I agree with Tom Philpott. This is not a rebuttal at all. It is actually an admission that no suchrebuttal is forthcoming nor will be forthcoming.
The product has already been banned in key markets in
Europe and you would surely expect to see Bayer on theirbest game. Instead we have a weak ‘butyour agency approved it’ comment.
The present level of institutional integrity is soundermined in terms of public confidence that such defenses no longer work, ifthey ever did.
We have a problem Bayer, and the size of the market isnot big enough for you to bet the whole company trying to defend it. We all know that the EPA testing standardsare routinely skated around and that is plausibly permissible when there is nocreditable pathway to more serious harm.
Here the pathway is obvious and measurable. That the bee thresholdis way lower than originally hoped for is disappointing. A field proof using the entire
US corn crop was a bit over the top, and it hasdecimated the bee industry. From now on all losses areaccumulating to Bayer’s account in the inevitable class action suit. I suspect someone is trying to make it to retirement before the proverbial C### hits the fan. US
The agro chemical industry is big enough to do thisright. It takes years to introduce a newproduct for good reason. Large multiyear field tests are needed and I see that detailed biological studies areneeded in surrounding wilds and fields in order to assess impact.
That may still have missed colony collapse disorder butit would pick up a lot of effects that are happening under the radar.
Update: Bayerresponds to criticism of its potentially bee-killing pesticide
BY Tom Philpott
20 DEC 2010 8:56 AM
I recently wrote about a study, funded bythe German chemical giant Bayer, purporting to show that Bayer's blockbusterpesticide clothianidin doesn't harm honeybees when applied as a treatment toseeds.
The EPA had required the study before it wouldregister clothianidin. Years before it finally got the study in 2007, the EPAgranted the neonicotinoid pesticide "partial registration," andfarmers promptly began to apply it to millions of acres of farmland across thecountry. Meanwhile, a mysterious phenomenon called "colony collapsedisorder" arose -- across the nation, beekeepers were finding itincreasingly impossible to keep their hives alive.
To make a long story short, the EPA eventually accepted Bayer's studyand granted clothianidin full registration in early 2010. But as I reportedearlier, a leaked document (PDF) from November showsthat two EPA scientists had reviewed that Bayer study and found it wanting. Thestudy had "deficiencies," they wrote, that rendered it unacceptable.
The study was clearly flawed -- it appeared tolet test and control bees range widely and forage on both clothianidin-treatedand non-treated fields. "When I looked at the study,"
entomologist James Frazier told me in a phone interview, "I immediatelythought it was invalid." Penn State
Well, Bayer has now responded to critiques ofthe study on its website. Lamenting the "unauthorized release" of therecent EPA memo, the agrichemical giant declared:
The study referenced in the document is important research, conductedby independent experts and published in a major peer-reviewed scientificjournal. The long-term field study conducted in accordance with Good LaboratoryPractices (GLP) by independent experts using clothianidin-treated seed showedthat there were no effects on bee mortality, weight gain, worker longevity,brood development, honey yield and over-winter survival. The EPA reviewed andapproved the study protocol prior to its initiation and it was peer-reviewedand published in the Journal ofEconomic Entomology*. Upon reviewing the results of the long-term trial,the Agency noted the study as "scientifically sound and satisfies theguideline requirements for a field toxicity test with honey bees.
"Independent experts," huh? Notreally -- Bayer paid for that study.
But here's the important thing about thatresponse: It contains no substantial defense of the methodology, and no attemptto explain its obvious flaws. The response, essentially, is that the EPAinitially approved the study, therefore it is valid. Of course, in that"unauthorized release," EPA scientists explicitly withdrew approvalciting "deficiencies"
-- and Bayer has no comment on those concerns.
For me, Bayer's hollow response actuallyraises the level of alarm about what clothianidin is doing to our honeybeesrather than mutes it.
As I reported before, EPA continues to stand behind Bayer despite itsown scientists' concerns. If you want to let the agency's administrator, LisaJackson, know what you think about that decision, check out Pesticide ActionNetwork's petition.