Aug 7, 2017

The class of insecticides known as neonicotinoids or “neonics” that include imidacloprid, clothianidin, thiamethoxam and dinotefuran are currently undergoing Registration Review with the EPA.

The class of insecticides known as neonicotinoids or “neonics” that include imidacloprid, clothianidin, thiamethoxam and dinotefuran are currently undergoing Registration Review with the EPA. Registration Review is a multiyear process, scheduled for completion for all neonics in 2018/2019.

The first public comment period in 2016 was for the imidacloprid preliminary pollinator assessment.  Along the review timeline, there will continue to be opportunities for stakeholders to directly affect the review outcome by commenting to official EPA dockets.

When these opportunities arise, it is critical stakeholders articulate how important these products are and the consequences should they no longer be available. For certain, anti-pesticide groups take these same opportunities to advocate for their removal from the market.

The EPA recently solicited comments in regards to a combined Preliminary Pollinator Risk Assessment for clothianidin, thiamethoxam and dinotefuran, as well as an Aquatic Ecological Assessment for imidacloprid. The docket closed on July 24.

GCSAA is a member of the Pesticide Policy Coalition and PPC Final Comments re Neonicotinoids_072417 (00215419xAA4DC) in regards to this latest Registration Review activity surrounding the neonics. The comments focused on the following key points:

1. In regards to the agency's preliminary aquatic risk assessment for imidacloprid, the PPC encourages EPA to follow through with its improved risk assessment framework and dedicate the resources necessary to review higher tier studies (actual exposures, real world scenarios) provided by registrants to ensure that its final assessment is based on the best available science.
2. PPC asks EPA to reexamine exposure estimates which are guided by extreme, worst-case exposure scenarios.
3. EPA's risk assessment for neonics have indicated that widespread adoption of these products do not pose a significant risk to pollinator health. However, EPA is reluctant to more publicly announce these reassuring findings. PPC encourages EPA to better communicate the protective regulatory standards any pesticide has to meet and any real risks pesticides pose to pollinators as supported by the appropriate data-driven regulatory analysis.

GCSAA will continue to follow the fate of the neonic class of insecticides as they make their way through Registration Review and work with the agency to offer data and information to support a sound, scientific review of them.