U.S. Environmental Protection Agency 1. Tom Moriarty Office of Pesticide Programs U. S. Environmental Protection Agency.

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1 U.S. Environmental Protection Agency 1 Tom Moriarty Office of Pesticide Programs U. S. Environmental Protection Agency. 1

2 U.S. Environmental Protection Agency 2 Bee Health Multiple federal reports have identified pollinator declines. rd_id=

3 U.S. Environmental Protection Agency 3 Bee Health: USDA Winter Loss Survey Over wintering losses have averaged roughly 31% Percent Loss Year Based on USDA Winter Loss Survey Data; CCD Annual Report

4 U.S. Environmental Protection Agency 4 Bee Health and CCD Contribution of CCD to total winter losses has declined in recent years. Most recent data for indicate that CCD may account for ~60% of winter loss. Source: USDA Winter Loss Survey Data

5 U.S. Environmental Protection Agency 5 Bee Health USDA has identified multiple factors; no single factor identified as cause. Disease/Parasites Fungi Agricultural Practices Bacteria Viruses Urbanization Parasites Other Insects Bee Management Practices Pesticides Nutrition Source: USDA Agricultural Research Service

6 U.S. Environmental Protection Agency 6 Neonicotinoid Insecticides Several subclasses: nitroguanidines, cyanoamidines, sulfoxamines, nithiazines Nitroguanidine substituted: imidacloprid; thiamethoxam; clothianidin; dinotefuran Low application rates. Numerous use sites ag and non ag.; commercial and residential. High percentage of acreage treated (clothianidin, imidacloprid and thiamethoxam are among the top ten compounds applied to all agricultural acreage). All incorporate bee warning statements on labels. The majority of research and public interest has been focused on nitroguanidine subclass.

7 U.S. Environmental Protection Agency 7 Neonicotinoid Insecticides Imidacloprid: Registered in 1994 Thiamethoxam Registered in 2000 Clothianidin Registered in 2003 Dinotefuran Registered in 2003

8 U.S. Environmental Protection Agency 8 Neonicotinoid Insecticides Summary of Previous Risk Conclusions for the Neonicotinoids Main concern is risk to insects in terrestrial and aquatic habitats Cyano substituted neonics are less toxic to bees (acute) In some cases, neonics may pose a risk to mammals and birds Passerine birds may be more sensitive than standard test species In general, these chemicals do not pose a risk to fish or plants Acetamiprid is an exception Some of these chemicals have degradates of concern

9 Evolution of Pollinator Mitigation for Neonics Imidacloprid, Provado 1995 (at initial registration): This product is highly toxic to bees exposed to direct treatment or residues on blooming crops or weeds. Do not apply this product or allow it to drift to blooming crops or weeds when bees are visiting the treatment area. 2004: As with any insecticide, care should be taken to minimize exposure of PROVADO to honey bees and other pollinators. Use of PROVADO on crops requiring bee pollination should be avoided during bloom and a minimum of 1 0 days prior to bloom. Additional information on PROVADO uses for these crops and other questions may be obtained from the Cooperative Extension Service, PCAs, consultants or local Bayer CropScience representatives : (Added the following to strawberry, and citrus) Do not apply during bloom or within 1 0 days prior to bloom or when bees are actively foraging 9

10 10 Evolution of Pollinator Mitigation for Neonics Clothianidin, Arena 50 WG 2004 (at initial registration): This product is toxic to bees exposed to direct treatment or residues on blooming crops. Do not apply during bloom or when bees are present. 2007: This product is toxic to bees exposed to treatment and for more than 5 days following treatment. Do not apply this product to blooming, pollenshedding, or nectar producing parts of plants if bees may forage on plants during this time period, unless the application is made in response to a public health emergency declared by appropriate state of federal authorities.

