The public may think pesticides are only allowed onto store shelves and for use in agriculture and into consumer products if they have been approved by the U.S. Environmental Protection Agency (EPA) in a transparent and scientifically rigorous process. Recent investigations by the Natural Resources Defense Council (NRDC), however, reveal a deeply flawed system, indicating that the public's trust is misplaced.
NRDC spent several years examining federal government data and interviewing key officials, and has determined that the government has allowed the majority of pesticides onto the market without a public and transparent process and in some cases, without a full set of toxicity tests, using a loophole called a conditional registration. In fact, as many as 65 percent of more than 16,000 pesticides were first approved for the market using this loophole. This issue brief explains how the conditional registration program differs from full registration and provides case studies of two pesticides -- nanosilver and clothianidin -- to show how the conditional registration has been misused.
The case of nanosilver, approved by the EPA as an antimicrobial agent in textiles, highlights the ways that some new pesticides can obtain a conditional registration without thorough toxicity testing to evaluate risk. The case of clothianidin -- a pesticide that is designed to be absorbed into plant tissue but is then unintentionally passed on to bees and other pollinators, and consequently is linked to widespread bee deaths -- illustrates the types of problems that may arise after a pesticide has been conditionally approved, and are often hidden from public scrutiny. Finally, NRDC has found significant shortcomings in the EPA's data-gathering system. We cannot determine how many pesticides were first conditionally approved, allowed onto the market, and then lingered there for years while toxicity testing data was being submitted; or how many pesticides were subsequently withdrawn for various reasons; or how many were given full registration.