# Bee Health: The Role of Pesticides

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URL: https://www.frixlaw.com/law-library/documents/crs%3AR43900

## Record

- **Collection:** Congressional research report
- **Document type:** CRS Report
- **Published:** February 17, 2015
- **Citation:** R43900

## Text

Bee Health: The Role of Pesticides
(name redacted)
Specialist in Agricultural Policy
(name redacted)
Specialist in Natural Resources Policy
February 17, 2015

Congressional Research Service
7-....
www.crs.gov
R43900

Bee Health: The Role of Pesticides

Summary
Over the past few decades there has been heightened concern about the plight of honey bees as
well as other bee species. Given the importance of honey bees and other bee species to food
production, many have expressed concern about whether a “pollinator crisis” has been occurring
in recent decades. Although honey bee colony losses due to bee pests, parasites, pathogens, and
disease are not uncommon, there is the perception that bee health has been declining more rapidly
than in prior years, both in the United States and globally. This situation gained increased
attention in 2006 as some commercial beekeepers began reporting sharp declines in their honey
bee colonies. Because of the severity and unusual circumstances of these colony declines,
scientists named this phenomenon colony collapse disorder (CCD). Since then, honey bee
colonies have continued to dwindle each year, for reasons not solely attributable to CCD. The
U.S. Department of Agriculture (USDA) reports that CCD may not be the only or even the major
cause of bee colony losses in recent years. In the United States, USDA estimates of overwinter
colony losses from all causes have averaged nearly 30% annually since 2006.
The precise reasons for honey bee losses are not yet known. USDA and most scientists working
on the subject seem to agree that no research conclusively points to one single cause for the large
number of honey bee deaths. This general conclusion was reconfirmed in a 2013 joint report by
USDA and the U.S. Environmental Protection Agency (EPA). Reasons cited for bee declines
include a wide range of possible factors thought to be negatively affecting pollinator species.
However, one issue widely noted is the role that pesticides—in particular, neonicotinoid
pesticides—might play in overall bee health. Pesticides are the focus of this report. Pesticides are
among many identified factors known to affect bee health, including pests and diseases, diet and
nutrition, genetics, habitat loss and other environmental stressors, and beekeeping management
issues, as well as the possibility that bees are being negatively affected by cumulative, multiple
exposures and/or the interactive effects of several of these factors.
The focus of this report on bee exposure to pesticides is not intended to imply that pesticides are
any more important in influencing the health and wellness of bees than other identified factors
influencing bee health. Pesticides are one of many influences on bee health. The current state of
knowledge on pesticides and bee health is summarized in the USDA-EPA report:
it is not clear, based on current research, whether pesticide exposure is a major factor associated
with U.S. honey bee health declines in general, or specifically affects production of honey or
delivery of pollination services. It is clear, however, that in some instances honey bee colonies
can be severely harmed by exposure to high doses of insecticides when these compounds are
used on crops, or via drift onto flowers in areas adjacent to crops that are attractive to bees.

Some experts emphasize research supporting the hypothesis that “total pesticide load” is an
important influence on honey bee health, probably in combination with mite infestation, poor
nutrition, viruses, and perhaps other stressors.
The past two farm bills (P.L. 110-246, P.L. 113-79) provided for increased funding for bee
research, among other types of support to protect pollinators. Other bills in the 113th Congress
addressed pesticide issues more directly. H.R. 2692 would have suspended registrations of
neonicotinoids and banned new registrations of any pesticide in some cases. Another bill, H.R.
5447, would have amended U.S. pesticide laws to expedite the review and approval of products to
control “parasitic pests” in managed commercial bee colonies, and would have required USDA
and EPA to evaluate threats to pollinators and the availability of pesticides to manage bee pests.

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Contents
Background and Introduction .......................................................................................................... 1
U.S. Pesticide Laws and Regulation ................................................................................................ 4
Pesticide Laws and Statutory Framework ................................................................................. 4
Pesticide Registration Process ................................................................................................... 5
Neonicotinoid Pesticides ........................................................................................................... 6
Possible Role of Pesticides in Bee Health ....................................................................................... 8
Best Management Practices to Protect Pollinators ........................................................................ 11
Federal Agency Efforts .................................................................................................................. 15
National Pollinator Health Strategy (“Presidential Memorandum”) ....................................... 15
USDA-EPA Joint Report ......................................................................................................... 16
Environmental Protection Agency ........................................................................................... 17
EPA’s Pesticide Registration Review of Neonicotinoid Pesticides ................................... 17
EPA’s Consideration to Modify Thiamethoxam Tolerance Levels .................................... 19
EPA’s New “Bee Advisory” Labeling Requirements ........................................................ 20
EPA Support of State Pollinator Protection Plans ............................................................. 23
EPA Development of Voluntary Controls for Pesticide Drift ............................................ 23
Fish and Wildlife Service Memorandum ................................................................................. 24
Other Ongoing Efforts ................................................................................................................... 24
Restrictions in Some U.S. Cities and Counties ....................................................................... 24
Restrictions in the European Union ......................................................................................... 25
Restrictions in Canada ............................................................................................................. 27
Legal and Other Actions by Some Interest Groups ....................................................................... 28
Selected Actions by Environmental Groups ............................................................................ 28
Selected Actions by Agrochemical Companies ....................................................................... 30
Congressional Consideration ......................................................................................................... 31
Saving America’s Pollinators Act ............................................................................................ 32
Expedited Pesticide Registration for Managing Parasitic Pests .............................................. 33

Figures
Figure 1. Stress Factors in Honey Bee Populations ......................................................................... 3
Figure 2. Major Routes of Exposure of Foraging Bees to Pesticides ............................................ 10
Figure 3. EPA’s Bee Advisory Box ................................................................................................ 20
Figure 4. Pollinator Stewardship Council’s Analysis of EPA’s Bee Advisory Box ....................... 21

Tables
Table 1. Schedule for EPA Review of Neonicotinoid Pesticides ................................................... 17

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Appendixes
Appendix. Review of the Scientific Literature .............................................................................. 35

Contacts
Author Contact Information........................................................................................................... 43

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T

here is increasing concern both in the United States and globally about whether a
“pollinator crisis” has been occurring in recent decades. Reports worldwide indicate that
populations of managed honey bees, wild bees, and native bees have been declining, with
colony losses in some cases described as severe or unusual.1 Other reports indicate that many
insect pollinator species may be becoming rarer, which some say may be a sign of an overall
global biodiversity decline.2
Many reasons are cited for bee population declines, including bee pests and diseases, diet and
nutrition, genetics, habitat loss, agricultural pesticides, and beekeeping management. Because
pesticides have been the focus of concerns in Europe and in the United States, this CRS report
briefly describes recent scientific research and analysis regarding the potential role of pesticides
among the factors affecting the health and well-being of bees. The report concludes with a
summary of recent regulatory activity regarding neonicotinoids, a type of pesticide, and also
provides the statutory authority and regulatory activities related to pesticide use at the U.S.
Environmental Protection Agency (EPA), the federal agency charged with assessing risks and
regulating U.S. sale and use of pesticides.
The focus of this report on bee exposure to pesticides is not intended to imply that pesticides are
any more or less important in influencing the health and wellness of bees than any of the other
identified factors influencing bee health.

Background and Introduction
In the United States, honey bee colony losses due to bee pests, parasites, pathogens, and disease
are not uncommon. However, in late 2006, concerns about honey bees gained heightened
attention when commercial beekeepers along the East Coast began reporting sharp declines in
their bee colonies. Because of the severity and unusual circumstances of these colony declines,
scientists named this phenomenon colony collapse disorder (CCD). This issue was legislatively
active in the 110th Congress and resulted in increased funding for honey bee research, among
other types of farm program support to protect pollinators, as part of the 2008 farm bill (Food,
Conservation, and Energy Act of 2008, P.L. 110-246). The 2014 farm bill (P.L. 113-79)
reauthorized and expanded upon many of these provisions.3
The U.S. Department of Agriculture (USDA) reports that U.S. beekeepers continue to lose
colonies each year. Since 2006, USDA estimates that overwinter4 bee colony losses have
averaged nearly 30% annually.5 However, USDA reports that in 2012/2013, “there were more
colonies that dwindled away” rather than suffering from CCD, which is characterized by a sudden
loss in bee colony populations and the absence of dead bees.6 USDA also claims that “beekeepers
1

More information on the difference between managed honey bees and native bees is available in CRS Report R43191,
Bee Health: Background and Issues for Congress.
2
United Nations Environment Programme (UNEP), Global Honey Bee Colony Disorders and Other Threats to Insect
Pollinators, UNEP Emerging Issues, 2010.
3
For more information, see CRS Report R43191, Bee Health: Background and Issues for Congress.
4
Bee colony losses are common during the winter months, especially in colder climates. Hives should be strong and
healthy before going into winter in order to minimize losses.
5
D. vanEngelsdorp, et al., “Colony Loss 2013-2014,” May 15, 2014, http://beeinformed.org/.
6
K. Kaplan, “Fact Sheet: Survey of Bee Losses During Winter of 2012/2013,” http://www.ars.usda.gov/is/br/beelosses/
(continued...)

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did not report CCD as a major cause of colony loss” for overwinter losses reported in its 20122013 and 2011-2012 surveys. These data are tracked for managed honey bees only.
Comparable data and information is not collected available for native or wild bee species. Such
data collection is complicated by sheer number and solitary nature of native and wild bee species.
Managed Honey Bees and Wild Bee Species
Honey Bees
Honey bees (Apis mellifera; Family: Apidae) are the most well-known bee species. However, honey bees are only one
of the world’s estimated 17,000 described bee species, and one of the estimated total of 20,000 to 30,000 bee
species worldwide. Honey bees are not native to North America, but were introduced by European settlers in the
1600s. Honey bees are considered to be “social” bees in that they have a single egg-laying queen and sterile worker
bees that tend to work together in a highly structured social order, consisting of cooperation and division of labor
within a colony, as well as the presence of two generations in a single nest at the same time. Social behavior allows
bees to be domesticated and managed.
Some types of native bees may also be managed, such as bumble bees, orchard bees, and alfalfa leaf-cutting bees.
Some of these bees (such as bumble bees and some types of stingless bees) exhibit some of the social behaviors
commonly associated with honey bees. Some bumble bee species are managed in controlled environments to
pollinate greenhouse tomatoes.
Wild Bee Species
An estimated 4,000 species of bees are native to North America. With few exceptions, most of these are wild and
not managed. The five most common families of native bees in North America are Andrenidae, Apidae, Colletidae,
Halictidae, and Megachilidae. Andrenid bees are all ground nesters, and mostly comprise a large family of dark,
nondescript bees, although some are colorful. Bees in the large Apidae family include not only honey bees, but also
bumble bees (such as Bombus spp.), carpenter bees, squash or gourd bees, and others. Most types of wild bees are
“solitary” bees and do not have long-lived colonies. About 70% of native bee species are solitary ground nesting
bees, and about 30% are solitary wood nesting bees. About 45 species of native bees in the United States are social
bumble bees. Compared to most native species, bumble bees (Bombus) are better studied and, as noted by USDA,
among the most effective crop pollinators.
For more information, see: CRS Report R43191, Bee Health: Background and Issues for Congress.

To date, the precise reasons for honey bee colony losses are still unknown. USDA and most
scientists working on the subject seem to agree that none of the research conclusively points to
one single cause for the large-scale number of honey bee deaths. This general conclusion was
reconfirmed in a May 2013 report by USDA and the U.S. Environmental Protection Agency
(EPA), National Stakeholders Conference on Honey Bee Health (commonly referred to as the
“USDA-EPA joint report”).7 A 2007 study by the National Research Council (NRC) of the
National Academy of Sciences, Status of Pollinators in North America (referred to here as the
2007 NRC study), also provides a detailed scientific context for bee health. A series of other

(...continued)
index.htm. Whether losses may be attributable to CCD may be based, in part, on reported colony losses “with no dead
bees present, which is indicative of CCD.” See USDA, CCD Progress Report, June 2012, p. 9.
7
USDA, Report on the National Stakeholders Conference on Honey Bee Health, National Honey Bee Health
Stakeholder Conference Steering Committee, May 2013, http://www.usda.gov/documents/ReportHoneyBeeHealth.pdf.
This document, widely referred to as the USDA-EPA joint report, provides proceedings of an October 2012 workshop
convened by USDA and EPA (edited by the National Honey Bee Health Stakeholder Conference Steering Committee).

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reports documenting the findings of USDA’s ongoing research also describes the many factors
affecting honey bees.8 See Figure 1.
Figure 1. Stress Factors in Honey Bee Populations

Source: OPERA Bee Health in Europe, 2013, http://www.operaresearch.eu/.

