National Honey Bee Advisory Board

American Beekeeping Federation

American Honey Producers Association

Beyond Pesticides

Pesticide ActIon Network North America

Center for Biological Diversity

December 8, 2010

The Honorable lisa P. Jackson

Administrator

U.s. Environmental Protecton Agency

ArIel Rios Building, MC 110lA

1200 Pennsylvania Avenue NW

Washington DC 200

Dear Administrator Jackson:

In light of new revelations by your agency in a November 2, 2010 memorandum that

a core registration study for the insecticide clothianìdin has been downgraded to

unacceptable for purpses of registration, we are writing to request that you take urgent

action to stop the use of this toxic chemicaL. Clothianidin is a widely used pesticide linked to

a severe and dangerous decline in pollnator populations. As we are sure you appreciate,

the failure of the agency to provide adequate protection for pollinators under ìts pesticide

registration program creates an emergency with imminent hazards: Food production, public

health and the environment are all seriously threatened, and the collapse of the commerCÎal

honeybee-keeping industry would result In economic harm of the highest magnitude for

U.S. agriculture.

The debate on clothlanidin and the neonlcotlnoid pesticides is not new to the

agency, but the recognition of the past failure of the Office of Pesticide Program's (OPP)

2007 scientific review, now acknowledged, requires immediate action to stop use whHe new

studies are conducted. We refer you to the memorandum entitled "Clothianidin

Registration of Prosper T400 Seed Treatment on Mustard Seed and PonchoNotivo Seed

Treatment on Cotton," November i, 2010 (see pp. 2, 4), The science that the agency has,

and the independent lierature find that clothianidin-contaminated pollen and nectar

presents an imminent haiard. Because the hazards to honeybee health are present within

registered use parameters, it is dear that label chnges alone will not offer adequate

protection. The issue is not one of application error, in other words. We therefore urge the

agency to issue a stop use order immediately. Our nation cannot afford, and the

environment cannot tolerate another growing season of dothianindin use.
The Honorable Usa Jackson

PAGE TWO

December 8, 2010

In additIon, because this problem reflec an overuse of the conditional registration

program in OPP, we urge you to set an Immediate moratorium on the use of such

registrations unti the program is fully evaluated for compliance with its underlying

statutory responsibilties.. The conditonal registration of cJothlanidin in 2003 with

outstanding data critical to its safety assessment represents a failure that could and should

have been avoided. Clearly, the impacts on pollnators were not adequately evaluated prior

to the issuance of the conditional registration, despite knowledge of ffchronic toxic risk to

hone bee larvae and the eventual instabilty of the hive." This Is the case wJth poUinator

protecion and a host of other issues that have direct bearing on environmental protection

and pubUchealth.

In redoing the dothianidinstudy and evaluating the causes of Colony Collapse

Disorder and the larger issue of the pollnator decline crisis, we urge you to establish

protocol that fully assesses the compleidtiesthat come together to threaten the honeybees.

To be futly protective of bees, reviews must consider multiple chemical and cumulative

expsures, persistence. and sYnergistic effects. We can no longer rely on studies of

indivdual chemicals in isolatIon.

Thank you for your attention to the pollnator crisis and efforts to stem the tide of

contamination and poîsoning. We look forward to your reply.

Sincerelyi

National Ho.neyBee Advisry Board

Steve Ells.

Secretary

American Beekeeping Federation

David Mendes

President

American Honey Producers Association

Kenneth Haft

President

Beyond Pesticides

Jay feldman

Executive Director

Pesticide Action Network North America

Heather PilatIc

Co-Directr

Center for Biological Diversity

Justin Augustin

Staff Attorney

cc Steve Owens, Assistant Administrator, Office of Chemical Safety and Pollution Prevention
Steven Bradbury; Director, Office of Pesticide Programs
Message Information

Dat 1210812010 09:49 AM

From Jay Feldman -ejfeklman@beyondpeticides.org;:

To UsaP Jackson/DC/USEPNUS@EPA

cc

Subject Request Letter

Mesge Body

Full text of request letterfrcrn National Honey Bee Advisory Board,

k'lerican Beekeeping Federation, American Haney Producers Association,

Beyond Pesticides, Pesticide Action Network North America, and Center for

Biological Diversity is attached.

Dear Administrator Jackson:

In light of new revelations by your agency in a No\rêmber 2, 2010 memorandum

that a core registration study for the insecticide clothianidin has been

downgraded to unacceptable for purposes of registration, we are writing to

request that you take urgent action to stop the use of this toxic chemical.

Clothianidin is a widely used pesticide linked to a severe and dagerous

decline in pollinator populations. As we are sure you appre.ciate. the

failure of the agency to provide adequate protection for pollinators under

ita pesticide registrat:ion program creates an emergency with imminent

hazards: Food productioni public health and the environment are all

seriously threatened, and the collapse of the commercial honeybee-keeping

industry would result in economic harm of the highest magnitude for U. S.

agriculture.

8est regards.

Jay Feld'ln

EPA!1200 o pd

Jay Feldman I

.:mail to: j feldman@beyondpesticides. org::j feldman@beyondpesticides . org

Executive Director

Beyond Pesticides

701 B Street SE

Washington DC 20003

.:http://ww .beyondpesticides. org/~http://ww .beyondpesticides. org

(202.) 543-5450 , fax (202) 543-4791

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