The Center for Regulatory Effectiveness (CRE), a regulatory watchdog, has performed a Data Quality Analysis (DQA) on the European Food and Safety Authority’s (EFSA) report on neonicotinoids, in which EFSA concluded that neonicotinoids pose a risk to bees. Specifically, on January 16, 2013, EFSA published a report that identified a number of risks posed to bees by three neonicotinoids: clothianidin, thiamethoxam, and imidacloprid. Only two weeks after publishing the report the European Commission moved to implement a two-year ban on the use of the clothianidin, thiamethoxam, and imidacloprid.
Although the DQA does not apply to EFSA or the European Commission, the CRE has conducted a DQA analysis on the EFSA report to demonstrate the significant data deficiencies in the report. Specifically, the EFSA report failed to maximize the objectivity of the data by failing to reconcile numerous studies that had opposite conclusions of the EFSA report. In particular, the EFSA report did not address the following studies: (1) the varroa mite studies; (2) Dr. James Creswell’s Report “Comment on a ‘Common Pesticide Decreased Foraging Success and Survival in Honey Bees”; and (3) the UK’s Department for Environment, Food and Rural Affairs recent studies and findings on neonicotinoids.
The enclosed report outlines the serious DQA deficiencies in the EFSA report on neonicotinoids. Accordingly, the EPA cannot adopt the substance of the EFSA report without violating the DQA.