Reasons cited for bee population declines include a wide range of possible factors. Potential
identified causes include bee pests and diseases, diet and nutrition, genetics, habitat loss and other
environmental stressors, agricultural pesticides, and beekeeping management issues, as well as
the possibility that bees are being harmed by cumulative, multiple exposures and/or the
interactive effects of each of these factors.
One issue widely reported in the media is the potential role that pesticides—in particular,
neonicotinoid pesticides—might play in overall bee health. As one of the potential causes of
honey bee colony declines, this report addresses what role, if any, pesticides play in influencing
the health and wellness of bees. Regarding honey bee health, the current state of knowledge of
pesticides was summarized in a 2013 report by USDA and EPA:9

8
See, for example, USDA’s annual CCD Research Progress Reports, available at http://www.ars.usda.gov/News/
docs.htm?docid=15572.
9
USDA-EPA joint report, p. 16. Attributed to conferees Reed Johnson (Ohio State University) and James Frazier
(Pennsylvania State University). The report references consensus by the Pesticide Risk Assessment for Pollinators in a
2011 Executive Summary, published by the Society of Environmental Toxicology and Chemistry (SETAC).

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There is broad consensus among all stakeholders that pesticide use should not affect honey
bees in such a way that (1) honey production is reduced or (2) pollination services provided
by bees are threatened.... However, it is not clear, based on current research, whether
pesticide exposure is a major factor associated with U.S. honey bee health declines in
general, or specifically affects production of honey or delivery of pollination services. It is
clear, however, that in some instances honey bee colonies can be severely harmed by
exposure to high doses of insecticides when these compounds are used on crops, or via drift
onto flowers in areas adjacent to crops that are attractive to bees.

This report examines in greater detail the role of pesticides, providing a summary of selected
scientific literature. The relative importance of pesticides in U.S. or global bee health is a subject
of numerous research projects, some of which are discussed in this report.
Some groups have expressed concern about the assessment of most experts that the causes of
pollinator health concerns are multifaceted and may involve the interaction of multiple factors,
since this may deflect attention from the potential role of exposure to pesticides. On the other
hand, some groups appear unwilling to acknowledge that pesticide exposure may play an
important role in pollinator health concerns, especially if this acknowledgment leads to
restrictions or reductions in the use of certain pesticides or related crop pest controls.
This report provides information regarding the potential role of pesticides in the health of bee
colonies, and also the importance of pesticides relative to other influences on bee health. The
report provides general information about the nature of pesticides, pesticide uses, and pesticide
regulation in the United States, as well as more specific information about the registration status
of a class of pesticides known as neonicotinoids, which have been implicated in some studies
concerning honey bee colony declines. This report also describes a range of options to address
pesticide exposure by bees, including implementing crop- and/or product-specific best
management practices (BMPs) regarding pesticide use and applications. Some U.S. cities as well
as some other countries, including Canada and those in Europe, have opted to institute restrictions
on the use of certain pesticides. Congress has introduced similar legislation, but has also
considered alternative policy options to address this issue.

U.S. Pesticide Laws and Regulation
Pesticide Laws and Statutory Framework
Pesticides are broadly defined in U.S. law as chemicals and other products used to kill, repel, or
control pests.10 Familiar examples include pesticides used to kill insects (insecticides) and weeds
(herbicides) that can reduce the yield, and sometimes harm the quality, of agricultural crops,
ornamental plants, forests, and pastures, or wooden structures (e.g., through termite damage). But
the broad legal definition of “pesticide” also applies to products with less familiar “pesticidal
uses.” For example, substances are pesticides when used to control mites, mold, mildew, and
other nuisance growths in hives or on equipment. The term also applies to disinfectants and
sterilizing agents, animal repellents, rat poison, and many other substances. An estimated 18,000
pesticide products are currently in use in the United States.11 Pesticides vary greatly in toxicity,
10
11

FIFRA § 2(u). 7 U.S.C. 136-136y. See also CRS Report RL31921, Pesticide Law: A Summary of the Statutes.
S. Kaiser, EPA, personal communication with CRS staff, December 16, 2011.

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persistence in the environment, and ability to bioaccumulate up the food chain, as well as in the
range of plants and animals that are likely to be affected in the event of exposure. Some are nearly
nontoxic to some species but exquisitely toxic to other species.
All pesticides are regulated by EPA under the authority of the Federal Insecticide, Fungicide, and
Rodenticide Act (FIFRA),12 and approximately 5,800 pesticide products used in food production
also are regulated under the Federal Food, Drug, and Cosmetic Act (FFDCA).13 FIFRA requires
EPA to regulate the sale and use of pesticides in the United States through product registration
and labeling so as to prevent unreasonable adverse effects on people and the environment, taking
into account the costs and benefits of various pesticide uses. FIFRA prohibits the sale of any
pesticide in the United States unless it is registered (licensed) and labeled to indicate approved
uses and restrictions. It is a violation of the law to use a pesticide in a manner that is inconsistent
with the label instructions. EPA registers each pesticide product for each approved use. For
example, a product may be registered for use on bee hives to control mites or as a seed treatment
for corn.14 In addition, FIFRA requires EPA to reregister pesticides first registered prior to 1984
and to review all registered pesticides periodically on a 15-year cycle, based on new data that
meet current regulatory and scientific standards.
For the 600 or more active ingredients in pesticide products that are registered for use in food
production, Section 408 of the FFDCA authorizes EPA to establish maximum allowable residue
levels (also known as “tolerances”) to ensure that human exposure to the pesticide ingredients in
food and animal feed will be “safe.” A “safe” tolerance is defined in the law as a level at which
there is “a reasonable certainty of no harm” from the exposure, even when considering total
cumulative and aggregate pesticide exposure of children. Under the FFDCA, foods (or animal
feeds) with a residue of a pesticide ingredient for which there is no tolerance established, or with
a residue level exceeding an established tolerance limit, are declared “unsafe” and “adulterated”;
such foods cannot be sold in interstate commerce or imported to the United States. Pesticides may
not be registered under FIFRA for use on food crops unless tolerances (or exemptions) have been
established under the FFDCA.15

Pesticide Registration Process
When pesticide manufacturers apply to register an active ingredient for a pesticide, a commercial
pesticide product, or a new use of a pesticide registered under FIFRA Section 3, EPA requires
them to submit scientific data on toxicity and behavior in the environment. In evaluating a
pesticide registration application, EPA assesses a range of potential human health and
environmental effects associated with use of the product. EPA’s process of registering a pesticide
comprises a scientific, legal, and administrative procedure involving the ingredients of the
pesticide; the particular site or crop where it is to be used; the amount, frequency, and timing of
its use; and storage and disposal practices.16 EPA may require data from any combination of more
12

7 U.S.C. §136 et seq.
21 U.S.C. §§ 301, et seq.
14
The Federal Seed Act (7 U.S.C. § 1561) defines a treated seed as any seed “given an application of a substance or
subjected to a process designated to reduce, control, or repel disease organisms or other pests, which attack seeds or
seedlings growing therefrom.”
15
For more information, see CRS Report RL31921, Pesticide Law: A Summary of the Statutes; and CRS Report 96759, Pesticide Legislation: Food Quality Protection Act of 1996 (P.L. 104-170).
16
EPA, “About Pesticide Registration,” http://www2.epa.gov/pesticide-registration/about-pesticide-registration. Other
(continued...)
13

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than 100 different tests, depending on the potential toxicity of active and inert ingredients and
degree of exposure.
To register a pesticide for use on food, EPA also requires applicants to determine the amount of
residue that could remain on crops, as well as on (or in) food products (such as corn syrup),
assuming that the pesticide product is applied according to the manufacturers’ recommended rates
and methods. Based on the data submitted, EPA determines whether and under what conditions a
proposed pesticide use would present an unreasonable risk to human health or the environment,
and, for a food or residential use, whether its use would be safe. Some features of pesticides that
might affect registration decisions include the specificity of the pesticide for the targeted pest, its
toxicity to people who apply it, its tendency to persist in the environment over time, and its ability
to bioaccumulate in animals higher in the food chain.
EPA specifically takes into account unintended harm to bees and available information for other
nontargeted insects in its registration decisions. EPA requires studies to determine acute (shortterm) toxicity of a pesticide on individual bees when they come into body contact with pesticide
residue. EPA also collects reports on bee-kill incidents. If a pesticide appears to be very toxic to
bees, EPA may require long-term studies of its effects.
If the risk is determined to be unreasonable or unsafe, EPA attempts to mitigate the risk by
adjusting requirements on the label (for example, requiring a buffer zone around lakes and
streams or requiring personal protective equipment for pesticide handlers). If the risk remains
unreasonable or unsafe, EPA will refuse to register the pesticide. If the risk is determined to be
reasonable and safe, registration is granted, and the agency specifies the approved uses and
conditions of use, including safe methods of pesticide storage and disposal, which the registrant
must explain on the product label. EPA can and often does require specific application methods to
be printed on the product label to minimize environmental damage. For example, the label
sometimes requires that application of certain pesticides occur only when bees are not foraging,
when there is little wind, or in a granular form or as a seed coating rather than aerially, in order to
minimize spray drift off property. Pesticide registrations are reviewed at least once every 15 years
to consider new scientific information and may be reviewed at any time in response to reports of
adverse effects and possible unreasonable risks from use of particular pesticides.

Neonicotinoid Pesticides
Neonicotinoids are a relatively new major class of insecticides and among the fastest-growing
class of insecticides in modern crop protection. Developed in the 1980s, some products such as
imidacloprid were first introduced in the early to mid-1990s, but not widely marketed until the
mid-2000s. Neonicotinoids are systemic pesticides that, regardless of application method (spray,
drip irrigation, granular spreading, or seed coating), once taken into the plant, migrate into all
parts, including flowers, pollen, and nectar.17 Neonicotinoids are related to nicotine and were
developed as an alternative to highly toxic (to humans) organophosphate insecticides such as
methyl parathion.18 Active ingredients of some of the most commonly applied neonicotinoids
(...continued)
information is available at CRS Report RL32218, Pesticide Registration and Tolerance Fees: An Overview.
17
UNEP, Global Honey Bee Colony Disorders and Other Threats to Insect Pollinators, 2010.
18
S. P. Bradbury, Office of Pesticide Programs, letter to Peter T. Jenkins, Center for Food Safety and International
Center for Technology Assessment, July 17, 2012.

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include imidacloprid, clothianidin, and thiamethoxam. Others include acetamiprid, dinotefuran,
nitenpyram, and thiacloprid. (See text box below.)

Neonicotinoid Insecticides
In the United States, neonicotinoid pesticides are available for use in about 140 crops and garden/horticultural
products, and provide potent and systemic action for crop protection, particularly from pests in soil and sap-sucking
pests. They are used for seed treatment on most corn, soybeans, canola, sunflower, cereal grains, sugar beets, and
potatoes. They are also used as foliar sprays on field and many fruit and vegetable crops (such as apples, cherries,
peaches, oranges, berries, leafy greens, tomatoes, and potatoes) and are applied to cereal grains, rice, nuts, and wine
grapes. They may also be injected into tree roots or stems and sprayed on tree bark to protect against pests. A
single application can provide protection for several months or years and may remain with the plant as it grows.
Since these types of pesticides can persist in soil or plants for long periods of time, this raises the potential that bee
exposure will persist, even at low levels.
Neonicotinoids reportedly accounted for almost 25% of the global pesticide market, and imidacloprid was the largest
selling insecticide in the world in 2009, with sales exceeding $1 billion. More recent information suggests that the
total global market for neonicotinoid pesticides exceeded $2.6 billion in 2011.
Neonicotinoid Active Ingredients:
•

Acetamiprid

•

Clothianidin

•

Dinotefuran

•

Imidacloprid

•

Nitenpyram

•

Thiocloprid

•

Thiamethoxam

Major Trade Names: Admire®, Acceleron®, Axcess®, Attendant®, Belay®, Cruiser®, Gaucho®, Nitro Shield®,
Poncho®, and Trimax Pro®.
Selected Home and Garden Products: ALOFT®, ARENA®, Criterion™, DIY Tree Care Products, Fertilome®, Flagship™, Green Light®, Safari®, Hi-Yield®, Knockout Ready-to-Use products, Mallet®, Marathon®,
Maxide®, Meridian®, Merit®, Monterey Once A Year products, Ortho®, Safari products, Surrender®, Transtect™,
Xytect™, and Zylam®, and also several Bayer Advanced and Bayer Environmental Science products (including “12Month”; “2-in-1”; “All-in-One”; “Complete Brand”; “Dual Action”; “Hunter”; “Lesco Bandit”; “Season-Long”;
termite; and Bayer’s fruit, citrus, and vegetable products).
Major Manufacturers: Bayer Advanced, Syngenta Crop Protection, LLC, and The Scotts Company, as well as
ArborSystems, Arysta LifeScience, Control Solutions, Inc., Gro Tec, Inc., Gulfstream Home and Garden, Lawn and
Garden Products, Inc., Nufarm Americas Inc., OHP, Inc., Rainbow Treecare Scientific Advancements, Valent U.S.A.
Corporation, and Voluntary Purchasing Groups, Inc.
Sources: P. Jeschke1 and R. Nauen, “Neonicotinoids—from Zero to Hero in Insecticide Chemistry,” Pest
Management Science, Vol. 64, Issue 11 (November 2008), pp. 1084–1098; M. Tomizawa and J. E. Casida,
“Neonicotinoid Insecticide Toxicology: Mechanisms of Selective Action,” Annual Review of Pharmacology and
Toxicology, Vol. 45 (September 2004), pp. 247-268; P. Jeschke, R. Nauen, M. Schindler, et al., “Overview of the Status
and Global Strategy for Neonicotinoids,” Journal of Agricultural and Food Chemistry, v. 59 (2011), pp. 2897-2908; and B.
Essler, “Are These Nicotine-Like Insecticides Killing Bees,” Modern Farmer, November 12, 2014. Also Center for
Food Safety (http://www.centerforfoodsafety.org/files/pesticide_list_final_59620.pdf), April 2013.

