People often ask the EPA why we do not ban the neonicotinoid pesticides. Citing incidents that have been in the news or new studies they read about that claim cause-and-effect harm to bees from pesticide use, people want to know why the EPA does not take extraordinarily strong action and ban these chemicals. Put simply, extraordinary regulatory action requires extraordinarily robust evidence that a ban will be effective and no other action will suffice. EPA, as a federal regulatory agency, must also consider if it is appropriate to impose extraordinary actions all across the nation. EPA has not banned the neonicotinoids because the robustness of available evidence and the appropriateness of a nationwide ban fall short. The EPA’s response to a 2012 petition requesting an emergency ban on clothianidin and other supporting documents in the regulatory docket for the petition provide detailed information about these issues and the legal framework that underpins the EPA’s position.
Presentation of information in the news can also bias public understanding of this complex topic. For example, there was a bumble bee incident in Wilsonville, Oregon, in June 2013 that grabbed headlines. While the Wilsonville incident was widely reported initially, the Oregon Department of Agriculture's investigation that identified pesticide misuse as the cause of the incident received far less coverage. Needless to say, it would be inappropriate for the EPA to regulate pesticides at the federal level based on initial reports of pesticide incidents. Similarly, when an investigation concludes that an incident was caused by local misuse, this is generally not a good basis for regulatory action at the national level. The EPA must be very careful to honor our statutory mandate in the actions we take and the data we rely on to support those actions. Within that mandate, however, we are working very hard to advance the science of pollinator risk assessments to improve pollinator protection.
New studies on pollinators and pesticides also make headlines and exemplify the challenges we face regarding quality science. The fact of the matter is that many studies published in peer-reviewed journals or by foreign governments do not meet the EPA’s scientific and/or quality standards. This does not mean that open literature studies have no value for the Agency's pesticide regulatory purposes. Rather, the EPA must always weigh new studies against the preponderance of other available data and the requirements of federal law. To that end, the Agency will conduct an open literature review as part of our registration review of the neonicotinoid pesticides, and the studies we all read about in headlines will be included.
In the neonicotinoid pesticide Web page linked above, if you follow the links to the docket folders you can review all of the information that EPA has posted about these chemicals and our plan to review their registrations. You can also sign up for emailed alerts, so you will be automatically notified when the agency next posts documents for public review and comment. Submitting comments during public comment periods is the best way to ensure that your position is accounted for in the EPA’s final regulatory decisions.