 

a nonprobability sample of stakeholders, their views cannot be 

generalized to all such stakeholder organizations but can be illustrative. In 

addition, the views expressed by the stakeholders do not represent the 

views of GAO. Further, we did not assess the validity of the stakeholders’ 

views on what efforts USDA and EPA should make to protect bee health.

We conducted this performance audit from October 2014 to February

2016 in accordance with generally accepted government auditing 

standards. Those standards require that we plan and perform the audit to 

obtain sufficient, appropriate evidence to provide a reasonable basis for 

our findings and conclusions based on our audit objectives. We believe 

that the evidence obtained provides a reasonable basis for our findings 

and conclusions based on our audit objectives.
Appendix II: Stakeholders’ Views on Efforts 

USDA and EPA Should Make to Further Protect 

Bees

Page 64 GAO-16-220 Protecting Bee Health

This appendix presents stakeholders’ views regarding suggested efforts 

the U.S. Department of Agriculture (USDA) and Environmental Protection 

Agency (EPA) should make to further protect bee health. Stakeholders 

provided these views in interviews. Specifically, we interviewed a 

nonprobability sample of stakeholders from 35 of the following types of 

organizations or entities: general farming, including conventional and 

organic farming; commodity farmers whose crops are pollinated by 

managed bees; commercial beekeeping; pesticide manufacturing; state 

government; university research; and conservation/environmental 

protection.

In our interviews, we asked stakeholders for their familiarity with agency 

efforts to protect bee health as well as for their views on suggestions for 

any efforts the agencies should make to further protect bee health. The 

information in table 1 provides a summary of stakeholders’ views on 

commonly-cited topics and indicates the types of stakeholder groups that 

expressed those views.

Table 1: Stakeholders’ Views on Efforts U.S. Department of Agriculture (USDA) and Environmental Protection Agency (EPA) 

Should Make to Further Protect Bees

Stakeholders’ Views on USDA Efforts to Further Protect Bees

Stakeholders’ Views on USDA’s Research and Outreach on Bees

Stakeholders suggested that USDA generally, or the Agricultural Research Service (ARS) and National Institute of Food and 

Agriculture (NIFA), specifically, should increase research on: 

• Bees and the health of bees generally (general farming, pesticide manufacturing, and university research stakeholders). 

• Varroa mites and tools, such as miticides, to reduce the impact of the mites on honey bees (general farming, commercial 

beekeeping, pesticide manufacturing and state organization stakeholders). 

• Issues related to the effects of pesticides on bees, including: the effects from entire pesticide products, fungicides, inert 

ingredients, adjuvants, multiple pesticides from different crops and locations, treated seeds, and tank mixes; the sublethal and 

synergistic effects of pesticides; the effects on different life stages of bees, native bees, individual bees, and the entire colony 

over its life span; and the effects of pesticide concentrations in surface water (general farming, commercial beekeeping, state 

organization, university research, and conservation/environmental stakeholders). In contrast, USDA should conduct less research 

on the connection between pesticides and bee decline (pesticide manufacturing stakeholder). 

• The development of Integrated Pest Management (IPM) and Integrated Pest and Pollinator Management for different cropping 

systems (state organization, university research and conservation/environmental stakeholders).

• Forage and nutrition, including research to (1) identify which plants work best in different locations and are most attractive and 

nutritious for bees and other pollinators; (2) identify how to establish and maintain habitat; and (3) develop decision tools to inform 

USDA and growers of the costs and benefits of forage options (general farming, commodity farming, commercial beekeeping, 

university research, and conservation/environmental stakeholders).

• Monitoring wild, native bees. USDA should take additional actions to monitor wild, native bees because current monitoring is 

insufficient and will not facilitate provision of long-term trends in populations (pesticide manufacturing, university research, and 

conservation/environmental stakeholders). 

• Bee genetics and breeding (general farming, pesticide manufacturing, state organization, and university research stakeholders).

• Bee diseases, such as those that may be transmitted by commercial bumble bees to native bumble bees 

(conservation/environmental stakeholder).

Appendix II: Stakeholders’ Views on Efforts 

USDA and EPA Should Make to Further 

Protect Bees
Appendix II: Stakeholders’ Views on Efforts 

USDA and EPA Should Make to Further Protect 

Bees

Page 65 GAO-16-220 Protecting Bee Health

Stakeholders specifically suggested that ARS should:

• Classify honey bees as livestock and move them into NIFA animal and plant research groups—which receive more funding than 

insect research, so that honey bee grants would not detract from other insect research (university research stakeholder). 

