Sulfoxaflor: Response to Public Comments on EPA’s “Proposed Registration of the New Active Ingredient Sulfoxaflor for Use on Multiple Commodities, Turfgrass, and Ornamentals” (Docket # EPA-HQ-OPP-2010-0889)

Beyond Pesticides’ comment (Docket # EPA-HQ-OPP-2010-0889-0384): Once again EPA is proposing to repeat missteps of the past by registering a pesticide known to be toxic to non-target organisms without all required data to ensure its safety. As already seen with the neonicotinoid, clothianidin, and the herbicide aminocyclopyrachlor (Imprelis®), conditional registration without relevant ecological data can be detrimental to non-target species. It was pointed out to the agency in previous communications, risks to honey bees far outweigh any economic, social or environmental benefit of conditional registration, given that the honey bee has a $15 billion impact on the agriculture sector and that millions of dollars are at stake for commercial beekeepers, not to mention the economic and environmental costs to native, wild pollinators.