Pesticides and You News from Beyond Pesticides: Protecting Health and the Environment with Science, Policy & Action Volume 35, Number 4 Winter 2015-16

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Cultivating Plants that Poison A Special Report on Systemic Pesticides

Also in this issue: What’s Up With Organic Standards? Letter from Washington

35 Years of Progress and the Tipping Point Within Our Sight

eyond Pesticides in 2016 celebrates a rich 35-year history of agricultural systems can feed the world better than chemical-intensive accomplishments in organic policy and land management. We approaches. While we tinkered with integrated pest management Bare honored to be part of an extensive network of communities, (IPM) as an agricultural tool to reduce pesticide dependency, the lack people, organizations, scientists, and practitioners that educates on of a holistic approach to soil health, protection of biodiversity, and the hazards of pesticides, while moving decision and policy makers the identification of least-toxic inputs diminished its effectiveness as a to adopt sustainable organic practices. With its proven viability, we long-term sustainability approach in land management. see within our sights the opportunity for a societal transformation to organic practices that protect the environment on which life depends. I served on the National Organic Standards Board (NOSB) for a 5-year term (2010-2015). Having spearheaded the 1982 Organic Farming Meeting the urgent challenges Act, which became the 1983 Agricultural Productivity Act and USDA’s We use this occasion only to reenergize ourselves to meet the urgent Low-Input Sustainable Agriculture (LISA) program, and then the 1990 challenges ahead. We are at the center of the organic transformation Organic Foods Production Act (OFPA), we knew we had tremendous that crosses issues of clean air and water, healthy food, and soil practices institutional barriers within USDA to implement policies that defied that build organic matter, sequesters carbon, and slows climate change. the chemical-intensive norms. In fighting pesticides, we protect pollinators and the ecosystem, advance systems that eliminate toxic pesticides, ensure workplaces safe for We understood that change starts in the community. Communities workers, and create communities protective of vulnerable population are increasingly seeking to prevent and eliminate, rather than simply groups like children and those with pre-existing health conditions. reduce, toxic chemical use. They recognize the importance of healthy Organic management systems are required –whether in agriculture, ecological systems at a time when increasingly smaller doses of parks, playing fields, or rangeland, from backyards to vineyards, from systemic chemicals wreak havoc with life and the natural balance. playing fields to cornfields. We can no longer afford toxic-intensive approaches that are not necessary. Local power The recent passage in October, 2015 of legislation banning toxic lawn Talking a holistic organic approach pesticides on both public and private land in Montgomery County, Since our founding in 1981, Beyond Pesticides has taken a holistic Maryland, with one million people the largest such jurisdiction in approach to advancing sustainable practices and policies and solving the U.S., is an achievement that we seek to replicate in increasing the pesticide poisoning and contamination problem through the numbers across the country. This victory, in addition to ones in adoption of organic policies and practices. We understood from our Ogunquit, Maine (2014) and in Takoma Park, Maryland (2013), inception that the dependency on toxic pesticides is unnecessary brought national attention to possibility of community-wide transition since productivity, profitability, and quality of life can be achieved with to organic land management. Industry is now pushing legislation in organic systems. In this context, although our founders recognized the Maine and Maryland to overturn local law restricting pesticides and importance of measures to restrict pesticide use through improved prevent future local action, as is the case in 43 states that preempt chemical regulation and effective toxic pesticide use reduction local municipalities. Our community-based work recognizes that strategies, we believed a crosscutting grassroots organization was pesticides move off the target site and onto neighboring land and into needed to help reframe the public debate that had emerged since the waterways through drift in the air and runoff, causing “secondhand” publication of Silent Spring, less than 20 years earlier. poisoning and contamination.

Breaking down institutional barriers Providing the tools for change Despite laws governing clean air, water, food safety, and pesticides of Our continued documentation of the science on adverse health and the 1970’s, the chemicalization of society advanced at tremendous environmental effects of pesticides and weaknesses in the regulation speed with full support of the chemical industry, the U.S. Department of these toxic chemicals informs local action and is helping to drive of Agriculture (USDA), the Environmental Protection Agency (EPA), the market toward organic. At the same time, it is critical that we and state and local governments nationwide. In fact, the pesticide defend the foundational federal organic law that establishes the law, which remains to this day under the jurisdiction of the Agriculture standards governing sustainable practices Committees of Congress, incorporated an institutional bias that highly against an attack by some food and toxic pesticides are essential to food productivity and quality of life. chemical companies, and the right of local Our work to advance organic agricultural systems created a new policy governments to stop hazardous pesticide framework and helped to launch a precautionary approach, starting use throughout their jurisdictions. It’s an with the premise that we do not need toxic chemicals to achieve food honor to work with you! Thank you! productivity goals. Rather, we recognized that the law must require restoration and regeneration of the soil. Since the early years of the Jay Feldman is executive director of Beyond organization, numerous studies and experience show that organic Pesticides. Pesticides and You © 2016 (ISSN 0896-7253) is published four times a year by Beyond Pes- ticides. Beyond Pesticides, founded in 1981, is a voice for health and the environment, promoting protection from pesticides and safe Contents alternatives; donations are tax-deductible.

National Headquarters: 701 E Street, SE Washington DC 20003 ph: 202-543-5450 fx: 202-543-4791 email: [email protected] website: www.beyondpesticides.org

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BEYOND PESTICIDES STAFF Jay Feldman, Executive Director Stephanie Davio, Program Director/Forum Coordinator Nichelle Harriott, Science and Regulatory Director page 9 Drew Toher, Public Education Associate Nikita Naik, Science Associate Annie D’Amato, JD, Policy and Legal Associate Matt Wallach, IPM and Health Care Facility Project Director 2 Mail Amila Weerasingha, Public Education Kids Deserve Organic Lunches; How Far Has the Pesticide-Free Assistant Movement Spread? Jen Ruocco, Executive Assistant Sandy Rowley, Western Regional Coordinator Terry Shistar, Ph.D., Science Consultant 4 Washington, DC Aubrey Stevenson, Fellow Genetically Engineered Salmon Halted Due to Required Labeling Guidelines; EPA Releases Overdue Revisions to Worker Protection Standards; USDA PESTICIDES AND YOU Jay Feldman, Publisher, Editor Scientist Punished for Neonic Study Files Complaint (Federal Judge Permits Stephanie Davio, Jay Feldman, Nichelle USDA Whistleblower Case to Proceed); EPA Rule Clarifies Disclosure Harriott, Nikita Naik, Jen Ruocco, Annie Requirement of All Ingredients in Exempt Minimum Risk Pesticides D’Amato, JD, Drew Toher, Terry Shistar, Ph.D., Contributors Stephanie Davio, Layout 6 Around the Country EPA Sued for Failure to Regulate Neonics, as Agency Data Confirms Hazards; BOARD OF DIRECTORS Montreal, Canada Proposes “Complete Ban on Neonics;” DuPont and Dow Routt Reigart, M.D., president, Medical Merge to Become Biggest Pesticide Conglomerate; Records Show Suspended University of South Carolina, Charleston, SC Oregon Pesticide Spray Company Continues Operations; Campbell Soup Says Lani Malmberg, vice-president, Ewe4ic Eco- logical Services, Cheyenne, WY GE Food Is Safe, Endorses Mandatory GE Labeling to Preempt States with Terry Shistar, Ph.D., secretary, Lawrence, KS Weak Language; Home Depot Announces Phase Out of Bee-Toxic Pesticides Caroline Cox, treasurer, Center for Environmental Health, Oakland, CA 9 What’s Up With Organic Standards? Chip Osborne, at-large, Osborne Organics, Marblehead, MA Rella Abernathy, Ph.D., City of Boulder IPM 11 Cultivating Plants that Poison: A Special Report on Program, Boulder, CO Systemic Pesticides Nelson Carrasquillo, The Farmworkers Support Committee (CATA), Glassboro, NJ Paula Dinerstein, Public Employees for En- vironmental Responsibility, Washington, DC Lorna Donaldson, Donaldson Family Farm, Tiptonville, TN Melinda Hemmelgarn, RD, Food Sleuth, LLC., Columbia, MO Jay Feldman, Beyond Pesticides, Washington, DC Warren Porter, Ph.D., University of Wisconsin, Madison, WI Brett Ramey, University of Washington School of Medicine, Seattle, WA Robina Suwol, California Safe Schools, Van Nuys, CA

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Kids Deserve Organic School Lunches Share With Us! Dear Beyond Pesticides, Beyond Pesticides welcomes your questions, comments I am on the Wellness Committee for my community public school or concerns. Have something you’d like to share or ask system. I am trying to convince this entity to serve our children us? We’d like to know! If we think something might be organic, clean foods. Can you please provide me with information particularly useful for others, we will print your comments to help convince them of the health benefits of serving better food in this section. Mail will be edited for length and clarity, to their students? and we will not publish your contact information. There are Mary-Lou C., Amherst, MA many ways you can contact us: Send us an email at info@ beyondpesticides.org, give us a call at 202-543-5450, or Hi Mary-Lou, simply send questions and comments to: 701 E Street SE, We’re happy to help with your efforts to promote organic op- Washington, DC 20003. tions for children in your local school system. Children are more vulnerable to pesticide exposure because they take in more of a pesticide than adults relative to their body weight, and have sensitive, developing organ systems. In 2012, the American Academy account the advice of experts, such as the AAP, and consider the of Pediatrics (AAP) released a landmark policy statement recom- true cost of feeding children a diet of chemically grown food. These mending that governments take action to reduce children’s expo- costs are borne not only by individual children through health sure to pesticides, asserting that, “Children encounter pesticides impacts, such as cancer, ADHD, and other learning disorders caused daily and have unique susceptibilities to their potential toxicity.” by neurotoxic pesticides sprayed on conventional food. They also Of particular relevance to your efforts, the AAP notes that diet impact the health of farmers and farmworkers, the environment, is likely the main pathway for pesticide exposure in children. The water quality, and wildlife, including our declining pollinator report references a 2006 study which took a group of children and populations. A 2004 study estimated the cost of chemical-intensive switched them from a conventional diet to an all-organic diet for farm practices to be nearly $16.9 billion per year. We still pay these five days, and measured urinary pesticide metabolite levels two costs, just not at the end of a school’s lunch line. times a day. Results showed a stark drop in the levels of toxic organophosphate pesticides measured immediately after beginning Making the case for organic lunches will take more than just an organic diet. Levels remained below the level of detection until good data, unfortunately. A good strategy is to get in contact with the children resumed a conventional diet. Recent data backs up local farmers, experts, organic businesses, and chefs that agree this report. A 2015 study reviewing pesticide metabolite levels in with your approach to safer and healthier organic food for school 4,500 individuals’ urine found that those who reported eating or- lunches. Building a diverse group of advocates will help you break ganic fruits and vegetables, at least occasionally, had significantly through any politics that may impede this important work. Best of lower levels of organophosphate pesticides in their system. luck as you continue your efforts!

The last decade has seen a surge in the number of school districts serving organic food to their students, as well as the parents demanding these options for their children. School districts in Boulder, CO, Chicago, IL, Seattle, WA and New York, NY have begun moving toward providing children with organic options at lunch. Organic companies, like Stonyfield Farms, have sponsored organic lunch programs in Rhode Island, California, New Hampshire, New York and Connecticut.

Despite the data showing reductions in pesticide exposure as a result of a switch to organic, you may encounter push-back from school officials who claim the cost of organic food is too high. However, it’s important for public officials to take into

Page 2 Pesticides and You Vol. 35, No. 4 Winter 2015-16 A quarterly publication of Beyond Pesticides edited by Drew Toher

How Far Has the Pesticide-Free For example, while Manitoba, Nova Scotia, Ontario and Quebec Movement Spread? have banned a wide swath of pesticides for use on public space Have some countries in Europe banned cosmetic use of pesticides and private lawns for cosmetic purposes, provincial regulations just as they have done in Canada? And, have all provinces in Can- in Nova Scotia, New Brunswick, Prince Edward Island (PEI) only ada effectively done so to date, or just some? restrict the use of 2,4-D. Alberta requires that cosmetic pesticide Mara N., Mankato, MN use is conducted by a certified applicator, and Newfoundland and Labrador restrict a few additional chemicals beyond 2,4-D. The Hi Mara, weakest responses have been in British Columbia, which struck Certain Canadian provinces and European countries have stopped down a cosmetic pesticide ban in 2012, and Saskatchewan, where cosmetic use of pesticides, which is roughly defined as the use of no significant cosmetic pesticide regulations have been put into pesticides on lawns and landscapes for aesthetic purposes. In 2014, place. Over 170 municipalities across Canada have their own France passed a law, which will go into effect in 2020, prohibiting by-laws in place restricting cosmetic pesticide use. It’s worth pesticide use in green areas, forests, and public spaces, and put noting that in 2001 Canada’s Supreme Court affirmed the right in place restrictions on products that can be used in homes and of localities to enact cosmetic pesticide restrictions on public and gardens. After the World Health Organization determined that private property. The comprehensive ban in Ontario appears to be glyphosate is a carcinogen based on laboratory animal studies, the only provincial law that preempts localities from going further the country also moved to prohibit the sale of Roundup and other than the province in regulating cosmetic pesticide use. glyphosate-based pesticides in garden centers. Garden centers in other countries, including Germany and Switzerland, stopped The movement toward safer pest management practices in other selling glyphosate-based pesticides after France’s move, despite countries helps inform and inspire action here in the United the absence of government action. There are also major efforts led States. The widespread adoption of cosmetic pesticide restrictions by Pesticide Action Network UK to implement cosmetic pesticide on public and private property in Canada and Europe based on restrictions in local communities there. the precautionary principle strongly resonated with voters in Ogunquit, ME and lawmakers in Takoma Park and Montgomery Eight of ten Canadian provinces, including Alberta, Manitoba, New County, MD when debating their own comprehensive pesticide Brunswick, Newfoundland and Labrador, Nova Scotia, Ontario, bans. As advocates continue work here in the U.S., we can draw Prince Edward Island, and Quebec, have passed some form of upon the regulatory framework, strategies, and experiences restrictions on the use of cosmetic pesticides. There issome of other countries aiming to protect their citizens from the variation in requirements among the provincial bans, however. unnecessary use of toxic pesticides.

From the Web Beyond Pesticides’ Daily News Blog features a post each weekday on the health and environmental hazards of pesticides, pesticide regulation and policy, pesticide alternatives and cutting-edge science, www.beyondpesticides.org/dailynewsblog. Want to get in on the conversa- tion? “Like” us on Facebook, www.facebook.com/beyondpesticides, or send us a “tweet” on Twitter, @bpncamp!

DuPont and Dow to Merge to Become Biggest Pesticide Conglomerate Excerpt from Beyond Pesticides’ original blog post (12/14/2015): Chemical giants DuPont and Dow Chemical Companies announced that their boards of directors unanimously approved a merger of their companies through an all-stock deal, valuing the combined market capitalization at $130 billion. O. Boxworth comments: “Thank you for this article. I agree that this mega-merger (and other big mergers in other sectors) tends toward creating monopolies, which is bad for citizens, in terms of cost, innovation, and undue power and influence in politics. Getting Big Money out of politics in the U.S. is our best chance of curtailing these types of mergers, and of acknowledging the science on the manifold benefits of Organic food production.”

Gloria L. comments: “I’m hoping this will backfire on them. Increasing prices may be an incentive for farmers to go organic.”

Vol. 35, No. 4 Winter 2015-16 Pesticides and You Page 3 A quarterly publication of Beyond Pesticides Washington, DC

Genetically Engineered Salmon Halted Due to Required Labeling Guidelines

In November 2015, the U.S. Food and Drug such as “genetically engineered,” Administration (FDA) approved, without or “This salmon patty was made a labeling requirement, a genetically engi- from Atlantic salmon produced neered (GE) salmon designed to grow fast- using modern biotechnology,” er and come to market quicker than other that producers can consider farmed salmon. The fish, dubbed AquAd- using. The FDA policy makes vantage by its developer, Massachusetts- it virtually impossible for based biotechnology firm AquaBounty, has shoppers wishing to avoid been the center of considerable controversy, the GE fish to make an in- as it represents the first GE animal approved formed decision at the point for commercial sale and human consump- of purchase. While most tion. While FDA has declared the fish safe major food retailers, includ- to eat, and AquaBounty argues the fish will ing Trader Joe’s, Aldi, Whole help feed the world, opponents stress that Foods, Kroger, Costco, Safeway, the potential adverse effects of the tech- and Giant Eagle have announced nology have not been properly vetted, and they will not stock GE salmon, top re- consumers will have no way to tell whether tailer Walmart indicated it was too busy the salmon they purchase at the store is the with Black Friday to issue a decision, and has engineered AquAdvantage product. not issued a further statement. place labeling guidelines and “a program Draft guidelines released by FDA when the Then, in December 2015, a sprawling to disclose to consumers” whether a fish salmon was approved do not require re- federal spending bill passed, including a has been genetically altered. The language tailers to inform consumers that the fish is small section on GE salmon. Lawmakers represents a victory for advocates who genetically engineered. Instead, the agency instructed FDA to forbid the sale of GE en- have long opposed such foods from reach- provided examples of voluntary statements, gineered salmon until the agency puts in ing Americans’ dinner plates.

EPA Releases Overdue Revisions to Worker Protection Standards

In December 2015, the U.S. Senate passed legislation (S.697,Frank R. Lautenberg Chemical Safety for the 21st Century Act) to update the Toxic Substances Control Act (TSCA) of 1976, the national law that regulates industrial chemicals. Before the bill becomes law, it must go to conference committee to iron out the differences of a much different version of the bill approved in June by the U.S. House of Repre- sentatives (H.R. 2576, TSCA Modernization Act of 2015). If the differences are reconciled and passed by both Houses of Congress, it will then go to the president for signature.

The serious problems with the Senate bill include the following: • The legislation makes it more difficult for the Environmental Protection Agency (EPA) to identify and intercept imported products containing a toxic chemical. • States will be blocked from taking action while EPA studies a chemical, potentially delaying urgent public health interventions. • The “low priority” category requires EPA to greenlight some chemicals without a thorough safety review. • There are numerous requirements placed on EPA at industry’s behest that divert scarce resources from the core purpose of identifying and restricting chemicals that cause harm.

Similar to previous versions of TSCA overhaul bills, the latest version that has passed through the Senate takes away states’ rights to prohibit dangerous chemicals, also known as state preemption. According to a press release from the Environmental Health Strategy Center, the Senate bill “takes away states’ rights in a manner unprecedented in the history of federal environmental policy making. It blocks states from restricting dangerous chemicals after EPA simply begins to study a chemical’s danger. That means that known dangerous chemicals will remain unattended at any level of government for years.” This would create an enormous gap in chemical safety protections and expose human health and the environment to undue harm.

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USDA Scientist Punished for Neonic Study Files Complaint (Federal Judge Permits USDA Whistleblower Case to Proceed)

In October 2015, one of the top entomologists at the U.S. Department of Agriculture (USDA) filed a whistleblower complaint against the federal agency, citing unprofessional retaliation following the publication of a study linking neonicotinoid insecticides to the decline of monarch butterflies. Jonathan Lundgren, Ph.D., senior research entomologist and lab supervisor for the agricultural research service (ARS) in South Dakota, is fighting suspension for publishing research deemed “sensitive” by his USDA superiors. According to Jeff Ruch, executive director of Public Employees for Environmental Responsibility (PEER), which is providing legal services to Dr. Lundgren, this case underscores why legal protections for government scientists are sorely needed.

In April 2015, Dr. Lundgren published a study in The Science of Nature that found clothianidin, a neonicotinoid insecticide often used to coat seeds, kills monarch butterfly larvae in the laboratory. In August 2015, USDA imposed a 14-day suspension against Dr. Lundgren for submitting the study and for a paperwork error in his travel authorization for his invited presentation about his research to a panel of the National Academy of Sciences, as well as to a USDA stakeholder group, the Pennsylvania No-Till Alliance. The suspension was cut to 14 days from 30 after Dr. Lundgren filed an appeal.

