April 8, 2015 3:12 PM
Today, the Competitive Enterprise Institute published my paper on the honeybee health issue and pesticide use. We have had several media outlets ask, why is CEI focused on the honeybee issue now? If you read this blog, you know that I have been writing about pesticides and their impact on public health and well-being for at least a decade and a half.
CEI selects issues based on our goals to promote freedom and prosperity, using the market to advance public health and well-being. I focus on chemicals, which I believe are under appreciated and misunderstood market-generated technologies that advance human well-being. My work on pesticides has focused on allowing strategic uses to control disease carrying vermin such as mosquitos and ticks as well as the benefits and importance of crop protection chemicals for producing a stable food supply.
But I have another agenda when it comes to honeybees. As long as I have owned a piece of land, I’ve poured my heart and soul into my wildlife garden. While other people complain and look for regulations and government intrusions, I’d rather be part of the solution. And when it comes to public policy, we won’t help pollinators unless we use science and reason rather than alarmism-driven, anti-technology agendas.
That said, there are things that private parties can do to help honeybees, and other wildlife, without asking big brother to ban valuable technologies. Consider what I’ve done to my yard.
When I first moved in, the grass grew up to the house, and I barely saw a bird or butterfly. With lots of digging and effort, my yard is now a destination for myriad butterflies, bumblebees, and bugs I can’t even name. It’s also a favorite destination for all kinds of birds, from hummingbirds to finches and mockingbirds to crows and mourning doves. I even periodically see a crazy beautiful moth called the clearwing hummingbird moth. This amazing little creature really does look like a hummingbird! The feeders in the backyard attract a wide array of birds as well.
So, for those people who want to help the honeybee, consider growing some plants that will benefit them, whether it’s in your yard or simply in flower box. Habitat is critically important for these creatures. Here are some plants that do well in my Virginia garden. Why not try them in yours?
April 1, 2015 1:59 PM
At recent hearings on the the Frank R. Lautenberg Chemical Safety for the 21st Century Act (S. 697), senators, environmental activists, and local government officials claimed that the Toxic Substances Control Act (TSCA) law is not sufficient protect public health. As I have argued before, that’s certainly not the case.
There may be an economic reason to reform this law—to preempt a growing patchwork of nonsensical state-level consumer product regulations—but there’s no legitimate “safety” reason for reform.
Still, activists and some members of Congress at the hearing complained that TSCA’s risk standard has prevented the EPA from banning “a known human carcinogen,” i.e., asbestos. Cosponsor of S. 697 Senator Tom Udall (D-N.M.) exclaimed at the hearing, “I think we all agree: TSCA is fatally flawed. It has failed to ban even asbestos.”
Activists and members of Congress point out that EPA failed to address asbestos in part because TSCA requires EPA to pick the “least burdensome” regulation to achieve its goals.
But how can that be a bad thing? Shouldn’t we want to achieve our goals at the lowest costs? It doesn’t say EPA should pick a regulation that is less safe; rather, it says that EPA should simply pick a less expensive means to meet the safety goal.
That requirement is part of TSCA’s robust risk standard that holds regulators accountable and prevents them from passing rules that do more harm than good. Under TSCA, EPA may regulate when the agency finds that a chemical may pose an “unreasonable risk of injury to health or the environment.” This standard requires weighing the risks of the chemical against the risks of the regulatory action.
People who use the asbestos case to push TSCA reform are either grossly misinformed about the case or they are simply being disingenuous. It is true that the rule was thrown out by a federal court in part because EPA did not bother to find the “least burdensome” approach to meet its goals. In addition, the court pointed out that the rule might have produced more deaths than theoretical lives saved. Accordingly, this is not a TSCA failure, it’s a life-saving success!
March 26, 2015 2:23 PM
Dan Nosowitz in Modern Farmer offers some insights on the recent class action lawsuit filed against California winemakers. The plaintiffs found that some inexpensive wines contained arsenic at levels exceeding the federal drinking water standard for this substance. Nosowitz rightly points out that the standard is for water, not wine and “people don’t, or shouldn’t, drink as much wine as water.”
Well, let’s not go that far… kidding of course! Moderation is surely a good idea when it comes to alcohol consumption. Yet even if you drank as much wine as you do water, there’s still no reason to be alarmed about arsenic. The levels in wine are still too low to have any significant adverse impacts, and ironically, such small amounts might even have health benefits.