• Have a specific line item in its budget for pollinator research (university research stakeholder).

Stakeholders specifically suggested that NIFA should:

• Direct more competitive research funding to cooperative research efforts, as opposed to individual efforts (university research 

stakeholders). 

• Streamline its paperwork requirements for competitive grants and provide scientists with more time to prepare proposals 

(university research stakeholder).

• Improve the organization and search functions of its website to help scientists more easily find funding opportunities related to 

bees (university research stakeholder). 

• Discontinue funding to land-grant universities that develop or recommend tank mixtures that harm bees (commercial beekeeping 

stakeholder).

Stakeholders’ Views on USDA’s Habitat Management/Conservation Programs

Stakeholders specifically suggested that USDA should:

• Provide funding for improved monitoring of the effectiveness of habitat planting (conservation/environmental stakeholder).

• Expand its conservation programs to benefit bees and other pollinators by (1) increasing funding for the Conservation Reserve 

Program (CRP) and Environmental Quality Improvement Program (EQIP); (2) increasing participation by farmers who use

Integrated Pest Management (IPM) or organic practices; and (3) including states outside the five Midwestern states (Michigan, 

Minnesota, North Dakota, South Dakota, and Wisconsin) where the Natural Resource Conservation Service (NRCS) and Farm 

Service Agency have initiated honey bee habitat conservation efforts (general farming, commercial beekeeping, pesticide 

manufacturing, university research, and conservation/environmental stakeholders).

• Move funds from the crop insurance program to the CRP, for example, to stop the federal government from subsidizing the 

production of corn and soybeans on marginal lands (commercial beekeeping and university research stakeholders).

• Address the fact that federal biofuels and bioenergy subsidies encourage converting marginal lands, grasslands, and native 

prairies from pollinator-beneficial ecosystems into lands that produce monoculture crops (university research and 

conservation/environmental stakeholders).

• Have a pollinator habitat expert for native bees for each of the about 30 states that has a significant need for pollinator habitat 

(university research stakeholder).

• Increase funding for NRCS Plant Materials Centers so that they would have sufficient staff and facilities to increase conservation 

research and field demonstrations in their areasa (conservation/environmental stakeholder).

• Increase its emphasis on forage for honey bees (commercial beekeeping, state organization, university research, and 

conservation/environmental stakeholders). 

• Obtain more input from beekeepers regarding forage used in conservation programs (commercial beekeeping stakeholder). 

Stakeholders’ Views on USDA Training and Expertise

Stakeholders specifically suggested that USDA should:

• Hire and retain high-caliber research leaders at ARS laboratories (university research stakeholder). 

• Appoint someone to fill the role of a national extension agent for bees (university research stakeholder). 

• Provide more training to NRCS staff on how to promote the benefits of organic farming and IPM (general farming stakeholders). 

• Hire and train more NRCS staff to help landowners take advantage of available funding to help pollinators (university research 

and conservation/environmental stakeholders). 

• Improve the training and increase the hiring of NRCS staff throughout the states to ensure conservation plantings benefit bees 

(university research and conservation/environmental stakeholders). 

• Have NRCS ensure that each of the approximately 30 states with a significant need for pollinator habitat has a native bee expert 

(university research stakeholder). 
Appendix II: Stakeholders’ Views on Efforts 

USDA and EPA Should Make to Further Protect 

Bees

Page 66 GAO-16-220 Protecting Bee Health

Stakeholders’ Views on Efforts by Other USDA Agencies

Stakeholders specifically suggested that USDA should:

• Take more action to promote IPM (state organization and conservation/environmental stakeholder).

• Ensure that farmers have access to nontreated seeds in case they want to use them. Toward that end, the Economic Research 

Service should examine current market conditions regarding the availability of nontreated seeds (conservation/environmental 

stakeholder).

• Review the methods the Agricultural Marketing Service’s laboratory uses to test bee samples for pesticides. The stakeholder said 

they sent 100 bees contaminated with a large amount of an insecticide for testing, but the laboratory did not detect the insecticide 

(commercial beekeeping stakeholder). 

• Permanently fund the national honey bee disease survey conducted by the Animal and Plant Health Inspection Service (APHIS) 

in coordination with ARS (state organization stakeholder).