In late 2015, Judge Patricia M. Miller of the Merit Systems Protection Board denied USDA’s request to dismiss the claim filed by Dr. Lundgren. USDA and Dr. Lundgren were ordered by the court to convene a status conference, which occurred on January 6, 2016, to discuss a potential settlement, however as of this reporting a settlement has not been announced.

Dr. Lundgren will join Beyond Pesticides for a presentation at the 34th National Pesticide Forum in Portland, ME on April 15-16, 2016. The conference brings together top scientists, policy makers, and public health and environmental advocates to interact, engage in dialogue, and strategize on solutions that are protective of health and the environment. Dr. Lundgren in his lab. Photo courtesy USDA-ARS, 2012.

EPA Rule Clarifies Disclosure Requirement of All Ingredients in Exempt Minimum Risk Pesticides

In December 2015, the U.S. Environmen- citronella, corn meal gluten, peppermint The new rule requires manufacturers to tal Protection Agency (EPA) published its oil, sodium chloride and white pepper that more clearly disclose to state agencies, final rule to clarify the substances on the can be used for their pesticidal properties. companies, and the general public the minimum risk pesticide ingredient list, chemical ingredients contained in the also known as the Federal Insecticide, Fun- Currently, so-called inert ingredients, 25(b) products. Manufacturers of these gicide, and Rodenticide Act (FIFRA) Section which EPA considers proprietary informa- products are required to fully disclose their 25(b) List, and revise the way these ingre- tion and make up the majority of prod- ingredient list on product labels, which dients are identified on product labels. uct ingredients in many pesticides, are Beyond Pesticides has long championed not disclosed on pesticide product labels. for all pesticide products. The rule - reor Minimum risk pesticides, or 25(b) pesti- However, there has been a lack of clarity ganizes the ingredient list (40 CFR 125.25) cides, are a special class of pesticides that on minimum risk pesticide product labels and adds specific chemical identifiers (CAS are not required to be registered with EPA in the past, which has made it difficult for numbers) to make clearer the specific in- because their ingredients, both active and enforcement officials to ensure compli- gredients that are permitted in minimum inert, are considered nonhazardous to ance with the 25(b) criteria, given that the risk pesticide products. This will assist in human health or the environment. They manufacturer uses its own judgment on improving compliance and enforcement include commonly known botanicals and whether the product meets the exemp- oversight of these pesticide products and plant compounds, such as cedarwood oil, tion requirements. harmonize labels across manufacturers.

Vol. 35, No. 4 Winter 2015-16 Pesticides and You Page 5 A quarterly publication of Beyond Pesticides Around the Country

Montreal, Canada Proposes “Complete Ban on Neonics”

In December 2015, Montreal, the largest city in Canada’s Quebec province, announced plans for a comprehensive ban on the use of bee-toxic neonicotinoid pesticides. The new regulations represent the strongest move against this neurotoxic class of insecticides by any government entity to date. Environmental and health advocates are praising the ban as a sign that more and more localities in North America are finding these chemicals unnecessary to manage pest problems, and not worth the risk to pollinators and other wildlife.

Montreal’s regulations provide for a com- EPA Sued for Failure to Regulate Neonics, plete ban, “without exception,” on the use of neonicotinoids outside of buildings on city as Agency Data Confirms Hazards land. Prior to the new rules, private citizens and businesses could obtain a temporary According to government statistics, 42 percent of managed honey bees across the permit for the use of neonicotinoids in the country were lost over 2014/2015, representing the second highest loss to date. case of an infestation, however, the permit Neonicotinoids, a class of insecticides, have been tied to recent pollinator declines will no longer be available, and citizens will by an ever-growing body of science. These toxic chemicals share a common mode of be encouraged to employ alternative prac- action that affects the central nervous system of insects, resulting in disorientation, tices or products. The ban will also apply to paralysis, and death. golf courses and properties in the city used for agricultural and horticultural purposes. In early January 2016, the Environmental Protection Agency (EPA) released a preliminary honey bee risk assessment linking severely declining honey bee populations to “By adopting a regulation that prohibits the use of the neonicotinoid imidacloprid, which, along with clothianidin and thia- the use of such pesticides in Montreal, methoxam, is commonly used to coat agricultural seeds. This raises huge concerns our Administration places the health of because neonicotinoids are persistent in the environment, and when used as seed its citizens, the quality of life of its neigh- treatments (as well as drench treatments), translocate throughout the plant (thus are borhoods, and the preservation of biodi- systemic), ending up in pollen and nectar and exposing pollinators like bees, birds, versity, natural environments and green and butterflies long after the planting season has ended. spaces in the center of its concerns,” said Réal Ménard, head of sustainable develop- The Center for Food Safety, on behalf of several beekeepers, farmers and sustain- ment, environment, large parks and green able agriculture and conservation groups, filed a lawsuit in federal court in January, spaces for Montreal. “This tighter control the same day as EPA’s risk assessment release, charging the agency with a failure to of pesticides will, among other things, bet- adequately regulate neonicotinoid insecticide seed coatings used on dozens of crops ter protect bees and other pollinators.” throughout the U.S. The suit alleges that EPA has illegally allowed millions of pounds of coated seeds to be planted annually on more than 150 million acres nationwide, Montreal’s move follows a major overhaul constituting a direct violation of the registration requirements established bythe of pesticide laws announced in late No- Federal Insecticide, Fungicide and Rodenticide Act (FIFRA). Absent adequate assess- vember 2015 by Quebec province. Quebec ment of the serious ongoing environmental harms associated with coated seed use, acted to restrict the use of “high risk” pesti- as well as failure to require the registration of coated seeds and enforceable labels on cides, such as neonicotinoids, atrazine, and seeds bags, this lawsuit demands immediate action to protect beekeepers, farmers organophosphates, in both agriculture and and consumers from the harms associated with neonicotinoid coated seeds. urban and residential environments.

Page 6 Pesticides and You Vol. 35, No. 4 Winter 2015-16 A quarterly publication of Beyond Pesticides edited by Jen Ruocco

DuPont and Dow Merge to Become Biggest Pesticide Conglomerate

Chemical giants DuPont and Dow Chemi- dependent, publicly traded companies es is not a sustainable business practice. cal Companies announced in December through tax-free spin-offs. This would occur Chemical-intensive (or conventional) -ag 2015 that their boards of directors unani- as soon as feasible, which is expected to be riculture depends on chemical fertilizers mously approved a merger of their com- 18-24 months following the closing of the and toxic pesticides that have been shown panies through an all-stock deal, valuing merger, subject to regulatory and board ap- to reduce soil organic matter and decrease the combined market capitalization at proval.” The merger could revive attempts the diversity of soil biota. These chemical $130 billion. According to The Washington at consolidation between other big compa- inputs contaminate waterways leading to Post, “The combined company, analysts nies in the agrochemical industry. eutrophication and “dead zones,” where said, would be the world’s largest seed nothing is able to live or grow. Eventu- and pesticide conglomerate, controlling However, for the billion-dollar agrochemi- ally, as chemical-intensive agriculture de- 17 percent of global pesticide sales and cal industry, a merger is likely to provide pletes organic matter in the soil and there about 40 percent of America’s corn-seed short-term stability, increase the wealth is nothing left with which to grow food or and soybean markets.” of top executives, and raise the cost of sustain life, chemical inputs will become food, as the new corporation will create obsolete. Sustainability advocates say that The press release, states “The combined a near monopoly that will allow it to in- the only way that the agricultural industry company will be named DowDuPont. The crease prices. In the long-term, the market can create a sustainable business model is parties intend to subsequently pursue a will reveal that relying on the promotion to produce products that are compatible separation of DowDuPont into three in- of chemical-intensive agricultural practic- with organic agriculture.

Records Show Suspended Oregon Pesticide Spray Company Continues Operations

On September 25, 2015, Applebee Aviation’s license to spray pesticides commercially was suspended for one year, after an employee complained of chemical exposure and violations of worker protection rights. After Applebee Aviation’s one-year suspension was issued, it continued to operate and illegally sprayed at least 16 sites (over 800 acres of state and private land), according to reports. Two of those sites were public parks, 71 acres in total, overseen by the Oregon Department of Forestry (ODF). According to recent investigations, ODF knew about the license revocation before Applebee Aviation illegally sprayed state forests.

In April 2015, Applebee Aviation employee Darryl Ivy, a truck driver, spent 17 days on a spray crew in Oregon timber country. During that time, he and his crew were routinely exposed to aerial sprays. Mr. Ivy took shelter in his truck while a “milky chemical mixture” rained overhead and stained his vehicle. In the emergency room, Mr. Ivy’s urine showed elevated levels of the herbicide atrazine, a known endocrine disruptor. He suffered from sores and rashes and was spitting up blood. Before going to the hospital, however, Mr. Ivy managed to capture videos and photos of the spraying. Those videos were submitted to the Oregon Occupational Safety and Health (OSHA) and the Department of Agriculture (ODA), which then fined Applebee $8,850 and $1,100, respectively, citing a total of 22 “serious violations” related to herbicide exposure. According to the OSHA report, “The company did not provide emergency eye wash or decontamination, proper information and training, or protective equipment.”

On November 5, 2015, after a series of back-and-forth communica- tions between ODA and Applebee Aviation, and disclosure of the illegal spraying activity, ODA filed a restraining order and issued Applebee Aviation’s chemical truck rolled over loaded next to the Smith River in California. Photo courtesy of Beyond Toxics, 2015. $180,000 in fines, in addition to a five-year license revocation.

Vol. 35, No. 4 Winter 2015-16 Pesticides and You Page 7 A quarterly publication of Beyond Pesticides Around the Country

Campbell Soup Says GE Food Is Safe, Endorses Mandatory GE Labeling to Preempt States with Weak Language

In a precedent-setting move, Campbell Soup Company has announced its support for federal mandatory labeling of foods containing genetically engineered (GE) ingredients. If such labeling does not come soon, the company also indicated it is prepared to voluntarily label all products it produces that contain GE ingredients. Agri-Pulse reported, “Campbell made clear that it still supported the use of genetic engineering in agriculture but said that there is a need for national labeling standards that would preempt state standards.” With labeling and website material, Campbell seeks to educate consumers on the safety of GE.

The change marks the first breaking of ranks among the conventional food industry at a time when Congress is intensely debating the merits of a federal GE food labeling scheme. In July of last year, the House of Representatives passed a bill, HR 1599, aptly referred to as the Deny Americans the Right to Know Act (DARK Act), which would preempt (disallow) states from requiring GE labeling, and only allow voluntary labeling by food companies. While the Senate held hearings on the issue in October 2015, it was not included as a rider in an omnibus federal spending bill passed at the end of the year, despite intensive lobbying from the conventional food and chemical industry.

Consumers have a right to know whether the foods they buy contain GE ingredients, not only because of concerns over the safety of eating GE food, but also because of the direct and indirect effects of GE agriculture on the environment, wildlife, and human health. GE agriculture is associated with the increased use of herbicides – particularly glyphosate, the active ingredient in Roundup– that crops are developed to tolerate. In light of the recent findings by International Agency for Research on Cancer’s (IARC) that glyphosate is a human carcinogen based on laboratory animal test data, consumers have even more cause for concern about the health risks that Example of a label that complies with pending GE labeling these products pose. legislation in Vermont. Photo courtesy Business Wire.

Home Depot Announces Phase Out of Bee-Toxic Pesticides

In December 2015, Home Depot, the noids, so that now over 80% of our flow- cided to start requiring all nursery plants world’s largest home-improvement chain, ering plants are not treated with neonic- that have been treated with neonicoti- announced that it will no longer use neo- otinoids. We will continue this decrease noids to carry a label (although the label nicotinoid (neonic) pesticides (which have unless 1) it is required by state or fed- language was unclear) to inform custom- emerged as the leading class of pesticides eral regulation, or 2) undisputed science ers, following a report written last year. responsible for bee declines) in 80 per- proves that the use of neonicotinoids on The Friends of the Earth report, Garden- cent of its flowering plants, and that it will our live goods does not have a lethal or ers Beware (2014), shows that 36 out of complete its phase-out in plants by 2018. sub-lethal effect on pollinators. Other- 71 (51 percent) of garden plant samples This follows the announcement made by wise we will have a complete phase-out purchased at top garden retailers in 18 Lowe’s earlier this year to phase out the of neonicotinoid use on our live goods by cities in the United States and Canada sale of products containing neonicotinoid the end of 2018.” contain neonicotinoid pesticides. Some pesticides within 48 months (by 2019). of the flowers contained neonic levels Home Depot’s newest commitment to high enough to kill bees outright, and On its Eco Options gardening page, Home protecting pollinators follows steadfast concentrations in the flowers’ pollen and Depot says the following: “Our live goods demands from environmental allies and nectar were assumed to be comparable. suppliers have reduced the number of consumers to take neonicotinoids off of Further, 40% of the positive samples con- plants that they treat with neonicoti- the shelves. Home Depot previously de- tained two or more neonics.

Page 8 Pesticides and You Vol. 35, No. 4 Winter 2015-16 A quarterly publication of Beyond Pesticides What’s Up with Organic Standards? USDA institutes procedural changes that weaken National Organic Standards Board

Farmers protest outside of the Fall 2015 NOSB meeting in Stowe, VT in response to the policy allowing certifying hydroponic operations as organic. Photo by Mark Kastel, Cornucopia.

By Terry Shistar, Ph.D. those used in processed food. However, NOSB subcommittees no longer summarize their evaluations using the evaluation - check eyond Pesticides engages its members and network in the list, which has historically helped to focus discussion at the public twice-a-year public comment period on organic standards in meeting. Some subcommittee members did not do a thorough job an effort to ensure compliance with organic law and uphold of reviewing public comment and/or misrepresented comments. B In the end, most of the materials that had been proposed for del- public trust in the integrity of the organic seal. We track the work of the standard setting board, National Organic Standards Board isting were relisted. (NOSB), through our Keeping Organic Strong webpage (http://bit. ly/KeepingOrganicStrong) and contribute to a process of continu- Reversal of the two-thirds majority. ous improvement by evaluating new science and practices. Since The primary change made by the NOP in its sunset announcement organic standards and the label they support are unique in being of September 16, 2013 was a reversal of the voting requirement to created and updated in a transparent and public review process, keep a material on the National List during sunset review. In the past, we seek through our participation to ensure a meaningful and re- the review was truly a sunset –materials on the National List were re- spected alternative to harmful chemical-intensive practices in food moved unless a two-thirds majority voted to relist them. USDA policy production. This is especially important as the organic regulatory now requires a two-thirds majority to remove a material from the agency, the U.S. Department of Agriculture (USDA), and parts of the National List. This change creates a weaker standard that no longer food industry force changes undermining the procedures that have requires near consensus among stakeholders to keep a material on contributed to a thriving organic sector. In the spirit of growing or- the list after the sunset period –as is required to initially get on the list ganic on a strong legal foundation that embraces the protection of with a petition. Twenty-three materials that would have come off the health and the environment, we report on the Fall 2015 meeting of list under original sunset voting rules were relisted. the NOSB that was held in November in Stowe, Vermont. Restricting an allowed material (annotation) during Key issues: the sunset process. Beyond Pesticides and others supported the current annotation Sunset for the use of synthetic micronutrients only with clear site-specific Coming into the meeting, subcommittees had done a much more documentation. Despite prohibiting the procedure, USDA allowed thorough job than past boards –though it was still in need of im- during the sunset review an annotation change for micronutri- provement–of reviewing the 129 materials up for sunset review. ents that removed the requirement (weakened the standard, Many technical reviews were requested for materials whose pre- which normally would require a petition) that soil deficiency must vious reviews needed updating. Subcommittees proposed remov- be documented by testing, replacing it with a much more vague ing a large number of materials from the National List, particularly requirement that “deficiency must be documented,” which was

Vol. 35, No. 4 Winter 2015-16 Pesticides and You Page 9 A quarterly publication of Beyond Pesticides explained in the narrative to include recommendations of exten- tives, Beyond Pesticides said they were not compatible with- or sion agents and crop advisors based on regional soils. The NOSB ganic and opposed adding them to the National List. The NOSB approved the annotation change. sent the issue back to the Handling Subcommittee for further work. However, the materials continue to be in use. “Inerts” The NOSB backpedaled on previous 2010 and Beyond Pesticides opposed the subcommittee’s 2012 recommendations to evaluate the so- proposal to allow a large number of materials in called inert ingredients (ingredients that several functional classes as additives in ingre- are often toxic but not disclosed on the dients of ingredients, known as ancillary sub- product label) to the standard in the or- stances. Our position was based on the an- ganic law. On the original National List, cillary substances not having been reviewed the board allowed categories of inerts according to OFPA criteria, as required by that EPA had classified as “ingredients be- NOSB policy and OFPA, the allowance of lieved to present minimal risk” and those totally unreviewed substances in the future, for which EPA has “sufficient information and the carcinogenicity of some of the mate- to conclude that their current use patterns rials. The proposals were sent back to subcom- will not adversely affect public health and the mittee for more work. environment”–categories that EPA is no longer using– so a new review assessment was developed Livestock in accordance with the Organic Foods Production Act (OFPA). The Livestock Subcommittee did not produce any proposals out- USDA failed to move ahead with the review and the Crops and side of sunset materials, but did produce discussion documents Livestock Subcommittees proposed instead that any chemical on on parasiticides and anesthetics lidocaine and procaine. the EPA Design for the Environment (DfE) “Safer Chemical Ingredi- ents List” (SCIL) would be allowed as an “inert” in organic produc- Materials/GMO tion. However, the SCIL contains active substances like sanitizers Every fall, the Materials/GMO Subcommittee produces a list of as well as materials with different ratings relative to DfE criteria proposed research priorities to be sent to “national laboratories, that do not meet OFPA criteria. The plan was adopted as a new foundations, organizations, federal agencies, land-grant institu- listing for allowed synthetic materials in organic production. tions, non-land-grant colleges, individuals, organic farmers, and the organic community in carrying out research, education, and New Materials training activities related to facilitating the development of organ- Beyond Pesticides commented that laminarin and brown seaweed ic agriculture, handling, processing, and organic foods.” Research both are synthetic, and that neither should be allowed on the Na- priorities supported by the board at this meeting were: evalua- tional List because of unexamined hazards associated with their tion of the effectiveness of methods to prevent contamination by mode of action. However, the board voted that laminarin is nonsyn- genetically engineered organisms, prevention and management thetic and thus allowed it for use in organic production without re- of parasites, herd and flock health, evaluation of methionine in striction. Unlike laminarin, which is extracted through a process re- the context of a systems approach in organic poultry production, sulting in a net addition of sodium sulfate, brown seaweed extracts impacts of and alternatives to chlorine materials, and alternatives are extracted through a similar process resulting in a net addition to copper for control of disease and algae. Many suggestions were of potassium sulfate. Because brown seaweed extract products are made in public comments, and the subcommittee promised to also labeled as 0-0-1 fertilizers, the petition was denied. (Synthetic consider them in the future. fertilizers are not permitted under OFPA.) The discussion on these two petitioned materials raise questions about guidance that has The NOSB passed, with one abstention, recommended guidance never been codified on the classification of materials –determining on prevention of contamination with genetically engineered (GE) what extracted materials are synthetic or not synthetic depending organisms. Many people commented that most organic farmers on residuals of synthetic extractants, whether they have a “func- already do the suggested actions, and that actions to control the tional or technical effect” or whether their presence at any level de- spread of GE organisms needs to be taken by those who grow fines a synthetic material. The NOSB also voted in favor of a petition them and profit from them. to remove lignin sulfonate for floating pears post-harvest because it is no longer used. It also voted against a petition to allow sulfuric Policy Development acid to solubilize micronutrients because feeding highly soluble nu- The Policy Development Subcommittee brought forth “updates” to trients to plants is inconsistent with the OFPA. the Policy and Procedures Manual. It was universally criticized for not presenting a transparent format so that changes are apparent Handling and reasons for the changes given. The document was not up for Because sodium and potassium lactate are synthetic preserva- vote at this meeting and will be considered further in the spring.