Arsenic is an element that naturally occurs in the earth’s crust, so traces of arsenic inevitably appear in food and water. Certainly, high levels of arsenic are not healthy and concentrated exposures can be immediately deadly. But the trace levels found in water and food are rarely an issue. Problems have emerged primarily in developing nations like Bangladesh where poor people drink from untreated water sources with arsenic levels that range in the hundreds of parts per billion (ppb), and sometimes more than 1,000 ppb.
It’s worth noting that the levels allegedly found in wine are reportedly just five times greater (or 500 percent higher as noted in the press) than the federal drinking water standard of 10 ppb. So, some number of samples—we don’t know how many—tested by the plaintiffs in this case had some level of arsenic near the 50 ppb level. But did you know that until 2006, that was the allowable level in drinking water in the United States and it had been for decades?
The U.S. Environmental Protection Agency (EPA) changed the standard to 10 ppb in 2001 with full compliance not required until 2006. The 10 ppb standard for arsenic in drinking water is excessively overcautious. When EPA proposed it, it was very controversial because the cost to small drinking water systems was substantial and the benefits highly questionable. EPA’s Science Advisory Board highlighted lots of problems with EPA’s science and maintained that the change could actually undermine public health. The SAB explained that the costs might cause some small communities to disconnect their water systems, forcing people to use untreated well water, but EPA finalized the rule anyway.
If you look at the history, you can see that EPA did not change the standard for safety reasons; they did it for political ones. You may remember, environmental activists attacked the Bush administration for taking time to reconsider changing the standard, which the Clinton administration rushed out during the final hours of the Clinton presidency. Green groups made it sound like the Bush administration was adding arsenic to the water supply. And this bad press made a rational and scientific debate impossible.
March 19, 2015 1:57 PM
James Mills of the National Institute of Child Health and Human Development lamented in an article in the New England Journal of Medicine back in 1993: “‘If you torture your data long enough, they will tell you whatever you want to hear’ has become a popular observation in our office. In plain English, this means that study data, if manipulated in enough different ways can prove whatever the investigator wants to prove.”
Government regulators will resort to such data torture to justify an activist regulatory agendas if they can’t do it with good data and sound science. One approach includes selective use of data—excluding years or datasets that might change the conclusions of a risk assessment. The Consumer Product Safety Commission’s recent Chronic Hazard Advisory Panel (CHAP) report on the chemical class known as phthalates offers one new example of excluding inconvenient data.
In short, the CHAP report is being used to justify a proposed rule that would essentially ban the use of certain chemicals for toys that children might mouth or chew. These chemicals make plastics soft and pliable, suited for such things as a plastic version of a “rubber duckie.” For background on this issue, see my other blog posts here and here.
In addition, in the absence of any compelling body of data that any individual phthalate is the cause of human health effects, the panel relied on the possibility that the cumulative effects of phthalates as a class pose risks. Accordingly, they needed data on human exposure from all sources.
The panel developed a “cumulative risk assessment” that they maintained justified regulations. But pharmacologist Christopher J. Borgert, Ph.D., observes in a review of the CHAP report that the panel’s cumulative risk assessment: “failed to recognize obvious inconsistencies with human experience and clinical evidence”; “overstates the accuracy of its cumulative risk methods and conclusions”; and “appears to have grossly overestimated chemical potencies.” In other words, the panel failed to properly apply the available data and research.
To make matters worse, they used old and irrelevant data for their human exposure assessments even though more accurate and recent data was available. Former and current CPSC commissioners have noted that had the panel used the most recent data, their risk assessment would have produced the opposite result. This issue raises the prospect that the panel members were intentionally “selective” in their use of data because they desired to generate a particular conclusion, as appears to be the case with their selection of studies that they also reviewed.
March 18, 2015 2:00 PM
Many “stakeholders” have complained about the process through which the Consumer Product Safety Commission (CPSC) developed its proposed rule related to a class of chemicals called phthalates—and rightly so. In particular, the agency’s failure to allow public comment and open peer review of its Chronic Hazard Advisory Panel report (CHAP report) underscore the fact that bureaucrats want to avoid scrutiny that might hold them accountable for rash and unscientific decisions.
Designed to make plastics soft and pliable, these chemicals have many valuable uses for making a wide range of products from blood bags, to rain boots and swimming pool liners as well as children’s toys, which are the subject of this regulation. Safely used for decades, activists and regulators are poised to essentially throw away these valuable technologies based largely on junk science.
