June 26, 2008
CropLife America is the national trade association representing the developers, manufacturers, formulators and distributors of virtually all crop protection chemicals used by American farmers for agriculture and pest management. Our industry’s products help provide Americans and the world with abundant and affordable food and fiber, while also protecting people, animals and their homes and businesses from disease-carrying and destructive pests. I appreciate the opportunity to submit this testimony to you today.
I commend Chairman Cardoza and the entire Subcommittee for holding this important hearing on pollinator health. I represent CropLife America and our member companies that support the need for additional research to better understand the nature of Colony Collapse Disorder (CCD), and then develop solutions. The sudden disappearance of worker honey bees from a colony with an apparently healthy queen and brood left behind continues to be a profoundly troubling situation. As an indicator of our industry’s awareness of this problem and our commitment to being a part of the solution, I continue to proactively serve on the Native Pollinator in Agriculture Workgroup and have since 2006. CropLife America is also an active supporter of the North American Pollinator Protection Campaign.
As you are aware, bees are critical for a healthy and productive agricultural system. The nation’s farmers depend on bees to pollinate a significant number of crops. In fact, more than 90 crops – including almond, alfalfa (seed), sunflower seed, apple, cherry, melons and many berries – require pollination support from bees. According to the USDA, honey bees pollinate crops valued at more than $14 billion annually. Because only a few species of bees can be used for commercial pollination, their health is crucial to agricultural production.
The specialty non-agricultural pesticide industry is also keenly aware of the importance of flowering plants to sustaining native bee populations, particularly for crop pollination. Specialty pesticides are those used in non-agricultural applications to ensure the health and vitality of blooming plants, including trees, bushes and flowers, and for disease vector control. Carefully managed growth and care of such plants in fencerows or hedgerows, in riparian buffers, drainage ditches, rights-of-way and other naturalized areas near crops provide a diverse source of pollen and nectar forage for bees across multiple seasons. Specialty pesticides are an important part of an Integrated Pest Management approach to ensure the health of bee forage plants, along with effective control of insect predators and parasites that can harm native bees, and control of noxious weeds and non-native, invasive plant species that can harm bee forage areas.
The concern with declining bee populations is not new. Before Colony Collapse Disorder, the beekeeping industry experienced heavy losses of colonies from conditions called autumn collapse, May disease, spring dwindle, disappearing disease and fall dwindle disease as well as other unnamed maladies occurring sporadically since honey bees have been tended. In its report released in 2006 titled “Status of Pollinators in North America,” the National Academy of Sciences stated:
Although pesticides have been mentioned as one of many possible factors for the decline in bees, without protection by miticides, a significant percentage of bees in the U.S. would fall victim to varroa mite and tracheal mite, Acarapis woodi, which began affecting bees in the late 1980s. Before using miticides in beehives, the only way to stop the spread of the mites was to destroy infested beehives.
The pesticide industry, because of the nature of its products, is heavily regulated and remains committed to environmental responsibility and the safe use of its products. Every pesticide product sold or distributed in the U.S. must be granted a registration by the U.S. Environmental Protection Agency (EPA), with labeling and use requirements regulated under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA). The regulations and policies that implement FIFRA are revised and updated as necessary to address new needs and the latest science and technologies.
Nearly 900 scientists and program officials in EPA’s Office of Pesticide Programs make sure that products are properly registered and comply with federal law. These experts are responsible for ensuring that pesticides cause no unreasonable adverse effects on the environment and human health. EPA’s approval and re-registration processes include the evaluation of potential environmental effects on wildlife – birds, amphibians, mammals and beneficial insects, which include bees.
The commitment of our industry to bring a pesticide product from “lab to label” requires dozens of separate studies – all subject to Good Laboratory Practices. The development process for a new pesticide can cost in the range of $160-$200 million with a normal timeline of eight to 10 years.
EPA requires bee toxicity studies in the data package necessary to register a pesticide. The honey bee acute contact toxicity test (OPPTS Guideline
850.3020) is routinely conducted for all pesticides (not just insecticides) that would be sprayed when the crop is in bloom and attracting honey bees. Testing the toxicity of residues on foliage (OPPTS Guideline 850.3030) is required for the same pesticide uses if toxicity is indicated from the acute contact test. Field testing for pollinators (OPPTS Guideline 850.3040) is required when data from other studies indicate adverse effects on bee colonies, extended residual toxicity to bees, or reproductive or chronic effects occurring in other species. Based on the results of these studies, the agency specifies label language to ensure that the pesticide can be used without adverse effects on bees. The application of pesticides that are highly toxic to bees is restricted or prohibited when bees are actively visiting the application area.
The pesticide industry is committed to stewardship of its products. Our industry sponsors extensive outreach and education programs to help educate farmers and commercial applicators on proper application techniques and on following the label instructions. In addition, we are active in container recycling efforts and wildlife preservation. For economic reasons as well as environmental stewardship, farmers do not use more pesticides than necessary, as doing so would increase their cost per acre for the same yield. As part of Integrated Pest Management practices, farmers combine pesticide use with other agronomic practices, such as crop rotation and use of beneficial insects, to control pests and increase yields at a lower cost than can be achieved using any one method exclusively.
The importance of Colony Collapse Disorder and other pollinator-related issues is demonstrated by the attention this issue received in the recently enacted Farm Bill. The Farm Bill authorizes a host of new programs and protections designed to address these very serious concerns. Title II encourages the development of pollinator habitat and protections in conservation programs. Pollinator protection is identified as high priority research while bees and honey production are covered in agriculture disaster assistance programs. CropLife America supports the recognition of this important need and the new authorities contained in the Farm Bill as well as the leadership of Chairman Cardoza and others on the Subcommittee.
Bees are vitally important to agriculture, to our industry, and to the future of our nation’s crops. The crop protection industry supports vigorous efforts to determine the cause of the decline in honey bee populations and stands ready to continue to work with the USDA, Congress and other stakeholders in resolving this important dilemma.
Mr. Chairman, thank you again for the opportunity to share our views with the Subcommittee.