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Neonicotinoids are generally considered to be reduced-risk compared to some other types of
pesticides, and have low toxicity to mammals, birds, and fish compared to some other types of
pesticides. However, as their use has increased, so have concerns about their potential harm to
birds, earthworms, aquatic insects, and insect pollinators, including bees.19 They comprise a class
of active ingredients that have come under considerable scrutiny with respect to their potential
effects on bee health. The attention is partly due to an incident of misuse (that is, use not in
accord with the pesticide label) of one neonicotinoid, imidacloprid, in Germany20 that resulted in
a large bee kill, as well as widespread beekeeper concerns about use of another neonicotinoid,
clothianidin, and its impact on bees in France.21
Neonicotinoids are insect neurotoxins that vary in strength of their effect on honey bees.22 The
scientific evidence to date indicates that although neonicotinoids are highly toxic to bees exposed
to relatively high levels, individual pesticides in this class are not the only cause of declining bee
health, and pyrethroid exposures may be more significant.23 Although neonicotinoids have been a
focus of scientific, public, and political interest, they have not been proven to be the primary
cause of declines in bee health. Some experts, however, emphasize that research studies support
the hypothesis that “total pesticide load” is an important influence on honey bee health, probably
in combination with mite infestation, poor nutrition, viruses, and perhaps other stressors.24

Possible Role of Pesticides in Bee Health
Bees can be exposed to numerous different types of pesticides applied to field crops and other
types of plants in areas where they forage or maintain their hive.25 In addition, beekeepers may
also use pesticides registered for the control of bacteria, fungi, mites, and other bee pests. These
pesticides are applied within and in the vicinity of hives.26 Besides the active ingredients,
pesticide products include other ingredients, such as “inerts” or adjuvants that are intended to

19

See, for example, D. Goulson, “An Overview of the Environmental Risks Posed by Neonicotinoid Insecticides,”
Journal of Applied Ecology, vol. 50, issue 4 (2013), pp. 977–987; E. Stokstad, “Pesticides Under Fire for Risks to
Pollinators,” Science, v. 340, no. 6133 (May 10, 2013), pp. 674-676; and D. Gibbons, C. Morrisey, P. Mineau, “A
Review of the Direct and indirect Effects of Neonicotinoids and Fipronil on Vertebrate Wildlife,” Environ. Sci. Pollut.
Res., June 2014.
20
D. vanEngelsdorp and M. D. Meixner, “A Historical Review of Managed Honey Bee Populations in Europe and the
United States and Factors That May Affect Them,” Journal of Invertebrate Pathology, v. 103 (2010), Supp. 1, pp. S80S95.
21
L. Maxim and J. P. van der Sluis, “Expert Explanations of Honeybee Losses in Areas of Extensive Agriculture in
France: Gaucho® Compared with Other Supposed Causal Factors,” Environmental Research Letters, v. 5 (2010).
22
D. Laurino, M. Porporato, A. Patetta, et al., “Toxicity of Neonicotinoid Insecticides to Honey Bees: Laboratory
Tests,” Bulletin of Insectology, v. 64, n. 1 (2011), pp. 107-113.
23
Pyrethroids are synthetic pesticides modeled on the naturally occurring pyrethrins that are formed by
chrysanthemums. Most pyrethroids are more toxic and persistent than pyrethrins. Fenvalerate (an insecticide),
bifenthrin (a miticide and an insecticide), cypermethrin (an insecticide), and fluvalinate (a miticide) are pyrethroids.
24
J. L. Frazier, presentation to Senate staff on pesticides and bee health, April 17, 2013.
25
Pesticides broadly refer to chemicals used to prevent, destroy, or repel pests, such as insecticides, herbicides,
fungicides, rodenticides, and miticides, among others. Pesticides also are used to kill organisms that can cause diseases.
26
Some common pesticides applied deliberately to hives include formic acid (an organic acid), thymol (an essential
oil), coumaphos (an organophosphate), and fluvalinate (a pyrethroid).

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improve delivery of the active ingredient to the target pest.27 Others are used to increase the
toxicity of a pesticide, for example, by inhibiting breakdown of a pesticide by insets.28
Studies have shown that bees are exposed to pesticides in many ways throughout the foraging
period: from planter exhaust material produced during the planting of treated seed; from the soil
of both planted and unplanted fields; in flowers growing near these fields; as well as applications
in or near bee hives.29 Bees also sometimes are exposed to pesticides accidentally, either when
pesticides are misused or misapplied or when they are used according to label directions to
control pests in areas frequented by bees—for example, alongside roads or rights of way for the
control of weeds, trees, or other pests; on or near commercial farm crops; or on or near fields,
lawns, and gardens to control fleas, ticks, weeds, grubs, mosquitos, or other adult insects.
Figure 2 illustrates some significant paths of bee exposure to pesticides applied as a spray or as a
soil or seed treatment (systemic). If bees happen to fly through a newly treated field or dust
clouds from planting of seeds coated with pesticide or are orally exposed to pesticide in food or
water, and if exposure is high enough, bees may be sickened or die from pesticide exposure. With
respect to the role of pesticides in honey bee health, “[t]he most pressing research questions lie in
determining the true pesticide exposure that bees receive and the effect, if any, that pervasive
exposure to multiple pesticides have [sic] on the health and productivity of whole honey bee
colonies.”30
Pesticides are reported to have adverse local impacts on honey bees and some native bees.
Widespread use of herbicides reduces habitat available to bees;31 many pesticides are known to be
lethal to bees, given sufficient levels of exposure; and some reports of local bee kill incidents
have been well documented. Effects on individual bees may be lethal or sublethal depending on
dose and other conditions of exposure.32 A summary of the types of sublethal effects reported in
bees exposed to pesticides includes33
•

decreased navigation, orientation, and communication abilities;

•

altered foraging behavior and motor activity;

•

short- and long-term memory loss;

•

impaired learning behavior and sensory detection;

27
A 2012 study looked at the impact on bee health of three categories of inerts: nonionic surfactants, crop oil
concentrates, and organosilicone surfactants. Bee behavior was adversely affected after ingesting organosilicone
surfactant. Nonionic adjuvants also had a small effect, while the crop oil concentrates were inactive See T. J. Ciarlo, C.
A. Mullin, James L. Frazier, et al., “Learning Impairment in Honey Bees Caused by Agricultural Spray Adjuvants,”
PLoS ONE, v. 7, n. 7 (2012), p. e40848.
28
National Pesticide Information Center, Piperonyl Butoxide (fact sheet), http://npic.orst.edu/factsheets/pbogen.pdf.
29
See, for example, C. H. Krupke, G. J. Hunt, B. D. Eitzer, et al., “Multiple Routes of Pesticide Exposure for Honey
Bees Living Near Agricultural Fields,” PLoS ONE, v. 7. n. 1 (January 2012), p. e29268.
30
USDA-EPA joint report, p. 17.
31
J. H. Cane and V. J. Tepedino, “Causes and Extent of Declines Among Native North American Invertebrate
Pollinators: Detection, Evidence, and Consequences,” Conservation Ecology, v. 5, n. 1 (2001), p. 1.
32
Pesticides other than insecticides, such as fungicides or miticides, may be toxic to bees, although bees are insects and
not the targeted species.
33
Neonicotinoid Pesticides and Honey Bees, Washington State University Extension, Fact Sheet FS122E,
http://cru.cahe.wsu.edu/CEPublications/FS122E/FS122E.pdf; and comments by Nathalie Steinhauer (University of
Maryland) to the Virginia Native Plant Society, October 9, 2014.

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•

compromised immune functioning;

•

increased susceptibility to diseases and pests;

•

reduced fecundity (fertility and reproduction); and

•

impaired reproduction and development.

Although pesticides have been shown to damage bee health, it is unclear whether the level of
harm is sufficient to attribute pesticides as the single or as the major cause of honey bee
population declines.
Figure 2. Major Routes of Exposure of Foraging Bees to Pesticides

Source: European Food Safety Authority (EFSA), “Scientific Opinion on the Science Behind the Development of
a Risk Assessment of Plant Protection Products on Bees (Apis mellifera, Bombus spp. and Solitary Bees),” Figure
3.1, EFSA-Q-2011-00417, May 2012, http://www.efsa.europa.eu/en/efsajournal/pub/2668.htm.

The Appendix provides a summary of selected scientific literature based largely on publications
in peer-reviewed journals. In addition, a number of industry and advocacy groups have compiled
literature reviews regarding pesticide effects on bees, not all of which are specifically discussed in
this report.34 In general, studies looking at impacts of pesticides on other animal species, such as
birds, are also not addressed.35
34

For example, see J. Hopwood, et al., Are Neonicotinoids Killing Bees? A Review of Research into the Effects of
Neonicotinoid Insecticides on Bees, with Recommendations for Action, 2012, and A Review of Research into the
Beyond the Birds and the Bees: Effects of Neonicotinoid Insecticides on Agriculturally Important Beneficial
Invertebrates, 2013 (both prepared for Xerces Society for Invertebrate Conservation); V. Kindemba, The Impact of
Neonicotinoid Insecticides on Bumblebees, Honey Bees, and Other Non-Target Invertebrates, 2009 (Invertebrate
(continued...)

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Best Management Practices to Protect Pollinators
Best management practices (BMPs) are available for beekeepers, crop producers, and pesticide
applicators and include environmentally responsible pest management practices to reduce risk
and minimize pesticide exposure in bees.36 A number of states have also developed guidance to
protect pollinators. Some of these resources are listed on the Pesticide Environmental
Stewardship (PES) website37 and on EPA’s website.38
For beekeepers, guidance by apiculturists and university extension services emphasizes the
importance of reducing the exposure of bees to insecticides with high toxicity, recommending that
if such chemicals are used in an area where bees are foraging, steps may be necessary to reduce
risk of poisoning. This involves both selecting a site for an apiary in an area with low pesticide
risk and notifying “growers and applicators in the area, the county agent, and the State Apiary
Inspector of the location of your hives.... If the insecticide to be used has a long residual life and
is being applied to a plant where bees are foraging, it may be best to move your bees out of the
area.”39
For growers, recommendations involve reducing the hazards associated with insecticides,
including avoiding the use of dusts, such as those from treated seeds, and using chemicals with
reduced risk to bees whenever possible. Other recommendations include applying insecticides “in
the late evening, night, or early morning when fewer bees will be foraging, and when spray drift
and volatilization due to extreme heat are at a minimum”; not spraying “when winds favor
drifting, and us[ing] ground applications instead of air where possible”; and avoiding “spraying
when the crop or other plants in the field or nearby (including weeds) are in bloom.”40 Some
agricultural groups provide such guidance to their growers. For example, the Almond Board of
California recommends that growers avoid applying insecticides when plants are in bloom or

(...continued)
Conservation Trust); R. Heintzelman, et al., “Overview of Recent Publications on Neonicotinoids and Pollinators,”
May 2012 (prepared for Bayer Crop Science); Center for Food Safety (CFS), “Pollinators and Pesticides: A Report by
Center For Food Safety on Pollinator Health, Research, and Future Efforts for Pollinator Protection,” September 2013;
CFS, “Heavy Costs: Weighing the Value of Neonicotinoid Insecticides in Agriculture,” March 2014; CFS, Pollinator
Study Index (available at http://www.centerforfoodsafety.org/files/pollinator-study-index_73710.pdf); M. Simon,
Follow the Honey: 7 Ways Pesticide Companies are Spinning the Bee Crisis to Protect Profits, April 2014; and
PANNA, Pesticides and Honey Bees: State of the Science, May 2012.
35
For more information, see P. Mineau and C. Palmer, The Impact of the Nation’s Most Widely Used Insecticides in
Birds, American Bird Conservancy, March 2013; and C. A. Hallmann, et al., “Declines in Insectivorous Birds Are
Associated with High Neonicotinoid Concentrations,” Nature, vol. 511 (July 17, 2014), pp. 341-343.
36
Educational resources are available from most land grant universities and also the following organizations: Bee
Informed Partnership (www.beeinformed.org); Center for Urban Ecology and Sustainability/Pollinator Conservation
(www.entomology.umn.edu/cues/pollinators); National Pesticide Information Center (www.npic.orst.edu); Pesticide
Environmental Stewardship (www.pesticidestewardship.org); and Pollinator Partnership (www.pollinator.org).
37
PES, “Pollinator Protection,” http://pesticidestewardship.org/PollinatorProtection/Pages/default.aspx.
38
EPA, “Find Best Management Practices to Protect Pollinators,” http://www2.epa.gov/pollinator-protection/find-bestmanagement-practices-protect-pollinators.
39
C. H. Krupke, G. Hunt, and R. E. Foster, “Protecting Honey Bees from Pesticides,” Purdue University Extension, E53-W, http://extension.entm.purdue.edu/publications/E-53.pdf.
40
Ibid.

