EPA Approves New Pesticide Highly Toxic to Bees
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In apparent contradiction to its stated intention to protect pollinators and find solutions to the current pollinator crisis, the U.S. Environmental Protection Agency (EPA) approved the unconditional registration of the new insecticide sulfoxaflor, which the agency classifies as highly toxic to honey bees. Despite warnings and concerns raised by beekeepers and environmental groups, sulfoxaflor will further endanger bees and beekeeping. The U.S. EPA continues to put industry interests first to exacerbate an already dire pollinator crisis.
In January, the agency proposed to impose conditional registration on sulfoxaflor due to inconclusive and outstanding data on long-term honey bee brood impacts. At that time, the agency requested two additional studies—a study on residue impacts, and a field test to assess impacts to honey bee colonies and brood development. This week, the EPA granted full unconditional registration to sulfoxaflor stating that there were no outstanding data, and that even though sulfoxaflor is highly toxic to bees it does not demonstrate substantial residual toxicity to exposed bees, nor are “catastrophic effects” on bees expected from its use. While sulfoxaflor exhibited behavioral and navigational abnormalities in honey bees, the EPA downplays these effects as “short-lived.” The agency says it has reviewed 400 studies in collaboration with its counterparts in Australia and Canada to support its decision. However, these studies do not seem to be currently available in the public scientific literature.
Instead of denying or suspending registration in the face of dire pollinator losses, the EPA instead has chosen to mitigate sulfoxaflor impacts to bees by approving a reduced application rate from that initially requested by the registrant, Dow AgroSciences LLC, as well as increasing the time interval between successive applications. The EPA also approved new pollinator label language it believes to be “robust” to protect pollinators. Sulfoxaflor labels will state language such as:
“Do not apply this product at any time between 3 days prior to bloom and until after petal fall.”
and advisory pollinator statement:
“Notifying known beekeepers within 1 mile of the treatment area 48 hours before the product is applied will allow them to take additional steps to protect their bees. Also limiting application to times when managed bees and native pollinators are least active, e.g., before 7 a.m. or after 7 p.m. local time or when temperature is below 55oF at the site of application, will minimize risk to bees.”
However, beekeepers have noted that 48 hour notice is oftentimes insufficient to move their hives to a safer location and that prior notification is not always provided. Label statements, like those authorized for sulfoxaflor, not only underscore the risks to bees, but like most pesticide product labels are unrealistic since sulfoxaflor is a systemic pesticide whose residues can continue to exist in the plant (including pollen and nectar) for longer periods of time that well surpasses the recommended application intervals, and therefore exposes bees to residues longer than suggested. Similarly, label language such as this is extremely difficult to enforce at the use level.
Several comments were submitted by concerned beekeepers and environmental advocacy groups, like Beyond Pesticides, that stated that approval of a pesticide highly toxic to bees would only exacerbate the problems faced by an already tenuous honey bee industry and further decimate bee populations. However, the EPA outrightly dismissed these concerns and instead pointed to a need for sulfoxaflor by industry and agriculture groups to control insects no longer being controlled by increasingly ineffective pesticide technologies.
The EPA also noted that none of the objections to sulfoxaflor registrations pointed to any data “to support the opinion that registration of sulfoxaflor will pose a grave risks to bees,” even though the agency itself acknowledges that sulfoxaflor is highly toxic to bees. Instead, the agency says, “Comments suggested that pesticides can pose risks to bees and that the agency should not allow yet another pesticide to threaten bees.”
The agency’s approval of sulfoxaflor and its attempts to mitigate risks to honey bees highlight the real deficiencies in the agency’s risk assessment process. Risk assessment approaches have historically underestimated real-world risks, and attempts to mitigate adverse impacts with measures that prove insufficient and impractical. These risk assessment approaches make determinations that the risks are “reasonable,” while failing to take into account numerous circumstances and realities that make honey bees vulnerable to chemical exposures, including user failure to adhere to application rate guidelines, and local environmental conditions that may predispose crops, and other plants, to accumulate higher chemical residues, especially in nectar and pollen. In addition to risks to bees, sulfoxaflor is also classified as “suggestive evidence of carcinogenic potential” based on the incidence of tumors and carcinomas in mice and rats.