Page 10 Pesticides and You Vol. 35, No. 4 Winter 2015-16 A quarterly publication of Beyond Pesticides Cultivating Plants that Poison Bees, Butterflies, and Birds

Photo by Carol Allaire.

By Nikita Naik, MPH chemicals, has resulted in an increased demand for new pesticides with lower human exposure and toxicity. This has led to the emer- Executive Summary gence of systemic pesticides. These pesticides can be applied with n the winter of 2006-07, U.S. beekeepers lost nearly 40 percent a variety of methods, including foliar sprays, granules, soil drenches, of their bee hives, documenting some of the first reports of “ab- and tree injections. However, insecticide or fungicide-coated seeds Inormally heavy losses” in managed honey bee colonies.1 Nearly a are among the most popular method of treating the target insect or decade later, losses in managed bee colonies remain elevated, with fungal disease, and account for the vast majority of seeds for major recent 2014-15 data showing record high losses of 42.1 percent.2 crops and ornamental plants in the U.S. (Stokstad, 2013; Douglas and Tooker, 2015; Friends of the Earth, 2013).3,4,5 With these application The preponderance of independent science links a class of insecti- methods, and given the toxicity, longevity or persistence of these cides known as neonicotinoids (or neonics) with the dramatic de- chemicals in soil and waterways, broad ecological impacts have and cline of pollinators and other wildlife. Bees, butterflies, birds, and a continue to be documented (Chagnon et al., 2015).6 range of soil and aquatic organisms essential to healthy ecological systems are imperiled by the use of these systemic and persistent In addition to the ecological harm caused by neonicotinoid use, pesticides. Systemic pesticides are chemicals that can be taken up the effect of systemic pesticide use on bees and other pollinators by the vascular system of a plant, and then expressed throughout has clear economic and human health impacts. Insect pollination the plant, including pollen, nectar, and guttation droplets, indis- has been shown to enhance crop yield, thus contributing to agri- criminately exposing target pests and non‐target organisms alike. cultural productivity by up to 71 percent, depending on the crop.7 While several classes of pesticides since the outset of the chemi- The total global economic valuation of pollination services is esti- cal-intensive agricultural era are systemic, neonicotinoids have at- mated to be 9.5% of global food production value (2005), or about tracted substantial scientific and public scrutiny because their ap- $190 billion.8 In the U.S., the value of crops directly reliant on in- pearance and proliferation in the market coincided with dramatic sect pollinators is $15.12 billion (2009), with the value attributed die-offs and the decline of honey bees around the world. to honey bees alone at $11.68 billion.9 Pollinator-dependent crops are also a source of nutrients critical to human health, accounting Over the last 20 years, public and regulatory pressure to limit human for one-third of the U.S. diet.10,11 The continuation of pollinator exposure to toxic pesticides on farms and in surrounding communi- decline, therefore, threatens the stability of the global economy ties, compounded by issues of insect and weed resistance to these and food supply, along with ecosystems and human health.

Vol. 35, No. 4 Winter 2015-16 Pesticides and You Page 11 A quarterly publication of Beyond Pesticides The empirical and sci- Systemic Herbicides entific data on the- ad Insecticides are not the only type of pesticides that can behave systemically. Some of the most widely- verse effects of systemic used herbicides on the market, such as glyphosate, are also able to translocate throughout a plant. pesticides document Glyphosate is shown to translocate well in a plant, from roots to foliar tissues, and can be exuded by the failure of the U.S. roots into soil.14 Glyphosate application to glyphosate-tolerant cotton is associated with poor pollen Environmental Protec- deposition on the stigma of male plants, as well as inhibition of pollen maturation, but has the po- tion Agency (EPA) to tential to translocate into developing pollen grains.15 Residues of glyphosate and its metabolite AMPA prevent the introduc- have been detected in the grains of glyphosate-resistant soybeans.16 tion and proliferation of substances that are devastating to the stability of healthy ecosystems. While various factors, including The Rise of Systemic Insecticides parasites, such as varroa mites, and habitat loss, have been Outside the context of complex ecological systems and im- identified as contributors to pollinator decline,12 only now pact associated with non-target effects, systemic insecticides has EPA begun to accept the growing scientific consensus that might otherwise present an attractive technology for reach- neonicotinoids are harming bees. As a result of systemic pesti- ing target pests by conferring long-lasting toxicity throughout cides’ environmental impacts and emerging human toxicologi- the plant. While applicator, farmer, and farmworker exposure cal profiles, EPA must begin removing these chemicals from the may be reduced, the creation of other sources of exposure market, rather than embracing them as “reduced risk” in com- have been documented, including that of fugitive dust con- parison to older toxic pesticides. Organic agriculture, which taminated with seed coatings, lubricants that escape off of now supports a nearly $40 billion industry,13 does not depend seed planters, and drift from planted fields.17 on neonicotinoids or other toxic pesticides, demonstrating that it can supply the world’s food needs while building soil health EPA defines systemic pesticides as pesticides that “can be moved and nurturing biodiversity. (translocated) from the site of application to another site within the plant or animal where they become effective.”18 Systemic This report documents the rise and use of systemic insecticides behavior is exhibited in different types of pesticides, such as in- and the threat that they present to the environment and health, in secticides, herbicides, and fungicides. However, the exact behav- light of regulatory inertia. The findings make the case that the use ior of these chemicals, their relationship and impact to target of persistent and systemic pesticides is inherently unsustainable and non-target organisms, and the implications of their use can at a time when protection of the biosphere is crucial. differ significantly.

Washing Produce from Pesticides –Implications for the Concerned Consumer Traditionally, consumers have been taught to carefully wash or peel their produce to remove traces of pesticide residues. However, the concept of washing or peeling away surface residues of pesticides does not apply to systemic pesticides. In fact, systemic insecticides, having been translocated within the plant, can exist within the fruit and leaves of treated crops, unable to be washed off.19,20,21

Page 12 Pesticides and You Vol. 35, No. 4 Winter 2015-16 A quarterly publication of Beyond Pesticides Systemic insecticides were first What Makes Pesticides Systemic? formally synthesized in the A log octanol/water partition coefficient (KOW) is a measure of likely systemic translocation within the 31 1940s and 1950s. The benefits vascular system of the plant, with a value of two or less indicating a higher ability to translocate. of these chemicals, document- Log KOW may also demonstrate the extent to which a chemical translocates into the pollen of plants, 32 ed in studies and patent docu- with lower values correlated with an increased likelihood. The table below illustrates the relationship ments from this period, include between log KOW values and water solubility with a handful of systemic and non-systemic chemicals. their distribution throughout Insecticide Chemical Class Solubility in Water (mg/L) Log KOW plant tissues, increased persis- Non-systemic 22,23 tence after initial application, Chlorpyrifos Organophosphate 1.05 (low) 4.7 and the ability to confer insec- Malathion Organophosphate 148 (moderate) 2.75 ticidal properties to new plant Carbaryl Carbamate 9.1 (low) 2.36 growth and hard-to-treat areas Permethrin Pyrethroid 0.2 (low) 6.1 (such as the underside of the leaf) Cyfluthrin Pyrethroid 0.0066 (low) 6 subsequent to application. Earlier Systemic generations of insecticides, including organophosphate (OP) Aldicarb Carbamate 4,930 (high) 1.15 compounds such as schradan, Acephate Organophosphate 790,000 (high) -0.85 demeton, dimethoate, demeton- Dimethoate Organophosphate 39,800 (high) 0.704 S-methyl, mevinphos, and pho- Oxamyl Carbamate 148,100 (high) -0.44 rate, exhibit systemic action.24,25 Carbofuran Carbamate 322 (moderate) 1.8 Carbamates with systemic prop- Imidacloprid Neonicotinoid 610 (high) 0.57 erties, such as aldicarb and car- Thiamethoxam Neonicotinoid 4,100 (high) -0.13 bofuran, were developed in the Fipronil Phenylpyrazole 3.78 (low) 3.75 1960s, followed by systemic Chlorantraniliprole Anthranilic Diamide 0.88 (low) 2.86 insect growth regulators in the Sulfoxaflor Sulfoximine 568 (high) 0.802 1980s and 1990s.26 Many of these older systemic insecticides Flupyradifurone Butenolide 3,200 (high) 1.2 are no longer available commer- Herbicide Chemical Class Solubility in Water (mg/L) Log KOW cially as a result of voluntary Systemic cancellations by manufacturers Glyphosate* Phosphanoglycine 10,500 (high) -3.2 (Source: University of Hertfordshire, Pesticides Properties Database) *See box on previous page.

Benefits of Neonicotinoids –Fact or Fiction? Although neonicotinoids are marketed as highly beneficial and advantageous, there has been a growing body of evidence that renders these claims suspect. Arguments in favor of these chemicals assert that they provide continuous protection from insect pests to the plant throughout the majority of the growing season, without the need for repeat applications. However, a 2014 EPA report offers evidence that neonicotinoid use in soybeans does not translate to better yields, with the finding that soybean seeds coated with the neonicotinoids imidacloprid, thiamethoxam, and clothianidin “provide negligible overall benefits in [yield] in most situations” when compared with no insect control treatment. Furthermore, neonicotinoid seed coatings are only bioactive for a period within the first 3 to 4 weeks of planting, which EPA states “does not overlap with typical periods of activity for some target pests of concern.”33 Thiamethoxam use is found to reduce predaceous beetles that feed on pest slugs by 60 percent, resulting in a decrease in soybean density (19%) and yield (5%) (Douglas, Rohr, and Tooker, 2015).34 Similarly, there is evidence that foliar and subterranean herbivores and key pests of sunflowers are unaffected by seeds coated with thiamethoxam, and there is no significant difference in sunflower yield between treated and untreated fields.35 A 2015 study finds that the use of aldicarb soil insecticide and thiamethoxam-coated seed does not reduce cutworm damage, and that, instead, plots treated with these insecticides had a higher percentage of defects when compared to untreated plots (Difonzo et al.).36 Other studies, including a 2014 Center for Food Safety review of the literature on the subject, finds that evidence is weighted toward lack of efficacy and agricultural yield benefits.37 Additionally, according to the UK’s Agriculture and Horticulture Development Board (AHDB) Final Harvest Summary for 2015, which provides the first harvest results of crops planted without neonicotinoid treatments, yields of all cereals were 7 to 14 percent above the ten-year average.38 These strong numbers bolster the position that the use of neonicotinoids is unnecessary.

Vol. 35, No. 4 Winter 2015-16 Pesticides and You Page 13 A quarterly publication of Beyond Pesticides A Historical Note Organophosphates (OPs) were originally introduced into commerce as a safer alternative to organochlorine pesticides, such as DDT, chlordane, heptachlor, aldrin, and dieldrin, with the claim that they would breakdown in the environment quickly, rather than bioac- cumulate. The OPs immediately proved to be disastrous to honey bees (see History of Bee Kills, p22), and some of the early thinking was disproved as the aggregate effect of dietary and non-dietary exposure raised safety questions.39,40

and/or because of adverse human health effects and environmen- Following absorption, translocation of the pesticide substance can tal contamination. Some, including the insecticides dimethoate and occur through the connecting vascular tissues of the plant: the -xy aldicarb, are still registered, but are used under restricted or limited lem and phloem. The translocation process varies according to the 49 circumstances.27,28 From the 1990s onward, insecticides, like fipronil chemical and the site of absorption. Systemic pesticides typically and neonicotinoids, slowly began replacing older systemic pesticides move through the xylem, which transports water, but they can also, that were shown to be more toxic to humans.29,30 In the last sev- less frequently, be transported within the phloem, which conducts 50 eral years, other systemic insecticides have been registered by EPA. carbohydrates. As with absorption, highly water-soluble chemicals These include chlorantraniliprole (from the chemical class known as are the most likely to be taken up by plant roots and translocated to 51,52 anthranilic diamides), sulfoxaflor (sulfoxamine), and flupyradifurone shoots. (butenolide). Systemic Chemicals of Concern Neonicotinoid pesticides are often presented as needing fewer re- Organophosphates (OP) and Carbamates peat applications due to their persistence, reducing exposure to The older systemic insecticides include some organophosphorus those working on the farm, and having a range of versatile appli- (OPs) compounds (e.g. dimethoate) and carbamates (e.g. aldicarb cation techniques, such as seed coatings, tree injections, andsoil and oxamyl) and were first registered in the 1950s. OPs and carba- drenching.41,42 Additionally, many newer systemics like neonicoti- mates inactivate the acetylcholinesterase enzyme (AChE), common- noids are accepted to be less toxic to mammals,43 although new evi- ly found in nervous tissues, brain cells, red blood cells, and muscle dence continues to emerge that disputes this (see box p16). At the tissues, which results in the continuous stimulation of muscle or same time, the efficacy of these chemicals has been called into ques- nerve fibers. Because AChE is present in most animals, these com- 53 tion by numerous studies, including a 2014 report by EPA (see box, pounds are toxic to many different types of organisms. Many of 54 55 Benefits of Neonicotinoids –Fact or Fiction? on p13). these systemic chemicals, including mevinphos, dimethoate, carbofuran,56 aldicarb,57 and oxamyl,58 continue to have wide food and/ How do they work? Systemic insecticides generally work via a se- quence of two processes: absorption and translocation. Absorption of an insecticide across cell membranes can occur in seeds, roots, or leaves –generally all external surfaces of the plant are able to absorb some material depending upon certain conditions.44 Systemic distribution of the chemical throughout the plant structure can be achieved following foliar application, root uptake from soil application, seed coating, trunk injections, drip irrigation, and other application methods, which can significantly influence the uptake, behavior, and persistence within a plant.45 Once absorbed from the plant surface, the systemic chemical typically travels upward through the plant’s vascular system via the xylem to various parts of the plant where it can be expressed in newly growing shoots.46 During foliar applications, the chemical penetrates into the leaf where it is expressed throughout due to translaminar activity, including the underside of the leaf. Ad- ditives in pesticide formulations help to increase The behavior of soil applied systemic pesticides when taken up plant roots. Image by Cornell University, 2012. the flow of the substance into the plant.47,48

Page 14 Pesticides and You Vol. 35, No. 4 Winter 2015-16 A quarterly publication of Beyond Pesticides or non-food (i.e. structural) uses, or are slowly being voluntarily The Growth of Seed Coatings– cancelled by manufacturers. Implications and Consequences for Pollinators

Neonicotinoids In chemical-intensive agriculture, many consider seed coatings Chemically similar to nicotine, neonicotinoids are nicotinic acetyl- to be a “beneficial” treatment that reduces loss of seeds and choline (nACh) receptor agonists that activate neuronal receptors seedlings from early season pests,79 provides targeted applica- and disrupt many sensory and cognitive processes in invertebrate tions with the potential to reduce pesticide delivery rates, de- organisms. The binding of neonicotinoids to the nicotinic acetyl- creases applicator exposure,80 and minimizes exposure to non- choline receptor is irreversible in arthropods.59,60 Thus, they are target organisms in comparison to foliar application.81 Since highly toxic to insects and other invertebrates.61,62 the onset of the use of seeds coated with systemic pesticides, the market has more than tripled in size between 1990 and In the early 1990s, imidacloprid was launched by Bayer Crop- 2005, with neonicotinoids representing 77 percent of the to- Science and soon became one of the most popular insecticides tal share for coated seeds.82 More recent estimates show that in the world. By 2008, imidacloprid became the world’s largest- from 2000 to 2012, virtually all neonicotinoids applied to corn, selling insecticide, second only to glyphosate (Roundup) in all pes- soybeans, and wheat crops were applied as seed coatings. ticide sales.63 There are now seven neonicotinoid compounds that These same estimates show that neonicotinoid use increased are commercially available worldwide: imidacloprid, thiacloprid, dramatically between 2003 and 2011 with a marked shift to- clothianidin, thiamethoxam, acetamiprid, nitenpyram, and di- ward large-scale, preemptive insecticide use via coated seeds. notefuran. Neonicotinoids have been registered in more than 120 Seed coatings were used on 34-44 percent of soybean acres countries around the world as of 201164 and now dominate the and 79-100 percent of corn acres in 2011, contradicting claims market with 27 percent of insecticide sales, nearly as much as or- that insecticides are used on fewer corn acres today than a ganophosphates, carbamates, and pyrethroids combined (31%).65 decade or more ago.83 Systemic fungicide seed treatments, which, like their insecticide counterparts, are taken up by the Fipronil growing plant and can thus persist for longer periods of time, Fipronil, belongs to a chemical class known as phenylpyrazoles and in- have also grown in popularity over the past 20 to 40 years.84 hibits the γ-aminobutyric acid (GABA)-gated chloride channel, exhibit- ing selective neurotoxicity in insects compared to mammals.66 Fipronil The growth in the use of seeds coated with systemic chemi- is registered for use in the U.S. to control a variety of insects, both in- cals is problematic for pollinators. For instance, guttation door and outdoor, as well as for in-furrow treatment, seed treatment, droplets, a source of water for bees, from corn plants grown soil injection, baits, and for spot treatment on pets. Citing concerns from neonicotinoid-coated seeds exhibit high levels of thia- about ecological risks, EPA converted the major remaining outdoor use methoxam and clothianidin, up to 100 mg/L, and imidaclo- products to a restricted use classification, which takes it off retail store prid, up to 200 mg/L, levels near or even higher than those shelves, but allows commercial applicators and farmers to continue to commonly applied in field sprays.85 Contamination of the apply it.67 Although EPA states that fipronil is non-systemic, there is evi- surrounding soil from chemicals not taken up by the coated dence that the chemical undergoes root uptake and transport within seed is a concern, as more than 90 percent of the active plants (Aajoud, A., et al., 2006).68 Fipronil and its metabolites have also ingredient from a neonicotinoid-coated seed can contami- been detected in the pollen of plants.69 Fipronil is relatively mobile in nate the soil after application.86 One study shows that only soils, degrades to form persistent metabolites, and is a pervasive water a small proportion of the systemic insecticide, between 1.8 contaminant.70,71 It has been found to be toxic to non-target organisms, to 6.8 percent, is taken up by the plant itself (El-Hamady, including honey bees72 and various aquatic species.73 Kubiak, and Derbalah, 2008).87 Coated seeds also lead to exposures to non-target organisms as a result of drift from New and Emerging Systemic Insecticides abraded seed coatings and fugitive dust from contaminated Over the past decade, newer classes of systemic insecticides have lubricants used in mechanical planters. These residues have emerged. Many of these emerging chemicals are a response to been shown to result in deposits on the soils of planted and a demand for novel modes of action due to increased pest resis- unplanted fields, on nearby plants visited by foraging bees tance to pesticides already on the market. (indicating uptake, deposition, or both), and in pollen collected by honey bees and stored in the hive.88 Anthranilic Diamides Anthranilic diamides make up a new class of insecticides that activate the ryanodine receptor, which is responsible for regulating muscle contraction. Their insecticidal mode of action targets insect over mammalian receptors, making them less hazardous to mammals.74,75 Diamides now account for a little over eight percent of total global insecticide sales, a number that has been gradu-

Vol. 35, No. 4 Winter 2015-16 Pesticides and You Page 15 A quarterly publication of Beyond Pesticides The Newest Systemics –Reduced Risk? The new systemic pesticides that EPA has registered over the last decade, those that have been found to be highly toxic to bees, are nonetheless listed by the agency under the misleading category of “reduced risk pesticides,” because of their relatively low acute toxicity to mammalian species. In addition to many of the neonicotinoids, this category includes the newest chemicals cyantraniliprole and flupyradifurone. However, they, too, are highly toxic to non-target organisms, and their long-term impacts on terrestrial and aquatic ecosystems are not fully understood.89,90

The Food Quality Protection Act(FQPA) requires EPA to expedite the registration of “reduced risk” pesticides, defined as those that “may reasonably be expected to accomplish one or more of the following: (i) reduce the risks of pesticides to human health; (ii) reduce the risks of pesticides to nontarget organisms; (iii) reduce the potential for contamination of groundwater, surface water, or other valued environmental resources; or (iv) broaden the adoption of integrated pest management [IPM] strategies, or make such strategies more available or more effective.”91

Since FQPA requires that a “reduced risk” pesticide must meet at minimum one of the above criteria, and because neonicotinoids and other newer systemics may be less toxic to humans than organophosphate insecticides, they meet the criteria for “reduced risk,” in spite of higher ecological risks. Because of the prophylactic (applied in advance of a pest problem) nature of systemic pesticide use –the chemical is essentially an inoculant that becomes an inherent part of the seed or seedling– they are not compatible with an integrated pest management (IPM) system that relies on monitoring and thresholds for economic damage before the application of a pesticide, but may be considered consistent with “IPM” seen as pesticide chemical rotation.