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when pollen is available and honey bees are feeding.41 Additional grower BMPs are listed in the
text box below.
Almond Board of California’s “Top 10 Honey Bee BMPs”
1. Communication should occur between all pollination stakeholders about pest control decisions. These
stakeholders can include beekeeper, bee broker, county agricultural commissioner, grower (owner/lessee), farm
manager, pest control adviser (PCA), and pesticide applicator.
2. Agreements should include a pesticide plan that outlines which pest control materials may be used. The grower
and the beekeeper should agree on which products may be applied if a treatment is deemed necessary. If deemed
necessary, growers should give beekeepers 48-hour notice before treatment.
3. If applying pesticides, contact your local county agricultural commissioner and give advance notification to
beekeepers with nearby managed hives.
4. Avoid applying insecticides during almond bloom until more is known, particularly about their impact on bee
brood, or young developing bees in the hive. If treatment is necessary, only apply fungicides and avoid tank-mixing
insecticides with fungicides.
5. Any fungicide application deemed necessary during bloom should occur in the late afternoon or evening, when
bees and pollen are not present. This timing avoids contaminating pollen with spray materials.
6. Provide clean water for the bees to drink. This will ensure they spend more time pollinating the crop than
searching for water. Cover or remove water sources before a pest control treatment, or empty and refill water
after a treatment is made. Check water levels throughout bloom and refresh as necessary.
7. Do not directly spray hives with any pesticide spray application. Ensure that the spray-rig driver turns off nozzles
when near hives. Spray applications that come in contact with bee hives could adversely affect bee health and the
pollination of the crop.
8. Do not hit flying bees with any spray application materials. Bees that come in contact with agricultural sprays will
not be able to fly because of the weight of spray droplets on their wings.
9. Report suspected pesticide-related bee incidents to the county agricultural commissioner’s office. Bee health
concerns cannot be addressed without the data from these incidents.
10. The beekeeper and the grower should agree on hive removal timing. The University of California recommends
bee removal when 90% of the flowers on the latest blooming variety are at petal fall. Past this point, no pollination is
taking place, and bees that forage outside the orchard (up to 4 miles) seeking alternate food sources and water will
have a higher risk of coming in contact with crops that have been treated with an insecticide.
Source: Almond Board of California, “Honey Bee BMPs,” http://www.almonds.com/newsletters/outlook/honey-beebmps-pest-management-and-honey-bees. See also http://www.growingproduce.com/nuts/top-10-honey-bee-bmps/.

Pesticide applicator BMPs recommend avoiding pesticide use when crops are blooming and
applying pesticides to blooming crops only after bees are done foraging for the day and
preferably at night.42 Bayer Crop Science notes the importance of following pesticide label
recommendations as “naturally beneficial to bees’ safety,” as well as cooperation between farmers
and beekeepers “to optimize spray times and minimize exposure to foraging bees.”43
41

Almond Board of California, “Honey Bee BMPs,” http://www.almonds.com/newsletters/outlook/honey-bee-bmpspest-management-and-honey-bees. See also testimony of Arthur Cummings, Capay Farms, at a House Agriculture
Subcommittee on Horticulture, Research, Biotechnology, and Foreign Agriculture hearing, April 29, 2014.
42
W. Buhler, “Pesticide Applicator BMPs,” Pesticide Environmental Stewardship, available at
http://pesticidestewardship.org/PollinatorProtection/PesticideApplicatorBMPs/Pages/Pesticide-Applicator-BMPs.aspx.
43
Bayer pamphlet, “Honey Bee Health: Understanding the Issues, Providing Solutions.”

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Such BMP guidance is generally voluntary. Several studies suggest, in general, adoption of
voluntary BMPs is characterized by both slow adoption rates (i.e., long lead times) and long lag
times between BMP adoption and observed effects; also BMP implementation tends to be mostly
self-funded.44 Some claim therefore that reliance on voluntary agricultural BMPs regarding
pesticide use and potential pollinator impacts is unlikely to produce timely behavioral changes
and BMP adoption, even with a broad outreach and education program.45
In response to recent bee die-offs in Canada, federal agencies there have instituted additional
protective requirements when using treated seed in corn and soybean production. These include
required use of safer dust-reducing seed flow lubricants; adherence to safer seed planting
practices; pesticide and seed package labels with enhanced warnings; and evaluation of the need
for neonicotinoid treatment on certain commercial crops.46 (More information on Canada’s
requirements is discussed in “Restrictions in Canada.”)
Agro-chemical industry representatives maintain that unwanted pesticide exposure is best
addressed through “effective product labeling and the implementation of meaningful stewardship
actions that help minimize harmful interactions,” along with “crop- and product-specific
integrated pest management (IPM) practices and messaging to improve bee and pollinator
safety.”47 However, some claim that because the use of systemic insecticides applied via seed
coatings is mostly “prophylactic” (i.e., applied regardless of actual pest pressure) the use of such
insecticides violates basic IPM principles, which recommend minimizing use of chemical
pesticides through pest monitoring, maximizing the use of biological and cultural controls,
applying chemical pesticides only when needed, and avoiding broad-spectrum, persistent
compounds.48 The text box below provides additional information on IPM practices.
Other guidance by apiculturists and university extension focuses on providing recommendations
to private landowners and homeowners for proper use of pest control products on ornamental
plants. One recommendation is to avoid applying any pesticides, including insecticides and
fungicides, during bloom of ornamental plants that attract bees (e.g., heather, lavender, linden,
rhododendron, and rose). It is also recommended that any pesticides be applied “only after flower
petals have fallen, when ornamental plants are less attractive to bees,” and that all specific
requirements to protect bees on the pesticide label be strictly followed.49 If pesticides are used
when plants are in bloom, those that are less toxic to bees are recommended. Some recommend
44

See, for example, E. Lichtenberg, D. Parker, and S. Lane, “Best Management Practice Use and Nutrient Management
in Maryland: A 2010 Snapshot,” 2010, University of Maryland; D. Stoddard, “Monitoring, Prevention and Mitigation
of Agricultural Contaminant Sources,” November 2006; Minnesota Department of Agriculture; M. Ribaudo, J. Savage,
M. Aillery, An Economic Assessment of Policy Options To Reduce Agricultural Pollutants in the Chesapeake Bay, June
2014; and American Farmland Trust, “The Adoption of Conservation Practices in Agriculture,” August 2013.
45
CRS communication with the Center for Food Safety, February 13, 2015.
46
Health Canada, “Notice of Intent, NOI2013-01, Action to Protect Bees from Exposure to Neonicotinoid Pesticides.”
47
Honey Bee Health Coalition, “Bee Healthy Roadmap,” October 2014, https://www.keystone.org/images/keystonecenter/spp-documents/Environment/BeeHealth/Bee-Healthy-Roadmap-October-2014.pdf. Also testimony of David
Fischer, Bayer North American Bee Care Center, at a House Agriculture Subcommittee on Horticulture, Research,
Biotechnology, and Foreign Agriculture hearing, April 29, 2014.
48
CRS communication with the Center for Food Safety, February 13, 2015 (citing D. Goulson, “An Overview of the
Environmental Risks Posed by Neonicotinoid Insecticides,” Journal of Applied Ecology, vol. 50, issue 4 (2013), pp.
977–987.
49
See, for example, Washington State Department of Agriculture (WSDA), “10 Ways to Protect Bees from Pesticides,”
AGR PUB 701-388, http://agr.wa.gov/fp/pubs/docs/388-TenWaysToProtectBeesFromPesticides.pdf.

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using certain pesticides—including products containing clothianidin, dinotefuran, imidacloprid,
and thiamethoxam—only after flower petals have fallen, and avoiding soil drench or tree
injection methods when using these products for plants known to attract bees because “these
methods may contaminate nectar and pollen for up to several years after the insecticide is
applied,” or, alternatively, recommend against buying plants treated with insecticides containing
these ingredients.50
What Is Integrated Pest Management (IPM)?
Integrated pest management (IPM) refers to practices that have been developed to improve pest control while also
minimizing risks to beneficial species, including pollinators. IPM combines pest control with an understanding of the
underlying ecology of the species and the environment where it occurs. The University of California Statewide
Integrated Pest Management Program (UC IPM) defines IPM as:
an ecosystem-based strategy that focuses on long-term prevention of pests or their damage through
a combination of techniques such as biological control, habitat manipulation, modification of cultural
practices, and use of resistant varieties. Pesticides are used only after monitoring indicates they are
needed according to established guidelines, and treatments are made with the goal of removing only
the target organism. Pest control materials are selected and applied in a manner that minimizes risks
to human health, beneficial and nontarget organisms, and the environment.
EPA further states: “IPM relies on easy-to-implement, environmentally sensitive practices that prevent pests from
becoming a threat. These practices involve monitoring and identifying pests and taking preventive action before
pesticides are used. If pesticides are needed, methods such as targeted spraying may be used.” In IPM strategies,
pesticides may be considered part of IPM but generally are intended as a last resort, after other non-chemical
methods have been exhausted or proved to be ineffective or are not available. According to UC IPM, pesticides are
used “only when needed and in combination with other approaches for more effective, long-term control,” and “are
selected and applied in a way that minimizes their possible harm” to humans and other organisms, as well as the
environment (air, soil, and water quality). The U.S. Fish and Wildlife Service (FWS) further states that in addition to
reducing risks from pests and pest management-related strategies to people, property, resources, and the
environment, one of the other benefits of IPM is the ability to “decrease or eliminate unnecessary pesticide use.”
In January 2014, EPA announced it had awarded nearly $500,000 in agricultural grants for IPM practices to reduce
the use of potentially harmful pesticides and lower risk to bees. These grants are intended to expand public-private
stewardship efforts and reduce pesticide risk in agriculture. These IPM grants were awarded to Louisiana State
University, Pennsylvania State University, and the University of Vermont.
Source: UC IPM website: http://www.ipm.ucdavis.edu; FWS, “Integrated Pest Management: Reducing the Risks to
Pollinators from Pest Management Activities;” and EPA’s press release, “EPA Awards Almost Half a Million in
Funding to Three Universities for Projects to Reduce Pesticide Risk Including Risks to Bees,” January 8, 2014. See
also USDA, Natural Resources Conservation Service (NRCS), “Integrated Pest Management Plan Criteria
Practice/Activity Code (114) (No.),” September 2011.

Consumer campaigns have been initiated to encourage businesses and home gardening centers to
stop selling certain pesticides or plants treated with these products because of concerns about the
effects on bees and other pollinators.51 A consumer campaign initiated by the Center for Food
Safety highlights that more than 60 commonly used home and garden products contain
neonicotinoid pesticides and recommends that homeowners avoid certain commonly used
pesticide products.52 In addition, concerns have been raised about the use of mosquito control
50

Ibid.
See, for example, Xerxes, “Protecting Bees from Neonicotinoid Insecticides in Your Garden,” 2013; J. Hopwood and
M. Shepherd, “Neonicotinoids in Your Garden,” 2012; and Friends of the Earth, Gardeners Beware: Bee-Toxic
Pesticides Found in “Bee-Friendly” Plants, June 2014 (updated).
52
For a listing of these products, see Center for Food Safety, “Help Save the Bees,” April 2013,
(continued...)
51

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services by some homeowners, because of potential adverse effects to bees and other beneficial
insects that might feed on plants or be exposed to pesticides within the sprayed areas, as well as
effects to species on adjacent or nearby property due to drift.

Federal Agency Efforts
National Pollinator Health Strategy (“Presidential Memorandum”)
In June 2014, the Obama Administration issued its Presidential Memorandum, “Creating a
Federal Strategy to Promote the Health of Honey Bees and Other Pollinators,” directing federal
agencies to take steps to protect and restore domestic populations of pollinators.53 It established a
“Pollinator Health Task Force,” co-chaired by USDA and EPA, with representatives of the
Departments of State, Defense, the Interior, Housing and Urban Development, Transportation,
Energy, and Education; among other agencies and offices.
The task force is directed to develop a National Pollinator Health Strategy, which is to include a
Pollinator Research Action Plan to “focus federal efforts on understanding, preventing, and
recovering from pollinator losses.” Among the many activities expected to inform the action plan
is “identification of existing and new methods and best practices to reduce pollinator exposure to
pesticides, and new cost-effective ways to control bee pests and diseases.” Task force member
agencies will develop plans to increase and improve pollinator habitat. These plans may include
“use of integrated vegetation and pest management,” among other actions. Member agencies will
also “make any necessary and appropriate changes to enhance pollinator habitat on federal lands
through the use of integrated vegetation and pest management and pollinator-friendly best
management practices.” The task force is expected to release its National Pollinator Health
Strategy in spring 2015.54
In November 2014, USDA and EPA held a number of public listening sessions to inform the task
force members. Concerns about pesticide use were among the major discussion points.
Commercial beekeepers, environmental groups, and some food businesses55 continue to push for
restrictions on pesticide use and question whether other factors, such as parasitic mites, are the
primary driver behind bee declines. Most pesticide industry groups and commercial growers
continue to encourage broader consideration beyond pesticides and claim that some alternative
pesticides are more toxic than neonicotinoids.56

(...continued)
http://www.centerforfoodsafety.org/files/pesticide_list_final_59620.pdf.
53
White House, “Presidential Memorandum—Creating a Federal Strategy to Promote the Health of Honey Bees and
Other Pollinators,” June 20, 2014, http://www.whitehouse.gov/the-press-office/2014/06/20/presidential-memorandumcreating-federal-strategy-promote-health-honey-b.
54
Announcement by Michael Stebbins, White House Office of Science and Technology Policy, at the 14th annual
conference of the North American Pollinator Protection Campaign (NAPPC), October 22, 2014. Other information is
available in CRS Report R43191, Bee Health: Background and Issues for Congress.
55
See, for example, letter to U.S. President Barack Obama from more than 100 environmentally friendly food
companies urging the Administration to protect bees and other pollinators from pesticides, January 13, 2015.
56
J.R. Pegg, “Neonicotinoid Controversy Hits Pollinator Health,” Food Chemical News, December 3, 2014.