Given the global phenomenon of bee decline and the recent precautions taken in the European Union regarding bee health with the two-year suspension of neonicotinoid pesticides known to be highly toxic to bees, it is irresponsible that the EPA will allow yet another chemical with a high potential to be hazardous to bee health into the environment. It is also counterintuitive to current agency and interagency work to protect pollinators.
Sulfoxaflor is a new active ingredient, whose mode of action is similar to that of neonicotinoid pesticides—it acts on the nicotinic acetylcholine receptor in insects. Even though it has not been classified as a neonicotinoid, it elicits similar neurological responses in honey bees, with many believing that sulfoxaflor is the new generation of neonicotinoid. Sulfoxaflor will be registered for use on vegetables, fruits, barley, canola, ornamentals, soybeans, wheat and others.
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By Lindsey Schneider, Joshua Sbicca and Stephanie Malin
The SARS-CoV-2 virus is novel, but pandemic threats to indigenous peoples are anything but new. Diseases like measles, smallpox and the Spanish flu have decimated Native American communities ever since the arrival of the first European colonizers.
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History Reverberates on Native Lands<p>Native communities in North America have been disrupted and displaced for centuries. Many face long-standing food and water <a href="http://www.nativepartnership.org/site/DocServer/2017-PWNA-NPRA-Food-Insecurity-Project-Grow.pdf?docID=7106" target="_blank">inequities</a> that are further complicated by this pandemic.</p><p>On the Navajo reservation, which covers more than 27,000 square miles in Arizona, Utah and New Mexico, 76% of households already <a href="https://www.researchgate.net/publication/235390130_High_levels_of_household_food_insecurity_on_the_Navajo_Nation" target="_blank">have trouble affording enough healthy food</a>, and the nearest grocery store is often hours away. COVID-related restrictions have further curtailed access to food supplies.</p><p>Clean water for basic sanitary measures like hand-washing is also scarce. Native Americans are <a href="http://uswateralliance.org/sites/uswateralliance.org/files/Closing%20the%20Water%20Access%20Gap%20in%20the%20United%20States_DIGITAL.pdf" target="_blank">19 times more likely</a> to lack indoor plumbing than whites in the U.S. Nearly one-third of Navajo households <a href="https://www.nbcnews.com/news/us-news/coronavirus-hits-indian-country-hard-exposing-infrastructure-disparities-n1186976" target="_blank">lack access to running water</a>.</p><p>Many <a href="https://www.cdc.gov/mmwr/volumes/69/wr/mm6915e3.htm" target="_blank">health issues</a> that can increase COVID-19 mortality rates occur at high levels among Native Americans. These <a href="http://www.ncai.org/news/articles/2020/03/18/the-national-congress-of-american-indians-calls-for-more-attention-to-covid-19-impacts-to-indian-country" target="_blank">underlying</a> and <a href="https://doi.org/10.1016/S0140-6736(20)30893-X" target="_blank">preexisting</a> conditions – things like hypertension, diabetes, obesity and cardiovascular disease – are <a href="https://www.cdc.gov/mmwr/volumes/69/wr/mm6913e2.htm" target="_blank">linked to diet</a> and stem from <a href="https://www.oupress.com/books/15107980/indigenous-food-sovereignty-in-the-united-sta" target="_blank">disruption and replacement</a> of Indigenous food systems.</p>
High Exposure Rates<p>These factors have clear health impacts. On the Navajo reservation, for instance, through May 27, 2020, <a href="https://www.navajo-nsn.gov/News%20Releases/OPVP/2020/May/FOR%20IMMEDIATE%20RELEASE%20-%201620%20recoveries_102%20new%20cases%20of%20COVID-19_and%20one%20more%20death%20reported.pdf" target="_blank">4,944 people</a> out of a population of 173,000 had tested positive for COVID-19, and 159 had died.</p><p>This infection rate per capita exceeds those in hot spots such as <a href="https://www.forbes.com/sites/alexandrasternlicht/2020/05/19/navajo-nation-has-most-coronavirus-infections-per-capita-in-us-beating-new-york-new-jersey/#11a4fac08b10" target="_blank">New York and New Jersey</a>. Importantly, however, it may also reflect a much <a href="https://www.sltrib.com/news/2020/04/19/navajo-nation-has-higher/" target="_blank">more proactive approach to testing</a> on reservations than in many other jurisdictions.