While companies are not allowed to put a reduced risk claim on their pesticide labels, EPA “believes that companies use the conventional reduced risk pesticide status to their marketing advantage,” with additional advantages possible at the state level (e.g. New York State waives reporting requirements for reduced risk uses).92 Reduced-risk products can be recommended for IPM programs on the label. For example, the label for Acelepryn, active ingredient chlorantraniliprole, states that the product is “recommended for IPM programs on turf and landscape ornamentals because it does not directly impact natural arthropod predator and parasitoid populations including ladybird beetles, lacewings, minute pirate bugs and predatory mites.”93

“Reduced risk” pesticides should not be confused with “minimum risk” pesticides, which EPA has determined pose little to no risk to human health or the environment and are exempt from registration under theFederal Insecticide, Fungicide and Rodenticide Act(FIFRA). 94 While minimum risk pesticides provide a real least-toxic alternative, the term “reduced risk pesticide” does not.

ally increasing and will likely continue to grow with the potential ity, prove that it is a novel insecticide.95,96 However, other industry addition of new diamides to the market.76 Chlorantraniliprole, an scientists argue that sulfoxaflor has a pharmacological profile con- anthranilic diamide insecticide, was registered in 2008 by DuPont sistent with that of imidacloprid, suggesting that the chemical is for agricultural and non-agricultural uses. Chlorantraniliprole is in fact a neonicotinoid.97 As of now, EPA classifies sulfoxaflor as a characterized as persistent and mobile in terrestrial and aquatic sulfoximine.98 Sulfoxaflor has relatively low toxicity to mammals,99 environments, and is expected to accumulate in soil from year and lacks cross-resistance between it and other neonicotinoids,100 to year.77 Its cousin, cyantraniliprole, was registered in 2014, and but concerns have been raised regarding its high toxicity to honey like chlorantraniliprole, impairs regulation of muscle contraction, bees and other non-target beneficial organisms.101 The U.S. Court causing paralysis and eventual death of the insect. Cyantranilip- of Appeals in September 2015 concluded that EPA violated federal role is classified by EPA as a “reduced risk” pesticide, despite data law and its own regulations when it approved sulfoxaflor under an gaps, and is highly toxic to honey bees.78 unconditional registration without reliable studies regarding the impact that the insecticide could have on honey bee colonies.102 Sulfoximines Designated under a new class of insecticides known as sulfoxi- Butenolides mines, sulfoxaflor is a systemic insecticide that, like neonicotinoids, The recently registered systemic insecticide flupyradifurone was acts on nACh receptors. Sulfoxaflor was first registered by EPA in approved for use in 2015, and is classified as a “butenolide” in- 2013. Dow AgroSciences, sulfoxaflor’s manufacturer, put forth the secticide. Like neonicotinoids, flupyradifurone targets the nACh claim that sulfoxaflor is distinct from neonicotinoids, and as such receptor, but differs from other chemicals with a similar mode of is the first chemical belonging to a class of insecticides known as action, given how it binds to the receptor and the extent to which sulfoximines. Industry scientists at Dow AgroSciences claim that it is metabolized.103,104 These differences present another attempt sulfoxaflor’s very high efficacy at nACh receptors, coupled with its to address growing resistance to similar pesticides. Flupyradifu- chemical structure, lack of cross-resistance, and metabolic stabil- rone is considered an alternative insecticide to certain pyrethroids,

Page 16 Pesticides and You Vol. 35, No. 4 Winter 2015-16 A quarterly publication of Beyond Pesticides neonicotinoids, organophosphates, and avermectins. EPA classifies characterized as being persistent to very persistent with half- flupyradifurone as a “reduced risk” pesticide based on its relatively lives greater than 60 days and 180 days in soil, sediment, and more favorable human health toxicity profile, but this pesticide is even water.119 Sulfoxaflor’s breakdown products (which, along also highly toxic to honey bees.105 with the breakdown products of other systemic insecticides, can be more toxic and persistent than the parent compound), Environmental Fate and Contamination are expected to be highly persistent in aerobic soil systems.120 Soil Insecticide residues in soil can come from a variety of different Systemic insecticides can be highly mobile in certain soils (with routes, such as sprays or dusts from application onto foliage, or high water content) due to their high solubility in water. Twenty insecticides applied directly to the soil.106 Seed coatings constitute percent of systemic insecticides are prone to leaching, while 45 a major source of soil contamination. Typically, more than 90 per- percent are mobile in wet soils.121 cent of the active ingredient from a neonicotinoid-coated seed ends up in the soil after application,107 while a small proportion Water of the systemic insecticide, between 1.8 to 6.8 percent, is taken The presence of pesticides in water is hazardous for aquatic and up by the plant.108 In certain soil drench treatments, pesticides terrestrial organisms, and can contaminate drinking water. Ac- can directly leach below the root zone of the treated plants.109 For cording to a 2006 U.S. Geological Survey (USGS) report, the most granular formulations, it is estimated that 1 to 15 percent of the frequently detected systemic insecticide carbofuran was found pesticide remains on the soil surface, which is a source of expo- at levels at or above 0.1 µg/L in both streams and groundwa- sure for birds and other terrestrial organisms and could runoff into ter, often exceeding EPA’s aquatic-life safety benchmarks, along surface water.110 While the breakdown of pesticides in the soil can with methomyl and phorate.122 Another USGS report found that occur through microbial degradation, these pesticides may also fipronil was detected in streams from 17 to 63 percent of the adversely affect these communities, depleting the beneficial- or time from 2002-2011 and frequently found at levels of poten- ganisms needed to sustain a healthy soil ecosystem. tial concern for aquatic organisms in urban streams.123 In 2015, USGS also found neonicotinoids to contaminate half of all U.S. The level of persistence of pesticide residues in soil typically streams,124 while another found the chemicals to persist in depends on factors such as soil type, formulation, concentra- Midwest waterways from applications from previous years.125 tion, moisture, temperature, and pH, so half-lives of various Similarly, widespread use of neonicotinoids has resulted in their systemic insecticides may vary worldwide contamination of aquat- significantly with respect to these ic media. A 2015 review examin- Estimated Half-lives of Systemic factors.111 Neonicotinoids, for in- ing the concentrations of neonic- Insecticides in Various Soils stance, have half-lives in soil that otinoids in surface waters around vary greatly among compounds, the world found that water-borne soil type, and across studies (see Chemical DT50 (half-life)* in Days neonicotinoid occurrences are table, right), with reported half- Aldicarb 2.4-35 frequent and long-term, often ex- lives ranging from 1 to nearly Carbofuran 12.8-47 ceeding several existing water qual- 7,000 days.112 Fipronil remains in ity guidelines. Eighty-one percent Chlorantraniliprole 6.5-597 treated soil for at least 30 months, and 74 percent of global surface and the chemical leaches into Clothianidin 17.2-6,932 water studies reporting maximum non-treated areas directly below Cyantraniliprole 9-92 and average individual neonicoti- treated soil, both at levels toxic Dimethoate 2.6-16 noid concentrations, respectively, 113 enough to kill termites. Chloran- Fipronil 68-217 exceed recommended ecological traniliprole has soil half-lives vary- thresholds for neonicotinoids in wa- Flupyradifurone 37.5-401.0 ing from 8 days to 16 days, with ter. 126 Newer systemic insecticides, residues persisting up to nearly 60 Imidacloprid 28.7-187 with their high mobility, also have days,114,115 and is characterized by Oxamyl 3.19-43.31 a potential to contaminate water. EPA as persistent (half-life greater Sulfoxaflor 2.2-6.03 Flupyradifurone, for example, is than 60 days) and mobile in terres- Thiacloprid 1.3-19.1 characterized as moderately mobile trial environments, with extended and thus has a potential to reach *Refers to time it takes for pesticide to degrade or dissipate use expected to cause accumula- to half of original value aquatic environments, including tion of residues in soil from year surface and groundwater for sev- to year.116,117 Cyantraniliprole also eral months after application.127 has half-lives ranging from 2 days to 3 months in terrestrial environments, with some degradates being more persistent and The detection of high concentrations of these chemicals in more mobile than the parent compound.118 Flupyradifurone is groundwater and surface water is becoming more widespread.

Vol. 35, No. 4 Winter 2015-16 Pesticides and You Page 17 A quarterly publication of Beyond Pesticides Given their toxicity to aquatic organisms, monitoring the levels of sessment Guidance, avenues of potential exposure to bees and these chemicals in water bodies becomes increasingly important other pollinators from the foliar application of systemic pesticides to determine the environmental risk they present. include direct deposition on bees, deposition on plants and soil (after which residues of the chemical contaminate plant surfaces, Effects on Non-Target Organisms soil, pollen, and nectar), and deposition onto surface water. A 2012 Exposure of systemic insecticides to non-target organisms can oc- study by Krupke et al. finds that bee-attractive plants, like dande- cur via contaminated soil, water, and air, and by multiple exposure lions, that are adjacent to treated fields can also be contaminated routes. For instance, exposure to pesticide drift from foliar spray- by pesticide drift and thus expose bees. Contaminated field dust, ing or from contaminated dust plumes from treated seed can kill which results from the sowing of treated seeds, is another source or impair many species.128,129 Potential exposure from systemic of exposure that puts bees at risk.139 Soil dwelling/burrowing pesticides applied to soil includes runoff/erosion of soil residues bees, like the mining bee, are also at risk from soil contamination. onto surface water and/or from root uptake into target and non- Bees given a choice between dimethoate-treated and untreated target plants from residues in the soil to pollen, nectar, and other syrup displayed no aversion or preference to either, suggesting exuded substances.130 Seed-eating vertebrates, like birds, are ex- that not only are levels of dimethoate found in nectar toxic, but posed to lethal doses if they consume coated seeds131 or granular they are also not repellent.140 Similarly, honey bees cannot taste pesticides on the soil surface.132,133,134 Organisms that drink or live neonicotinoids and are not repelled by them, and instead prefer in contaminated waters, or soil dwellers like earthworms are all food containing neonicotinoids even though the pesticides caused at risk from exposure. For organisms like bees, poisoned pollen them to eat less food overall.141 and nectar can lead to long-term sublethal impacts on individual bees and the colony. These exposures can increase the organisms’ Several acute and chronic impacts on bees have been attributed vulnerability to disease and parasites.135,136 to exposure to systemic insecticides found in the pollen and nectar of treated plants. Dimethoate residues are found in the pollen of Impacts on Managed and Wild Bees alfalfa plants at levels toxic to honey bees as much as two weeks There are many routes of exposure by which bees are exposed after initial treatment, with residues increasing from 0.5 parts to systemic pesticides, including contaminated pollen and nec- per million (ppm) in pollen one day after application, to 3 ppm in tar that they forage and ingest, as well as guttation droplets they nectar one week later and 1 ppm in nectar two weeks later. Bees drink from plants. EPA’s preliminary imidacloprid pollinator risk as- exposed to these levels displayed inhibited cholinesterase activ- sessment, released in January 2016, confirms harmful residues of ity and reduced survival (Barker, Lehner, and Kunzmann, 1980).142 imidacloprid in crops where pollinators forage.137 A Harvard study by Chensheng Toxic effects result- Lu et al. (2015), ing from exposure found that 73 to very low levels percent of pollen of systemic insec- and 72 percent ticides are exten- of honey samples sive. Systemics, contained at least like fipronil, have one detectable been demonstrat- neonicotinoid. ed to impair the Forty-nine per- olfactory learning cent, 20 percent, and sucrose per- and four percent ception of honey of pollen samples bees, even at very contained one, low levels (0.5 ng/ two, and three bee and 1 ng/bee, neonicotinoids respectively).143 respectively,138 Continuous expo- while 57 percent sure to a sub-lethal and 15 percent dose of thiameth- of honey samples oxam was found contained one and to damage organs two neonicoti- used during the noids respectively. metabolism and According to EPA’s detoxification of 144 Pollinator Risk As- Photo by Cameron Crane, 2014. the insecticide.

Page 18 Pesticides and You Vol. 35, No. 4 Winter 2015-16 A quarterly publication of Beyond Pesticides Photo by Anneliese Markle. Ecological Risk Assessment Like its health risk assessments, EPA’s ecological risk assessments suffer from a framework that ignores the precautionary principle. As part of the pesticide registration process, EPA performs an ecological assessment that “evaluates the likelihood that exposure to one or more pesticides may cause harmful ecological effects”148 based on data submitted on the potential hazards to non-target fish and wildlife species. The effects can be direct or indirect, short-term (acute) or long-term (chronic), as shown by tests on organisms that broadly represent non-target organisms. EPA “may require testing for effects in insect pollinators, such as honey bees, when the typical end-use product (TEP) is intended for outdoor use and honey bees may be exposed to the pesticide.”149 The environmental fate of the pesticide –the interaction with soils, air, sunlight, surface water, and ground water– is also studied.150

EPA’s characterization of ecological risk is based on a comparison (Risk Quotient, or RQ) of the expected environmental concentration (EEC) of the pesticide and certain threshold concentrations, which vary for different types of risk. For example, the Risk Quotient for dietary exposures are: • Acute dietary RQ = EEC/LC50 • Chronic dietary RQ = EEC/NOEC

The LC50 is the median lethal dose –the dose that kills 50% of the test animals, and the NOEC is the no observed effect concentration– the highest level that did not produce an effect in test animals. Unless threatened or endangered species are known to be exposed, the LC50 and NOEC used are those of the most sensitive animal tested. The RQ is compared to a level of concern (LOC) for the particular type of risk. The predicted level of the pesticide in the environment would reach the “level of concern” for acute impacts on birds, for example, when the estimated environmental concentration is half the median lethal concentration.

EPA’s ecological assessments for pesticides have been critiqued and challenged in court by many stakeholder and citizen groups, especially with regard to endangered species. The courts have ruled that EPA’s ecological assessments failed to adequately protect critical species like salmon and steelhead,151 the California red-legged frog,152 and most recently, honey bees.153

A 2013 National Academy of Science (NAS) report,Assessing Risks to Endangered and Threatened Species from Pesticides, identified de- ficiencies in EPA’s ecological assessments and outlined recommendations to improve assessments and consultations with other federal agencies.154 Since then, EPA has worked with other federal agencies (e.g. U.S. Fish and Wildlife Service) to develop shared scientific approaches that reflect the advice provided by NAS.

NAS identified important issues that affect EPA’s ability to produce a scientifically defensible assessment of risk to plants and animals, but the critique is based on the risk assessment paradigm of the National Research Council (NRC) report, Risk Assessment in the Federal Government: Managing the Process.155 This paradigm, the basis of all of EPA’s risk assessments, is anti-precautionary, built on the premise that releasing toxic chemicals into the environment is acceptable unless shown to present a high level of risk. The biodiversity and climate of the planet are in critical condition, and a new framework for decision making is needed –one based on the precautionary principle and the premise that human action should heal the planet, not merely slow its demise.

The best decision-making framework that exists in U.S. law today is the one embedded in the Organic Foods Production Act (OFPA). OFPA and organic regulations require that organic farmers build and protect habitat for organisms that provide natural support for the agroeco- system. If such biodiversity conservation measures fail to provide an environment in which crops can thrive, then organic producers may use materials that (1) do not harm humans, other species, or the environment; (2) are necessary; and (3) are compatible with organic and sustainable production. This kind of precautionary approach should be adopted by EPA in deciding what risks are “unreasonable.”

The scientific literature on honey bee and pollinator decline indicates that current required eco-toxicology reviews do not adequately evaluate, as necessary, complex biological communities in nature. Rather, the requirements allow the registration of materials that have

Vol. 35, No. 4 Winter 2015-16 Pesticides and You Page 19 A quarterly publication of Beyond Pesticides Researchers in the UK found low, field-realistic exposure (0.7 ppb in the beetles. The loss of predatory beetles contributed to a reduction sugar water and 6 ppb in pollen) to imidacloprid resulted in a reduc- in soybean densities by 19 percent and yield by five percent.160 Expo- tion in bumblebees’ ability to gather food by 57 percent (Feltham, sure to systemic insecticides may also adversely affect soil organisms. Park, and Goulson, 2014).145 Exposure to imidacloprid has led to Fallen leaves from neonicotinoid-treated trees were found to result both acute and chronically impaired pollen foraging performance, in reductions in feeding rates by insects and earthworms, inhibition resulting in effects that include a decrease in pollen foraging- ef of aquatic and terrestrial microbial decomposition activity, and a deficiency and a change in flower preference and/or impairment in crease in leaf decomposition.161,162 ability to find flowers in exposed bumblebees.146 A 2013 study by Smagghe et al. reports that at levels representing 1/100 of the concentration recommended for use in the field, chronic exposure to chlorantraniliprole- contaminated pollen causes bumble bees and their offspring to become lethargic. The same study also showed severe sub-lethal effects on reproduction in bumblebee colonies exposed via the same route.147

Impacts on Other Beneficial Insects and Microorganisms While bee declines have been the most visible of non- target impacts, other beneficial insects such as ladybugs, beetles, and predators of agricultural pests are also neg- atively affected by the use of systemic insecticides. The loss of these and other non-target organisms pose serious concern for ecosystem diversity and natural control of other pests. Macrolophus pygmaeus, a predatory mirid from the Mediterranean used to control whiteflies, thrips, aphids, mites, and eggs and larvae of other pests, was found to undergo 100 percent mortality when exposed Harmful to Humans and Mammals, Too? to thiacloprid, while chlorantraniliprole exposure resulted Due to their mode of action, many of the newest systemic insecticides, in a decrease in plant feeding.156 The beneficial predatory including neonicotinoids, are touted as being less toxic or non-toxic to insect Orius insidiosus (insidious flower bug) experienced humans and mammals. However, evidence is emerging that this may not reduced egg viability, delayed oviposition (egg laying), be the case. A study by Japanese researchers (2012) found that acet- reduced nymph and female survival, and delayed devel- amiprid, imidacloprid, and nicotine exert similar effects at mammalian opment when exposed to sunflowers grown from seed nACh receptors, suggesting that excitation or desensitization or both treated with thiamethoxam and chlorantraniliprole.157 of nACh receptors by neonicotinoids affect the developing human and The predatory mite Neoseiulus fallacis is susceptible to mammalian nervous system, as is known to occur with nicotine.163 These several systemic insecticides, including clothianidin and findings were cited when, in 2013, the European Food Safety Authority the now-cancelled spirotetramat. Exposure to these two (EFSA) proposed that guidance levels for acceptable exposure to the two systemics caused 61.4 and 40.2 percent mortality of adult neonicotinoids be lowered, while further research is being carried out to N. fallacis, as well as significantly reduced fecundity.158 Mi- provide more reliable data on developmental neurotoxicity.164 croplitis croceipes, a wasp parasitoid of caterpillar pests, was found to have impaired foraging ability after feeding EPA identifies sulfoxaflor as having “Suggestive Evidence of Carcinogenic on extrafloral nectar from cotton treated with various sys- Potential” based on the preputial gland tumor response seen in rats. Ac- temic insecticides. Nectar from imidacloprid-treated cot- cording to regulatory documents, sulfoxaflor targets the nervous system ton reduced the flight response to host-associated odors and liver, resulting in developmental toxicity, liver toxicity, and other ef- of the parasitoid for four days, acephate for six days, and fects. Developmental and offspring toxicity, in the form of skeletal ab- aldicarb for as long as 18 days after application. Wasps normalities and neonatal deaths, were seen in rat studies. Liver toxicity that fed on nectar from plants treated with all three of expressed as changes in liver weight and enzymes, hypertrophy, prolif- these insecticides were also found to have reduced lon- eration, and tumors in subchronic and chronic studies have also been gevity (Stapel, Cortesero, and Lewis, 2000).159 Secondary observed. Other effects include a decrease in food consumption and poisonings of other non-target organisms also occur. Slugs body weight, as well as changes in the male reproductive system.165 Pre- exposed to thiamethoxam in fields, while unaffected by liminary studies on cyantraniliprole describe changes in the liver, thyroid the chemical, poisoned the predaceous beetles that fed gland, and renal cortex, and altered thyroid functioning in mammals. on them, resulting in a 60 percent population reduction in Dogs are found to be more sensitive to cyantraniliprole than both rats and mice.166

