One of the many ways in which PSC supports pollinator health is through participation in targeted pesticide campaigns and actions across the country. Our most recent work has been focused in California, with two opportunities to influence potential regulatory changes for neonicotinoids.
Last fall, detections of high levels of imidacloprid in 15 groundwater wells triggered a review process with the California Department of Pesticide Regulation (DPR) to determine if the pesticide was present due to legal agricultural use and if so, whether continued use should be allowed. In accordance with state law, when pesticides are detected in groundwater, the manufacturers of these dangerous pesticides have the opportunity to request a hearing in order to maintain their product registration. As of September 2021, 125 products containing imidacloprid as an active ingredient were registered for sale in California (out of 253) and subject to the state’s Pesticide Contamination Prevention Act based on their use in agricultural settings. Manufacturers of these damaging pesticides are highly invested in keeping them on the market and are spending significant resources to defend their sale and use. They requested a hearing to defend the distribution of these dangerous chemicals and PSC has been following the review process closely, submitting comments from scientific experts and working in collaboration with EarthJustice. Research has proven chronic exposure over time, even at low levels, has a catastrophic impact on pollinator health. We have been providing DPR with critical testimony and comprehensive statements backed by peer reviewed scientific studies, to help inform their knowledge as they review registration for these dangerous products, responding to each opportunity to provide information untainted by the chemical manufacturers.
In a separate case, California DPR is also reevaluating the use of neonics. Although this process was initiated over 13 years ago with data indicating that ornamental use of imidacloprid in California left residue at levels lethal to bees and remained high for more than 500 days after treatment application, the progress has been slow and thus far has failed to adopt regulations to provide adequate protection to pollinators. In 2020, a draft proposal was published but was insufficient for pollinator health primarily related to a lack of restrictions for non-agricultural use and neonic treated seed coatings, both of which pose some of the highest risks for bees. Throughout the reevaluation process, PSC has been a persistent defender of pollinators by providing substantive comments and testimony at each stage of the regulatory review process. Dr. Susan Kegley has been instrumental in preparing statements and providing scientific evidence illustrating the damage impact of neonics on pollinators. Dr. James Niel is currently preparing a comment letter for the upcoming hearing on April 25th, detailing the impacts of chronic exposure to neonics which will be made available on our website.
With the assistance of our amazing legal team at EarthJustice and the contribution of our scientific advisory board, PSC continues to actively engage in the defense of pollinators and advocate for the elimination of neonic use in California.