Pollinator Protection: Strategic Plan
In recent years, Colony Collapse Disorder (CCD) in honeybees and pollinator declines in general have become serious environmental concerns that could ultimately threaten the functioning of our natural ecosystems and affect the production of many important crops in the United States (Status of Pollinators in North America1 and Colony Collapse Disorder Action Plan2). Pesticide use has been identified as a potential contributing factor to these declines along with other potential factors such as new and reemerging pathogens, habitat loss, pests, bee management practices, and nutritional stress.
To address the potential contribution of pesticides to the decline of pollinators, and honey bees in particular, the Office of Pesticide Programs established a multidisciplinary team, the OPP Pollinator Protection Team (PPT), which includes staff from the various scientific and regulatory divisions within OPP as well as staff from EPA’s regional offices and the Office of General Counsel. This multidisciplinary team is tasked with exploring possible approaches, tools, and resources for reducing the potential risks of pesticides to pollinators and with developing a strategic plan that will guide its future work and direction.
Before developing a strategic plan, the PPT met with numerous interest groups, researchers, and stakeholders to understand the many challenges and potential factors involved in pollinator declines. Although the role that pesticides play in pollinator declines has not been determined, the PPT has moved ahead and developed a broad strategic plan that ensures the Agency’s risk assessments and risk management decisions make use of best available information and scientific methods, and full evaluation of pollinator protection when making registration decisions. The strategy will also serve as the foundation for developing a work plan with accompanying activities that in turn will be incorporated into OPP’s future planning process.
Our vision is to promote and enhance pollinator protection consistent with the Agency’s mission to protect public health and the environment and in particular to ensure that pollinators are not subject to unreasonable adverse effects from exposure to pesticides. To accomplish this vision, the PPT will work closely with its international, federal, and state partners and stakeholders in the implementation of a strategic plan for protection and conservation of pollinators, with an emphasis on reducing the potential effects of pesticides.
Goal 1: Advance the Agency’s Scientific Knowledge and Assessment of Pesticide Risks to Pollinators
The Agency bases its regulatory decisions for registering and reevaluating pesticides for use in the United States on sound science. To further enhance the scientific basis for characterizing the potential adverse effects of pesticides to pollinators, PPT members are working with researchers domestically and abroad to identify and advance the scientific knowledge that will inform the Agency’s risk management decisions. Team members are also exploring options for pollinator research and protection through contract and grant programs. The Agency is actively working with its federal, state, tribal, and international partners in efforts to identify, measure, and describe the potential impact of pesticides on pollinators. As part of that effort, PPT members are also working to facilitate reporting of bee incidents to the Agency. Since the formation of the USDA-led Colony Collapse Disorder Steering Committee, PPT members have been actively involved in helping to design and collect information on research studies examining the potential adverse effects of pesticides to honey bees.
To further the Agency’s characterization of effects to pollinators, the PPT will work with stakeholders and researchers to improve testing protocols for pollinator toxicity studies required under the Agency’s pesticide data requirement regulations. While the current battery of tests provide information on the potential contact toxicity of pesticide residues on plant surfaces from foliar application, reliable measures of the potential toxicity to honey bees from systemic pesticides are needed. Besides developing testing protocols for systemic pesticides, PPT members will also be examining existing protocols to ensure that they more fully capture potential sublethal and chronic effects of pesticides to adult honey bees and brood. Finally, the PPT will explore the feasibility of convening workshops to develop a risk assessment process for honey bees, and to identify the data necessary to inform this process.
Goal 2: Improve Risk Management Tools for Mitigating Potential Risks to Pollinators
Another PPT goal is to develop management tools that will balance the benefits of pesticide use with their impacts on pollinators. This includes working with various federal partners, NGOs, and other stakeholders. With respect to pollinators, exposure and toxicity studies submitted to support the registration of pesticide products are used to develop bee precautionary statements/warnings on pesticide labels. Based on the Agency’s experience with label language and effected stakeholders, the Agency believes that the idea of “one size fits all” approach does not work for bee labeling statements. Therefore, an important area of work for the PPT will be developing improved label language that is designed with stakeholder feedback which is clear and enforceable. As part of its strategy to improve risk management tools, the PPT will examine the entire range of current mitigation options such as best management practices (BMPs), and Integrated Pest Management (IPM) techniques. Through its efforts, this workgroup will build a toolkit of effective mitigation measures for protecting pollinators.
An important part of mitigating risk to pollinators is managing the way in which pesticides are applied in the field. Working with advisory groups (e.g. Pesticide Program Dialogue Committee and the State-FIFRA Issues Research and Evaluation Group), partners, and stakeholders, PPT members will examine the current guidance for pesticide applicators and explore more effective guidance and application techniques to reduce potential pesticide exposure to pollinators. The PPT will also work closely with the states and other federal partners to investigate the feasibility of education initiatives such as incorporating competency standards and guidance for pollinator protection into the pesticide applicator certification regulations and training manuals.
Goal 3: Increase and Broaden Collaboration and Communication with Governmental and Non-governmental Organizations and the Public in Addressing Pollinator Issues
Collaboration and communication with our domestic and international partners and our stakeholders are key to enhancing our ability to protect pollinators. Through continued meetings with interest groups, registrants, states, regions, other federal agencies, and international regulators, OPP can become better informed of the issues/concerns facing these organizations and provide them with better information concerning our programs for protecting pollinators. In implementing this goal, the PPT will establish a workgroup to explore new options for reaching its stakeholders and the public through such mechanisms as list serves, outreach materials, scientific meetings, and news outlets.
To minimize the impact of pesticides on pollinators, collaborations will include various mechanisms for increasing and improving the adoption of IPM, and reduced risk pesticides as well as other measures such as habitat conservation through USDA’s Conservation Reserve Program. The Team will also pursue opportunities for technical assistance and training of agricultural pesticide users.
Because many of the issues associated with pollinator declines occur at the local level, communication and cooperation between beekeepers and growers/applicators are critical in protecting pollinators from potential adverse effects of pesticides. For this reason, the PPT will work with states and regions to evaluate and enhance the infrastructure for beekeeping operations, including hive registries and notification procedures, and will work to encourage local partnerships or agreements among beekeepers, growers, and pesticide applicators. As communication is always a critical component of success, the PPT will strive to communicate with all its partners and stakeholders on all these many issues and efforts with the goal of transparency, balance, and inclusion.
1National Academies Press, Washington, D.C, 2007.
2USDA, available at http://www.ars.usda.gov/is/br/ccd.