Page 20 Pesticides and You Vol. 35, No. 4 Winter 2015-16 A quarterly publication of Beyond Pesticides Impacts on Aquatic Organisms spirotetramat was found to result in oxidative stress and peroxi- Systemic insecticides present an especially large threat to aquatic dation in tadpoles of the Chinese toad (Bufo bufo gargarizans).179 systems.167 Older systemics like dimethoate are highly toxic to ju- venile carp, with exposure resulting in adverse effects that include Population level effects, such as a reduction in biodiversity, have erratic swimming, increased surfacing, reduced agility, and the in- also been documented. A study in Japan found that zooplank- ability to maintain normal posture and balance with increasing ton, bottom-dwelling, and water surface aquatic communities in exposure time, as well as a decrease in oxygen consumption.168 imidacloprid-treated rice fields had a significantly reduced abun- Methomyl is also toxic to fish and aquatic invertebrates, and can sig- dance of species. There are also differences in abundance of nificantly decrease the number of molts, total neonates, malformed swimming organisms in both imidacloprid- and fipronil-treated neonates, fertility and sex ratio index in aquatic invertebrates like paddies, as well as an impairment of the growth of Japanese rice Daphnia obtusa.170 There is evidence that carbofuran adversely af- fish, in both adults and their offspring (Hayasaka et al., 2012).180 fects reproduction in freshwater fish, reducing the number of eggs Another study found that locations where high concentrations as well as hatching percentage (Adhikari et al., 2008).171 of imidacloprid are detected have less abundant communities of aquatic macroinvertebrates (Van Dijk, Van Staalduinen, and Van A study investigating fipronil and three of its environmental der Sluijs, 2013).181 metabolites found very high toxicity to crayfish (Schlenk et al., 2001).172 Aquatic insects in waters containing fallen leaves from Impacts on Birds trees that were treated with imidacloprid exhibited reduced Ingestion of treated seeds or granular pesticides present a source of feeding rates.173 While chlorantraniliprole has been found in exposure for some species of birds. A report by the American Bird some studies to have relatively low toxicity to certain fish,174 Conservancy (2013) found that neonicotinoids are lethal to birds, other studies have found the chemical to be highly toxic to vari- as well as the aquatic systems on which they depend for food. The ous types of aquatic organisms on both an acute and chronic lev- report also found that a single corn kernel coated with a neonic- el.175 Amphibians, which otinoid can kill a songbird, have been facing an and even a tiny grain of existential threat with wheat or canola treated staggering declines in with imidacloprid can poi- populations across spe- son a bird. Furthermore, cies over the past few as little as 1/10 of a corn decades,176,177 have also seed per day during egg- been shown to be sen- laying season can affect sitive to systemic in- reproductive endpoints, secticide exposure. Re- such as fertility and em- searchers in Argentina bryonic development, found that imidacloprid with any of the registered exposure to the Monte- neonicotinoids.182 A sepa- video tree frog tadpoles rate study found oral ex- resulted in acute ef- posure of male quails to fects, such as increased clothianidin adversely genetic damage (Pérez- affects the reproduc- Iglesias et al., 2014).178 tion of the birds through Sub-lethal exposure to Red Munia Amandava amandava. Photo by Dr. Raju Kasambe, 2011. fragmentation of DNA in

Botanical Systemic Insecticides Some naturally-occurring or naturally-derived insecticides also have systemic action. Azadirachtin, an active ingredient derived from the oil found in neem tree seeds, is one such example. Studies have indicated the ability of this chemical to translocate through treated plants, with a relatively short half-life ranging from 5.1 to 12.3 days.187 Evidence has shown that azadirachtin repels bumblebees, although exposure to the chemical can also result in adverse reproductive effects (i.e. inhibited egg laying and decrease in ovarian length).188 Thus, more research is needed to determine whether, and under which circumstances, azadirachtin could be used in a way that does not threaten non-target organisms and ecosystems.

Other biologically-based chemicals that induce systemic responses include elicitors, which are chemicals from various sources that induce plant defenses. They include biologically generated volatile organic compounds (VOCs) released by plants as well as materials like laminarin, salicylic acid, and chitosan that may be applied to plants.198 The toxicological and ecological impacts of these materials have not been adequately studied.

Vol. 35, No. 4 Winter 2015-16 Pesticides and You Page 21 A quarterly publication of Beyond Pesticides History of Bee Kills – Temporary Fixes for a Persistent Problem

As long as there has been pesticide-intensive agriculture, bee- aquatic organisms, as well as bees and other beneficial insects, keepers have been faced with bee die-offs associated with- ex was first registered for agricultural use in 1954.193 The change posure to toxic chemicals, highlighting a persistent flaw in the from the spray form of the chemical to an encapsulated form U.S. approach to pesticide regulation. In order to compensate known as Penncap-M was blamed for the loss of several thou- beekeepers for these type of burdens, the government has his- sand colonies, as bees were shown to carry the capsules to the torically created indemnification programs. Indemnification pro- hive along with pollen.194 Although beekeepers were aware of the grams have served to compensate those harmed by regulatory highly toxic nature of methyl parathion, they were not prepared action190 –in this case, allowing the use of pesticides more toxic to for the lengthened period over which the encapsulated chemical bees following the cancellation of DDT. The Beekeeper Indemnity would kill bees.195 Penncap-M was classified as a restricted use Payment Program was enacted by Congress in the Agricultural pesticide (RUP) due to residual effects on avian species and bees, Act of 1970 after commercial beekeeping operations in California and in 2010 all methyl parathion product registration uses were and Arizona were virtually destroyed due to a spray program to cancelled.196 control pink bollworm on cotton. A 1976 USDA document,Report on the Beekeeper Indemnity Program, stated that the “Beekeeper EPA uses language on pesticide product labeling in an attempt to Indemnity Program has kept pollination costs low by indirectly reduce exposure of toxic chemicals to bees and other organisms. subsidizing crop producers through direct payments to beekeep- Penncap-M contained specific language warning about the dan- ers providing pollination services,” in face of large-scale use of ar- gers of this product to bees, stating that the “product is highly tificial fertilizers and pesticides.191 The report concluded: toxic to bees exposed to direct treatment or residues on blooming Unless Federal and State governments act to regulate and crops or weeds. Do not apply this product or allow it to drift to caution applicators of toxic pesticides, colony damage will blooming crops or weeds if bees are visiting the treatment area,” continue to be a major problem for beekeepers. However, and outlined various prohibitions to use based on crop types and most government officials emphasize that farmers and spray times when bees are foraging.197 However, label language does applicators are already confronted with enough regulations… little to prevent exposure to chemicals that are persistent in the the current development of stronger and longer-lasting pes- environment, and is limited in its application to the domesticated ticides…is creating an environment entirely unsuitable for honey bee. It is also often difficult to determine whether or not an honey bees in many parts of the U.S. These areas will find applicator is in violation of a label. Recent EPA label changes for it harder to maintain the present level of bee population re- neonicotinoids include wording such as “Do not apply this product gardless of an Indemnity Program or higher honey and pol- while bees are foraging. Do not apply this product until flowering lination prices.192 is complete and all petals have fallen… .”198 This language has similar limitations and does not address issues such as persistence or The risks of earlier pesticides to bees and other pollinators through the use of neonicotinoids as seed coatings. systemic action were never a focus of pesticide regulation. In- stead, EPA (and before that, USDA) used label instructions to try Advances in pesticide technology have often done more dispropor- to minimize direct contact of domestic honey bees with insecti- tionate harm to beekeepers and the bees they manage. Indemnifi- cides. Methyl parathion, an organophosphate insecticide highly cation programs have propped up the hazardous chemicals, eventu- toxic to birds, mammals, ally taken off the market, and changes to labeling do little to protect the health of bees. More importantly, as essential as commercial beekeeping is to agriculture, the ecosystem services provided by wild pollinators, predators, parasites, and soil organisms are of equally important and cannot be addressed by compensation or avoid- ance through labeling.

Page 22 Pesticides and You Vol. 35, No. 4 Winter 2015-16 A quarterly publication of Beyond Pesticides germ cells and the inhibition or delay of embryonic development (Tokumoto et al., 2013).183 Ingestion of imidacloprid-treated seeds Coated Seeds and the Treated Article Exemption by red-legged partridges at the recommended application rate Seeds of corn, soybean, canola, and others are typically coat- was found to result in 100 percent mortality, while dosage at 20 ed with pesticides before they are planted. Pesticide manu- percent of the recommended application rate resulted in adverse facturers believe the applied pesticides (insecticides, fungi- effects including reduced nutrient levels in plasma, as well as re- cides, etc.) protect the seed before and after germination duced clutch size, delayed egg-laying, and depressed T-cell immune from soil pests. Despite being coated with pesticides, these response in chicks.184 Researchers in the Netherlands (2014) found seeds are not regulated under FIFRA or any other federal law. that local insect-eating bird population numbers were inversely as- As such, there is no federal product labelling or federal/state sociated with higher surface-water concentrations of imidacloprid. enforcement and oversight around the cultivation or subse- Bird populations declined by 3.5 percent on average annually in ar- quent environmental contamination from their use. This is eas where imidacloprid concentrations of more than 20 ng/L were because, the seeds are categorized as treated articles and fall found (Hallmann et al., 2014).185 Low dose exposure of imidacloprid under the treated article exemption “loophole.” in the diet of Red Munia (Amandava amandava) was found to bring about changes in thyroid functioning.186 According to 40 C.F.R. § 152.25, the exemption states that a treated article is: New Generation Pesticides and the [...an] article or substance treated with, or containing, a Shortcomings of Pesticide Regulation pesticide to protect the article or substance itself (for -ex The current approach to assessing the risks posed by systemic ample, paint treated with a pesticide to protect the paint pesticides and others is designed to accept harm and uncertain- coating, or wood products treated to protect the wood ty. Risk assessment calculations under the Federal Insecticide, against insect or fungus infestation), if the pesticide is 200 Fungicide, and Rodenticide Act (FIFRA) –the law that regulates registered for such use. pesticide registration and use– overlook many real world scenar- ios, leading to an underestimation of hazards posed to human The interpretation of this exemption when it comes to seeds health and the environment. Furthermore, pesticide registra- is subject to challenge. tion decisions employ risk/benefit analyses that assume certain market or economic “benefits” without determining whether Pesticides that are systemic and used as seed coatings trans- the products are in fact necessary, or whether safer alternative locate throughout the plant, essentially making the entire are available. EPA issues determinations on the reasonableness plant a pesticidal agent. Thus, coated seeds should not be of risk, FIFRA’s legal standard, or assessments of acceptable risk exempt from regulation as a pesticide. The lack of a pesticide without data on the availability of less or non-toxic alternative designation for coated seeds means there can be little to no practices or materials. enforcement mechanism against the potential misuse of or harm from these products. Neonicotinoids and their impacts to pollinators and the wider environment exemplify the problems with the current risk assessment process that does not fully account for the sublethal and indirect effects of pesticides and impacts on ecological communities. New advances in pesticide technologies and application methods expose the inadequacies of the regulatory system.

In 2014, the White House issued a Presidential Memorandum directing federal agencies to create a federal task force to come EPA’s Steps to Address the Pollinator Decline Are up with recommendations to “reverse pollinator losses and help Insufficient restore populations to healthy levels.” The memorandum recog- EPA has proposed product label amendments, a moratorium on nized the severe losses in the populations of the nation’s polli- new neonicotinoid pesticide products, and restrictions on foliar nators, including honey bees, wild bees, monarch butterflies, and applications of bee-toxic pesticides during bloom when managed others.199 The final report, issued a year later, identifies key rec- bees are on-site and under contract. For all other situations, states ommendations to protect pollinator populations, but falls short have been tasked with creating their own pollinator protection of necessary regulatory action, including the cancellation and plans that rely heavily on notification requirements and best man- suspension of bee-killing systemic pesticides. Concerned groups, agement practices for farmers, placing continued responsibility environmentalists and beekeepers believe that without the sus- on beekeepers. The federal government’s emphasis on creating pension of neonicotinoid and other systemic insecticide use, the “physical and temporal space” between the use of pesticides and expansion of pollinator habitat recommended by the federal plan the presence of pollinators does little to address the chronic, sub- will remain a source of pesticide exposure and poisoning. lethal threat of systemic, neonicotinoid pesticides.201

Vol. 35, No. 4 Winter 2015-16 Pesticides and You Page 23 A quarterly publication of Beyond Pesticides “By their very nature, chemical controls are self-defeating, for they have been devised and applied without taking into account the complex biological systems against which they have been blindly hurled. The chemicals may have been pretested against a few individual species, but not against living communities . . . To assume that we must resign ourselves to turning our waterways into rivers of death is to follow the counsel of despair and defeatism. We must make wider use of alternative methods that are now known, and we must devote our ingenuity and resources to developing others.” –Rachel Carson, Silent Spring, 1962

New systemic insecticides that are highly toxic to bees continue to be registered. The latest, flupyradifurone, was registered in 2015, much to the dismay of beekeepers and concerned groups. We argue that these new systemics will compound the already dire pollinator crisis. Label amendments, which apply to all bee-toxic pesticides, focus only on foliar applications, but do not cover seed treatments or other applications, making no attempt to address the systemic nature of these chemicals. Environmental groups, beekeepers, and others have taken action challenging EPA’s continued approval of systemic pesticides, including lawsuits filed against the registrations of sulfoxaflor, cyantraniliprole and some neonicotinoids.

U.S. Fish and Wildlife Phases Out Neonicotinoids Distinguishing itself from EPA, the U.S. Fish and Wildlife Service (FWS) announced in the spring of 2014 that it will ban neonicotinoid insecticides from all wildlife refuges nationwide by January 2016,202 making it the first federal agency to adopt policy stating that the prophylactic use of toxic materials with broad spectrum Beyond Pesticides Staff joins other environmental groups to rally at the White House impacts is inconsistent with IPM policy.203 The White House Coun- to demand that the federal government ban neonicotinoid pesticides. cil on Environmental Quality (CEQ) also announced new guidelines for federal agencies to incorporate pollinator-friendly practices at and impacts that are unacceptable at a period in history when federal facilities and on federal lands, including recommendations toxic chemicals are not needed in productive, profitable, and cost- to avoid treating plants with systemic insecticides.204 effective organic production systems. Coupled with a piecemeal response to problems –label warnings or cancellation of particular Conclusion “problem” pesticides– it ratchets up the threat to biodiversity and Systemic pesticides present an increased intensification ofthe ecological systems. The perceived advancements in the protection threat to biodiversity that has not been observed since catastrophic of those who handle systemic insecticides cannot be traded for wildlife declines associated with DDT. The pesticide treadmill –the wreaking havoc with critical ecosystems that provides the founda- continuous push to find new chemistry when, inevitably, chemicals tion for all life. The very characteristics that enable the unsupported in use face resistance from target pests– brings with it trade-offs economic benefits of systemic pesticides –high solubility in water and persistence– are traits that make them a devastating threat to the ecosystem. A precautionary approach is needed when deal- International Efforts to Protect Pollinators ing with substances whose ecological fate and impact are not fully International efforts to protect pollinators from highly toxic understood. The reign of systemic pesticides must end –if only to systemics pesticides have had more success restricting neonic- save pollinators from extinction. With these special organisms as otinoids. In 2013, the European Union (EU) took critical steps a bellwether for change, it is time to take a hard look at how the to protect pollinators from the hazards associated with their systems we use to grow food and manage pests creates a pesticide use. Despite attempts by agrichemical corporations to delay or dependency that only serves to endanger vital ecosystems. The bio- reverse the decision, the two-year (still continuing), continent- diversity and climate of the planet are in critical condition, and a wide ban on bee-harming pesticides (clothianidin, thiameth- new framework that embraces and builds on certified organic sys- oxam, and imidacloprid) went into effect. The ban came- sev tems for decision making is needed –one based on the precaution- eral months after the European Food Safety Authority (EFSA) ary principle and the premise that human action should heal the released a report identifying “high acute risk” to honey bees planet, not merely slow its demise. from uses of certain neonicotinoid chemicals.206 EFSA is continuing to update its assessment of the risks to bees posed by the A fully cited version of this is available at bit.ly/pesticidesandyou. three neonicotinoid chemicals, which will take a look into their use as seed treatments and granules. The assessment is slated Nichelle Harriott, Terry Shistar, PhD, and Jay Feldman contributed for completion by January 2017.207 to this piece.

