Update on EPA’s Pollinator Protection Efforts Rick Keigwin, Director Office of Pesticide Programs U.S. Environmental Protection Agency

Discussion Topics Neonicotinoid Registration Review U.S. Environmental Protection Agency Discussion Topics Neonicotinoid Registration Review https://www.epa.gov/pollinator-protection/schedule-review-neonicotinoid-pesticides Acute Risk Mitigation Policy https://www.epa.gov/pesticides/epa-finalizes-steps-better-protect-bees-pesticides Study Protocol Development and Additional Ongoing Efforts There are a diverse number of perspectives on pollinator declines and these are reflected in social and scientific media. The extent of supporting information used in these various accounts can vary widely; however, each account informs stakeholder perspectives across multiple public and private sectors including government, industry, academia, and the general public. These accounts also fuel concerns that insufficient resources, government bureaucracy, and outright intrigue are delaying appropriate responses to understand and mitigate pollinator declines.

Neonicotinoid Registration Review U.S. Environmental Protection Agency Neonicotinoid Registration Review Imidacloprid January 2016: Preliminary pollinator-only assessment January 2017: Preliminary aquatic-only risk assessment September 2017: Draft human health and ecological risk assessments Clothianidin, Thiamethoxam and Dinotefuran January 2017: Preliminary pollinator-only risk assessment released December 2017: Draft human health and ecological risk assessments Benefits Assessments December 2017: Assessments for cotton and citrus

Preliminary Pollinator Risk Conclusions U.S. Environmental Protection Agency Preliminary Pollinator Risk Conclusions Some use patterns have low on-field risk based on attractiveness and agronomic practices Examples: root and tuber vegetables, leafy vegetables, seed treatments For bee-attractive crops Tier I risks identified for all uses (all 4 neonicotinoids) Tier II (imidacloprid, thiamethoxam and clothianidin) Potential risks with cotton, citrus, cucurbits, stone fruit Spray drift risks off-field from foliar applications

Next Steps Risk Assessments Other Assessments U.S. Environmental Protection Agency Next Steps Risk Assessments 2018: Updated pollinator assessments for all neonicotinoids Other Assessments 2018: Other benefits assessments may also be conducted Interim Risk Management Decisions Planned for 2019

Acute Risk Mitigation Policy U.S. Environmental Protection Agency Acute Risk Mitigation Policy Proposal was released for public comment in May 2015 Addressed acute contact exposure to foliar pesticide applications Over 113,000 comments received EPA’s Policy to Mitigate the Acute Risk to Bees from Pesticide Products - Issued January 12, 2017 EPA revised the policy in response to comments Prohibits pesticide applications under certain conditions Also provides some flexibility for growers in some circumstances

Acute Risk Mitigation Policy U.S. Environmental Protection Agency Acute Risk Mitigation Policy Applies to Products: With outdoor foliar uses; That are registered for crops that may use pollination services; and, With uses that have application rates that exceed the EPA Tier I acute risk Level of Concern (LOC) for bees Policy Applies When: The target crop is in bloom; A contract exists for pollination services to the target crop; and, Managed bees are present under contract for pollination services to the target crop

Acute Risk Mitigation Policy: Labeling U.S. Environmental Protection Agency Acute Risk Mitigation Policy: Labeling Restrict foliar applications for crops with managed bees during bloom Exceptions Chemicals with short residual toxicity time Applications allowed between 2-hours prior to sunset but not less than 8 hours prior to sunrise. Applications to indeterminate blooming crops An application can be made in the time between 2-hours prior to sunset until sunrise An application can be made when the temperature at the application site is 50oF or less.

Acute Risk Mitigation Policy: Labeling U.S. Environmental Protection Agency Acute Risk Mitigation Policy: Labeling Environmental Hazard Statement The Policy revises pollinator protection language located in the environmental hazards section of the pesticide label (a section typically reserved for advisory information). The previous language used broad and directive terms that effectively prohibited pesticide use in many scenarios. The existing language was considered by the state lead agencies, as unenforceable and problematic. The revised language is informational and generic in nature.

Study Protocol Development U.S. Environmental Protection Agency Study Protocol Development EPA working with researchers in academia and industry to further refine test methods to improve the likelihood of success Improved experience with maintaining suitable environmental/ husbandry test conditions Exploring alternative exposure methods for chemicals with limited solubility or high sorption properties (e.g., TGAI suspensions; emulsions; TEP)

Other Efforts Non-Apis bee test protocols U.S. Environmental Protection Agency Other Efforts Non-Apis bee test protocols Pollen & nectar residue data analysis and study protocols Colony simulation models Toxicity data extrapolations Neonic / honey bee Adverse Outcome Pathway Non-Apis bee exposure EPA has been working with its regulatory counterparts and the research community to identify additional test methods for assessing exposure and effects on bees.  Methods for addressing the uncertainty of whether bees are suitable surrogates for non-Apis bees are under development.  Last year the working group on pesticides reviewed draft guidelines for examining acute oral and contact toxicity for the social non-Apis bumble bee (Bombus spp).  Test methods are also under development for the solitary non-Apis mason bee (Osmia spp).   EPA has also been working with the regulated community to develop standardized protocols for examining exposure in pollen and nectar of a wide range of crops. In addition, EPA has been working with the USDA to develop a colony simulation model for examining the effects of pesticides and looking at interactions with other stressors such as varroa mite and poor queen bee performance.  EPA is also engaged in a retrospective analysis of bee toxicity data to determine the extent to which adult bee toxicity tests may be predictive for larval bee toxicity; once sufficient data are available, a similar analysis of the extent to which honey bees data are protective for non-Apis bees can be undertaken.  These efforts may limit the extent to which additional data may be needed/required in the future. The EPA Office of Research and Development has also identified an Adverse Outcome Pathway for nicotinic acetylcholine receptor agonism.  These conceptual models identify a molecular initiating event that leads to a series of key events culminating in an adverse outcome of regulatory interest.  The 2014 Guidance on Assessing Risks to Bees discussed the utility of such conceptual models in integrating information over multiple levels of biological organization to support read-across or directed approaches where data for other chemicals with similar molecular initiating events may be used to estimate risk. EPA also hosted a workshop in January 2017 on non-Apis bee exposure to determine the extent to which honey bees do or do not serve as reasonable surrogates for evaluating exposure to bees.  This international workshop represented a collaborative effort between industry, academia and government. Also ORD is working with Land Grant Universities through Regionally Administered Research Effort (RARE) grants to develop data to inform colony simulation models and to develop suitable test methods for non-Apis bees.