Sunday, March 18, 2012

EPA Petition


     The EPA grants "conditional" registration to new pesticides which allows the use of these products until complete safety testing can be completed. If testing reveals there are "no unreasonable environmental effects" full registration is granted.  The EPA granted conditional registration to the pesticide Clothianidin under the condition that a "Core honeybee life cycle study" be completed in 2003.  Although this study was not completed Clothianidin was granted full registration.  This petition to the Environmental Protection Agency is to remove the "full registration" status of Clothianidin until it's required environmental impact testing be completed.  The petition uses as evidence studies showing the dire effects of Clothianidin on insects like bees (Insecticides and Bees). The EPA is currently reviewing the status of Clothianidin with a projected completion date of 2018.  Bees are dying now and we can't wait another 6 years for this study to be completed.
     Below is a letter providing you with the opportunity to sign this petition to the EPA:


Dear Fellow Beekeepers, 
We are writing to give you an opportunity to sign a petition to the Environmental Protection Agency, which at its core is a request for the agency to follow it's own mandates. This petition calls EPA ‘out on the carpet’ for improperly granting FULL registration to a pesticide that lacks the necessary data to support that registration. 
  
In recent years EPA Risk Assessment has “Conditionally” registered nearly 70% of all pesticides coming on to the market. While the law allows EPA to issue these conditional registrations, the original idea was too (“conditionally”) allow the use of new chemistries until test data could be generated confirming their safety. Once the ‘conditions’ are met, the pesticide can then be granted “Full Registration”. EPA has become dangerously lax in following through and completing the full registration process for pesticides which have not demonstrated they have  “no unreasonable environmental effects” as required by law. 

This petition is a request for EPA to remove FULL registration from the chemical Clothianidin based specifically on the fact that EPA has lacked a Core honeybee life cycle study which was supposed to be completed in 2003. It is also intended to instigate a discussion of the appropriateness of the Conditional Registration process.  This petition is only a request that the EPA be required to follow it's own rules and guidelines for pesticide registrations. 
  
Please take time to examine the summary and and consider adding your name to the petition.   It is important that beekeepers participate in this request that the EPA do it's job in protecting our honey bees and our own personal safety as well. 
  
Please send your name, address contact info and a few sentences about why this issue matters to you to Paul Towers: ptowers@panna.org by March 16th.  Or feel free to call him at 415-625-9072 if that is easier. 
  
A link to the petition is available here: Emergency Petition to the EPA

Go to Panna, the Pesticide Action Network to sign a petition to the U.S. E.P.A to pull Bayer's bee-killing pesticide Clothianidin (Petition).

This note is from informed/concerned beekeepers… 
  
 Sincerely,

Jeff Anderson, California Minnesota Honey Farms 
Steve Ellis, Old Mill Honey Co. 
Dave Hackenberg, Hackenberg Apiaries 
Tim Tucker 

Paul Towers
Organizing & Media Director
Pesticide Action Network North America 

Frequently Asked Questions: Legal Petition on Clothianidin

What action is being taken? The parties to this action are exercising their lawful right to petition the U.S. Environmental Protection Agency (EPA) to acknowledge that it has failed to satisfy the legal requirements necessary to allow use of (the legal term is register) the pesticide clothianidin and that, consequently, the Agency should revoke all existing allowances to use this chemical.
Why is this action being taken?        The petitioners are taking this action because the public record confirms that in the case of clothianidin, the EPA has not satisfied the legal conditions that must be met for a pesticide to be registered. This procedural failure by itself is sufficient grounds to revoke a pesticide’s registration because the EPA is not following its own rules. Scientists within the Agency required a field study examining the potential harms of clothianidin to non-target insects - specifically honey bees - because they had reason to believe the pesticide may harm pollinators. In the years since the Agency first required this study, a substant ial body of evidence has accumulated in the peer-reviewed scientific literature confirming that the use of clothianidin as a seed treatment on corn in particular presents substantial risks to honey bees and other insects that are in or near recently sown fields and foraging on corn pollen or on the pollen of nearby plants that take up this extremely persistent pesticide. 
How has EPA failed to meet its legal obligations regarding clothianidin? EPA granted a conditional registration to clothianidin in 2003 without a required field study establishing that the pesticide would have no “unreasonable adverse effects” on pollinators. Granting conditional registration was contingent upon the subsequent submission of an acceptable field study, but this requirement has never been met. EPA continues to allow the use of clothianidin nine years after acknowledging that it had an insufficient legal basis for allowing it to begin with. Additionally, the product labels on pesticides containing clothianidin are inadequate to prevent excessive damage to non-ta rget organisms, which is a second violation of the requirements for using a pesticide and further warrants removing all such mislabeled pesticides from use. Further, the EPA did not consult as required with the U.S. Fish and Wildlife Service under the Endangered Species Act on the potential effects of clothianidin on Federally-listened threatened and endangered species. 
Who is responsible for this action? The petition was researched, written and submitted by a partnership of public interest organizations in collaboration with a national network of affected parties including commercial beekeepers, farmers and consumers. The lead organizations submitting the petition are the Center for Food Safety and its sister organization, the International Center for Technology Assessment, Pesticide Action Network North America and Beyond Pesticides. 
Are the petitioners suing EPA?         No.  A lawsuit would involve filing a court case claiming that the EPA has failed to satisfy its legal obligations and requesting that the judicial system intervene to redress their error. The petition process is an opportunity for a more immediate resolution because the petitioners are going directly to EPA and requesting that it acknowledge and redress its error by itself.
What are the expected outcomes of this action?          This petition initiates a public process under which EPA is required to consider the arguments it contains to revoke clothianidin’s conditional registration. Any individual or organization can submit information that would be relevant to EPA’s review of this subject.  It is possible that EPA could move swiftly to revoke clothianidin’s conditional registration and thereby prohibit its use, take a longer period of time to revoke the conditional registration, impose use restrictions on products containing clothianidin or take no action. The EPA is concurrently conducting a review of clothianidin’s registration, which it projects completing in 2018, which is far too long to wait given the urgent concerns raised in the petition. 

Go to Panna, the Pesticide Action Network to sign a petition to the U.S. E.P.A to pull Bayer's bee-killing pesticide Clothianidin (Petition).



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