Page 24 Pesticides and You Vol. 35, No. 4 Winter 2015-16 A quarterly publication of Beyond Pesticides Endnotes

1. Van Engelsdorp, D., Underwood, R., Caron, D., & Hayes Jr., J. (2007). An Estimate of Managed pdf/dimethoate_ired_revised.pdf Colony Losses in the Winter of 2006-2007: A Report Commissioned by the Apiary Inspectors 28. U.S. Environmental Protection Agency. (2007). Reregistration Eligibility Decision for Aldicarb. of America. American Bee Journal. Retrieved from http://beeinformed.org/wp-content/up- Retrieved from http://www.epa.gov/pesticides/reregistration/REDs/aldicarb_red.pdf loads/2012/08/AnEstimateofManagedColonyLossesintheWinterof2006-2007.pdf 29. Sánchez-Bayo, F., Tennekes, H. A., & Goka, K. (2013). Chapter 13: Impact of Systemic Insecti- 2. Steinhauer, N., Rennich, K., Lee, K., Pettis, J., Tarpy, D. R., Rangel, J., … van Engelsdorp, D. cides on Organisms and Ecosystems. In Stanislov Trdan (Ed.), Insecticides – Development of (2015). Colony Loss 2014-2015: Preliminary Results. Bee Informed Partnership, Apiary Inspec- Safer and More Effective Technologies. doi: 10.5772/52831 tors of America, and US Department of Agriculture (USDA). Retrieved from https://beein- 30. Jeschke, P., Nauen, R., Schindler, M., & Elbert, A. (2011). Overview of the Status and Global formed.org/results/colony-loss-2014-2015-preliminary-results/ Strategy for Neonicotinoids. Journal of Agricultural and Food Chemistry, 59(7), 2897-2908. 3. Stokstad, E. (2013). How Big a Role Should Neonicotinoids Play in Food Security? Science, doi: 10.1021/jf101303g 340(6133), 675. doi: 10.1126/science.340.6133.675 31. James Tano Z. Chapter 1: Identity, Physical and Chemical Properties of Pesticides. Pesticides 4. Douglas, M. R., & Tooker, J. F. (2015). Large-Scale Deployment of Seed Treatments Has Driven in the Modern World – Trends in Pesticides Analysis. 2011. Available at: http://www.inte- Rapid Increase in Use of Neonicotinoid Insecticides and Preemptive Pest Management in U.S. chopen.com/books/pesticides-in-the-modern-world-trends-in-pesticidesanalysis/identity- Field Crops. Environmental Science and Technology, 49(8), 5088-5097. doi: 10.1021/es5061g physical-and-chemical-properties-of-pesticides. 5. Friends of the Earth. (2013). Gardeners: Beware, Bee-Toxic Pesticides Found in “Bee Friendly” 32. Bonmatin JM, et al. Systemic insecticides (imidacloprid and fipronil) reach pollen. A -wor Plants Sold at Garden Centers Nationwide. Retrieved from http://www.foe.org/system/ risome situation for bees. International conference on Bees: agriculture and biodiversity. storage/877/60/a/3130/Gardeners_beware_report_8-13-13_final_updated.pdf Mamer, Luxembourg, November 16-17, 2007. Available at: http://www.researchgate.net/ 6. Chagnon, M., Kreutzweiser, D., Mitchell, E. A. D., Morrissey, C. A., Noome, D. A., & van der publication/236846525_Systemic_insecticides_%28imidacloprid_and_fipronil%29_reach_ Sluijs, J. P. (2015). Risks of large-scale use of systemic insecticides to ecosystem functioning pollen._A_worrisome_situation_for. and services. Environmental Science and Pollution Research, 22(1), 119-134. doi: 10.1007/ 33. U.S. Environmental Protection Agency (EPA). Benefits of Neonicotinoid Seed Treat- s11356-014-3277-x ment to Soybean Production. 2014. Available at: http://www2.epa.gov/sites/production/ 7. Bartomeus, I., Potts, S. G., Steffan-Dewenter, I., Vaissiére, B. E., Woyciechowski, M., files/2014-10/documents/benefits_of_neonicotinoid_seed_treatments_to_soybean_pro- Krewenka, K. M., … Bommarco, R. (2014). Contribution of insect pollinators to crop yield and duction_2.pdf. quality varies with agricultural intensification. PeerJ, 2, e328. doi: 10.7717/peerj.328 34. Douglas, M. R., Rohr, J. R., & Tooker, J. F. (2015). Neonicotinoid insecticide travels through 8. Gallai, N., Salles, J.-M., Settele, J., & Vaissiére, B. E. (2009). Economic valuation of the vulner- a soil food chain, disrupting biological control of non-target pests and decreasing soya bean ability of world agriculture confronted with pollinator decline. Ecological Economics, 68(3), yield. Journal of Applied Ecology, 52, 250-260. doi: 10.1111/1365-2664.12372 810-821. doi: 10.1016/j.ecolecon.2008.06.014 35. Bredeson, M. M. and Lundgren J. G. (2015). Thiamethoxam Seed Treatments Have No 9. Calderone, N. W. (2012). Insect Pollinated Crops, Insect Pollinators and US Agriculture: Trend Impact on Pest Numbers on Yield in Cultivated Sunflowers. Journal of Economic Entomology. Analysis of Aggregate Data for the Period 1992-2009. PLoS ONE, 7(5), e37235. doi:10.1371/ Retrieved from http://jee.oxfordjournals.org/content/early/2015/09/02/jee.tov249.abstract journal.pone.0037235 36. Difonzo, C. D., Chludzinski, M. M., Jewett, M. R., and Springborn, F. (2015). Impact of Western 10. Eilers, E. J., Kremen, C., Greenleaf, S. S., Garber, A. K., & Klein, A.-M. Contribution of Pollinator- Bean Cutworm (Lepidoptera: Noctuidae) Infestation and Insecticide Treatments on Damage Mediated Crops to Nutrients in the Human Food Supply. PloS ONE, 6(6), e21363. doi: 10.1371/ and Marketable Yield of Michigan Dry Beans. Journal of Economic Entomology;108(2): pp. journal.pone.0021363 583-591. Retrieved from http://www.bioone.org/doi/abs/10.1093/jee/tov037 11. Klein, A.-M., Vaissiére, B. E., Cane, J. H., Steffan-Dewenter, I., Cunningham, S. A., Kremen, C., 37. Center for Food Safety. Heavy Costs: Weighing the Value of Neonicotinoid Insecticides in & Tscharntke, T. (2007). Importance of pollinators in changing landscapes for world crops. Pro- Agriculture. 2014. Available at: http://www.centerforfoodsafety.org/files/neonic-efficacy_ ceedings of The Royal Society B: Biological Sciences, 274(1608). doi: 10.1098/rspb.2006.3721 digital_29226.pdf. 12. U.S. Department of Agriculture. (2007). Colony Collapse Disorder Action Plan. Retrieved from 38. Agriculture and Horticultural Development Board (ADHB). ADAS Final 2015 Harvest Sum- http://www.ars.usda.gov/is/br/ccd/ccd_actionplan.pdf mary. 2015. Available at: http://cereals.ahdb.org.uk/markets/market-news/2015/october/09/ 13. Organic Trade Association. (2015). State of the Organic Industry: 2015. Retrieved January 19, adas-final-harvest-summary-report-2015.aspx. Accessed on January 14, 2015. 2016 from http://ota.com/sites/default/files/indexed_files/StateOfOrganicIndustry_0.pdf 39. http://www.epa.gov/sites/production/files/2015-07/documents/guidance_on_com- 14. Cerdeira, A. L., & Duke, S. O. (2006). The current status and environmental impacts of mon_mechanism.pdf glyphosate-resistant crops: a review. Journal of Environmental Quality, 35(5), 1633-1658. doi: 40. http://www.epa.gov/pesticide-science-and-assessing-pesticide-risks/guidance-identifying- 10.2134/jeq2005.0378 pesticide-chemicals-and-other 15. Pine, W. A., Viator, R., Wilcut, J. W., Edmisten, K. L., Thomas, J., & Wells, R. (2002). Reproduc- 41. Cloyd, R. A. (2002, November 27). Systemic, Local Systemic, or Translaminar Insecticides: tive abnormalities in glyphosate-resistant cotton caused by lower CP4-EPSPS levels in the What’s the Difference? University of Illinois Extension: Home, Yard & Pest Newsletter. Re- male reproductive tissue. Weed Science, 50(4), 438-447. http://dx.doi.org/10.1614/0043- trieved February 12, 2016 from http://hyg.ipm.illinois.edu/pastpest/200220e.html. 1745(2002)050[0438:RAIGRC]2.0.CO;2 42. Simon-Delso, N., Amaral-Rogers, V., Belzunces, L. P., Bonmatin, J. M., Chagnon, M., Downs, 16. Arregui, M. C., Lenardón, A., Sanchez, D., Maitre, M. I., Scotta, R., & Enrique, S. (2003). Moni- C., … Wiemers, M. (2015). Systemic insecticides (neonicotinoids and fipronil): trends, uses, toring glyphosate residues in transgenic glyphosate-resistant soybean. Pest Management mode of action and metabolites. Environmental Science and Pollution Research, 22(1), 5-34. Science, 60, 163-166. doi: 10.1002/ps.775 doi: 10.1007/s11356-014-3470-y 17. Krupke, C. H., Hunt, G. J., Eitzer, B. D., Andino, G., & Given, K. (2012). Multiple Routes of 43. Tomizawa, M., & Casida, J. E. (2003). Selective Toxicity of Neonicotinoids Attributable to Pesticide Exposure for Honey Bees Living Near Agricultural Fields. PLoS ONE, 7(1), e29268. doi: Specificity of Insect and Mammalian Nicotinic Receptors. Annual Review of Entomology, 48, 10.1371/journal.pone.0029268 339-364. doi: 10.1146/annurev.ento.48.091801.112731 18. U.S. Environmental Protection Agency. (2013, May 7). What are pesticides and how do 44. Bennett, S. H. (1957). The Behavior of Systemic Pesticides Applied to Plants. Annual Review they work? Retrieved February 12, 2016 from http://www.epa.nsw.gov.au/pesticides/pest- of Entomology, 2, 279-296. doi: 10.1146/annurev.en.02.010157.001431 whatrhow.htm 45. Van Timmeren, S., Wise, J. C., VanderVoort, C., & Isaacs, R. (2011). Comparison of foliar and 19. Klinhom, P., Halee, A., & Methawiwat, S. (2008). The Effectiveness of Household Chemicals soil formulations of neonicotinoid insecticides for control of potato leafhopper, Empoasca in Residue Removal of Methomyl and Carbaryl Pesticides on Chinese-Kale. Kasetsart Journal: fabae (Homoptera: Cicadellidae), in wine grapes. Pest Management Science, 67(5), 560-567. Natural Science, 42, 136-143. Retrieved from http://kasetsartjournal.ku.ac.th/kuj_files/2009/ doi: 10.1002/ps.2097 a0903191322516718.pdf 46. Elbert, A., Haas, M., Springer, B., Thielert, W., & Nauen, R. (2008). Mini-review: Applied 20. Hoffman, E. J., Vandervoort, C., & Wise, J. C. (2010). Plum curculio (Coleoptera: Curculioni- aspects of neonicotinoid uses in crop protection. Pest Management Science, 64, 1099-1105. dae) adult mortality and associated fruit injury after exposure to field-aged insecticides on doi: 10.1002/ps.1616 tart cherry branches. Journal of Economic Entomology, 103(4), 1196-1205. Retrieved from 47. Satchivi, N., Stoller, E. W., Wax, L. M., & Briskin, D. P. (2000). A Nonlinear Dynamic Simulation http://www.ncbi.nlm.nih.gov/pubmed/20857728 Model for Xenobiotic Transport and Whole Plant Allocation Following Foliar Application: I. 21. Mota-Sanchez, D., Cregg, B., Hoffmann, E., Flore, J., & Wise, J. C. (2012). Penetrative and Dis- Conceptual Foundation for Model Development. Pesticide Biochemistry and Physiology, lodgeable Residue Characteristics of 14C-Insecticides in Apple Fruits. Journal of Agricultural 68(2), 67-84. doi:10.1006/pest.2000.2501 and Food Chemistry, 60, 2958-2966. dx.doi.org/10.1021/jf205169f 48. Vermeer, R., & Baur, P. (2012, February 7). U.S. Patent No. 8,110,592 B2. Retrieved from 22. Abramitis, W. W. (1956, June 26). U.S. Patent No. 2,751,713. Washington, DC: U.S. Patent https://www.google.com/patents/US8110592 Office. Retrieved from http://www.google.com/patents/US2751713#forward-citations 49. Bennett, S. H. (1957). The Behavior of Systemic Pesticides Applied to Plants. Annual Review 23. Jeppson, L. R. (1953). Systemic Insecticides: Entomological Aspects of Systemic Insecticides. of Entomology, 2, 279-296. doi: 10.1146/annurev.en.02.010157.001431 Agricultural and Food Chemistry, 1(13), 830-832. doi: 10.1021/jf60013a003 50. Grayson, B. T., & Kleier, D. A. (1990). Phloem mobility of xenobiotics. IV. Modelling of 24. Metcalf R. L., March R. B., & Fukuto T. R. (1954). Study of Systemic Insecticides: location and pesticide movement in plants. Pest Management Science, 30(1), 67-79. doi: 10.1002/ amounts of residue in plant tissues determined with aid of radio-phosphorous tracers. Califor- ps.2780300108 nia Agriculture, 5-6. Retrieved from http://ucanr.edu/repositoryfiles/ca806p5-67041.pdf. 51. Dettenmaier, E. M, Doucette, W. J., & Bugbee, B. (2009). Chemical Hydrophobicity and 25. Sánchez-Bayo, F., Tennekes, H. A., & Goka, K. (2013). Chapter 13: Impact of Systemic Insecti- Uptake by Plant Roots. Environmental Science & Technology, 43(2), 324-329. doi: 10.1021/ cides on Organisms and Ecosystems. In Stanislov Trdan (Ed.), Insecticides – Development of es801751x Safer and More Effective Technologies. doi: 10.5772/52831 52. Sicbaldi, F., Sacchi, G. A., Trevisan, M., & Del Re, A. A. M. (1997). Root Uptake and Xylem 26. Sánchez-Bayo, F., Tennekes, H. A., & Goka, K. (2013). Chapter 13: Impact of Systemic Insecti- Translocation of Pesticides from Different Chemical Classes. Pest Management Science, 50(2), cides on Organisms and Ecosystems. In Stanislov Trdan (Ed.), Insecticides – Development of 111-119. doi: 10.1002/(SICI)1096-9063(199706)50:2<111::AID-PS573>3.0.CO;2-3 Safer and More Effective Technologies. doi: 10.5772/52831 53. Bocquené, G., & Galgani, F. (1998). Biological effects of contaminants: Cholinesterase inhibi- 27. U.S. Environmental Protection Agency. (2006). Revised Interim Reregistration Eligibility Deci- tion by orgranophosphate and carbamate compounds. No. 22. Copenhagen, Denmark: Inter- sions for Dimethoate. Retrieved from http://archive.epa.gov/pesticides/reregistration/web/ national Council for the Exploration of the Sea. Retrieved from http://www.ices.dk/sites/pub/ Endnotes 1 Pesticides and You Vol. 35, No. 4 Winter 2015-16 A quarterly publication of Beyond Pesticides Publication%20Reports/Techniques%20in%20Marine%20Environmental%20Sciences%20 Control of Early-Season Pests of Corn and Its Effects on Yield. Journal of Agricultural and (TIMES)/times22/TIMES22.pdf Urban Entomology, 21(2), 75-85. doi: http://dx.doi.org/10.3954/1523-5475-24.4.177 54. U.S. Environmental Protection Agency. (1994). RED FACTS: Mevinphos. Retrieved from 80. Taylor, A. G., Eckenrode, C. J., & Straub, R. W. (2001). Seed Coating Technologies and Treat- http://www.epa.gov/opp00001/chem_search/reg_actions/reregistration/fs_PC-015801_1- ments for Onion: Challenges and Progress. HortScience, 36, 199-205. Retrieved from http:// Sep-94.pdf hortsci.ashspublications.org/content/36/2/199.full.pdf 55. U.S. Environmental Protection Agency. (2006). Reregistration Eligibility Decision for 81. Gourmet, C., Kolb, F. L., Smyth, C. A., & Pedersen, W. L. (1996). Use of Imidacloprid as a Seed- Dimethoate. Retrieved from http://www.epa.gov/pesticides/reregistration/REDs/dimetho- Treatment Insecticide to Control Barley Yellow Dwarf Virus (BYDV) in Oat and Wheat. Plant ate_red.pdf Disease, 80(2), 136-141. Retrieved from http://www.apsnet.org/publications/PlantDisease/ 56. U.S. Environmental Protection Agency. (2008). Carbofuran IRED FACTS. Retrieved BackIssues/Documents/1996Articles/PlantDisease80n02_136.PDF from http://www.epa.gov/opp00001/chem_search/reg_actions/reregistration/fs_PC- 82. Elbert, A., Haas, M., Springer, B., Thielert, W., & Nauen, R. (2008). Mini-review: Applied 090601_20-Jun-08.pdf aspects of neonicotinoid uses in crop protection. Pest Management Science, 64, 1099-1105. 57. U.S. Environmental Protection Agency. (2010). Agreement to Terminate All Uses of Aldicarb. doi: 10.1002/ps.1616 Retrieved from http://www.epa.gov/oppsrrd1/REDs/factsheets/aldicarb_fs.html#action 83. Douglas, M. R., & Tooker, J. F. (2015). Increase in Use of Neonicotinoids Insecticides and 58. U.S. Environmental Protection Agency. (2010). Oxamyl Summary Document. Retrieved Preemptive Pest Management in U.S. Field Crops. Environmental Science & Technology, from http://www.regulations.gov/contentStreamer?documentId=EPA-HQ-OPP-2010-0028- 49(8). doi: 10.1021/es506141g 0010&disposition=attachment&contentType=pdf 84. CropLife Foundation. (2013). The Role of Seed Treatment in Modern U.S. Crop Production: A 59. Buckingham, S. D., Lapied, B., Le Corronc, H., Grolleau, F., & Sattelle, D. B. (1997). Imidacloprid Review of Benefits. Retrieved from https://www.motherjones.com/files/seedtreatment.pdf actions on insect neuronal acetylcholine receptors. The Journal of Experimental Biology, 200, 85. Girolami, V., Mazzon, L., Squartini, A., Mori, N., Marzaro, M., Di Bernardo, A., Greatti, M., … 2685-2692. Retrieved from http://jeb.biologists.org/content/200/21/2685.full.pdf Tapparo, A. (2009). Translocation of Neonicotinoid Insecticides From Coated Seeds to Seed- 60. Zhang, A., Kayser, H., Maienfisch, P., & Casida, J. E. (2000). Insect Nicotinic Acetylcholine ling Guttation Drops: A Novel Way of Intoxication for Bees. Journal of Economic Entomology, Receptor: Conserved Neonicotinoid Specificity of [3H]Imidacloprid Binding Site. Journal 102(5), 1808-1815. doi: 10.1603/029.102.0511 of Neurochemistry, 75(3), 1294-1303. Retrieved from http://onlinelibrary.wiley.com/ 86. Goulson, D. (2013). Review: An overview of the environmental risks posed by neonicotinoid doi/10.1046/j.1471-4159.2000.751294.x/pdf insecticides. Journal of Applied Ecology, 50, 977-987. doi: 10.1111/1365-2664.12111 61. Hayasaka, D., Korenaga, T., Suzuki, K., Sánchez-Bayo, F., & Goka, K. (2012). Differences in sus- 87. El-Hamady, S. E., Kubiak, R., & Derbalah, A. S. (2008). Fate of imidacloprid in soil and plant ceptibility of five cladoceran species to two systemic insecticides, imidacloprid and fipronil. after application to cotton seeds. Chemosphere, 71(11), 2173-2179. doi: 10.1016/j.chemo- Ecotoxicology, 21(2), 421-427. doi: 10.1007/s10646-011-0802-2 sphere.2007.12.027 62. Jemec, A., Tišlera, T., Drobneb, D., Sepčićb, K., Fournierc, D., & Trebše, P. (2007). Comparative 88. Krupke, C. H., Hunt, G. J., Eitzer, B. D., Andino, G., & Given, K. (2012). Multiple Routes of toxicity of imidacloprid, of its commercial liquid formulation and of diazinon to a non- Pesticide Exposure for Honey Bees Living Near Agricultural Fields. PLoS ONE, 7(1), e29268. target arthropod, the microcrustacean Daphnia magna. Chemosphere, 68(8), 1408-1418. doi:10.1371/journal.pone.0029268 doi:10.1016/j.chemosphere.2007.04.015 89. U.S. Environmental Protection Agency. (2014). Registration of the New Active Ingredient 63. Simon-Delso, N., Amaral-Rogers, V., Belzunces, L. P., Bonmatin, J. M., Chagnon, M., Downs, Cyantraniliprole. Retrieved from http://www.regulations.gov/#!documentDetail;D=EPA-HQ- C., … Wiemers, M. (2014). Systemic insecticides (neonicotinoids and fipronil): trends, uses, OPP-2011-0668-0057 mode of action and metabolites. Environmental Science and Pollution Research, 22(1), 5-34. 90. U.S. Environmental Protection Agency. (2015). Registration Decision for the New doi: 10.1007/s11356-014-3470-y Active Ingredient Flupyradifurone. Retrieved from http://www.regulations.gov/ 64. Jeschke, P., Nauen, R., Schindler, M., & Elbert, A. (2011). Overview of the Status and Global contentStreamer?documentId=EPA-HQ-OPP-2013-0226-0044&disposition=attachment&c Strategy for Neonicotinoids. Journal of Agricultural and Food Chemistry, 59(7), 2897-2908. ontentType=pdf doi: 10.1021/jf101303g 91. Food Quality Protection Act of 1996, 7 U.S.C. § 136. (1996). Retrieved from https://www.gpo. 65. Sparks, T. C., & Nauen, R. (2015). IRAC: Mode of action classification and insecticide resis- gov/fdsys/pkg/PLAW-104publ170/pdf/PLAW-104publ170.pdf tance management. Pesticide Biochemistry and Physiology, 121, 122-128. doi: 10.1016/j. 92. U.S. Environmental Protection Agency. (2016, January). Conventional Reduced Risk Pesticide pestbp.2014.11.014 Program. Retrieved February 17, 2016 from http://www.epa.gov/pesticide-registration/ 66. Cole, L. M., Nicholson, R. A., & Casida, J. E. (1993). Action of phenylpyrazole insecticides at conventional-reduced-risk-pesticide-program the GABA-gated chloride channel. Pesticide Biochemistry and Physiology, 46(1), 47-54. doi: 93. Syngenta. (2014). Acelepryn Insecticide (Label). Retrieved from http://www.domyownpest- 10.1006/pest.1993.1035 control.com/msds/Syngenta_Acelepryn_Label.pdf 67. U.S. Environmental Protection Agency. (2011). Fipronil Summary Document Reg- 94. U.S. Environmental Protection Agency. (2015, December). Minimum Risk Pesticide: Defini- istration Review: Initial Docket. Retrieved from http://www.regulations.gov/ tion and Product Confirmation. Retrieved February 17, 2016 from http://www.epa.gov/ contentStreamer?documentId=EPA-HQ-OPP-2011-0448-0003&disposition=attachment&c minimum-risk-pesticides/minimum-risk-pesticide-definition-and-product-confirmation ontentType=pdf. 95. Watson, G. B., Loso, M. R., Babcock, J. M., Hasler, J. M., Letherer, T. J., Young, C. D., … Sparks, 68. Aajoud, A., Raveton, M., Aouadi, H., Tissut, M., & Ravanel, P. (2006). Uptake and Xylem T. C. (2011). Novel nicotinic action of the sulfoximine insecticide sulfoxaflor. Insecticide Bio- Transport of Fipronil in Sunflower. Journal of Agricultural and Food Chemistry, 54, 5055-5060. chemistry and Molecular Biology, 41(7), 432-439. doi: 10.1016/j.ibmb.2011.01.009 doi: 10.1021/jf0604081 96. Insecticide Resistance Action Committee (IRAC) International Mode of Action Working 69. Chauzat, M.-P., Faucon, J.-P., Martel, A.-C., Lachaize, J., Cougoule, N., & Aubert, M. (2006). Group. (2015). IRAC Mode of Action Classification Scheme. Retrieved from http://www.irac- A Survey of Pesticide Residues in Pollen Loads Collected by Honey Bees in France. Journal of online.org/documents/moa-classification/?ext=pdf Economic Entomology, 99(2), 253-262. doi: http://dx.doi.org/10.1603/0022-0493-99.2.253 97. Cutler, P., Slater, R., Edmunds, A. J., Maienfisch, P., Hall, R. G., Earley, F. G., … Crossthwaite, A. 70. Gunasekara, A. S., Truong, T., Goh, K. S., Spurlock, F., & Tjeerdema, R. S. (2007). Environmen- J. (2013). Investigating the mode of action of sulfoxaflor: a fourth-generation neonicotinoid. tal fate and toxicology of fipronil. Journal of Pesticide Science, 32(3), 189-199. doi: 10.1584/ Pest Management Science, 69(5), 607-619. doi: 10.1002/ps.3413 jpestics.R07-02 98. U.S. Environmental Protection Agency. (2013). Registration of the New Active Ingredient 71. U.S. Geological Survey. (2014). An Overview Comparing Results from Two Decades of Moni- Sulfoxaflor for Use on Multiple Commodities, Turfgrass and Ornamentals. Retrieved from toring for Pesticides in the Nation’s Streams and Rivers, 1992–2001 and 2002–2011. Retrieved http://www.regulations.gov/contentStreamer?documentId=EPA-HQ-OPP-2010-0889- from http://pubs.usgs.gov/sir/2014/5154/. 0396&disposition=attachment&contentType=pdf 72. El Hassani, A. K., Dacher, M., Gauthier, M., & Armengaud, C. (2005). Effects of sublethal 99. U.S. Environmental Protection Agency. (2013). Registration of the New Active Ingredient doses of fipronil on the behavior of the honeybee (Apis mellifera), 82(1), 30-39. doi:10.1016/j. Sulfoxaflor for Use on Multiple Commodities, Turfgrass and Ornamentals. Retrieved from pbb.2005.07.008 http://www.regulations.gov/contentStreamer?documentId=EPA-HQ-OPP-2010-0889- 73. Overmyer, J. P., Rouse, D. R., Avants, J. K., Garrison, A. W., DeLorenzo, M. E., Chung, K .W., … 0396&disposition=attachment&contentType=pdf Black, M. C. (2007). Toxicity of fipronil and its enantiomers to marine and freshwater non- 100. Zhu, Y., Loso, M. R., Watson, G. B., Sparks, T. C., Rogers, R. B., Huang, J. X., … Thomas, J. D. targets. Journal of Environmental Science and Health, Part B: Pesticides, Food Contaminants, (2011). Discovery and Characterization of Sulfoxaflor, a Novel Insecticide Targeting Sap- and Agricultural Wastes, 42(5), 471-480. doi: 10.1080/03601230701391823 Feeding Pests. Journal of Agricultural and Food Chemistry, 59(7), 2950-2957. doi: 10.1021/ 74. Cordova, D., Benner, E. A., Sacher, M. D., Rauh, J. J., Sopa, J. S., Lahm, G. P., … Tao, Y. (2006). jf102765x Anthranilic diamides: A new class of insecticides with a novel mode of action, ryanodine 101. Pollinator Stewardship Council v. U.S. EPA. United States Court of Appeals for the Ninth Cir- receptor activation. Pesticide Biochemistry and Physiology, 84(3), 196-214. doi:10.1016/j. cuit. (2013, December 6). Retrieved August 3, 2015 from http://earthjustice.org/sites/default/ pestbp.2005.07.005 files/files/sulfoxaflor-opening-brief_12-06.pdf 75. Ebbinghaus-Kintscher, U., Luemmen, P., Lobitz, N., Schulte, T., Funke, C., Fischer, R., … Tohni- 102. Pollinator Stewardship Council v. U.S. EPA. United States Court of Appeals for the Ninth shi, M. (2006). Phthalic acid diamides activate ryanodine-sensitive Ca2+ release channels in Circuit. (2015). Retrieved from http://earthjustice.org/sites/default/files/files/sulfoxaflor- insects. Cell Calcium, 39(1), 21-33. doi: 10.1016/j.ceca.2005.09.002 opinion.pdf 76. Sparks, T. C., & Nauen, R. (2015). IRAC: Mode of action classification and insecticide resis- 103. Nauen, R., Jeschke, P., Velten, R., Beck, M. E., Ebbinghaus-Kintscher, U., Thielert, W., … tance management. Pesticide Biochemistry and Physiology, 121, 122-128. doi: 10.1016/j. Raupach, G. (2015). Flupyradifurone: a brief profile of a new butenolide insecticide. Pesticide pestbp.2014.11.014 Management Science, 71(6), 850-862. doi: 10.1002/ps.3932 77. U.S. Environmental Protection Agency. (2008). Pesticide Fact Sheet (Chlorantraniliprole). 104. U.S. Environmental Protection Agency. (2015). Registration Decision for the New Retrieved from http://www.epa.gov/opp00001/chem_search/reg_actions/registration/ Active Ingredient Flupyradifurone. Retrieved from http://www.regulations.gov/ fs_PC-090100_01-Apr-08.pdf contentStreamer?documentId=EPA-HQ-OPP-2013-0226-0044&disposition=attachment&c 78. U.S. Environmental Protection Agency. (2014). Registration of the New Active Ingredient ontentType=pdf Cyantraniliprole – Decision Document. 2008. Retrieved from http://www.regulations.gov/ 105. U.S. Environmental Protection Agency. (2015). Registration Decision for the New contentStreamer?documentId=EPA-HQ-OPP-2011-0668-0057&disposition=attachment&c Active Ingredient Flupyradifurone. Retrieved from http://www.regulations.gov/ ontentType=pdf contentStreamer?documentId=EPA-HQ-OPP-2013-0226-0044&disposition=attachment&c 79. Wilde, G., Roozeboom, K., Claassen, M., Janssen, K., & Witt, M. (2004). Seed Treatment for ontentType=pdf

