Center for Regulatory Effectiveness Comments on Emergency Petition to Suspend Clothianidin
In evaluating the petition EPA must ensure that all data and reports to support the petition that EPA considers and relies on comply with the Data Quality Act (DQA). Moreover, section II of this comment outlines studies used by the petitioners that are clearly not compliant with the DQA and therefore EPA shall not consider the studies in evaluating the petition.
Finally, a substantial number of recent scientific studies conclude that Varroa Mites are the major cause of bee health decline, not clothianidin. Consequently there is no basis for suspending the registration of clothianidin.