11 11 Evolution of Pollinator Mitigation for Neonics Summer, 2013 Initiative July 22, 2013 Letter to Nitroguanidine Neonicotinoid Registrants Alerted Registrants to EPA s concern for potential adverse effects on pollinators and the need for clearer labeling, with guidance to follow in mid August Put Registrants on notice to submit pollinator protection stewardship plans and efficacy data that describes the movement and concentration of active ingredients and major degradates in plant structures, fluids and tissues ( translocation data ). Due September 4, 2013 August 15, 2013 Letter Describing the New Labeling Specific to foliar applied products containing clothianidin, dinotefuran, imidacloprid, thiamethoxam Bee Icon Pollinator Protection Box Restrictions for application at bloom in the Directions for Use Does not replace more restrictive labeling

12 U.S. Environmental Protection Agency 12 Neonicotinoid Insecticides Pollinator protection language that has been applied to the neonicotinoid insecticides. Pesticide labels on these products will continue to retain more restrictive language.

13 U.S. Environmental Protection Agency 13 Neonicotinoid Insecticides Registration Review Compound Docket Opened Data Generation Completion of Re evaluation Imidacloprid Dec Clothianidin Dec Thiamethoxam Dec Dinotefuran Dec Acetamiprid Dec All but imidacloprid were originally scheduled to open between FY 13 and FY 15. In 2009, all the neonics were moved up. Nitro guanidines were then further seperated from the cyano substituted. Collaborating with California DPR and Health Canada s PMRA on imidacloprid, clothianidin, thiamethoxam and dinotefuran. All compounds being approached in light of the pollinator risk assessment process. o Data approach between agencies is not identical, but supplement each other.

14 U.S. Environmental Protection Agency 14 Neonicotinoid Insecticides Registration Review Data in house includes acute studies, and some field data. Data on pollinators required under Registration Review include: Residues in Pollen and Nectar Larval Toxicity Test Chronic Toxicity Study Pollinator Field Study Semi field study Full field study Requesting additional data/information from the registrants (e.g. older studies, or data generated for European purposes) Including open literature in the review Partnering with CDPR and PMRA on the science.

15 U.S. Environmental Protection Agency 15 Neonicotinoid Insecticides Exposure via Dust Drift Actions to reduce potential exposure via dust drift (fugitive dust) EPA and USDA brought different stakeholders together and mediate an exchange of information and efforts that are aimed at reducing exposure associated with pesticide treated seed. Focused on technology of seed coatings Technology of seed delivery Communication and BMP s To reduce potential drift of abraded seed coat dust, equipment manufactures in collaboration with registrants and seed treaters are working domestically and internationally to develop international standards aimed at reducing dust from treated seed.

16 U.S. Environmental Protection Agency 16 Engaging Stakeholders Reducing Dust Drift EPA as well as other federal agencies have MOUs with the Pollinator Partnership Recognizes value of outreach, education and research toward understanding and mitigating factors associated with pollinator declines. EPA providing technical input to Corn Dust Research Consortium attempting to address uncertainties associated with dust off.

17 U.S. Environmental Protection Agency 17 Engaging Stakeholders Reducing Exposure Summit highlighting stewardship efforts Seed treatment stewardship guide Alternatives to currently used lubricant in seeding equipment Improvements in formulation technologies and Best Practices for seed treatments and grower education Education and outreach

18 U.S. Environmental Protection Agency 18 Advancing Communication and Outreach CCD and Honey Bee Health Steering Committee Honey Bee Health Summit EPA collaborated with USDA on two other summits examining factors affecting bee declines Other Stakeholder Summits Pests (Varroa mite) Vectoring diseases (viral) Nutrition

19 U.S. Environmental Protection Agency 19 Bee Health and Neonicotinoid Insecticides Multiple factors associated with declines in pollinator health. Pesticides are one factor; not a cause. The Agency is aware of no data that supports the claim that neonicotinoids are the cause of CCD or of honeybee health declines. Varroa mite and the viruses vectored by the mite contribute to reduced longevity of bees. (EPA has made efforts to make more miticide tools available to beekeepers) EPA is supportive of efforts to increase forage resources for bees EPA collaborating with its regulatory partners to evaluate the potential risks from neonicotinoids using a science based approach and the new pollinator risk assessment framework. EPA is collaborating with broad range of stakeholders to develop and implement tools for reducing exposure of bees to pesticides.

20 U.S. Environmental Protection Agency 20 Questions?