Endnotes 2 Pesticides and You Vol. 35, No. 4 Winter 2015-16 A quarterly publication of Beyond Pesticides 106. Edwards, C. A. (1966). Insecticide residues in soils. Reviews of Environmental Con- 133. Luttik, R., & de Snoo, G. R. (2004). Characterization of grit in arable birds to improve pesticide tamination and Toxicology, 13, 83-132. Retrieved from http://link.springer.com/chap- risk assessment. Ecotoxicology and Environmental Safety, 57(3), 319-329. doi: 10.1016/S0147- ter/10.1007/978-1-4615-8407-0_4. 6513(03)00034-4 107. Goulson, D. (2013). Review: An overview of the environmental risks posed by neonicotinoid 134. Balcomb, R., Bowen II, C. A., Wright, D., & Law, M. (1984). Effects on Wildlife of At-Planting insecticides. Journal of Applied Ecology, 50, 977-987. doi: 10.1111/1365-2664.12111 Corn Applications of Granular Carbofuran. The Journal of Wildlife Management, 48(4), 1353- 108. El-Hamady, S. E., Kubiak, R., & Derbalah, A. S. (2008). Fate of imidacloprid in soil and plant 1359. doi: 10.2307/3801796 after application to cotton seeds. Chemosphere, 71(11), 2173-2179. doi: 10.1016/j.chemo- 135. Coors, A., Decaestecker, E., Jansen, M., & De Meester, L. (2008) Pesticide exposure strongly sphere.2007.12.027 enhances parasite virulence in an invertebrate host model. Oikos, 117(12), 1840-1846. doi: 109. Leiva, J. A., Nkedi-Kizza, P., Morgan, K .T., Qureshi, J. A. (2015). Imidacloprid Sorption Kinetics, 10.1111/j.1600-0706.2008.17028.x Equilibria, and Degradation in Sandy Soils of Florida. Journal of Agricultural Food Chemistry, 136. Aufauvre, J., Biron, D. G., Vidau, C., Fontbonne, R., Roudel, M., Diogon, M., … Blot, N. (2012). 63(20), 4915-4921. doi: 10.1021/acs.jafc.5b00532 Paraside-insecticide interactions: a case study of Nosema ceranae and fipronil synergy on 110. U.S. Environmental Protection Agency. (2007). Reregistration Eligibility Decision for Aldicarb. honeybee. Scientific Reports 2, 326. doi: 10.1038/srep00326 Retrieved from http://www.epa.gov/opp00001/chem_search/reg_actions/reregistration/ 137. U.S. Environmental Protection Agency. (2016). EPA Releases the First of Four Preliminary Risk red_PC-098301_1-Sep-07.pdf Assessments for Insecticides Potentially Harmful to Bees (Press Release). Retrieved February 111. Arias-Estévez, M., López-Periago, E., Martínez-Carballo, E., Simal-Gándara, J., Mejuto, J.-C., 18, 2016 from http://yosemite.epa.gov/opa/admpress.nsf/0/63E7FB0E47B1AA3685257F32 García-Río, L. (2008). The mobility and degradation of pesticides in soils and the pollution of 0050A7E3 groundwater resources. Agriculture Ecosystems & Environment, 123, 247-260. doi: 10.1016/j. 138. Lu, C., Chang, C.-H., Tao, L., & Chen, M. (2015). Distributions of neonicotinoid insecticides in agee.2007.07.011 the Commonwealth of Massachusetts: a temporal and spatial variation analysis for pollen and 112. Goulson, D. (2013). Review: An overview of the environmental risks posed by neonicotinoid honey samples. Environmental Chemistry, 13(1), 4-11. http://dx.doi.org/10.1071/EN15064 insecticides. Journal of Applied Ecology, 50, 977-987. doi: 10.1111/1365-2664.12111 139. Krupke, C. H., Hunt, G. J., Eitzer, B. D., Andino, G., & Given, K. (2012). Multiple Routes of 113. Peterson, C. J. (2010). Effect of vegetation on the longevity, mobility and activity of fipronil Pesticide Exposure for Honey Bees Living Near Agricultural Fields. PLoS ONE, 7(1), e29268. doi: applied at the termiticidal rate in laboratory soil columns. Pest Management Science, 66(9), 10.1371/journal.pone.0029268 944-948. doi: 10.1002/ps.1964 140. Barker, R., Lehner, Y., & Kunzmann, M. R. (1980). Pesticides and Honey Bees: Nectar and Pol- 114. Zhang, J.-M., Chai, W.-G., Wu, Y.-L. (2012). Residues of chlorantraniliprole in rice field ecosys- len Contamination in Alfalfa Treated with Dimethoate. Archives of Environmental Contamina- tem. Chemosphere, 87(2), 132-136. doi:10.1016/j.chemosphere.2011.11.076 tion and Toxicology, 9(2), 125-133. doi: 10.1007/BF01055368 115. Sharma, N., Mandal, K., Kumar, R., Kumar, B., & Singh, B. (2014). Persistence of chlorantra- 141. Kessler, S. C., Tiedeken, E. J., Simcock, K. L., Dervau, S., Mitchell, J., Softley, S., … Wright, G. niliprole granule formulation in sugarcane field soil. Environmental Monitoring and Assess- A. (2015). Bees prefer foods containing neonicotinoid pesticides. Nature, 521, 74-76. doi: ment, 186(4), 2289-2295. doi: 10.1007/s10661-013-3537-0 10.1038/nature14414 116. U.S. Environmental Protection Agency. (2008). Pesticide Fact Sheet (Chlorantraniliprole). 142. Barker, R. J., Lehner, Y., & Kunzmann, M. R. (1980). Pesticides and honey bees: Nectar and Retrieved from http://www.epa.gov/opp00001/chem_search/reg_actions/registration/ pollen contamination in alfalfa treated with dimethoate. Archives of Environmental Contami- fs_PC-090100_01-Apr-08.pdf nation and Toxicology, 9(2), 125-133. doi: 10.1007/BF01055368 117. U.S. Environmental Protection Agency. (2012, September 4). Criteria Used by the PBT Pro- 143. El Hassani, A. K., Dacher, M., Gauthier, M., & Armengaud, C. (2005). Effects of sublethal filer. Retrieved July 13, 2015 from www.pbtprofiler.net/criteria.asp doses of fipronil on the behavior of the honeybee (Apis mellifera), 82(1), 30-39. doi:10.1016/j. 118. U.S. Environmental Protection Agency. (2014). Registration of the New Active Ingredient pbb.2005.07.008 Cyantraniliprole. Retrieved fron http://www.regulations.gov/#!documentDetail;D=EPA-HQ- 144. Catae, A. F., Roat, T. C., De Oliveira, R. A., Nocelli, R. C. F., & Malaspina, O. (2014). Cytotoxic OPP-2011-0668-0057 effects of thiamethoxam in the midgut and malpighian tubules of Africanized Apis mellifera 119. U.S. Environmental Protection Agency. (2014). Environmental Fate and Ecological Risk As- (Hymenoptera: Apidae). Microscopy Research and Technique, 77(4), 274-281. doi: 10.1002/ sessment of Foliar, Soil Drench, and Seed Treatment Uses of the New Insecticide Flupyradifu- jemt.22339 rone (BYI 02960). Retrieved from http://moraybeedinosaurs.co.uk/neonicotinoid/Flupyradi- 145. Feltham, H., Park, K., & Goulson, D. (2014). Field realistic doses of pesticide imidacloprid furone%20New%20Insecticide.pdf reduce bumblebee pollen foraging efficiency. Ecotoxicology, 23(3), 317-323. doi: 10.1007/ 120. U.S. Environmental Protection Agency. (2013). Registration of the New Active Ingredient s10646-014-1189-7 Sulfoxaflor for Use on Multiple Commodities, Turfgrass and Ornamentals. Retrieved from 146. Gill, R. J., & Raine, N.E. (2014). Chronic impairment of bumblebee natural foraging behavior http://www.regulations.gov/contentStreamer?documentId=EPA-HQ-OPP-2010-0889- induced by sublethal pesticide exposure. Functional Ecology, 28(6), 1459-1471. doi: 0396&disposition=attachment&contentType=pdf 10.1111/1365-2435.12292 121. Sánchez-Bayo, F., Tennekes, H. A., & Goka, K. (2013). Chapter 13: Impact of Systemic Insecti- 147. Smagghe, G., Deknopper, J., Meeus, I., & Mommaerts, V. (2013). Dietary chlorantraniliprole cides on Organisms and Ecosystems. In Stanislov Trdan (Ed.), Insecticides – Development of suppresses reproduction in worker bumblebees. Pest Management Science. 2013. doi: Safer and More Effective Technologies. doi: 10.5772/52831 10.1002/ps.3504 122. Gillion, R. J., Barbash, J. E., Crawford, C. G., Hamilton, P. A., Martin, J. D., Nagasaki, N., … 148. U.S. Environmental Protection Agency. (2016, February 9). Factsheet on Ecological Risk Wolock, D. M. U.S. Geographical Survey. (2006). The Quality of Our Nation’s Waters—Pesti- Assessment for Pesticides. Retrieved February 18, 2016 from http://www.epa.gov/pesticide- cides in the Nation’s Streams and Ground Water, 1992-2001 (U.S. Geological Survey Circular science-and-assessing-pesticide-risks/factsheet-ecological-risk-assessment-pesticides 1291). Retrieved from http://pubs.usgs.gov/circ/2005/1291/pdf/circ1291.pdf 149. U.S. Environmental Protection Agency. (2016, January 28). Technical Overview of Ecological 123. Stone, W. W., Gilliom, R. J., & Martin, J. D. U.S. Geological Survey. (2014). An Overview Com- Risk Assessment – Analysis Phase: Ecological Effects Characterization. Retrieved February 18, paring Results from Two Decades of Monitoring for Pesticides in the Nation’s Streams and 2016 from http://www.epa.gov/pesticide-science-and-assessing-pesticide-risks/technical- Rivers, 1992–2001 and 2002–2011 (U.S. Geological Survey Scientific Investigations Report overview-ecological-risk-assessment-0 2014–5154). http://dx.doi.org/10.3133/sir20145154. 150. The data required and the review process is described in EPA’s Guidelines for Ecological Risk 124. Hladik, M. L., & Kolpin, D. W. (2015). First national-scale reconnaissance of neonicotinoid Assessment. insecticides in streams across the USA. Environmental Chemistry, 13(1), 12-20. http://dx.doi. 151. Northwest Center for Alternatives to Pesticides (NCAP) v EPA, No. 2:10-cv-01919-TSZ (2014, org/10.1071/EN15061 August 15) 125. Hladik, M. L., Kolpin, D. W., & Kuivila, K. M. (2014). Widespread occurrence of neonicotinoid 152. Center for Biological Diversity (CBD) v. Johnson, No. 3:11-cv-5108-JSW (2013, November 11) insecticides in streams in a high corn and soybean producing region, USA. Environmental 153. Pollinator Stewardship Council v. U.S. Environmental Protection Agency, No. 13-72346, pg. Pollution, 193, 189-196. doi:10.1016/j.envpol.2014.06.033 29 (2015, September 10) in which the court concluded that EPA violated federal law when it 126. Morrissey, C. A., Mineau, P., Devries, J. H., Sanchez-Bayo, F., Liess, M., Cavallaro, M. C., & approved the insecticide sulfoxaflor without reliable studies regarding the impact the insecti- Liber, K. (2015). Neonicotinoid contamination of global surface waters and associated risk cide would have on honey bee colonies. to aquatic invertebrates: A review. Environmental International, 74, 291-303. doi:10.1016/j. 154. National Academy of Sciences. (2013). Assessing Risks to Endangered and Threatened envint.2014.10.024 Species from Pesticides. Committee on Ecological Risk Assessment Under FIFRA and ESA; 127. U.S. Environmental Protection Agency. (2014) Environmental Fate and Ecological Risk Assess- Board on Environmental Studies and Toxicology; Division on Earth and Life Studies; National ment of Foliar, Soil Drench, and Seed Treatment Uses of the New Insecticide Flupyradifurone Research Council. Washington, D.C.: National Academies Press. Retrieved from http://www. (BYI 02960). Retrieved from http://moraybeedinosaurs.co.uk/neonicotinoid/Flupyradifu- beyondpesticides.org/assets/media/documents/documents/NASpesticideESAreport2013. rone%20New%20Insecticide.pdf pdf 128. Bonmatin, J.-M., Gioro, C., Girolami, V., Goulson, D., Kreutzweiser, D. P., Krupke, … Tapparo, A. 155. National Research Council. (1983). Risk Assessment in the Federal Government: Managing (2014). Environmental fate and exposure; neonicotinoids and fipronil. Environmental Science the Process. Washington, DC: National Academy Press. Retrieved from http://www.nap.edu/ and Pollution Research, 22(1), 33-67. doi: 10.1007/s11356-014-3332-7 read/366/chapter/1 129. Tapparo, A., Marton, D., Giorio, C., Zanella, A., Soldá, L., Marzaro, M., … Girolami, V. (2012). 156. Martinou, A. F., Seraphids, N., & Stavrinides, M. C. (2014). Lethal and behavioural effects of Assessment of the Environmental Exposure of Honeybees to Particulate Matter Contain- pesticides on the insect predator Macrolophus pygmaeus. Chemosphere, 96, 67-173. http:// ing Neonicotinoid Insecticides Coming from Corn Coated Seeds. Environmental Science & dx.doi.org/10.1016/j.chemosphere.2013.10.024 Technology, 46, 2592-2599. dx.doi.org/10.1021/es2035152 157. Gontijo, P. C., Moscardini, V. F., Michaud, J. P., & Carvalho, G. A. (2014). Non-target effects of 130. U.S. Environmental Protection Agency. (2014). Guidance for Assessing Pesticide Risks to two sunflower seed treatments on Orius insidiosus (Hemiptera: Anthocoridae). Pest Manage- Bees. Retrieved from http://www2.epa.gov/sites/production/files/2014-06/documents/pol- ment Science, 71(4), 515-522. doi: 10.1002/ps.3798 linator_risk_assessment_guidance_06_19_14.pdf 158. Lefebvre, M., Bostonian, N. J., Mauffette, Y., Racette, G., Thistlewood, H., & Hardman, J. M. 131. Mineau, P., & Palmer, C. (2013). The Impact of the Nation’s Most Widely Used Insecticides (2012). Laboratory-Based Toxicological Assessments of New Insecticides on Mortality and on Birds. American Bird Conservancy. Retrieved from http://extension.entm.purdue.edu/ Fecundity of Neoseiulus fallacis (Acari: Phytoseiidae). Journal of Economic Entomology, 105(3), neonicotinoids/PDF/TheImpactoftheNationsMostWidelyUsedInsecticidesonBirds.pdf 866-871. http://dx.doi.org/10.1603/EC11260 132. Goulson, D. (2013). Review: An overview of the environmental risks posed by neonicotinoid 159. Stapel, J. O., Cortesero, A. M., & Lewis, W. J. (2000). Disruptive Sublethal Effects of Insecti- insecticides. Journal of Applied Ecology, 50, 977-987. doi: 10.1111/1365-2664.12111 cides on Biological Control: Altered Foraging Ability and Life Span of a Parasitoid After Feeding

