The fatal flaw of the EPA and the decline of the honeybee

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"Hey hey, ho ho, Monsanto has got to go!"

A long line of protesters snaked its way down Mill Avenue in Tempe, Ariz., last month, wearing bee costumes and holding signs identifying Monsanto as the target of their ire. Protests in the U.S. were held from Portland to Texas, as part of a recurring series of worldwide "Marches Against Monsanto."

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Participants aren't militant leftists, fringe radicals, anti-science freaks — stereotypes some would like you to believe. Those in Tempe appeared to be a mish-mash of local citizens: parents pushing strollers, kids skipping along holding signs, young couples, students and professionals, cheering loudly as drivers enthusiastically honked their support. This is a movement of concerned citizens who suspect that their interests are going unprotected in decisions about how their food is grown, processed, regulated and labeled.

A recent study from the Harvard School of Public Health adds to a growing body of evidence that agricultural chemicals, especially a class of systemic pesticides called neonicotinoids, are primarily to blame in colony collapse disorder (CCD) — the name given to the alarming ongoing disappearance of bee populations.

Researchers were able to reproduce colony collapse in hives dosed with low levels of imidacloprid, compared to healthy control hives that were not dosed. The dosed hives were still fine after 16 weeks, but after 23 weeks, 15 of the 16 hives had collapsed. This indicates the destructive effects of the pesticide delayed over time, which go overlooked in studies performed by chemical companies in order to get their products approved by the Environment Protection Agency (EPA).

It isn't just bees that are harmed by the chemical intensive agriculture that defines food production in the U.S. and much of the world. Research on one of the most widely used agricultural herbicides, Roundup, links it to a number of human health disorders, including birth defects and non-Hodgkin lymphoma.

Focusing protests on Monsanto, though, fails to call out the systematic failure of the EPA (and of course the U.S. Department of Agriculture and the Food and Drug Administration for the same reasons) to protect consumer interests across a range of issues. It is natural for corporations — whose primary interest and responsibility to shareholders is to maximize profits — to expand their market reach and political power within the limits of the system. The rules of the game — how we regulate and monitor corporations, the rights and limits that we grant them in society — contribute greatly to their tendency toward doing harm or good. This is why regulatory agencies must become the central focus of those interested in protecting themselves from the likes of Monsanto.

It isn't a single instance or two where the agency has failed to protect the public. Rather the norms of regulation and narrowly conceived "sound science" approach to regulation broadly enshrined in U.S. regulatory practices lead predictably to outcomes that result in repeated negative environmental and health consequences.

An excellent example of how the narrow conception of sound science bears on EPA regulation is the recent experience of University of California, Berkeley researcher Tyrone Hayes, who was harassed by Syngenta for researching the toxic properties of atrazine. The EPA has repeatedly ignored his results on the basis that his research is not sound science.

According to Rachel Aviv's New Yorker profile of Tyrone Hayes, the Data Quality Act, passed in 2000, "requires that regulatory decisions rely on studies that meet high standards for 'quality, objectivity, utility, and integrity.'" This language was proposed by the Center for Regulatory Effectiveness, which is run by lobbyist and Syngenta consultant Jim Tozzi. This is the same center that petitioned to have Hayes's findings dismissed. Industry lobbyists are repeatedly effective in getting studies that counter their claims for the safety of their products thrown out on this basis.

While the phrase "sound science" sounds on the surface like a responsible strategy for decision-making, it masks a framework that systematically excludes the use of a precautionary framework based on all available evidence to prevent environmental and public health crises, and is promoted and defended by major industries that regulatory agencies are meant to regulate.

Scholars Daniel Lee Kleinman and Sainath Suryanarayanan find bee science and EPA chemical regulation severely limited in a number of ways that they term the "social production of ignorance." This self-imposed ignorance is produced by a number of factors that combine to create a narrow, impractically limited body of "legitimate" knowledge surrounding the issue of colony collapse disorder.

They emphasize the narrow conception of legitimate scientific evidence that focuses on the isolation of variables and the immediate toxicological effects of agrochemicals, systematically limiting our ability to gain knowledge about complex interactions between factors such as disease, mites and chemicals that occur in the real world. This approach also limits understanding of the longer-term effects of chemicals like neonicotinoids, which are engineered intentionally to persist at low levels across time, rather than having a single, sudden deadly effect.

Additionally, researchers are systematically encouraged to produce conclusive evidence, thus the kinds of research projects they design and the kinds of results they pay attention to become more and more narrow. For this reason, research that takes into account complexity, time and variable interaction — research that is more applicable to real-world situations in which CCD occurs — remains largely undone. When it is undertaken, it is often discredited — by organizations such as the Center for Regulatory Effectiveness — as falling outside of the bounds of sound science, and thus cannot be taken into account in the EPA's regulatory decision-making processes.

Kleinman and Suryanarayanan also emphasize the wealth of important knowledge systematically established by beekeepers that is ignored in this narrow interpretation of legitimate evidence observed by regulatory agencies. A position they eloquently defend in a 2013 Guardian article on the same topic.

In order to fulfill its mission, the EPA must be empowered to use a broader body of evidence than the strictly limited available evidence allowed under “sound science.” The approach must be precautionary and comprehensive, allowing for consideration of all available evidence.

Doezema is a Ph.D. student in the Consortium for Science, Policy & Outcomes at Arizona State University. She studies politics, communication and biotechnology.

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