• Require (through APHIS) that managed bumble bee colonies be certified as free of parasites and diseases harmful to wild 

bumble bees prior to being sold, imported, or moved between states (conservation/environmental stakeholder).

• Prohibit (through APHIS) the release of managed, nonnative bumble bee species outside of their native ranges 

(conservation/environmental stakeholder).

• Require (through APHIS) that all companies supplying native, bumble bees produce them within their native ranges 

(conservation/environmental stakeholder). 

• Fund the National Agricultural Statistics Service to increase its monitoring of pesticide use (conservation/environmental 

stakeholder).

Stakeholders’ Views on EPA Efforts to Further Protect Bees

Stakeholders’ Views on EPA’s Bee Kill Incident Data

Stakeholders specifically suggested that EPA should:

• Automatically forward bee kill reports that are sent to EPA’s beekill@epa.gov e-mail address to the relevant state department of 

agriculture and state apiaristb (state organization stakeholder).

• Ensure that state agencies do an adequate job of investigating and enforcing label requirements in response to reports of bee 

kills (commercial beekeeping stakeholder).

• Require states to conduct more investigations of bee kill incidents and to do so more quickly (conservation/environmental 

stakeholder).

• Work with USDA to help the states investigate bee kills by improving state access to laboratory resources and technical expertise 

(state organization stakeholder).

• Train state apiarists on how to investigate bee kills associated with pesticides and work with states to conduct more timely 

investigations (state organization stakeholder).

• Provide more funding to the states to carry out bee kill incident investigations and reporting (university research stakeholder). 
Appendix II: Stakeholders’ Views on Efforts 

USDA and EPA Should Make to Further Protect 

Bees

Page 67 GAO-16-220 Protecting Bee Health

Stakeholders’ Views on EPA’s Pesticide Regulation, Registration, and Registration Review

Stakeholders suggested EPA take several actions related to the agency’s regulation of pesticide labels:

• Ensure that labels for registered pesticides contain appropriate language warning about the effects of the pesticide on species of 

bees other than honey bees. For example, some fungicides should have label warnings about their potential effect on orchard 

mason bees (commercial beekeeping stakeholder).

• Provide better warnings on labels for pesticides used by homeowners (university research stakeholder).

• Require that registrants disclose all ingredients—both active and inert—on pesticide labels (university research stakeholder). 

• Ensure that the wording in products’ bee advisory box is consistent with the environmental warning statement elsewhere on the 

products’ labels (commodity farming stakeholder).

• Modify the bee icon in the bee advisory box so that it does not appear to be a healthy bee (university research stakeholder).

• Make the directions for use on pesticide labels consistent for crops pollinated by managed bees and crops not pollinated by 

managed bees (commercial beekeeping stakeholder).

• Expand the scope of label changes for neonicotinoid pesticides to include seed treatment applications 

(Conservation/environmental stakeholders).

• Develop clear labels for which pesticide mixtures are allowed (commercial beekeeping stakeholder).

Stakeholders suggested EPA take several actions related to how the agency assesses the risks that pesticides pose to bees:

• Expand the risk assessment process to include testing the effects of pesticides on pollinators other than honey bees, including 

other commercial and native bees (general farming, commercial beekeeping, university research, and 

conservation/environmental stakeholders). 

• Require companies to conduct toxicity studies on pesticide mixtures (commercial beekeeping, university research, and 

conservation/environmental stakeholders).

• Focus attention on commonly used pesticide mixtures, including mixtures promoted by pesticide manufacturers, companies that 

apply pesticides, and extension agents, and mixtures found in bee hives (commercial beekeeping, university research, and 

conservation/environmental stakeholders).

• Require pesticide registrants to test entire pesticide formulations—all inert ingredients, as well as active ingredients in the 

product—in the risk assessment process (commercial beekeeping, university research, and conservation/environmental 

stakeholders).

Stakeholders suggested EPA take several actions related to the agency’s monitoring of pesticide use:

• Develop or expand upon the public reporting of pesticide use (commercial beekeeping, university research, and 

conservation/environmental stakeholders).

• Collect data on the use of seeds treated with pesticides (commercial beekeeping, university research, and 

conservation/environmental stakeholders). 

• Monitor the environment to determine which pesticides bees are exposed to (university research stakeholders).

Stakeholders suggested EPA take several actions related to the agency’s oversight of seeds treated with pesticides: 

• Revise the definition of a pesticide under FIFRA to include seeds that are treated with pesticidesc (conservation/environmental 

stakeholders).