Endnotes 3 Pesticides and You Vol. 35, No. 4 Winter 2015-16 A quarterly publication of Beyond Pesticides on Extrafloral Nectar of Cotton Treated with Systemic Insecticides. Biological Control, 17, treated seed ingestion has lethal effect on adult partridges and reduces both breeding 243-249. doi: 10.1006/bcon.1999.0795 investment and offspring immunity. Environmental Research, 136, 97-107. doi: 10.1016/j. 160. Douglas, M. R., Rohr, J. R., & Tooker, J. F. (2015). Neonicotinoid insecticide travels through envres.2014.10.023 a soil food chain, disrupting biological control of non-target pests and decreasing soya bean 185. Hallmann, C. A., Foppen, R. P. B., van Turnhout, C. A. M., de Kroon, H., & Jongejans, E. (2014). yield. Journal of Applied Ecology, 52, 250-260. doi: 10.1111/1365-2664.12372 Declines in insectivorous birds are associated with high neonicotinoid concentrations. Nature. 161. Kreutzweiser, D. P., Good, K. P., Chartrand, D. T., Scarr, T. A., & Thompson, D. G. (2008). Are doi: 10.1038/nature13531 Leaves that Fall from Imidacloprid-Treated Maples Trees to Control Asian Longhorned Beetles 186. Pandey, S. P., & Mohanty, B. (2015). The neonicotinoid pesticide imidacloprid and the Toxic to Non-target Decomposer Organisms? Journal of Environmental Quality, 37(2), 639- dithiocarbamate fungicide mancozeb disrupt the pituitary-thyroid axis of a wildlife bird. 646. doi: 10.2134/jeq2007.0278 Chemosphere, 122, 227-234. doi: 10.1016/j.chemosphere.2014.11.061 162. Larson, J. L., Redmond, C. T., & Potter, D. A. (2012). Comparative impact of an anthranilic 187. Grimalt, S., Thompson, D., Chartrand, D., McFarlane, J., Helson, B., Lyons, B., … Scarr, T. (2011). diamide and other insecticidal chemistries on beneficial invertebrates and ecosystem services Foliar residue dynamics of azadirachtins following direct stem injection into white and green in turfgrass. Pest Management Science, 68, 740-748. doi: 10.1002/ps.2321 ash trees for control of emerald ash borer. Pest Management Science, 67(10), 1277-1284. doi: 163. Kimura-Kuroda, J., Komuta, Y., Kuroda, Y., Hayashi, M., & Kawano, H. (2012). Nicotine-Like 10.1002/ps.2183 Effects of the Neonicotinoid Insecticides Acetamiprid and Imidacloprid on Cerebellar Neurons 188. Barbosa, W. F., De Meyer, L., Guedes, R. N. C., & Smagghe, G. (2015). Lethal and sublethal from Neonatal Rats. PLoS ONE, 7(2), e32432. doi:10.1371/journal.pone.0032432 effects of azadirachtin on the bumblebee Bombus terrestris (Hymenoptera: Apidae). Ecotoxi- 164. European Food Safety Authority. (2013). EFSA assesses potential link between two neonic- cology, 24(1), 130-142. doi: 10.1007/s10646-014-1365-9 otinoids and developmental neurotoxicity (Press Release). Retrieved from http://www.efsa. 189. Zhao, J., Davis, L. C., & Verpoorte, R. (2005). Elicitor signal transduction leading to production europa.eu/en/press/news/131217 of plant secondary metabolites. Biotechnology advances, 23(4), 283-333. Retrieved from 165. U.S. Environmental Protection Agency. (2013). Registration of the New Active Ingredient http://www.ncbi.nlm.nih.gov/pubmed/15848039 Sulfoxaflor for Use on Multiple Commodities, Turfgrass and Ornamentals. Retrieved from 190. U.S. Environmental Protection Agency. (1983). Background Report for the Indemnification http://www.regulations.gov/contentStreamer?documentId=EPA-HQ-OPP-2010-0889- Report to Congress. Retrieved from http://nepis.epa.gov/Exe/ZyNET.exe/91012A26.TXT?ZyA 0396&disposition=attachment&contentType=pdf ctionD=ZyDocument&Client=EPA&Index=1981+Thru+1985&Docs=&Query=&Time=&EndTi 166. U.S. Environmental Protection Agency. (2014). Registration of the New Active Ingredient me=&SearchMethod=1&TocRestrict=n&Toc=&TocEntry=&QField=&QFieldYear=&QFieldMo Cyantraniliprole. Retrieved from http://www.regulations.gov/#!documentDetail;D=EPA-HQ- nth=&QFieldDay=&IntQFieldOp=0&ExtQFieldOp=0&XmlQuery=&File=D%3A%5Czyfiles%5 OPP-2011-0668-0057. CIndex%20Data%5C81thru85%5CTxt%5C00000021%5C91012A26.txt&User=ANONYMOUS 167. Sánchez-Bayo, F. Insecticides Mode of Action in Relation to Their Toxicity to Non-Target &Password=anonymous&SortMethod=h%7C-&MaximumDocuments=1&FuzzyDegree=0& Organisms. Environmental & Analytical Toxicology, S4, 002. doi: 10.4172/2161-0525.S4-002 ImageQuality=r75g8/r75g8/x150y150g16/i425&Display=p%7Cf&DefSeekPage=x&SearchBa 168. Singh, R. N., Pandey, R. K., Singh, N. N., & Das, V. K. (2009) Acute Toxicity and Behavioral ck=ZyActionL&Back=ZyActionS&BackDesc=Results%20page&MaximumPages=1&ZyEntry=1 Responses of Common Carp Cyprinus carpio (Linn.) To an Organophosphate (Dimethoate). &SeekPage=x&ZyPURL World Journal of Zoology, 4(2), 70-75. Retrieved from http://www.researchgate.net/profile/ 191. U.S. Department of Agriculture. (1976). Report on the Beekeeper Indemnity Program. Dr_Rakesh_Pandey2/publication/215576855_Acute_Toxicity_and_Behavioral_Respons- Retrieved from http://babel.hathitrust.org/cgi/pt?id=coo.31924001799307;view=1up;seq=41 es_of_Common_CarpCyprinus_carpio_(Linn.)_To_an_Organophosphate_(Dimethoate)/ 192. U.S. Department of Agriculture. (1976). Report on the Beekeeper Indemnity Program. links/05ac5fdbd9b47c3a75446541.pdf Retrieved from http://babel.hathitrust.org/cgi/pt?id=coo.31924001799307;view=1up;seq=41 169. Van Scoy, A. R., Yue, M., Deng, X., & Tjeerdema, R. S. (2013). Environmental Fate and Toxicol- 193. U.S. Environmental Protection Agency. (2009, June). Methyl Parathion Summary Docu- ogy of Methomyl. Reviews of Environmental Contamination and Toxicology, 222, 93-109. doi: ment – Registration Review: Initial Docket. Retrieved from http://www.regulations.gov/ 10.1007/978-1-4614-4717-7_3 contentStreamer?documentId=EPA-HQ-OPP-2009-0332-0002&disposition=attachment&c 170. Gaete, H., Olivares, Y., & Escobar, C. (2013). Assessment of the effect of a commercial formu- ontentType=pdf lation of Methomyl on reproduction of Daphnia obtusa Kürz (1874). Latin American Journal of 194. Burgett, D. M., & Fisher, G. C. (1980). Recovery of Penncap.M® from Foraging Honey Bees Aquatic Research, 41(5), 979-984. doi: 103856/vol41-issue5-fulltext-16 and Pollen Storage Cells. Environmental Entomology, 9, 430-431. Retrieved from https:// 171. Adhikari, S., Sarkar, B., Chattopadhyay, A., Chattopadhyay, D. N., Sarkar, S. K., & Ayyappan, S. ir.library.oregonstate.edu/xmlui/handle/1957/19328 (2008). Carbofuran induced changes in breeding of a freshwater fish, Labeo rohita (Hamilton). 195. U.S. Department of Agriculture. (1980). Beekeeping in the United States. Retrieved from Toxicological & Environmental Chemistry, 90(3), 457-465. doi: 10.1080/02772240701589487 http://www.thebeeyard.org/wp-content/uploads/2014/02/Beekeeping.in_.the_.United. 172. Schlenk, D., Huggett, D. B., Allgood, J., Rimoldi, J., Beeler, A. B., Block, D., … Bedient, P. (2001). States.pdf Toxicity of Fipronil and Its Degradation Products to Procambarus sp.: Field and Laboratory 196. U.S. Environmental Protection Agency. (2010, September). Methyl Parathion – Studies. Archives of Environmental Contamination and Toxicology, 41(3), 325-332. doi: Registration Rview Final Decision. Retrieved from http://www.regulations.gov/ 10.1007/s002440010255 contentStreamer?documentId=EPA-HQ-OPP-2009-0332-0018&disposition=attachment&c 173. Kreutzweiser, D. P., Good, K. P., Chartrand, D. T., Scarr, T. A., & Thompson, D. G. (2008). Are ontentType=pdf Leaves that Fall from Imidacloprid-Treated Maples Trees to Control Asian Longhorned Beetles 197. United Phosphorous, Inc. (2010). Penncap-M (Label). Retrieved from http://www.kellysolu- Toxic to Non-target Decomposer Organisms? Journal of Environmental Quality, 37(2), 639- tions.com/erenewals/documentsubmit/KellyData%5CVA%5Cpesticide%5CProduct%20 646. doi: 10.2134/jeq2007.0278 Label%5C70506%5C70506-193%5C70506-193_PENNCAP_M_10_26_2010_1_31_42_ 174. Barbee, G. C., McClain, W. R., Lanka, S. K., & Stout, M. J. (2010). Acute toxicity of chlorantra- PM.pdf niliprole to non-target crayfish (Procambarus clarkii) associated with rice-crayfish cropping 198. U.S. Environmental Protection Agency. (2013, August 15). Pollinator Protection Labeling systems. Pest Management Science, 66(9), 996-1001. doi: 10.1002/ps.1972 for Nitroguanidine Neonicotinoid Products. Retrieved from http://www.epa.gov/pollinator- 175. Lavtižar, V., Helmus, R., Kools, S. A. E., Dolenc, D., van Gestel, C. A. M., Trebše, P., … Kraak, M. protection/new-labeling-neonicotinoid-pesticides H. (2015). Daphnid Life Cycle Responses to the Insecticide Chlorantraniliprole and Its trans- 199. The White House, Office of the Press Secretary. (2014). Presidential Memorandum – Creat- formation Products. Environmental Science & Technology, 49(6), 3922-3929. doi: 10.1021/ ing a Federal Strategy to Promote the Health of Honey Bees and Other Pollinators. Retrieved es506007q from http://www.whitehouse.gov/blog/2014/06/20/new-steps-protect-pollinators-critical- 176. Adams, M. J., Miller, D. A. W., Muths, E., Corn, P. S., Grant, E. H. C., Bailey, L. L., … Walls, S. C. contributors-our-nation-s-economy (2013). Trends in Amphibian Occupancy in the United States. PLoS ONE, 8(5), e64347. doi: 200. Exemptions for pesticides of a character not requiring FIFRA regulation, 40 C.F.R. § 152.25 10.1371/journal.pone.0064347 201. The White House, Pollinator Health Task Force. (2015). National Strategy to Promote the 177. Stuart, S. N., Chanson, J. S., Cox, N. A., Young, B. E., Rodrigues, A. S. L., Fischman, D. L., & Health of Honey Bees and Other Pollinators. Retrieved from https://www.whitehouse.gov/ Waller, R. W. (2004). Status and Trends of Amphibian Declines and Extinctions Worldwide. sites/default/files/microsites/ostp/Pollinator%20Health%20Strategy%202015.pdf Science, 306(5072), 1783-1786. doi: 10.1126/science.1103538 202. U.S. Department of the Interior, Fish and Wildlife Service. (2014). Use of Agricultural Practices 178. Pérez-Iglesias, J. M., Ruiz de Arcaute, C., Nikoloff, N., Dury, L., Soloneski, S., Natale, G. S., & Lar- in Wildlife Management in the National Wildlife Refuge System. Retrieved from http://www. ramendy, M. L. (2014). The genotoxic effects of the imidacloprid-based insecticide formula- centerforfoodsafety.org/files/agricultural-practices-in-wildlife-management_20849.pdf tion Glacoxan Imida on Montevideo tree frog Hypsiboas pulchellus tadpoles (Anura, Hylidae). 203. U.S. Department of the Interior, Fish and Wildlife Service. (2014). Guidelines regarding the Ecotoxicology and Environmental Safety, 104, 120-126. doi: 10.1016/j.ecoenv.2014.03.002 interim use and phase out of neonicotinoid insecticides to grow agricultural crops for wildlife 179. Yin, X. H., Jiang, S. J., Yu, J., Zhu, G. N., Wu, H. M., Mao, C. L. (2014). Effects of spirotetramat on NWRs in the Pacific Region. Retrieved from http://www.centerforfoodsafety.org/files/ on the acute toxicity, oxidative stress, and lipid peroxidation in Chinese toad (Bufo bufo guidelines-for-interim-use-and-phase-out-of-neonicotinoid-insecticides-in-refuge-farming- gargarizans) tadpoles. Environmental Toxicology and Pharmacology, 37(3), 1229-1235. doi: for-wildlife-programs-signed-kf-7914_67415.pdf. 10.1016/j.etap.2014.04.016 204. White House Council on Environmental Quality. (2014). Supporting the Health of Honey Bees 180. Hayasaka. D., Korenaga, T., Sánchez-Bayo, F., & Goka, K. (2012). Differences in ecological and Other Pollinators. Retrieved from https://www.whitehouse.gov/sites/default/files/docs/ impacts of systemic insecticides with different physicochemical properties on biocenosis of supporting_the_health_of_honey_bees_and_other_pollinators.pdf experimental paddy fields. Ecotoxicology, 21(1), 191-201. doi: 10.1007/s10646-011-0778-y 205. Official Journal of the European Union. (2013). Commission Implementing Regulation (EU) 181. Van Dijk, T. C., Van Staalduinen, M. A., & Van der Sluijs, J. P. (2013). Macro-Invertebrate No485/2013 of 24 May 2013 amending Implementing Regulation (EU) No 540/2011, as Decline in Surface Water Polluted with Imidacloprid. PLoS ONE, 8(5), e62374. doi: 10.1371/ regards the conditions of approval of the active substances clothianidin, thiamethoxam and journal.pone.0062374 imidacloprid, and prohibiting the use and sale of seeds treated with plant protection products 182. Mineau, P., & Palmer, C. (2013). The Impact of the Nation’s Most Widely Used Insecticides containing those active substances. Retrieved from http://eur-lex.europa.eu/LexUriServ/ on Birds. American Bird Conservancy. Retrieved from http://extension.entm.purdue.edu/ LexUriServ.do?uri=OJ:L:2013:139:0012:0026:EN:PDF. neonicotinoids/PDF/TheImpactoftheNationsMostWidelyUsedInsecticidesonBirds.pdf 206. European Food Safety Authority. (2013). EFSA identifies risks to bees from neonicotinoids 183. Tokumoto, J., Danjo, M., Kobayashi, Y., Kinoshita, K., Omotehara, T., Tatsumi, A., … Hoshi, N. (Press Release). Retrieved from http://www.efsa.europa.eu/en/press/news/130116?utm_ (2013). Effects of exposure to clothianidin on the reproductive system of male quails. Journal source=homepage&utm_medium=infocus&utm_campaign=beehealth of Veterinary Medical Science, 75(6), 755-760. Retrieved from http://www.ncbi.nlm.nih.gov/ 207. European Food Safety Authority. (2016, January 11). Pesticides and bees: EFSA to update pubmed/23358514 neonicotinoid assessments. Retrieved January 14, 2016 from http://www.efsa.europa.eu/en/ 184. Lopez-Antia, A., Ortiz-Santaliestra, M. E., Mougeot, F., & Mateo, R. (2015). Imidacloprid- press/news/160111

Endnotes 4 Pesticides and You Vol. 35, No. 4 Winter 2015-16 A quarterly publication of Beyond Pesticides Show Your Support for a Pesticide-Free Community History was made in Montgomery County, Maryland on October 6, 2015 when a grassroots coalition of moms, families, progressive businesses, and local and national health and environmental advocates stopped hazardous pesticide use on public and private property throughout the county. Let’s work together to help make the conversion to organic lawn care spread to localities throughout the U.S. If you support the ordinance passed by Montgomery County and want to see similar legislation enacted in your community, let us know.

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