While this rule only affects toys that children might place in their mouths or chew, it sets a terrible precedent. I already detailed how this rule might harm consumers in a blog post last week. Now let’s look at the so-called “science” behind it.
The justification for the proposed regulations are found within the CHAP report, which is a review and risk assessment that the agency released in July 2014. A key problem stems from the fact that the CHAP report relies on a selective review of limited studies that offer scant evidence that individual phthalates or cumulative exposure pose any significant risk to humans at current exposure levels.
Most of the CHAP-report-identified “evidence” that these chemicals pose health risks comes from lab tests that over-dose rodents to trigger health effects. Such tests are not particularly relevant to humans that better metabolize the substance and who are exposed to traces that are multitudes lower.
The human research highlighted in the CHAP report is not particularly compelling either. Many of these human studies are noted to be “small,” which limits their value for drawing any conclusions. And many of them report associations between potential health effects in babies whose mothers’ phthalate exposure levels were measured in single “spot” urine samples during pregnancy. Given that humans metabolize phthalates relatively quickly, one time spot measurements may be misleading about actual exposures, raising important questions about the utility of such studies.
March 13, 2015 8:58 AM
On Monday, the Consumer Product Safety Commission will close the comment period for a proposed rule related to chemicals used to make soft and pliable plastics. While they claim to do this in the name of children’s health, it’s not clear that the rule will do more good than harm.
The process and the “scientific” review that brings us to this proposed rule has been controversial, to say the least. I detail some of those issues in comments that I will submit on Monday and will post some of that here on Monday as well.
Unfortunately, not enough attention has focused on the fact that the agency-commissioned study—referred to as the Chronic Hazard Advisory Panel (CHAP) report—failed to fully consider the potential implications of substitute products that will replace those they ban.
Before initiating a rulemaking that may remove chemical technologies from the marketplace that have been safely used for decades, CPSC should consider whether replacement products pose greater risks. The CHAP allegedly addresses replacement products by reviewing data on the potential environmental health effects of other chemical substitutes. But the CHAP did not address whether or not the substitutes that might actually win a place in the market would affect product performance in ways that help or harm public health and safety.
The rule should ensure net safety, considering all factors. It is incumbent that regulators don’t inadvertently increase risks with short-sighted decisions. Based on the CHAP, we lack reasonable assurance that regulatory action will increase net safety and, in fact, such actions might accidentally introduce new hazards and even greater public health and safety risks.
December 15, 2014 11:27 AM
As reported in a blog post by David Zaruk, some of the “science” on the impact of neonicotinoid pesticides on honeybees appears to have resulted from a pre-orchestrated campaign, rather than an unbiased scientific process. The researchers involved are members of the International Task Force on Systemic Pesticides, which is part of the International Union for Conservation of Nature (IUCN).
The task force was ostensibly set up “to bring together through research an integrated assessment of the worldwide impact of systemic pesticides on biodiversity and ecosystems, based on articles published in peer-reviewed scientific journals.” But Zaruk explains that he discovered a document indicating that the effort was more political than scientific.
The document summarizes a workshop held at the University of Paris back in 2010 at which task force members outlined a strategy designed to make the case that neonicotinoids do in fact harm bees—drawing that conclusion before completing an unbiased, scientific assessment. To that end, it appears that they planned out where they would place studies condemning the chemicals to gain political impact, rather than exploring how they would critically review the body of research.
IUCN is in fact an activist group, so their desire to undermine chemicals is not all that surprising. But this case does show how activism has permeated scientific research, confusing the world about the state of science on many issues. While we all have opinions, there needs to be a clearly defined line between policy goals and scientific research.
As Zaruk notes: “[N]o credible scientist starts with a campaign strategy and then conjures up some evidence as an afterthought to fit his or her activist agenda. That is not science!”
Indeed, legitimate scientific discovery requires that researchers try to keep their biases in check, rather than plan studies and placements to garner a desired political objective. In fact, researchers are supposed to begin with a hypothesis and conduct experiments aimed at disproving that hypothesis. So researchers do not leap to conclusions too quickly, scientists are trained to search extensively for reasons to reject their hypotheses. That means that rather than try to prove their theory, they act as a sort of devil’s advocate, attempting to show no effect. In that case, biases may be kept in check and positive associations should be more robust.
November 24, 2014 9:58 AM
As the Ontario provincial government in Canada considers policies that may force farmers to stop using, or drastically reduce use of, a class of pesticides called neonicotinoids, a new study shows why such policies are unlikely to do any good. Supposedly, limiting use of these pesticides will improve honeybee hive health, but such regulations will simply make it harder for farmers to produce an affordable food supply.
