It should be understood that these comments are intended for beekeepers and others who have been following this issue, to clarify and challenge some of the evasion and misinformation being offered under the guise of an official “response.” These comments are not intended as a response to the EPA. The EPA is listening only to itself, and further dialogue at this point would appear to be pointless.
Clothianidin was originally evaluated for registration through a North American Free Trade Agreement (NAFT A) Joint Review with Canada and was identified as an alternative to the organophosphate insecticides, a class of insecticides that is generally very highly acutely toxic to bees and, unlike clothianidin, also very highly acutely toxic to humans and wildlife. During the clothianidin registration process, hundreds of studies were reviewed and evaluated. When EPA granted the initial registration for clothianidin seed treatment uses in 2003, the Agency determined that the uses met the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) risk benefit standard for registration.
f this is true, then why was clothianidin released to the market under a “conditional” registration in 2003 rather than full registration? EPA’s own documents clearly show that there were serious concerns, serious enough that EPA scientists said the life cycle study should be completed before registration, and the “condition” of conditional registration was the completion of the life cycle study by the end of the first growing season. It was not completed until 4 full growing seasons has passed. Anyone can see that by looking at the EPA memos. Do they think we can’t read? Or just that we can’t think?
“Hundreds of studies…?” Just send us a list of the first 200…
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