EPA document trail

A trail of documents showing how incomplete research was eventually declared “scientifically sound.”

2/20/03 Risk assessment, corn

Considering the toxicity profile and reported incidents of other neonicotinoids (e.g., imidacloprid), the proposed seed treatment with clothianidin has the potential for toxic risk to honey bees, as well as other
pollinator insects. As a result of this concern, EFED is asking for additional chronic testing on bee hive activity (e.g., effects to queen, larvae, etc.).

4/10/03 Bee study protocol, clothianidin

The possibility of toxic chronic exposure to nontarget pollinators through the translocation of clothianidin residues in nectar and pollen has prompted EFED to require field testing (141-5) that can help in evaluating this uncertainty. In order to fully evaluate the possibility of this long term toxic effect, a complete worker bee life cycle study must be conducted, as well as an evaluation of exposure and effects to the queen…

3/11/04 Gabe Patrick’s memo on clothianidin protocol

Although it is stated that no flowering crops will be planted in the vicinity, bees can forage as far as 10 krn from the hive. This could pose a risk of cross-contamination in the study if bees start foraging in other fields. Not knowing a lot about the flowering phenology of canola, it is hard for me to suggest an exact number of days or to know how long it would take before the flowers are near tapped, but these are things the researcher should consider.

11/16/07 EPA’s review of the Bayer clothianidin study

This study is scientificallysound and satisfies the guideline requirements for a field toxicity test with honeybees (OPP Gdln. No. 141-5; OPPTS 850.3040).

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