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Currently, at EPA, the agency’s pollinator strategic plan outlines efforts to advance scientific
knowledge and assessment of pesticide risks to pollinators; improve management tools for
mitigating risks to pollinators; and increase and broaden communication and public outreach.57

USDA-EPA Joint Report
In 2013, USDA and EPA published a joint report, National Stakeholders Conference on Honey
Bee Health.58 Among the goals of the conference were to “synthesize the current state of
knowledge regarding CCD, bee pests, pathogens, and nutrition, potential pesticide effects on
bees, and bee biology, genetics and breeding.” The report’s key findings include
recommendations to address risks to honey bees from parasites and disease; increase the genetic
diversity in bee colonies; and improve nutrition for honey bees. In addition, regarding pesticides,
the report acknowledged the following needs:59
•

Collaboration and Information Sharing. Best management practices (BMPs)
associated with pesticide use and bees are known but are not widely or
systematically followed by U.S. crop producers. “Informed and coordinated
communication between growers and beekeepers” is needed, along with
“effective collaboration between stakeholders on practices to protect bees from
pesticides.” Beekeepers have identified the need for “accurate and timely bee kill
incident reporting, monitoring, and enforcement.”

•

Additional Pesticide Research. According to EPA, “[t]he most pressing
pesticide research questions relate to determining actual pesticide exposures and
effects of pesticides on bees in the field and the potential for impacts on bee
health and productivity of whole honey bee colonies.”

The National Honey Bee Health Stakeholder Conference Steering Committee is made up of
representatives from Pennsylvania State University; from USDA’s Office of Pest Management
Policy (OPMP), National Institute of Food and Agriculture (NIFA), Agricultural Research Service
(ARS), Animal and Plant Health Inspection Service (APHIS), Natural Resources Conservation
Service (NRCS), and National Agricultural Statistics Service (NASS); and from EPA’s Office of
Pesticide Programs (OPP). Much of the current research on bee health is being conducted by
scientists at USDA and its Beltsville bee laboratory, by the USDA-supported Bee Informed
Partnership, and by scientists at many of the land-grant universities nationwide.60

57
EPA, Pollinator Protection Strategic Plan, http://www2.epa.gov/pollinator-protection/pollinator-protection-strategicplan.
58
USDA, Report on the National Stakeholders Conference on Honey Bee Health, National Honey Bee Health
Stakeholder Conference Steering Committee, May 2013, http://www.usda.gov/documents/ReportHoneyBeeHealth.pdf.
59
EPA news release, “USDA and EPA Release New Report on Honey Bee Health,” May 2, 2013.
60
More information is available in CRS Report R43191, Bee Health: Background and Issues for Congress.

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Environmental Protection Agency
EPA’s Pesticide Registration Review of Neonicotinoid Pesticides
Neonicotinoid pesticide registrations are being reviewed by EPA. According to EPA:61
Some uncertainties have been identified since their initial registration regarding the potential
environmental fate and effects of neonicotinoid pesticides, particularly as they relate to
pollinators. Data suggest that neonicotinic residues can accumulate in pollen and nectar of
treated plants and may represent a potential exposure to pollinators.
Adverse effects data as well as beekill incidents have been reported, highlighting the
potential direct and/or indirect effects of neonicotinic pesticides. Therefore, among other
refinements to ecological risk assessment during registration review, we will consider
potential effects of the neonicotinoids to honeybees and other pollinating insects.

Review of several neonicotinoid pesticide registrations began December 2011, with review of
imidacloprid starting a few years earlier, in December 2008 (Table 1). EPA aims to review all
neonicotinoids as a group.
Table 1. Schedule for EPA Review of Neonicotinoid Pesticides
Chemical Name and Docket Number

Initiation

Data Generation

Projected Completion

Imidacloprid (EPA-HQ-OPP-2008-0844)

Dec. 2008

2010-2015

2016-2017

Clothianidin (EPA-HQ-OPP-2100-0865)

Dec. 2011

2013-2016

2017-2018

Thiamethoxam (EPA-HQ-OPP-2011-0581)

Dec. 2011

2013-2016

2017-2018

Dinotefuran (EPA-HQ-OPP-2011-0920)

Dec. 2011

2013-2016

2017-2018

Acetamiprid (EPA-HQ-OPP-2012-0329)

Dec. 2012

2014-2017

2018-2019

Thiacloprid (EPA-HQ-OPP-2012-0218)

Dec. 2012

2014-2017

2018-2019

Source: EPA’s website, http://www2.epa.gov/pollinator-protection/schedule-review-neonicotinoid-pesticides.

In July 2014, the Natural Resources Defense Council (NRDC) petitioned EPA to conduct an
emergency review of the impacts of neonicotinoid pesticides on bees and to complete its review
within one year.62 At an October 2014 meeting, an EPA official indicated that the agency would
move up its dates for its review of neonicotinoid pesticides from 2018-2019 to 2016-2017.63
Currently, among the neonicotinoid pesticides under review, some products are being used under
a “conditional” registration, while some products are being used under an “unconditional”
registration. FIFRA provides that EPA register a pesticide if, among other findings, it meets the
statutory standard, namely: (1) the pesticide will perform its intended function without
61

EPA, “Groups of Pesticides in Registration Review,” http://www2.epa.gov/pesticide-reevaluation/groups-pesticidesregistration-review.
62
NRDC, “Petition for Interim Administrative Review of Neonicotinoid Pesticides,” filed July 7, 2014,
http://docs.nrdc.org/health/files/hea_14070701a.pdf.
63
Public statements by EPA’s Assistant Administrator for the Office of Chemical Safety and Pollution Prevention, Jim
Jones, at the 14th Annual NAPPC International Conference, October 22, 2014.

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unreasonable adverse effects on human health and the environment, and (2) the pesticide will not
generally cause unreasonable adverse effects on human health and the environment when used in
accordance with widespread and commonly recognized practice. Under an unconditional
registration, after reviewing the data and information submitted to support an
applicant/registrant’s pesticide product application under consideration, if EPA determines that
the pesticide meets the statutory standard and there are no outstanding data requirements, the
agency may approve an “unconditional” registration.64 If, however, EPA finds that the pesticide
meets the standard for registration, but there are outstanding data requirements, the agency may,
under certain circumstances, grant a “conditional” registration.65 Before granting a conditional
registration, EPA must determine that, although an application lacks some of the necessary data,
use of the pesticide would not significantly increase the risk of unreasonable adverse effects on
the environment during the time needed to generate the necessary data. A product’s “conditional”
or “unconditional” status is determined on a product registration by product registration basis, and
not for the pesticide’s active ingredient as a whole.66 An indication of a product’s current status
can be found at EPA’s searchable label database.67
The U.S. Government Accountability Office (GAO) has conducted studies that are critical of
EPA’s pesticide registration process, particularly regarding the program’s conditional
registrations.68 Environmental and other groups argue that conditional registrations are a loophole
in EPA’s requirements, allowing pesticides onto the market that might not otherwise be allowed
under a thorough agency review.69 These groups further claim that EPA has overused conditional
registrations and that the agency does not have a reliable data-gathering system to track
conditional registrations.70 GAO’s 2013 report states that “the total number of conditional
registrations granted is unclear” due to database inaccuracies and confusion in EPA’s
recordkeeping system for tracking pesticides.71
In the process of reviewing registrations for neonicotinoids, EPA has revised its risk assessment
process “to reflect advancements in the state of the science that underlie bee exposure and effects
assessments.”72 The draft risk assessment policy was released to the public, and materials were
distributed and discussed at a FIFRA Scientific Advisory Panel (SAP) meeting in September
2012.73 The final risk assessment guidance was released in June 2014.74 The guidance is founded
64

FIFRA section 3(c)(5).
FIFRA section 3(c)(7).
66
For more information, see EPA’s website: http://www2.epa.gov/pesticide-registration/conditional-pesticideregistration.
67
A pesticide’s labels and the indication of their current conditional (or not) status at EPA’s Label database:EPA,
“Pesticide Product Label System,” http://iaspub.epa.gov/apex/pesticides/f?p=PPLS:1.
68
See, for example, GAO, EPA Should Take Steps to Improve Its Oversight of Conditional Registrations, GAO-13145, August 2013; and GAO, EPA’s Formidable Task To Assess and Regulate Their Risks, RCED-86-125: April 1986.
69
J. Sass and M. Wu, “Superficial Safeguards: Most Pesticides Are Approved by Flawed EPA Process,” NRDC Issue
Brief, IB: 13-01-B, March 2013, http://www.nrdc.org/health/pesticides/files/flawed-epa-approval-process-IB.pdf.
70
Ibid.
71
See, for example, GAO, EPA Should Take Steps to Improve Its Oversight of Conditional Registrations, GAO-13145, August 2013.
72
EPA, Environmental Fate and Effects Division (EFED), EFED Response to Comments Submitted to the Clothianidin
Registration Review Docket (docket: EPA-HQ-OPP-2011-0865), June 11, 2012. References EPA’s interim guidance
from 2011, Pesticides: Science and Policy, Interim Guidance on Honey Bee Data Requirements.
73
Meeting materials and public comments are posted in the regulatory docket (docket: EPA-HQ-OPP-2012-0543).
EPA, “Proposed Decision Framework for Assessing Risks of Pesticides to Honey Bees,” presentation at the 2012
(continued...)
65

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on EPA’s ecological risk assessment framework, integrates an analysis of honey bees and other
pollinators within the agency’s broader components of ecological risk assessment, and was
prepared in collaboration with Health Canada’s Pesticide Management Regulatory Authority and
California’s Department of Pesticide Regulation. The guidance describes the basic framework of
the risk assessment process and the data used to support risk management decisions, and includes
a process to assess both foliar spray applications and soil/seed treatment applications.
Some groups argue that EPA does not take into account chronic, sub-lethal effects in its risk
assessments, nor synergistic effects with other compounds used in real field settings, such as
fungicides, adjuvants, and inerts.75 These groups also claim native and wild bee species are
generally not addressed as part of EPA’s risk assessment. Since most native bee species (about
70%) are ground nesting,76 these groups further claim that the use of systemic insecticides poses
risks to native bees from exposure through their habitats in the ground. Native and wild bee
species are also generally not addressed as part of EPA’s pesticide labeling approach (discussed in
“EPA’s New “Bee Advisory” Labeling Requirements”).
As part of EPA’s overall review, the agency has conducted a study of the benefits of neonicotinoid
seed treatments for insect control in U.S. soybean production.77 EPA’s analysis concluded: “these
seed treatments provide little or no overall benefits to soybean production in most situations.
Published data indicate that in most cases there is no difference in soybean yield when soybean
seed was treated with neonicotinoids versus not receiving any insect control treatment.”78
Reportedly, EPA also studied the potential benefits of neonicotinoid seed treatments to corn
production but has not published those findings.79 In 2013, EPA and USDA conducted a summit
with stakeholders on reducing exposure to dust from treated seed and potential acute exposure of
honey bees and pollinators to pesticides. Information and stakeholder presentations from the
summit are at EPA’s website.80

EPA’s Consideration to Modify Thiamethoxam Tolerance Levels
In September 2014, EPA announced that it had received “several initial filings of pesticide
petitions requesting the establishment or modification of regulations for residues of pesticide
chemicals in or on various commodities,” including a petition by Syngenta that EPA increase the
allowable threshold for residues of thiamethoxam.81 Syngenta’s petition would apply to alfalfa,
(...continued)
FIFRA SAP meeting. Also see EPA’s presentation, “Ecological Risk Assessment Process for Honey Bees.”
74
EPA, Guidance for Assessing Pesticide Risks to Bees, June 19, 2014, http://www2.epa.gov/sites/production/files/
2014-06/documents/pollinator_risk_assessment_guidance_06_19_14.pdf.
75
CRS communication with the Center for Food Safety, February 13, 2015.
76
USDA, “Enhancing Nest Sites For Native Bee Crop Pollinators,” Agroforestry Notes, AF Note 34, September 2007.
77
EPA, “Benefits of Neonicotinoid Seed Treatments to Soybean Production,” October 15, 2014, http://www2.epa.gov/
sites/production/files/2014-10/documents/benefits_of_neonicotinoid_seed_treatments_to_soybean_production_2.pdf.
78
EPA, “Benefits of Neonicotinoid Seed Treatments to Soybean Production,” October 15, 2014. See also
http://www2.epa.gov/pollinator-protection/benefits-neonicotinoid-seed-treatments-soybean-production
79
Public statements by EPA’s Assistant Administrator for the Office of Chemical Safety and Pollution Prevention, Jim
Jones, at the 14th Annual NAPPC International Conference, October 22, 2014.
80
EPA, “Summit on Reducing Exposure to Dust from Treated Seed,” http://www2.epa.gov/pollinator-protection/2013summit-reducing-exposure-dust-treated-seed.
81
79 Federal Register 172: 53009: September 5, 2014.