• Take additional steps to address situations in which a pesticide applied to seeds is dislodged in the form of dust (commercial 

beekeeping and conservation/environmental stakeholders).

• Ensure that farmers have access to seeds that are not treated with pesticides (conservation/environmental stakeholder).
Appendix II: Stakeholders’ Views on Efforts 

USDA and EPA Should Make to Further Protect 

Bees

Page 68 GAO-16-220 Protecting Bee Health

Stakeholders’ Views on EPA Research

Stakeholders suggested EPA conduct additional research on: 

• The effect that combinations of multiple pesticides can have on bees (commodity farming and university research stakeholders). 

• The chronic effects that pesticides can have on bees (university research stakeholders).

• The effect of pesticides on the larval stage of bees’ life cycle (university research stakeholders).

• The economic benefits of pesticide use, including seeds treated with systemic pesticides (conservation/environmental 

stakeholders).

Stakeholders’ Views on EPA Outreach

Stakeholders suggested EPA conduct additional outreach related to:

• Promoting pesticide use practices that benefit bees through additional training for farmers, pesticide application companies, and 

homeowners (general farming, state organization, and conservation/environmental stakeholders).

• Providing easily accessible fact sheets on pesticides (university research stakeholder).

• Providing information to the public and beekeepers about the risk associated with using pesticides in hives to combat Varroa

mites (pesticide industry and state organization stakeholders).

• Providing training to Pest Control Advisors on the risks that pesticides pose to bees. Advisors need to know more about how to 

protect beneficial insects—including bees—and not just how to kill harmful insects (commercial beekeeping stakeholder).

• Promoting communication between commercial beekeepers and farmers (pesticide manufacturing stakeholder).

Stakeholders’ Views on Agency Coordination

Stakeholders’ Views on Federal-State Coordination

Stakeholders suggested:

• USDA needs to provide better advice to state and county weed abatement programs on the impact of weed abatement on 

beneficial pollinator plants and bees (commercial beekeeping stakeholder).

• USDA should work with states to establish a more uniform framework for regulating the movement of nonhoney bees. 

Specifically, APHIS and states should facilitate permitting for moving these bees (commercial beekeeping stakeholder). 

• USDA should provide training to state apiarists on methods for diagnosing threats to bee health (state organization stakeholder).

• USDA and EPA should work together to help the states investigate bee kills by improving state access to laboratory resources 

and technical expertise (state organization stakeholder). 

• EPA should continue to: engage in all managed pollinator protection plan discussions; help develop protection plan guidance; 

evaluate state pollinator protection plans; and give the states flexibility to find local solutions regarding pesticide regulatory 

decisions (state organization stakeholder).

• Managed pollinator protection plans should include county extension agents, funded in part by USDA’s NIFA, as key players for

disseminating best management practice information and facilitating communication between beekeepers and farmers (state 

organization stakeholder).

Stakeholders’ Views on Intra-Agency Coordination

Stakeholders suggested:

• USDA should initiate a multistakeholder campaign to protect bees across a range of USDA agencies, similar to their International 

Year of Soils campaign for healthy soils (general farming stakeholder).

• NRCS should include APHIS’s invasive species advisory group in determinations of whether a plant that may be planted as bee 

forage is invasive or not (commodity farming stakeholder).

• ARS and NIFA should more closely coordinate their bee-related research to avoid duplication. Coordination could include a 

formal agreement that spells out how they communicate with each other about their pollinator research plans if one does not 

already exist (commodity farming, commercial beekeeping, and university research stakeholders).

• NIFA should allow ARS scientists to be principal investigators on and to collaborate with university researchers that have 

received NIFA competitive grants (university research stakeholder).
Appendix II: Stakeholders’ Views on Efforts 

USDA and EPA Should Make to Further Protect 

Bees

Page 69 GAO-16-220 Protecting Bee Health

Stakeholders’ Views on Inter-Agency Coordination

Stakeholders suggested:

• USDA and other agencies, such as the Department of the Interior’s U.S. Geological Survey, should coordinate federal monitoring 

efforts (university research and conservation/environmental stakeholders). Without such a coordinated policy, agencies will not 

know which species are declining, endangered, or extinct (university research stakeholder).

• ARS and NIFA should ensure research they fund or conduct will be useful to EPA regulators in making regulatory decisions 

(commodity farming stakeholder).

