Submission of comments on docket: EPA–HQ-OPP-2008-0844                                 Pollinator Ecological Risk Assessments: Imidacloprid Registration

Submitted online:                           !submitComment;D=EPA-HQ-OPP-2008-0844-0142;p=0

April 8, 2016

To: U.S. Environmental Protection Agency

We are writing to express our deep concerns regarding the use of imidacloprid and its toxicity to bees, as well as to entire ecosystems, including humans.   It is imperative that the U.S. EPA move as quickly as possible to cancel registration of this toxic pesticide.

As a systemic neonicotinoid, imidacloprid poisons the entire plant, contaminating pollen and nectar, exposing bees to the harmful residues.

Though preliminary, EPA’s assessment provides evidence for a ban on imidacloprid for five reasons:

  1. The insecticide is highly toxic to honey bees, even at extremely low levels. Reduced numbers of worker bees, foraging, queen survival and delayed development have all been observed.
  2. Wild and native bees, many more vulnerable than honey bees, continue to go overlooked and unprotected.
  3. Impacts from contaminated soil, water, and even honey dew also go underestimated.
  4. Contaminated dust from planting imidacloprid-coated seeds which leads to residues on nearby plants, soil and surface water, causing direct and indirect exposures was not considered in the assessment.
  5. Treated crops like cotton and citrus pose grave risks to bees.

Neonicotinoids: Environmental Risks

  • Cynthia Palmer, Pesticides Program Manager for ABC, one of the nation’s leading bird conservation organizations, says of neonicotinoids, “It is clear that these chemicals have the potential to affect entire food chains. The environmental persistence of the neonicotinoids, their propensity for runoff and for groundwater infiltration, and their cumulative and largely irreversible mode of action in invertebrates raise significant environmental concerns.”
  • Neonicotinoids’ toxicity to bees and other insects has brought these chemicals the most attention thus far and has dominated recent concerns of regulatory institutions worldwide. The serious risk to bees should not be understated as one-third of the U.S. diet depends on these insect pollinators. However, the ABC assessment mentioned above also makes clear that the potential environmental impacts of neonicotinoids go well beyond bees. The report urges EPA to expand its registration review of neonicotinoids to include birds, aquatic invertebrates, and other wildlife.
  • A U.S. Environmental Protection Agency preliminary honey bee risk assessment released on Jan. 6, 2016 confirmed harmful residues of neonicotinoids on crops, including citrus, where the pollinators forage. The assessment confirms bees’ widespread and sustained exposure to the highly toxic and persistent chemical through poisoned pollen and nectar.


Human Health Risks

  • Experts at the European Food Safety Authority have found evidence that

neonicotinoids can damage the developing human nervous system – particularly the brain. The harmful effects on brain development are similar to those caused by nicotine found in tobacco. This finding suggests that these chemicals pose a particular threat to developing infants and children by damaging their ability to learn, which could limit their achievements in school and later life.

Cumulative and Synergistic Health Effects

  • A University of California, Los Angeles study released in February, 2016

( found increased cancer risk from exposure to a combination of 3 commonly used pesticides in California and asserts that the California Department of Pesticide Regulation should, by law, be evaluating the cumulative and synergistic effects of exposure to multiple pesticides whether or not the pesticides have the same mechanism of action.

There is a growing understanding that the health of the ecosystem is the most effective deterrent to pest problems.       

  • Supporting a healthy soil food web – Healthy soil needs food, such as compost,

mulch, and green manure cover crops, for soil microbes. According to renowned soil microbiologist Dr. Elaine Ingham, maximizing the diversity and strength of soil life prevents pest and disease-causing problems.   For information about Dr. Ingham’s research, see:…/, especially from 11:58 to 13:46

  • The Food and Agriculture Organization of the United Nations’ Report: Soils and

Biodiversity speaks about the functions of soil biota including the “suppression of pests, parasites and diseases”.

“The quality and health of soils largely determine agricultural production and sustainability, environmental quality and, as a consequence of both, has bearing on plant, animal and human
health. Improving soil biodiversity is vital to ensuring soil health and future food and nutrition security.”

In summary, we are advocating for sustainable agricultural methods that support healthy biodiversity in the ecosystem. It is increasingly apparent that imidacloprid is too toxic for bees and entire ecosystems. Given the high degree of uncertainties in the EPA’s assessment, it is imperative that the EPA cancel the registration of imidacloprid.


Patricia Pagaling                                                                                                                                     Director, Transition to Organics