</p><p>The fact that elderly people are especially vulnerable to COVID-19 could worsen the pandemic's effects in Indian Country. Elders are the <a href="https://ais.washington.edu/research/publications/spirits-our-whaling-ancestors" target="_blank">keepers of traditional knowledge, tribal languages and culture</a> – legacies whose loss already threatens the persistence of indigenous communities.</p><p>Elders also play key roles in preserving traditional plant and medicine knowledge. In the absence of COVID-19 interventions from Western medicine, many elders have been called on to perform healing practices, which increases their exposure risk.</p>
Little Help From Federal and State Governments<p>Many tribal members rely on the federal government's <a href="https://www.ihs.gov/" target="_blank">Indian Health Service</a> for health care. But <a href="https://theconversation.com/tribal-leaders-face-great-need-and-dont-have-enough-resources-to-respond-to-the-coronavirus-pandemic-134372" target="_blank">lack of capacity</a> at the agency has hampered its response. Budget shortfalls, <a href="https://indiancountrytoday.com/news/report-grossly-inaccurate-data-used-to-divvy-up-relief-funds-for-tribes-9qkkHmeXj0uhRC42mXYqCA" target="_blank">inaccurate data</a>, the challenges of providing <a href="https://indiancountrytoday.com/news/coronavirus-risk-is-compounded-by-the-rural-DC-rMTUzzE6WDGee8jbENQ" target="_blank">rural health care</a> and ongoing personnel shortages in IHS clinics are compounded by staff being <a href="https://navajotimes.com/reznews/dikos-ntsaaigii-doodaa-nation-musters-defense-against-covid-19/" target="_blank">pulled away</a> to fight the virus in large cities.</p><p>And while many states have raised frustrations with the Trump administration's unwillingness to distribute protective supplies from the <a href="https://www.vox.com/recode/2020/4/3/21206170/us-emergency-stockpile-jared-kushner-almost-empty-coronavirus-medical-supplies-ventilators" target="_blank">dwindling national stockpile</a>, IHS and tribal health care authorities <a href="https://www.azpm.org/p/home-articles-news/2020/3/17/167874-bill-calls-for-more-tribal-community-access-to-federal-stockpile-of-medical-supplies/" target="_blank">never had access</a> to the stockpile at all.</p><p>Although the federal government has begun <a href="https://www.hhs.gov/about/news/2020/05/22/hhs-announces-500-million-distribution-to-tribal-hospitals-clinics-and-urban-health-centers.html" target="_blank">distributing relief funds</a> to IHS agencies, there have been serious problems with the accompanying supplies. The Navajo Nation has received <a href="https://www.indianz.com/News/2020/05/22/propublica-former-trump-aide-provided-fa.asp" target="_blank">faulty masks</a>, and a Seattle Native health center asked for tests but <a href="https://www.nbcnews.com/news/us-news/native-american-health-center-asked-covid-19-supplies-they-got-n1200246" target="_blank">received body bags instead</a>.</p><p>Meanwhile, federally imposed limits on tribal sovereignty have obstructed tribal governments' efforts to deal with the pandemic themselves. Federal and state governments are <a href="https://www.seattletimes.com/seattle-news/makah-tribe-fights-coronavirus-with-self-reliance-and-extreme-isolation/" target="_blank">challenging tribes' jurisdictional authority</a> to <a href="https://www.azfamily.com/news/mayor-of-page-accused-of-racist-social-media-comment-toward-navajo-nation-president/article_e2e6efd6-8db4-11ea-a8a2-7f6976d702f6.html" target="_blank">close borders to tourists</a> who may carry the virus. South Dakota's governor has <a href="https://www.theguardian.com/us-news/2020/may/14/sioux-coronavirus-roadblocks-south-dakota-governor" target="_blank">threatened legal action</a> against two tribes who set up checkpoints to monitor incoming traffic on their reservations.</p>
