EPA And Leaked Clothianidin Memo

Wikileaks revealed a memo from the EPA, the regulatory body that grants marketing authorisations for pesticides such as Clothianidin, in the USA.

The EPA has been criticised for allowing the sale of pesticides pending further evidence to be provided by the pesticide manufacturer.

Here is a quote from the leaked memo:

“However, after another review of this field study in light of additional information, deficiencies were identified that render the study supplemental.

It does not satisfy the guideline 850.3040, and another field study is needed to evaluate the effects of clothianidin on bees through contaminated pollen and nectar.

Exposure through contaminated pollen and nectar and potential toxic effects therefore remain an uncertainty for pollinators.”

(Note for British readers: Clothianidin is also licensed for use in the UK and the EU.  The insecticide was approved by the EU regulatory system for insecticides).

Finally, the EPA have responded to overwhelming criticism from the public. US Beekeeper and campaigner, Tom Theobald has put together his own comments on the EPA response. 

However, before you read Tom’s comments, I’d like to draw your attention to a particular comment, and it is this: 

The EPA say:

- Your letter refers to the "imminent hazard" you believe to be posed by clothianidin and urges the Agency to issue a "stop use order" to address the situation. Let me clarify how a stop sale, use and removal order operates.

The Agency is authorized to issue a stop sale, use, and removal order under section 13 of FIFRA in response to a violation of FIFRA or after a pesticide has been cancelled or suspended. 7 U.S.C. ~ 136k(a).

Since clothianidin has not been cancelled or suspended and there has not been a violation of FIFRA, it is unclear what basis the Agency would have for issuing such an order.

Tom Theobald says:

- Is this a Catch 22 or what? We can’t stop the sale or use because it hasn’t been cancelled, and we aren’t going to cancel it.

The basis for issuing such an order is that clothianidin has failed to meet the requirements for registration, independent of all this other gibberish.

Tom skilfully returns the EPA back to the central point: if the product has not met the registration requirements, should it be on the market in the first place?

In Europe, there exists a ‘Precautionary Principle’. 

The Precautionary Principle states:

“Member States shall ensure that a plant protection product is not authorized unless…..it has no unacceptable influence on the environment…Authorizations may be reviewed at any time if there are indications that any of the requirements….are no longer satisfied.” - EU Directive 91/414

However, they have not required a full ban on neonicotinoids regardless, and the EFSA investigation showed that not all regulatory requirements had been met prior to approval of systemic insecticides via the EU regulatory system.

EPA Response to Clothianidin Memo and Tom Theobald's Comment

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