• EPA should coordinate with ARS, and potentially other organizations and private companies, to develop the tests that EPA needs 

to assess bee toxicity (commodity farming stakeholder).

• USDA should be the lead agency in the honey bee health issue area, because bees are part of agriculture (commodity farming 

stakeholder).

• EPA and USDA should work together to develop a real-time database of pesticide spraying (commercial beekeeping 

stakeholder). 

• ARS labs should be involved in the pesticide registration process administered by EPA. In particular, ARS labs should help 

provide third-party, objective verification of the toxicity of pesticides to bees. ARS should be involved in validating the claims 

made by the manufacturers and in commenting on EPA regulations and guidance (commercial beekeeping stakeholders). 

• USDA and EPA should consider establishing a USDA laboratory that would not only conduct pesticide analysis, but also examine 

the effect of diseases, insect pests, and general nutrition in determining the cause of bee kill incidents (state agency stakeholder).

• EPA should work with USDA’s ARS every 5 to 10 years to assess the state of research on pesticides and bee health (university 

research stakeholder).

• A national effort should be initiated to coordinate and encourage planting as well as better management of wildflowers on field 

margins, highway rights of way, power line cutouts, and other similar areas (university research stakeholder).

Stakeholders’ Views on the Role of Congress in Protecting Bee Health

Stakeholders suggested:

• Congress should understand the benefits that the extension service can provide to farmers (general farming stakeholder). 

• USDA and Congress should continue to support Farm Bill funding that pays for state-led honey bee research and monitoring 

(state organization stakeholder).

• The Department of Energy, the White House, and Congress should develop biofuel policies that include a high degree of 

sustainability, so that land pollinators use for their habitat is not lost. NRCS’s role could be helping ensure that the forage crops 

are well-placed in the landscape and well-maintained (university research stakeholder).

• Farm Bill policies and crop insurance statutory provisions should be changed to avoid planting in marginal lands that would 

benefit pollinators and other wildlife (conservation/environmental stakeholder).

• Congress should promote IPM and encourage the chemical industry to offer IPM education to farmers 

(conservation/environmental stakeholder). 
Appendix II: Stakeholders’ Views on Efforts 

USDA and EPA Should Make to Further Protect 

Bees

Page 70 GAO-16-220 Protecting Bee Health

Stakeholders’ Views on Federal-Nongovernmental Coordination

Stakeholders suggested:

• Chemical companies should be involved in public-private partnerships on research to maintain and improve bee health (general 

farming stakeholder).

• Before USDA or other federal agencies, states, and counties decide what plants are weeds, they should consult the beekeeping 

industry (commercial beekeeping stakeholder).

• Research leaders at ARS laboratories need to work more closely with nongovernmental researchers at universities and in 

industry, instead of working in isolation (commercial beekeeping stakeholder).

• USDA and ARS should increase coordination related to bee research with universities and others (commercial beekeeping, 

university research, and pesticide manufacturing stakeholders). 

• ARS should improve communication with stakeholders, particularly beekeepers, prior to making significant personnel changes 

affecting stakeholders (general farming and university research stakeholders).

• NIFA should help encourage collaboration between ARS and universities by establishing an institute to bring ARS and university 

researchers together and to integrate research in genomics, applied bee health, and systems biology (university research 

stakeholder).

• The Bee Informed Partnership, under NIFA’s direction, should involve EPA and industry scientists, in addition to other 

nongovernmental organizations, more closely in its analysis of its findings on the presence of pesticides in bee hives (pesticide 

manufacturing stakeholder).

• In addition to research, USDA should promote existing opportunities for public-private partnerships among the different 

organizations working in this area (general farming, pesticide manufacturing stakeholder).

• EPA should work with USDA and the agricultural community to facilitate a transition to more IPM-based, sustainable agricultural 

systems that leave room for bees and other wildlife (conservation/environmental stakeholder).

• USDA should engage beekeeping representatives, as well as scientists and other credible stakeholders in supporting the 

beekeeping industry on forage and nutrition issues (conservation/environmental stakeholder). 

• USDA should seek out and leverage private sector and nongovernmental organization partners to leverage limited Conservation 

Reserve Program funds for incentives and outreach (conservation/environmental stakeholder).

Stakeholders’ Views on U.S.-International Coordination

Stakeholders suggested:

• To help improve its guidelines for assessing pesticide risks to bees, EPA should collaborate more with European experts on how 

to protect honey bees, bumble bees, and solitary bees and also examine and follow the more protective European approach to 

risk assessment (commercial beekeeping stakeholder).