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Environmental Injustices on Native Land<p>Energy development and resource extraction have had <a href="https://www.haymarketbooks.org/books/898-all-our-relations" target="_blank">disproportionate impacts</a> on tribes for many years. Today, many Native American leaders worry that ongoing energy production – <a href="https://www.ncsl.org/research/labor-and-employment/covid-19-essential-workers-in-the-states.aspx" target="_blank">an "essential" activity under federal guidelines</a> will bring outsiders into close contact with reservation communities, worsening COVID risks.</p><p>The owners of the Keystone XL oil pipeline have announced that they intend to continue construction, which will bring an influx of workers along the proposed route through Montana, South Dakota and Nebraska. The Rosebud Sioux Tribe in South Dakota and Fort Belknap Indian community in Montana have filed for a <a href="https://www.narf.org/keystone-xl/" target="_blank">temporary restraining order</a>, and a key permit for the pipeline was <a href="https://www.democracynow.org/2020/4/16/headlines/us_judge_revokes_crucial_permit_for_keystone_xl_pipeline" target="_blank">revoked in April 2020</a>, but work continues at the U.S.-Canada border.</p><p>Construction is accelerating on the <a href="https://www.azcentral.com/story/news/politics/border-issues/2020/03/17/border-patrol-waives-laws-border-wall-construction-southern-arizona/5063618002/" target="_blank">southern border wall</a>, which bisects the <a href="http://www.tonation-nsn.gov/" target="_blank">Tohono O'odham reservation</a> in Arizona and Mexico. The Trump administration has <a href="https://www.thenation.com/article/politics/border-coronavirus-military-immigration/" target="_blank">increased patrols at the border</a>, despite the tribe's concern that the patrols' presence is <a href="https://www.usatoday.com/story/news/nation/2020/04/06/coronavirus-cbp-160-cases-covid-19-officers-agents/2958736001/" target="_blank">spreading coronavirus</a> on the reservation.</p><p>And in Bristol Bay, Alaska, a salmon fishing season that brings in thousands of temporary workers is <a href="https://indiancountrytoday.com/news/it-s-hard-when-you-love-something-xlS49l2N20KZjqumwfzZfQ" target="_blank">set to open in June</a> because the federal government has also deemed commercial fishing "<a href="https://www.cisa.gov/sites/default/files/publications/CISA-Guidance-on-Essential-Critical-Infrastructure-Workers-1-20-508c.pdf" target="_blank">essential critical infrastructure</a>." Many local Native villages depend on the fishery for income, but have nonetheless pleaded with state regulators to <a href="https://indiancountrytoday.com/news/urgent-calls-to-close-the-massive-bristol-bay-fishery-8lYsGkUeDUyCBW7FMwpSfA?fbclid=IwAR1710u4rQnriq_MgH2ueQxOFtfGiGiH8I2ZdJRCZS9f28Zl-JNkPLpnzZo" target="_blank">cancel the season</a>. The regional hospital has just four beds for possible COVID-19 patients.</p>
Bold Action in Native Communities<p>Native communities are taking decisive action to reduce the spread of COVID-19. They're imposing aggressive <a href="https://www.nytimes.com/2020/04/09/us/coronavirus-navajo-nation.html" target="_blank">quarantine</a> measures like lockdowns, curfews and border closures. Communities are <a href="https://www.theguardian.com/us-news/2020/mar/18/covidcoronavirus-native-american-lummi-nation-trailblazing-steps" target="_blank">ramping up health care capacity</a> and elder support services, and banishing nontribal members who <a href="https://rapidcityjournal.com/news/local/oglala-sioux-council-banishes-non-member-with-covid-19-from-reservation/article_60b665c3-9d1b-5d48-a576-51774e4fb41a.html" target="_blank">violate travel restrictions</a>.</p><p>Other strategies include helping hunters <a href="https://indiancountrytoday.com/news/ammo-fuel-for-hunters-to-feed-others-Ki3zK6du-ky-UogoB9-aNQ" target="_blank">provide traditional foods</a> to their communities, <a href="https://ndncollective.org/indigenizing-and-decolonizing-community-care-in-response-to-covid-19/" target="_blank">mobilizing to support tribal health care workers</a>, and <a href="https://www.ehn.org/coronavirus-native-americans-2645923635.html" target="_blank">linking the pandemic and the climate crisis</a>. Looking ahead to a post-COVID future, we believe one priority should be attending to <a href="http://www.beacon.org/As-Long-as-Grass-Grows-P1445.aspx" target="_blank">front-line environmental justice struggles</a> that center tribes' sovereignty to act on their own behalf at all times, not just during national crises.</p>
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