Bees, Foxes and Hens: EPA's Failure to Protect Our Food Supply

That's outrageous. Potentially dangerous chemicals should stay in the jar at the lab until their safety is determined through a thorough scientific investigation -- and certainly before they are poured willy-nilly all over the planet.
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Co-written by Stephen J. McConnell

Stephen J. McConnell is a Denver-based creative and professional writer who recently finished a novel about environmental collapse.

You would think by now that science would halt the use of chemicals that can threaten life on this planet.

And you would hope that scientific uncertainty about any chemical that has the potential to hurt life (and not in any sort of beneficial way), would make us err on the side of caution -- "caution," of course, being withholding use of that chemical until we are sure it will not do unintended harm.

But if a recent Rolling Stone piece about the effects of neonicotinoid pesticides on bees and human health is any indication, then it's just wishful thinking to think and hope that science informs our decisions to utilize questionable chemicals worldwide.

I can hear you now, "Why should I even care about bees?" Because bees are a key contributor to the U.S. food supply. For about every third bite of food you eat, you can give thanks to a bee and other pollinators for that nourishment.

The Rolling Stone story examines the controversial use of the chemicals known as neonicotinoids (also known as neonics) on the nation's farms, and EPA's decision to allow them to be widely used with apparently minimal mitigation of risk (until enacting some restrictions in recent years). However, recent studies have shown that neonics cause a wide range of adverse impacts on bees and bee colonies, including damage to their central nervous system, memory and learning; increased susceptibility to diseases; developmental impairments; and bee colony loss, among other issues.

In addition, there is some speculation that neonics are either a direct or a contributing factor to colony collapse disorder (CCD) -- essentially a dead bee colony. However, according to the USDA, "no scientific cause for CCD has been proven" but pesticides, like neonics, could be one of several contributing factors for CCD.

These cautionary flags raised by the scientific community no doubt spurred the EU to ban the use of neonicotinoid pesticides. While the moratorium was slightly relaxed recently, their use is still highly restricted. Come January, the U.S. Fish and Wildlife Service will also ban neonicotinoid pesticides on National Wildlife Refuge System lands based on their "precautionary approach to our wildlife management practices," according to an agency memo.

Even the EPA has begun restricting the use of neonicotinoids, including halting the approval of "new outdoor neonicotinoid pesticide uses until new bee data is submitted and pollinator risk assessments are complete," as well as engaging in a comprehensive "re-evaluation of the neonicotinoid family of pesticides," according to the agency. That review and "risk mitigation" is still underway.

But that's the issue. We react after the facts become clear, after we start seeing life get sick or perish. Sadly, environmental policy in the U.S. is still at times reactive rather than proactive. But a reactive approach in which we backpedal and reverse course after the poisons are unleashed is a lethal policy. Instead, we allowed neonics to become the "most widely used class of insecticides with a global market share of more than 25 percent" in less than 20 years. However, as the science caught up to this phenomenon, the science began showing that neonics may pose an adverse threat to bees, in addition to a few studies pointing to human health impacts.

In fairness, the issue is complex and the science is still developing. However, the trends are clear: a USDA report released in May revealed a staggering decline in honey bee colonies in recent years in the U.S. And while a USDA-EPA report stated that "it is not clear, based on current research, whether pesticide exposure is a major factor associated with U.S. honey bee health declines" it is clear 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 ... drift onto flowers in areas adjacent to crops that are attractive to bees."

Sadly, despite the science, some of these chemicals are still being used. And that's part of the larger issue here. Because of lax laws and regulations and the prioritizing of economic expedience over thorough scientific analysis, we are constantly spewing thousands of chemicals into the environment worldwide, while waiting for the science to catchup and measure the harm. That's just unacceptable.

And in the U.S., it's because our laws often let the fox guard the henhouse. As the Rolling Stone article points out, "new chemicals can in certain circumstances enter the market before a company has submitted all the tests requested by the EPA." And the agency often lets the companies provide the chemical data to them, rather than the regulators doing their own extensive scientific analysis. By that rationale, the chemical manufacturers do the legwork and the EPA gives the stamp of the approval based on the chemical manufacturers' analysis of their own chemicals.

According to a study by the Natural Resources Defense Council, the EPA has relied on a process called "conditional registration," which is loophole of sorts that allows the lawful registration of "some pesticides without all the necessary data."

"Despite the intention of Congress that conditional registration be used sparingly, NRDC's investigations of the EPA's pesticide registration database revealed that as of August 2010, more than 11,000 -- about 65 percent -- of the 16,000-plus currently active pesticide products have been conditionally registered and allowed on the market," according to the NRDC study. "The EPA's own website acknowledges that it needs improved registration tracking and staff training to avoid continued misuse and overuse of the conditional registration provision."

Regulatory laws and policies like Federal Insecticide, Fungicide, and Rodenticide Act and the Toxic Substances Control Act govern much of what EPA can and cannot do. Yet those laws contain a horrid blend of provisions that pander to a wide range of special interests and economic expedience often prevails over all other concerns, including the potential risks to human health and the environment. And we know those laws also get watered down by Congress, the White House, and the judiciary before they finally become the law of the land. Well-intentioned policy meant to protect human health and the environment becomes utterly toothless over time.

Ultimately, if the science is uncertain or nonexistent, it is immoral and unethical to introduce substances into our world that have the potential to cause harm, especially because we live in a time in which science can provide precise answers. Bees dying off in droves shouldn't be our indicator to change course. Illness and death shouldn't be our guides, when science can safely guide us. Nor should we let the fox guard the hen house.

And if the science is uncertain, lacking, or nonexistent, we should adhere to the precautionary principle to guide us until the science develops, until we understand the gravity and the complexity of the things we are introducing into the environment before we flippantly give potentially dangerous and/or lethal chemicals the green light. We must stick to the precautionary principle and proactively investigate whether a chemical will harm life first before we let that chemical or policy destroy life. Our world should not be a laboratory where we learn whether something is harmful or not through trial and error.

We must always exercise caution in the face of uncertainty and try our best to resolve scientific uncertainty and assure safety in order to prevent dangerous outcomes. But as Rolling Stone notes, "unlike in Europe -- which operates under the precautionary principle -- chemicals in America are often given the benefit of the doubt."

That's outrageous. Potentially dangerous chemicals should stay in the jar at the lab until their safety is determined through a thorough scientific investigation -- and certainly before they are poured willy-nilly all over the planet. Then, we can ensure the safety of human health and bee colonies worldwide before it becomes the subject of a story in Rolling Stone, or even worse, written in our history books as another example of industry run amok in the name of profits. Precaution must always prevail.

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