The study, which relies on data from actual field conditions, confirms that farmers can protect their crops using these chemicals without harming honeybee hives. Published in PeerJ, it assessed the impact of neonicotinoid-treated canola crops on hives that foraged among these crops in 2012. The researchers found no adverse impacts and very low exposure to the chemicals. The authors report:
Overall, colonies were vigorous during and after the exposure period, and we found no effects of exposure to clothianidin seed-treated canola on any endpoint measures. Bees foraged heavily on the test fields during peak bloom and residue analysis indicated that honey bees were exposed to low levels (0.5–2 ppb) of clothianidin in pollen. Low levels of clothianidin were detected in a few pollen samples collected toward the end of the bloom from control hives, illustrating the difficulty of conducting a perfectly controlled field study with free-ranging honey bees in agricultural landscapes. Overwintering success did not differ significantly between treatment and control hives, and was similar to overwintering colony loss rates reported for the winter of 2012–2013 for beekeepers in Ontario and Canada. Our results suggest that exposure to canola grown from seed treated with clothianidin poses low risk to honey bees.
Despite all the media hype about how these chemicals harm honeybees, these findings are not surprising. Research condemning these chemicals has tended to focus on lab studies that overdose bees to see if pesticides affect hive health. But those studies have little relevance to real-life exposure to these chemicals in the field. The U.S. Agricultural Research Service’s Kim Kaplan explains that such studies have “relied on large, unrealistic doses and gave bees no other choice for pollen, and therefore did not reflect risk to honey bees under real world conditions.”
October 20, 2014 9:52 AM
Butterflies offer powerful imagery for environmental groups looking to advance their agendas. After all, who doesn’t want to save these beautiful creatures? Surely green activists could leverage those desires to advance voluntary efforts to create butterfly habitat. But the actions of some groups indicates that they would rather exploit the butterflies to gain policy victories in Washington, even if the butterflies suffer as a result.
Conservationists rightly point out that monarch butterflies face challenges associated with habitat loss because there are not enough of the type of plants that they need for food and reproduction. In particular, these creatures feed and reproduce among milkweed, a flower that many people consider to be nothing more than an undesirable weed. As a result, farmers, homeowners, and other property owners have removed these plants, leaving less habitat for the butterflies.
Part of the solution is rather simple: educate people about the value of this plant. If we can transform what people think about it, we might just get more individuals to plant it rather than pull it up.
A massive educational campaign pushed by environmental groups, which collectively have tens of millions of dollars at their disposal, could make the critical difference. Some groups are working this angle, but too many others would rather spend the money to lobby for more government controls on businesses and property owners.
The green lobby’s agenda includes suing the U.S. Environmental Protection Agency to prevent approval of a new herbicide formulation because they say it will enable more destruction of milkweeds. They are also calling for the listing of the monarch butterfly under the Endangered Species Act (ESA). It may be counterintuitive, but both actions may actually undermine butterfly habitat and contribute to its demise.
August 13, 2014 4:14 PM
If you read the news about honeybee survival, it’s all very confusing. Some sources sound the alarm by pointing out that the number of honeybee hives has dropped significantly in recent decades. Others say just the opposite: There are more hives today than ever before.
Which is it? Actually, both. Some regions of the world have fewer hives, while globally there are more commercial hives now than there were in 1960. The key here is to understand which dataset is more important to the debate about sustaining these helpful creatures.
The Hoover Institution’s Dr. Henry Miller notes in a Wall Street Journal op-ed: “The reality is that honeybee populations are not declining. According to U.N. Food and Agriculture Organization statistics, the world's honeybee population rose to 80 million colonies in 2011 from 50 million in 1960.” Meanwhile Jennifer Sass of the Natural Resources Defense Council responds in a letter to the editor: “The number of managed honeybee colonies in the U.S. has dropped from four million hives in 1970 to 2.5 million today, according to White House statistics.”
Surprisingly, both of these claims are correct. Miller points to the “global” commercial honeybee-hive count, which has grown considerably. Sass points to domestic colony numbers only, which have in fact declined.
Miller’s numbers are more relevant because if honeybee survival is really at stake, we would see declines on a global scale. Miller also points out that U.S. and European hive numbers are relatively stable, and Canadian numbers increased. Miller is certainly correct to point out that honeybees are not about to disappear.