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barley, corn and wheat, both the crop itself and the straw and stover82 left over after cultivation.
According to some reports, the petition seeks to increase the tolerance levels ranging from about
1.5 times current levels for stover from sweet corn to about 400 times current levels for hay from
wheat.83 EPA’s review of this request is still pending. Thiamethoxam is one of the neonicotinoid
pesticides banned for use in the European Union.

EPA’s New “Bee Advisory” Labeling Requirements
In August 2013, EPA announced that it had developed new pesticide labels that prohibit use of
some neonicotinoid pesticide products where bees are present. The new requirements apply to
foliar applications of products containing imidacloprid, dinotefuran, clothianidin, thiamethoxam,
tolfenpyrad, and cyantraniliprole.84 Exceptions apply under certain conditions for agricultural
crops and commercially grown ornamental plants. The new labels require a “Pollinator Protection
Box” (or “bee advisory,” Figure 3) and bee icon with information on routes of exposure and
spray drift precautions, as well as new language added under “Directions for Use.”
Figure 3. EPA’s Bee Advisory Box

Source: EPA, http://www2.epa.gov/sites/production/files/2013-11/documents/bee-label-info-graphic.pdf.

82

Stover refers to the leaves and stalks of field crops, such as corn or soybeans, commonly left in a field after harvest.
T. Stecker, “Syngenta Asks EPA to Raise Tolerance Level for ‘Bee-Killing’ Chemical,” Greenwire, September 5,
2014.
84
EPA, “New Pesticide Labels Will Better Protect Bees and Other Pollinators,” press release, August 15, 2013; and
letter from EPA’s Office of Investigations to the Pollinator Stewardship Council, February 28, 2014. See also letters
from EPA to registrants of nitroguanidine neonicotinoid products, July 22, 2013, and August 15, 2013.
83

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The bee advisory will, among other things, alert pesticide applicators to restrictions regarding
certain pesticides when bees are present; clarify that pesticides cannot be applied until all petals
have fallen; and emphasize the importance of avoiding pesticide drift (for example, due to wind)
to other areas where bees may be present. The new bee icon will signal the pesticide’s potential
hazard to bees, and warns that direct contact and ingestion can harm pollinators. Information is at
EPA’s website.85
EPA’s new labeling requirements have received mixed reviews from beekeepers, who argue that
the new labels are inadequate and include exceptions that may make them less protective for bees
and other pollinators.86 Groups, such as the Pollinator Stewardship Council, have expressed
concerns about EPA’s label as well as concerns about the conditions under pesticide applications
would be allowed. Figure 4 shows some of this group’s concern with EPA’s label, including
concerns that none of the terms in the label is defined and many are ambiguous (which they claim
makes the requirements unenforceable), as well as the concern that the label refers applicators to
a pesticide industry website, among several other issues.87
Figure 4. Pollinator Stewardship Council’s Analysis of EPA’s Bee Advisory Box

Source: Pollinator Stewardship Council. Other comments regarding exceptions to the label’s requirements are
at http://pollinatorstewardship.org/wp-content/uploads/2014/02/PSC-label-layout-of-concerns.pdf.
85

EPA, “New Labeling for Neonicotinoid Pesticides,” http://www2.epa.gov/pollinator-protection/new-labelingneonicotinoid-pesticides.
86
J. R. Pegg, “State Pesticide Officials, EPA Ready to Join Forces on Pollinator Protection,” Food Chemical News,
December 10, 2014.
87
For more information, see Pollinator Stewardship Council, “Analysis of the New Label,”
http://pollinatorstewardship.org/wp-content/uploads/2014/02/PSC-label-layout-of-concerns.pdf.

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Some groups, including the Pollinator Stewardship Council, have voiced concerns about EPA’s
exceptions to the new labeling requirements, which would allow application under certain
conditions.88 Exceptions to the labeling requirements are as follows.
For “Crops Grown Under Contracted Pollination Services,” the label for some neonicotinoid
pesticide products states: “Do not apply this product while bees are foraging” or “until flowering
is complete and all petals have fallen.” Exceptions are allowed for in cases where “an application
must be made when managed bees are at the treatment site, the beekeeper providing the
pollination services must be notified no less than 48 hours prior to the time of the planned
application so that the bees can be removed, covered or otherwise protected prior to spraying.”
For “Food Crops and Commercially Grown Ornamentals not Under Contract for
Pollination Services But Attractive to Pollinators,” the label for some products also states: “Do
not apply this product while bees are foraging” or “until flowering is complete and all petals have
fallen.” Exceptions are allowed for in cases where:
•

The application is made to the target site after sunset.

•

The application is made to the target site when temperatures are below 55˚F.

•

The application is made in accordance with a government-initiated public health
response.

•

The application is made in accordance with an active state-administered apiary
registry program where beekeepers are notified no less than 48 hours prior to the
time of the planned application so that the bees can be removed, covered, or
otherwise protected prior to spraying.

•

The application is made due to an imminent threat of significant crop loss, and a
documented determination consistent with an IPM plan or predetermined
economic threshold is met. Every effort should be made to notify beekeepers no
less than 48 hours prior to the time of the planned application so that the bees can
be removed, covered, or otherwise protected prior to spraying.

Among the expressed concerns regarding EPA’s exceptions to its label advisory are:89
•

harm caused by foliar application of the affected pesticides will be the
responsibility of the beekeeper, including damage or die-off from applications
allowed for under the labels exceptions;

•

uncertainty about what constitutes notifying a beekeeper to move their bees, and
concern that native bees will be harmed since they are not similarly managed;

•

foliar application of adjacent or nearby sites may affect bees since they have a 3mile to 7-mile forage range;

•

exceptions to applications made when temperatures are below 55˚F may affect
bees that forage at temperatures as low as 45˚F; and

88

Letter from EPA to registrants of nitroguanidine neonicotinoid products, August 15, 2013.
Pollinator Stewardship Council, http://pollinatorstewardship.org/wp-content/uploads/2014/02/PSC-label-layout-ofconcerns.pdf. See also blog posting, March 21, 2014, http://pollinatorstewardship.org/?p=2143.
89

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•

other labeling issues, including who decides when foliar treatments are needed,
what are the criteria for determining whether treatment are needed, where should
beekeepers transport bees during applications, and who determines what
mitigation measures are appropriate.

Exceptions do not apply to non-agricultural crops, such as ornamental crops grown by
homeowners, and the pesticide label requires that the product not be applied while bees are
foraging or when plants are flowering.

EPA Support of State Pollinator Protection Plans
EPA is working with states to draft guidance on the development of EPA-approved, statemanaged pollinator protection plans. Guidance is being developed by EPA’s State FIFRA
Research and Evaluation Group (SFIREG), and will outline a process for reviewing and accepting
state pollinator protection plans as part of EPA’s broader pollinator protection efforts related to
pesticides. The draft guidance was presented at a December 2014 meeting of the Association of
American Pesticide Control Officials (AAPCO),90 and contained information on the core
elements for EPA-approved state pollinator plans, the process for EPA review and updating of
state plans, how to reference state plans through labeling requirements, and how to access
recommended best management practices.91 Pollinator protection plans are in place in several
states, including California, Colorado, Florida, Mississippi, and North Dakota.92 Other states are
considering similar initiatives.

EPA Development of Voluntary Controls for Pesticide Drift
In October 2014, EPA announced a new voluntary Drift Reduction Technology (DRT) program to
encourage the use of verified, safer pesticide spray products to reduce exposure and pesticide
movement, and also to reduce costs to farmers from pesticide loss. EPA defines pesticide spray
drift as the “movement of pesticide dust or droplets through the air at the time of application or
soon after, to any site other than the area intended.”93 More information is at EPA’s website.94 A
similar effort—the DriftWatch Specialty Crop Site Registry—provides for a voluntary
communication tool between crop producers, beekeepers, and pesticide applicators, and is
intended to protect high-value, pesticide-sensitive crops and commodities before applying
pesticides.95 The program is currently in use in many midwestern and mid-Atlantic states.

90

SFIREG Full Committee meeting, December 8, 2014, http://aapco.org/meetings/agen-120814.pdf.
C. Purdy, “EPA to Review State Pollinator Protection Plans,” Politico Morning Agriculture, December 9, 2014.
92
J.R. Pegg, “State Pesticide Officials, EPA Ready to Join Forces on Pollinator Protection,” Food Chemical News,
December 10, 2014.
93
EPA, “Introduction to Pesticide Drift,” http://www2.epa.gov/reducing-pesticide-drift/introduction-pesticide-drift.
Pesticide droplets are produced by spray nozzles used in application equipment for spraying pesticides on crops,
forests, turf, and home gardens. Dust formulations refer to very fine dry particles of pesticides.
94
EPA, “Reducing Pesticide Drift,” http://www2.epa.gov/reducing-pesticide-drift.
95
Information is at DriftWatch’s website: https://www.driftwatch.org/.
91

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Fish and Wildlife Service Memorandum
In July 2014, the U.S. Fish and Wildlife Service (FWS) in the Department of the Interior
announced that it would phase out the feeding of genetically engineered crops to wildlife and the
use of neonicotinoid pesticides in all of its wildlife refuges by January 2016.96
Initially this decision was meant to phase out the use of neonicotinoids in Region 1 only, which
covers Oregon, Washington, Idaho, Hawaii, and the Pacific Islands.97 Under the guidelines,
refuge managers will also need to comply with new mandatory requirements for all chemically
treated seeds on refuge lands.98
In early 2013, Representative Austin Scott, chairman of a House Agriculture subcommittee,
indicated that the committee would direct FWS to undergo “a uniform risk assessment process ...
when making decisions on products already approved” under FIFRA and/or the Plant Protection
Act.99 To date, no such action has been untaken.

Other Ongoing Efforts
Restrictions in Some U.S. Cities and Counties
A number of cities and counties, among other local jurisdictions, have instituted restrictions on
the use of neonicotinoid pesticides in an effort to protect pollinators. In March 2014, Eugene,
Oregon, became the first U.S. city to restrict neonicotinoid use. (Despite the ban, a mass die-off
of bees was reported in June 2014 at an apartment complex in northwest Eugene. It was attributed
to insecticide sprayed on blooming linden trees.) Since then other cities have also instituted bans,
including Seattle and Spokane in Washington; Shoreline, Minnesota; and Skagway, Alaska. Other
cities and counties, such as Tucson and Pima County in Arizona, and Boulder County in
Colorado, also are considering restrictions. Some state legislatures, including Alaska, California,
Maryland, Minnesota, New York, New Jersey, Oregon, and Vermont, have considered legislation
to further study and/or restrict neonicotinoid use. Some localities also have instituted other types
of pesticide restrictions, such as with disclosure laws in the county of Kauaˋi in Hawaii. Other
localities have implemented programs to encourage households and municipalities to pledge to
create “pollinator-friendly, toxin-free ecosystem habitats,” such as in the city and county of
Denver, Colorado. Some state agencies are actively studying the issue.100

96
FWS memorandum, “Use of Agricultural Practices in Wildlife Management in the National Wildlife Refuge
Service,” July 17, 2014, http://www.peer.org/assets/docs/fws/FWS_Memorandum.pdf.
97
T. Stecker, “FWS Bans GMO Feed, Bee-Killing Chemicals Nationwide,” Greenwire, August 1, 2014.
98
See Region 1 FWS memorandum, “Guidelines Regarding the Interim Use and Phase Out of Neonicotinoid
Insecticides to Grow Agricultural Crops for Wildlife on NWRs in the Pacific Region,” June 9, 2014.
99
OpEd by U.S. Representative Austin Scott, “Protecting Bee Health Is a Long-Term Commitment,” Agri-Pulse, 2013.
100
See, for example, Minnesota Department of Agriculture Pesticide and Fertilizer Management Division, Scoping a
Review of Neonicotinoid Use, Registration and Insect Pollinator Impacts in Minnesota, March 2014 (draft).