Sources: GAO analysis of stakeholders’ views. | GAO-16-220

a

According to the NRCS website, the agency’s Plant Materials Centers, which are based in 

ecologically distinct service areas, work with plant materials specialists to seek out and test plants 

and plant technologies that restore and sustain healthy natural ecosystems; conserve and enhance 

critical wildlife habitat; mitigate diverse environmental and natural resource concerns; provide 

economic and socially acceptable solutions; and support a safer human environment. These centers 

evaluate plants for conservation traits and make these materials available to commercial growers who 

provide plant materials to the public. The centers also develop innovative techniques for land 

managers to use in managing a variety of conservation plants.

b

A collection of bee hives is called an apiary, and an apiarist is someone who keeps bee hives. A 

state apiarist is responsible for regulating bee hives according to the laws of that state.

c

EPA’s interpretation of FIFRA as set forth in its implementing regulations at 40 C.F.R. 152.25(a) is 

that the agency does not regulate seeds that are treated with registered pesticides and that meet the 

requirements of the treated article exemption. EPA considers the seeds to be “treated articles” that 

are exempt from FIFRA regulation. However, the pesticide active ingredients that are used to treat 

seeds are regulated under FIFRA and, according to EPA officials, the agency assesses the risks and 

benefits that may be associated with using the pesticide as a seed treatment.
Appendix III: Bee Health Stakeholders We 

Interviewed

Page 71 GAO-16-220 Protecting Bee Health

Name of stakeholder Title Affiliation Type of organization

Laurie Davies Adams Executive Director Pollinator Partnership Conservation or environmental 

protection

Brett Adee Representative to the National 

Honey Bee Advisory Board 

American Honey Producers 

Association

Commercial beekeeping 

Matthew Allan Pollination Specialist Pacific Pollination, LLC Commercial beekeeping 

Scott Hoffman Black Executive Director Xerces Society Conservation or environmental 

protection

Daniel A. Botts Chairman of the Technical 

Committee/Vice President, Industry 

Resources 

Minor Crop Farmer 

Alliance/Florida Fruit & Vegetable 

Association

Commodity farming

Gene Brandi Vice President American Beekeeping Federation Commercial beekeeping

Mary Byrne Plant Ecologist Pollinator Partnership Conservation or environmental 

protection

Dan Campbell Stewardship and Regulatory Policy 

Team Leader

Syngenta Crop Protection, LLC Pesticide manufacturing

Aimee Code Pesticide Program Coordinator Xerces Society Conservation or environmental 

protection

Darren Cox President American Honey Producers 

Association

Commercial beekeeping

Robert Curtis Associate Director of Agricultural 

Affairs 

Almond Board of California Commodity farming

Tom Driscoll Government Relations 

Representative

National Farmers Union General farming

Mark Dykes President Apiary Inspectors of America State government

Jay Feldman Executive Director Beyond Pesticides Conservation or environmental 

protection

Michelle Flenniken, PhD Assistant Professor of Plant 

Sciences and Plant Pathology

Montana State University University research

David Fischer, PhD Director of Pollinator Safety Bayer CropScience Pesticide manufacturing

Jim Frazier, PhD Professor Emeritus of Entomology Pennsylvania State University University research

Chandler Goule Senior Vice President of Programs National Farmers Union General farming

Jim Gray Chair State-FIFRA Issues Research 

and Evaluation Group

State government

Thomas Green, PhD Executive Director and Board 

Member

The IPM Institute of North 

America, Inc.

General farming

Nichelle Harriott Science and Regulatory Director Beyond Pesticides Conservation or environmental 

protection

Jeff Harris, PhD Assistant Extension/Research 

Professor of Entomology 

Mississippi State University University research

Jerry Hayes Commercial Director of Beeologics Monsanto Company Pesticide manufacturing

Christi Heintz Executive Director Project Apis m. Commercial beekeeping

Appendix III: Bee Health Stakeholders We 

Interviewed
Appendix III: Bee Health Stakeholders We 

Interviewed

Page 72 GAO-16-220 Protecting Bee Health

Name of stakeholder Title Affiliation Type of organization

Dudley Hoskins Public Policy Counsel National Association of State 

Departments of Agriculture

State government

Rufus Isaacs, PhD Professor and Extension Specialist 

in Entomology

Michigan State University University research

Reed Johnson, PhD Assistant Professor of Entomology The Ohio State University University research

