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  • Writer's picturePollinator Stewardship Council

Advocacy Update- PSC Comment Letter to the EPA


At the end of January, the Pollinator Stewardship Council (PSC) submitted a comment letter to the Environmental Protection Agency (EPA) regarding the use of treated seed and the treated article exemption.  Prepared by PSC Scientific Advisory Panel member Dr. Susan Kegley and with the support of the American Beekeeping Federation, the letter urged the EPA to address the use of treated seeds and the treated article exemption.


PSC emphasized that current regulations exempting treated seeds from oversight under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) pose risks to honey bees, beekeepers, farms reliant on pollination services, and consumers. The letter cited the hazardous waste issue at the AltEn plant in Nebraska, caused by the use of treated seeds for ethanol production. PSC argued that neonicotinoid seed coatings have significantly increased environmental toxicity, and improper disposal of treated seeds has led to environmental disasters. The letter criticized the EPA's risk assessment process for underestimating pollinator risks and emphasized that the benefits of treated seeds in crop production do not outweigh the risks. PSC cited numerous studies that demonstrate the acute and sublethal toxicity of neonicotinoid insecticides to bees, beneficial insects, and wildlife and called for FIFRA regulation of these pesticides. The failure of EPA to provide adequate protections at the federal level has resulted in  an increasing number of states that have been forced to provide regulations and legislation at the state level to protect their constituents. 


Dr. Kegley writes "...We note here that it is not US EPA’s job to make it easier and less costly for someone to disperse a poison into the environment. In fact, cost and complexity can serve as a deterrent to pollution, as evidenced by the results in Québec. An easy solution is for farmers to plant untreated seed. There is a great deal of simplicity in that approach. And because there is little to no economic benefit to farmers from planting treated seed, and significant economic benefit from creating safe habitat for pollinators and beneficial insects in agricultural fields, there should be no question about the best way to proceed. US EPA has a mandate to protect the environment and not allow ‘unreasonable adverse effects.’ The failure to regulate treated seed is causing significant adverse effects on bees, beekeepers, farmers relying on pollination, and consumers who eat the food pollinated by bees.” 


Read the full comment letter here.

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