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In addition, several states—California, Colorado, Florida, Mississippi, and North Dakota—have
state pollinator protection plans in place, and other states are considering similar initiatives.101
(For information, see “EPA Support of State Pollinator Protection Plans”)

Restrictions in the European Union
Like the rest of the world, the countries of the EU have experienced overwinter honey bee colony
losses. As reported by the nonprofit honey bee research association, COLOSS,102 overwinter
colony losses averaged 9% in 2013/2014, the lowest since the group began collecting such data in
2007.103 Across countries, losses ranged from 6% to 12%. This is lower than results reported for
2012/2013, when overwinter losses ranged from 6% to a high of 37% across all reporting
countries.104 Another report commissioned by the European Commission and EU member states
concluded honey bee colony mortalities were “better than previously expected” and “higher than
normal in certain countries, with significant regional (and possibly temporal) differences.”105
In response to concerns about declining bee populations, in May 2013, the European Commission
(EC) adopted Regulation No 485/2013 banning the use of certain neonicotinoid pesticides for a
period of two years, among other proposed limits on the use of other pesticides.106 The regulation
includes the following provisions:
•

use of three neonicotinoid pesticides—clothianidin, imidacloprid, and
thiamethoxam—is restricted for seed treatment, soil application (granules), and
foliar treatment on bee attractive plants and cereals;

•

any authorized uses are available to professionals only;

•

any exceptions to these restrictions are limited to treating bee-attractive crops in
greenhouses or in open-air fields after flowering; and

•

restrictions are to be maintained for two years, effective December 1, 2013.

As new information becomes available, the EC will review the approval conditions for these three
pesticides and take into account relevant scientific and technical developments. Previous
mitigation measures (EC Regulation No 1107/2009) restricted spraying of insecticides on beeattractive flowering crops.107
101

J.R. Pegg, “State Pesticide Officials, EPA Ready to Join Forces on Pollinator Protection,” Food Chemical News,
December 10, 2014.
102
COLOSS (Prevention of honeybee COlony LOSSes), http://www.coloss.org/, collects data from 19 European
countries, and also from Israel and Algeria.
103
COLOSS, “Losses of Honey Bee Colonies over the 2013/14 Winter,” July 18, 2014.
104
COLOSS, “Losses of Honey Bee Colonies over the 2012/13 Winter,” July 24, 2013.
105
EpiloBee, “A Pan-European Epidemiological Study on Honeybee Colony Losses 2012-2013,” August 2014. See
also OPERA Research Center, Bee Health in Europe—Facts & Figures and Bee Health in Europe, An Overview, 2012,
http://www.operaresearch.eu/.
106
Regulation (EC) No 485/2013 of 24 May 2013 amending Implementing Regulation (EU) No 540/2011, as regards
the conditions of approval of the active substances clothianidin, thiamethoxam and imidacloprid, and prohibiting the
use and sale of seeds treated with plant protection products containing those active substances. See also European
Commission, “Bees & Pesticides: Commission Goes Ahead with Plan to Better Protect Bees,” http://ec.europa.eu/food/
archive/animal/liveanimals/bees/neonicotinoids_en.print.htm.
107
Restrictions were placed in some member states, such as Italy (ban on corn seed coating), Slovenia (ban on corn and
(continued...)

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The EC’s 2013 regulatory action was in response to the European Food Safety Authority’s
(EFSA)108 scientific assessment that identified “high risks for bees for some uses of three
neonicotinoids (imidacloprid, clothianidin and thiamethoxam) and fipronil,” such that “the
approval criteria of these pesticides were no longer satisfied.”109 Regarding the three restricted
pesticides, EFSA identified “high acute risks” for bees from exposure to pesticides associated
with the production of several crops such as corn, grains, and sunflower, as well as exposure to
residue in pollen and nectar in certain crops.110
The EU Commission has further proposed to restrict the use of fipronil, an insecticide which
EFSA has identified as posing an acute risk to Europe’s honey bees when they are exposed to
seeds treated with the chemical.111
Other reports, such as a study published by the United Kingdom’s Department for Environment,
Food and Rural Affairs (DEFRA), dispute some of the findings linking bee health and exposure to
neonicotinoids.112 Other studies also highlight the likely multifaceted nature of possible factors
contributing to pollinator declines.113 Researchers in Europe continue to study this issue and
reportedly are in the process of completing a large-scale study reviewing the landscape-scale
effects of neonicotinoid use on crops.114 Some member state officials are also questioning the ban
and its possible effects on agricultural production.115

(...continued)
sugar beet seed coating), France (ban on corn and canola seed coating), and Germany (ban on corn seed coating). M.
Dermine, “Neonicotinoids in the European Union,” presentation at November 4, 2014, webinar.
108
EFSA is an agency of the European Union that provides independent scientific advice and communication on
existing and emerging risks associated with food and feed safety.
109
EC, “Bee Health: What Is the EU Doing? Questions and Answers,” April 7, 2014 http://europa.eu/rapid/pressrelease_MEMO-14-260_en.htm. See also EC press releases, “Bee Health: EU-Wide Restrictions on Pesticide Use to
Enter into Force on 1 December,” May 24, 2013; and “Bees and Pesticides: Commission to Proceed with Plan to Better
Protect Bees,” April 29, 2013.
110
Regarding the EFSA study, EPA claims its own scientific conclusions “are similar to those expressed in the EFSA
report with regard to the potential for acute effects and uncertainty about chronic risk,” but notes “the EFSA report does
not address risk management” which is a requirement for EPA under U.S. law. See EPA, “Colony Collapse Disorder:
European Bans on Neonicotinoid Pesticides,” August 2013, http://www.epa.gov/pesticides/about/intheworks/ccdeuropean-ban.html.
111
EC, “Bee Health: EU Takes Additional Measures on Pesticides to Better Protect Europe’s Bees,” July 16, 2013,
http://europa.eu/rapid/press-release_IP-13-708_en.htm. EFSA’s analysis, “Conclusion on the Peer Review of the
Pesticide Risk Assessment for Bees for the Active Substance Fipronil,” EFSA Journal 2013, 11(5):3158, 27 May 2013,
http://www.efsa.europa.eu/en/efsajournal/pub/3158.htm.
112
See, for example, DEFRA, Food and Environment Research Agency (FERA), “Effects of Neonicotinoid Seed
treatments on Bumble Bee Colonies Under Field Conditions,” March 2013.
113
See, for example, a 2013 study by the European Landowners’ Organization (ELO), the European Crop Protection
Association (ECPA), and the European Initiative for Sustainable Development in Agriculture (EISA), “Pollinators and
Agriculture: Agricultural Productivity and Pollinator Protection.”
114
P. Case, “Neonicotinoid Field Studies to Assess Effect on Bees,” Farmers Weekly, September 26, 2014. Reportedly,
large-scale field experiments will look at the effects on bees of two seed treatments—clothianidin and thiamethoxam.
115
See, for example, N. Robinson, “Neonic Ban Threatens UK Mustard Crop,” FoodManufacture, August 19, 2014;
and M McGrath, “Scientific opinions differ on bee pesticide ban,” BBC News, April 23, 2013.

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Restrictions in Canada
In Canada, the Canadian Association of Professional Apiculturists (CAPA) reports that overwinter
honey bee colony losses in 2013/2014 averaged 25% across Canada, but some provinces, such as
Ontario, reported wintering losses of 58%.116 In addition, in 2012, Health Canada’s Pest
Management Regulatory Agency (PMRA) began reporting higher bee mortalities associated with
pesticide applications in some areas as part of its pesticide incidents reporting.117
In April 2012, PMRA reported a “significant number of honey bee mortality reports” in the
provinces of Alberta, Manitoba, Saskatchewan, Nova Scotia, Quebec, and Ontario. Most reports
were from southern Ontario, involving more than 40 beekeepers and 240 different locations, with
also one report from Quebec involving eight bee yards. Health Canada concluded “an unusually
high number of reports of honey bee mortalities were received from beekeepers in corn growing
regions of Ontario and Quebec.... Timing and location of these honey bee mortalities appeared to
coincide with planting corn seed treated with insecticides.”118
PMRA’s preliminary findings conclude “there is an indication that pesticides used on treated corn
seeds may have contributed to at least some of the 2012 spring bee losses that occurred in
Ontario.”119 The agency continued to “receive a significant number of pollinator mortality reports
from both corn and soybean growing regions of Ontario and Quebec, as well as Manitoba” in
spring 2013.120 A 2013 field study by researchers at the University of Guelph reported no link
between bee health and pesticide applications.121
Following this investigation, PMRA determined that “current agricultural practices related to the
use of neonicotinoid treated corn and soybean seed are affecting the environment due to their
impacts on bees and other pollinators.”122 The agency implemented measures to reduce honey bee
exposure to dust generated during planting of treated corn seed, including “communication of
best practices to reduce the exposure of honey bees, labelling of treated seed, a treated seed dust
standard, and development of technical solutions to reduce dust, including developments in the
areas of seed coating quality, seed flow lubricants, planting equipment, and disposal of treated
seed bags.”123 For the 2014 planting season, PMRA issued additional protective measures for corn
and soybean production.124 PMRA has continued to re-evaluate nitro-guanidine neonicotinoids to
116

CAPA, “CAPA Statement on Honey Bee Wintering Losses in Canada (2014),” July 2014. Losses in prior years are
available at CAPA’s website, http://www.capabees.com/.
117
See, for example, Health Canada, “2012 Report on Pesticide Incidents,” available at http://www.hc-sc.gc.ca/.
118
Health Canada, “Evaluation of Canadian Bee Mortalities that Coincided with Corn Planting in Spring 2012,”
http://www.hc-sc.gc.ca/cps-spc/pubs/pest/_decisions/bee_corn-mort-abeille_mais/index-eng.php.
119
Health Canada, “Ontario Bee Incidents 2012-Update,” September 2013, http://www.hc-sc.gc.ca/cps-spc/pubs/pest/
_fact-fiche/bees-incidents-abeilles-2012/index-eng.php.
120
Health Canada, “Notice of Intent, NOI2013-01, Action to Protect Bees from Exposure to Neonicotinoid Pesticides,”
September 2013, http://www.hc-sc.gc.ca/cps-spc/pest/part/consultations/_noi2013-01/noi2013-01-eng.php.
121
Presentation by C. Scott-Dupree, “Field Study Reliability: A Honey Bee & Neonicotinoid Perspective,” University
of Guelph, http://sesss08.setac.eu/embed/sesss08/Cynthia_Scott-Dupree_Field_study_Reliability__A_Honey_bee__Neonicotinoid_PERSPECTIVE.pdf.
122
Ibid.
123
Health Canada, “Pollinator Protection: Reducing Risk from Treated Seed,” April 2013, http://www.hc-sc.gc.ca/cpsspc/pubs/pest/_fact-fiche/pollinator-protection-pollinisateurs/index-eng.php.
124
Health Canada, “Notice of Intent, NOI2013-01, Action to Protect Bees from Exposure to Neonicotinoid Pesticides.”

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determine if further regulatory action was needed.125 PMRA is reportedly also planning to
implement label changes similar to those being considered by EPA in the United States (see
“EPA’s New “Bee Advisory” Labeling Requirements”).
In November 2014, the province of Ontario announced a proposal to reduce the use of
neonicotinoid-treated corn and soybean seed (based on acreage of treated seeds planted) by
80%.126 If approved, the new regulations would go into effect by July 1, 2015, prior to the 2016
planting season. Manufacturers of the chemicals claim the decision is not supported by science.
The Canadian industry association, CropLife Canada, is also urging the Canadian government to
broaden its examination of bee population declines beyond pesticides and neonicotinoids.127 The
Canadian government continues to study this issue.128
In September 2014, two large beekeeping operations filed a class-action lawsuit129 on behalf of
Canadian beekeepers against several chemical manufacturers, claiming thiamethoxam (and its
predecessor, imidacloprid) and its breakdown product clothianidin led to more than C$450
million (about US$410 million) in total damages from 2006 to 2013.130 The alleged chronic
effects of the use of these pesticides include “bee deaths; impaired reproduction; immune
suppression; behavioral abnormalities resulting in hive loss; reduced honey production; impacts
on the quality of honey; contamination of hive equipment; loss of queen bees; breeding stock; and
difficulties fulfilling honey product or pollination contracts.” The lawsuit alleges that Bayer and
Syngenta were “negligent in their design and development of the neonicotinoid pesticides,” and
were and continue to be “negligent in their distribution and sale of the neonicotinoid pesticides,”
as well as “negligent in permitting or failing to prevent the damages caused by the neonicotinoids
to the beekeepers.” The plaintiffs further claim that Bayer and Syngenta “knew or ought to have
known that the neonicotinoids would cause damage to the property” of beekeepers, since they
allege that the harm to the beekeepers was “reasonably foreseeable.”

Legal and Other Actions by Some Interest Groups
Selected Actions by Environmental Groups
A number of environmental and food safety advocacy groups, along with individual beekeepers,
have remained active in pressing federal and state authorities on policies and issues pertaining to
125

PMRA, “Re-evaluation Note REV2012-02, Re-evaluation of Neonicotinoid Insecticides,” June 12, 2012,
http://www.hc-sc.gc.ca/cps-spc/pubs/pest/_decisions/index-eng.php.
126
See Ministry of the Environment and Climate Change, “Reducing Pesticide Use and Protecting Pollinator Health
Ontario Sets Goal to Reduce Neonicotinoid Use by 80 Per Cent,” November 25, 2014; and the Ontario Ministry of
Agriculture, Food and Rural Affairs (OMAFRA), “Pollinator Health: A Proposal for Enhancing Pollinator Health and
Reducing the Use of Neonicotinoid Pesticides in Ontario,” November 2014.
127
“Canadian Industry Seeks Broader Approach to Bee Problem,” Food Chemical News, November 15, 2013.
128
See, for example, Environmental Commissioner of Ontario, Managing New Challenges, Annual Report 2013/2014.
129
Sun Parlor Honey Ltd. and Munro Honey v. Bayer CropScience Inc., Bayer Inc., Bayer AG, Syngenta Canada Inc.
and Syngenta International AG, Court File No.: CV-14-21208 (Ontario Superior Court of Justice, Ontario, Canada),
September 2, 2014. The complaint is available at http://www.ontariobee.com/sites/ontariobee.com/files/DOCSLIB%232440628-v1-AMENDED_Claim.pdf.
130
The lawsuit seeks C$400 million (about $370 million) in general and specific damages and C$50 million (about $46
million) in punitive damages, plus interest and legal costs.