Aaron Kinsman Media Relations Specialist Rodale Institute General farming

Claire Kremen, PhD Professor of Arthropod Biodiversity University of California-Berkeley University research

Gabriele Ludwig, PhD Associate Director of 

Environmental Affairs

Almond Board of California Commodity farming

Rene Ruiter North American Business Unit 

Manager

Koppert Biological Systems Commercial beekeeping

Gene Robinson, PhD Director, Institute for Genomic 

Biology

University of Illinois University research

Jennifer Sass, PhD Senior Scientist Natural Resources Defense 

Council

Conservation or environmental 

protection

Caydee Savinelli, PhD Pollinator and IPM Stewardship 

Team Lead

Syngenta Crop Protection, LLC Pesticide manufacturing

Paul Schlegel Director American Farm Bureau 

Federation

General farming

Michael Schmaeling Facilities Team Member and Honey

Bee Conservancy Manager

Rodale Institute General farming

Mark Seetin Director of Regulatory and Industry 

Affairs 

U.S. Apple Association Commodity farming

Steve Sheppard, PhD Chair of Entomology Department Washington State University University research

Mark Smallwood Executive Director Rodale Institute General farming

Marla Spivak, PhD Extension Entomologist University of Minnesota University research

David Tarpy, PhD Professor and Extension 

Apiculturist

North Carolina State University University research

Tim Tucker President American Beekeeping Federation Commercial beekeeping

Tom Van Arsdall Director of Public Affairs Pollinator Partnership Conservation or environmental 

protection

Dennis van Engelsdorp, 

PhD 

Assistant Professor of Entomology University of Maryland University research

Mace Vaughan Pollinator Program Co-Director Xerces Society Conservation or environmental 

protection

Mark Wagoner Board Member and Past President Western Alfalfa Seed Growers 

Association

Commodity farming

Gordon Wardell, PhD Board Chairman Project Apis m. Commercial beekeeping

Neil Williams, PhD Associate Professor of Entomology University of California-Davis University research
Appendix III: Bee Health Stakeholders We 

Interviewed

Page 73 GAO-16-220 Protecting Bee Health

Name of stakeholder Title Affiliation Type of organization

Victoria Wojcik, PhD Research Director Pollinator Partnership Conservation or environmental 

protection

Bob Young Chief Economist and Deputy 

Executive Director, Public Policy

American Farm Bureau 

Federation

General farming

Source: GAO. | GAO-16-220
Appendix IV: Comments from the Department 

of Agriculture

Page 74 GAO-16-220 Protecting Bee Health

Appendix IV: Comments from the 

Department of Agriculture
Appendix IV: Comments from the Department 

of Agriculture

Page 75 GAO-16-220 Protecting Bee Health
Appendix IV: Comments from the Department 

of Agriculture

Page 76 GAO-16-220 Protecting Bee Health
Appendix IV: Comments from the Department 

of Agriculture

Page 77 GAO-16-220 Protecting Bee Health
Appendix V: Comments from the 

Environmental Protection Agency

Page 78 GAO-16-220 Protecting Bee Health

Appendix V: Comments from the 

Environmental Protection Agency
Appendix V: Comments from the 

Environmental Protection Agency

Page 79 GAO-16-220 Protecting Bee Health
Appendix V: Comments from the 

Environmental Protection Agency

Page 80 GAO-16-220 Protecting Bee Health
Appendix V: Comments from the 

Environmental Protection Agency

Page 81 GAO-16-220 Protecting Bee Health
Appendix V: Comments from the 

Environmental Protection Agency

Page 82 GAO-16-220 Protecting Bee Health
Appendix VI: GAO Contact and Staff 

Acknowledgments

Page 83 GAO-16-220 Protecting Bee Health

Steve D. Morris, (202) 512-3841 or Morriss@gao.gov

In addition to the individual named above, Anne K. Johnson, (Assistant 

Director), Kevin Bray, Ross Campbell, John Delicath, Ashley Hess, 

Meredith Lilley, Beverly Peterson, and Leigh White made key 

contributions to this report. Barbara El Osta, Karen Howard, Ying Long, 

Perry Lusk, Jr, Anne Rhodes-Kline, Dan Royer, Kiki Theodoropoulos, and 

Walter Vance also made important contributions to this report.

Appendix VI: GAO Contact and Staff 

Acknowledgments

GAO Contact

Staff 

Acknowledgments

(361600)
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