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the approval and use of neonicotinoid pesticides, among other agrochemicals. Among these are
the Center for Food Safety (CFS); Earthjustice; Pesticide Action Network North America
(PANNA); Beyond Pesticides; Friends of the Earth; Sierra Club; and the Center for
Environmental Health. These groups have published a series of widely available reports
supporting their policy positions and/or have posted literature reviews on their organization’s
websites, and also have undertaken a series of legal challenges in these matters.131
In March 2013, CFS and a coalition of four beekeepers and five environmental and consumer
groups filed a lawsuit against the EPA to stop the use of pesticides containing clothianidin and
thiamethoxam, which beekeepers in the case claim is damaging the central nervous system of
their bees.132 The lawsuit also challenges EPA’s risk assessment framework for determining
whether pesticides harm pollinators and questions EPA’s approval of certain neonicotinoids. An
opening brief was filed in December 2013 further challenging EPA’s risk assessment framework
and requesting that the court reverse EPA’s decision to register sulfoxaflor.133 In July 2014, CFS,
Earthjustice, PANNA, and Beyond Pesticides challenged California’s approval of new
agricultural uses for two neonicotinoid pesticides, Venom Insecticide and Dinotefuran 20SG.134
Previously, in 2005, two beekeepers residing in Minnesota sued the state’s Department of Natural
Resources for losses incurred from spraying of a pesticide, carbaryl. In that case, the pesticide
users reportedly offered to settle, and the state’s Department of Natural Resources stopped using
the pesticide.135
These legal challenges follow previous requests for EPA to restrict the use of certain pesticides. In
a March 2012 citizen petition, CFS and a coalition of beekeepers along with PANNA filed an
“Emergency Petition” with EPA asking for a suspension of the use of clothianidin until it is
proven safe to pollinators and the environment.136 EPA responded in part to the petition in July
2012.137 A few weeks later, EPA announced that it was denying the request to suspend
131
For example, CFS, “Heavy Costs: Weighing the Value of Neonicotinoid Insecticides in Agriculture” (March 2014)
and “Pollinators & Pesticides” (September 2013); PANNA, “Honey Bees and Pesticides: State of the Science” (May
2012); and Friends of the Earth, “Follow the Honey” (April 2014) and “Gardeners Beware” (October 2013, June 2014).
132
Steve Ellis, Tom Theobald, Jim Doan, Bill Rhodes, CFS, et al. v. Steven P. Bradbury and Bob Perciasepe, U.S.
Environmental Protection Agency, Case No. 3:13-Cv-01266-Lb (U.S. District Court for the Northern District of
California, San Francisco Division), May 31, 2013. In addition to CFS, the coalition is represented by Beyond
Pesticides, Pesticide PANNA, Sierra Club, and the Center for Environmental Health, as well as four beekeepers with
operations located in California, Colorado, Florida, New York, and Minnesota. The amended complaint is at
http://www.centerforfoodsafety.org/issues/304/pollinators-and-pesticides/legal-actions. For more information, see CFS,
“CFS, Beekeepers and Public Interest Groups Sue EPA over Bee-Toxic Pesticides,” March 21, 2013,
http://www.centerforfoodsafety.org/issues/304/pollinators-and-pesticides/press-releases.
133
Pollinator Stewardship Council et al. v. USEPA and Dow Agrosciences, Case No.13-72346 (U.S. Court of Appeals
for the 9th Circuit), December 13, 2013. The amicus curiae brief is at http://www.centerforfoodsafety.org/issues/304/
pollinators-and-pesticides/legal-actions.
134
PANNA, CFS, and Beyond Pesticides v. California Department of Pesticide Regulation et al., Case No.
RG14731906 (Superior Court for the State of California for the County of Alameda), July 8, 2014. The original
complaint is at http://www.centerforfoodsafety.org/issues/304/pollinators-and-pesticides/legal-actions.
135
Jeffrey Anderson, et al., v. State of Minnesota, Department of Natural Resources, A03-679 (State of Minnesota in
Supreme Court), March 3, 2005 (posted: http://www.beyondpesticides.org/documents/MNSUPREME_Decision.pdf).
136
Emergency Citizen Petition to the United States Environmental Protection Agency, March 12, 2013
http://www.centerforfoodsafety.org/files/cfs-clothianidin-petition-3-20-12_57213.pdf.
137
EPA’s response: S. P. Bradbury, EPA Office of Pesticide Programs, letter to Peter T. Jenkins, Center for Food
Safety and International Center for Technology Assessment, “Clothianidin Emergency Citizen Petition dated March 20,
2012,” July 17, 2012. The petition and numerous supplemental submissions of research reports and opinions are posted
(continued...)

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registrations “to prevent imminent harm” because the petitioners did not meet the burden of proof
for registration suspension.138 However, EPA received public comments on this decision and may
revisit its decision as it reviews neonicotinoid registrations. Again, in July 2014, NRDC
petitioned EPA to conduct an emergency review of the impacts of neonicotinoid pesticides on
bees, and to complete its review within one year.139 For more information, see “EPA’s Pesticide
Registration Review of Neonicotinoid Pesticides.”
In June 2013, a coalition of advocacy groups, including CFS, sent a letter to President Obama
asking him to order EPA to ban use of neonicotinoid insecticides for at least two years.140 The
letter asserts that the registration process lacks consideration of pesticide effects on colonies and
focuses exclusively on acute mortality, rather than on sublethal effects of repeated exposure.
Another letter followed in January 2015 from commercial beekeepers, environmental groups, and
some food businesses, who continue to push for restrictions on pesticide use.141

Selected Actions by Agrochemical Companies
Some major agrochemical companies—in particular, Syngenta AG (a global Swiss agribusiness
company) and Bayer AG (a global German company)—have been actively engaged in defending
the use of neonicotinoid pesticides, among other agrochemicals, and claim there is no evidence to
support a systematic correlation between honey bee colony mortality and the use of
neonicotinoids.142 Bayer’s bee care pamphlet claims “poor bee health is correlated with the
presence of Varroa, a parasitic mite, viruses and many other factors, but not with the use of
insecticides.”143 These companies and other industry groups, as well as the trade association
CropLife Amercia,144 have published commissioned reports supporting their policy positions,145
and have supported various pollinator health146 as well as lobbying efforts.147

(...continued)
in the regulatory docket (docket: EPA-HQ-OPP-2012-0334-0015).
138
77 Federal Register 145: 44233-44234, July 27, 2012. Other information is in the regulatory docket (docket: EPAHQ-OPP-2012-0334).
139
NRDC, “Petition for Interim Administrative Review of Neonicotinoid Pesticides,” filed July 7, 2014,
http://docs.nrdc.org/health/files/hea_14070701a.pdf.
140
The June 20, 2013, letter is available at http://www.centerforfoodsafety.org/files/final-neonic-letter62013_43430.pdf. Also see P. Ambrosio, “Environmental Groups Urge President to Ban Neonicotinoids over Threat to
Bees,” Bloomberg BNA Daily Environment Report, June 24, 2013.
141
See, for example, letter to U.S. President Barack Obama from more than 100 environmentally friendly food
companies urging the Administration to protect bees and other pollinators from pesticides, January 13, 2015.
142
“Crop Protection Industry Plans Response to EPA on Neonicotinoids,” Agri-Pulse, October 29, 2014.
143
Bayer pamphlet, “Honey Bee Health: Understanding the Issues, Providing Solutions.”
144
CropLife represents “companies that develop, manufacture, formulate and distribute crop protection chemicals and
plant science solutions for agriculture and pest management” including Syngenta, Bayer, Dow, Dupont, and Monsanto.
145
See, for example, Ag Infomatics, “Value of Neonicotinoids in North American Agriculture” (October 2014); and
CropLife Foundation, “The Role of Seed Treatment in Modern U.S. Crop Production” (December 2013).
146
For example: Bayer’s “Bee Care Center” in North Carolina; Syngenta’s funding of research grants to study causes
of pollinator declines; and Monsanto’s purchase in 2011 of the Beeologics research organization in Missouri.
147
See, for example, postings by Corporate Europe Observatory, “Pesticides Against Pollinators: Private Letters Reveal
Syngenta and Bayer’s Furious Lobbying Against EU Measures to Save Bees,” April 11, 2013,
http://corporateeurope.org/agribusiness/2013/04/pesticides-against-pollinators.

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According to news reports, both Syngenta and Bayer are legally challenging the EU’s
neonicotinoid ban.148 Syngenta claims these pesticides are not responsible for the pollinator
population declines, which they claim are instead the result of disease, viruses, habitat loss, and
poor nutrition.149 According to reports, Syngenta wants to reverse the EU ban but also wants to be
compensated for damages and “defend our reputation which has been significantly damaged.”150
Syngenta claims the EU’s decision to ban the pesticides is based on “a flawed process, an
inaccurate and incomplete assessment by the European Food Safety Authority and without the
full support of EU Member States.”151
Syngenta also has petitioned EPA to increase the allowable threshold for residues of
thiamethoxam. EPA published its proposal in September 2014.152

Congressional Consideration
Given continued concerns about the health and well-being of honey bees and other pollinators,
this issue has continued to be legislatively active. The 2014 farm bill (P.L. 113-79) reauthorized
and expanded provisions supporting research on honey bees and other pollinators that were
enacted in the 2008 farm bill. In previous Congresses, bills were introduced to promote and
improve habitat for honey bees and wild bees, among other pollinators.153 Still other introduced
legislation would address a range of pesticide issues affecting pollinators. Over the past few
years, Congress has conducted hearings on this issue154 and hosted a series of congressional
briefings to discuss these and related issues representing a broad range of interested groups.155
For the 114th Congress, Representative Rodney Davis, the incoming chairman of the House
Agriculture Subcommittee on Biotechnology, Horticulture, and Research, is quoted as saying that
bee health will be a top issue for his subcommittee.156

148

T. Rabesandratana, “Pesticidemakers Challenge E.U. Neonicotinoid Ban in Court,” Science, August 28, 2013,
http://news.sciencemag.org/europe/2013/08/pesticidemakers-challenge-e.u.-neonicotinoid-ban-court.
149
Syngenta, “Syngenta Submits Legal Challenge to EU Suspension of Thiamethoxam,” August 27, 2013,
http://www.syngenta.com/global/corporate/en/news-center/news-releases/Pages/130827.aspx.
150
T. Rabesandratana, “Pesticidemakers Challenge E.U. Neonicotinoid Ban in Court,” Science, August 28, 2013,
http://news.sciencemag.org/europe/2013/08/pesticidemakers-challenge-e.u.-neonicotinoid-ban-court.
151
Syngenta, “Syngenta Submits Legal Challenge to EU Suspension of Thiamethoxam,” August 27, 2013,
http://www.syngenta.com/global/corporate/en/news-center/news-releases/Pages/130827.aspx.
152
79 Federal Register 172: 53009: September 5, 2014. For more information, see “EPA’s Consideration to Modify
Thiamethoxam Tolerance Levels.”
153
For more information, see CRS Report R43191, Bee Health: Background and Issues for Congress.
154
See, for example, “Subcommittee Examines Research Efforts to Combat Pests and Diseases of Pollinators,” House
Agriculture Subcommittee on Horticulture, Research, Biotechnology, and Foreign Agriculture hearing, April 29, 2014.
155
For example: “Impacts of Pesticides on Birds, Bees, and Broader Ecosystems” (March 2013); “Honey Bee Colony
Health” (April 2013); “Applied Bee-Nomics” (June 2013); “What’s Killing Our Bees?” (October 2013, December
2013); and “The Threat of Neonicotinoid Pesticides to Bees and Other Organism, and Risks to Human Health”
(September 2014).
156
T. Stecker, “New House Subcommittee Chief Will Push Forward on Bee Issues,” Environmental and Energy Policy,
December 16, 2014.

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Saving America’s Pollinators Act
In the 113th Congress, Representatives Earl Blumenauer and John Conyers Jr. introduced H.R.
2692, the Saving America’s Pollinators Act of 2013. The bill would have suspended registrations
of neonicotinoids and banned new registrations of any pesticide for use on “bee attractive plants,
trees, and cereals.” This bill was initially introduced, in part, as a response to reports that 50,0

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Source: Frix Law Library, https://www.frixlaw.com/law-library/documents/crs%3AR43900. Public record. Not legal advice.