Talk:Clothianidin/Archive 1

old comment
Pflanzenschutzmittel Schuld an Bienensterben --Stone (talk) 21:29, 16 May 2008 (UTC)

Germany
It appears to have had a very profound effect in that region. Dysmorodrepanis (talk) 22:08, 10 November 2008 (UTC)

I've taken a look at this text Bienensterben This is from the German Consumer Protection / Food Administration.
 * Hintergrundinformation zu den lokal aufgetretenen Bienenschäden in Süddeutschland


 * Bei den ersten Untersuchungen der Bienenschäden in Baden-Württemberg deutet sich nun an, dass pneumatische Sämaschinen je nach Konstruktionstyp eine erhebliche Staubabdrift mit Wirkstoffabrieb verursachen, die möglicherweise zu einer Clothianidinbelastung der Bienen führen können und für die Schäden verantwortlich sein könnten.


 * Nach dem aktuellen Stand der Erkenntnisse empfiehlt das BVL als Sofortmaßnahme, Bienenstöcke aus dem näheren Umkreis von Flächen zu entfernen, auf denen clothianidinbehandelter Mais ausgesät wurde oder noch wird. Anwender, die noch Mais aussäen, sollten vorzugsweise Geräte einsetzen, deren Abluft in den Boden abgeführt wird. Bei pneumatischen Geräten, deren Abluft nach oben oder zur Seite abgeführt wird, sollte am Abluftkanal ein Schlauch so angebracht werden, dass der Luftstrom bodennah austritt.


 * Unabhängig davon, ob sich Clothianidin letztlich als verantwortlich für die Bienenschäden erweist oder nicht, wird das BVL diese Erkenntnisse zum Anlass nehmen, sich mit der Staubabdrift von pneumatischen Sämaschinen zu befassen, im Zusammenhang damit gegebenenfalls Neubewertungen von clothianidinhaltigen und anderen Saatgutbehandlungsmitteln vorzunehmen und wenn nötig die Zulassungen zu modifizieren.

Rough translation:
 * It seems pneumatic seed sowing machines can cause significant dust clouds, which may contain active components. These dust clouds may increase the Clothianidin concentration bees perceive and could be responsible for the deaths.


 * We recommend removing immediately all bee colonies from the neighbourhood of fields where Clothianidin-treated corn (maize) is, or will be, planted. Users of Clothianidin who wish to plant corn should use sowing machines with an underground air exhaust. Piping should be added to pneumatic sowing machines with a topside or sideways air exhaust to divert the air close to the soil.


 * Irrespective of whether clothianidin is responsible for the bee deaths, the BvL (=German Consumer Protection / Food Administration) will investigate dust clouds caused by pneumatic sowing machines; any side effects of clothianidin and other seed treatments, and will modify usage permits if needed.

I provide this translation merely as a pointer to potentially interesting information. Perhaps it would be interesting to ask the guys of the German Wikipedia their opinion? 88.19.80.247 (talk) —Preceding undated comment added 13:13, 13 December 2010 (UTC).

Incorrect formula?
The structural formula shown appears to be incorrect. The NO2 group and the methyl group are transposed. As an example, see WO2006/069655, page 2. 192.188.71.2 (talk) 05:09, 16 September 2010 (UTC)
 * The two are just different tautomers of the same chemical compound. —Preceding unsigned comment added by 148.177.1.212 (talk) 21:18, 12 January 2011 (UTC)

Balance
In my opinion, this article needs some reorganising and rewording for balance. It should be mentioned that the EPA memo was leaked, and the published position of the EPA should be quoted, and other scientific summaries of the memo on both sides of the debate should be given.

Lengthy descriptions of risks should be moved to a "Risks" section, and merely summarised in the lead.

I may attempt some changes later.

--InfantGorilla (talk) 08:14, 19 January 2011 (UTC)


 * Yes I agree. I made some additions yesterday and then realized that I had messed up the lede.  I planned to move the information box up (though could not figure out how to do it) and add some more information other than just the information about the danger to bees. It is good to have some help. Gandydancer (talk) 12:29, 19 January 2011 (UTC)

"Takeda Chemical Industries"
Takeda Pharmaceutical Company ? --Jerome Potts (talk) 12:13, 19 January 2011 (UTC)
 * TCI is a chemical company with broader business than just pharmaceuticals (see for example http://tciamerica.com which sells laboratory chemicals in the US), so Takeda Pharmaceuticals is probably some type of subsidiary of TCI. —Preceding unsigned comment added by 96.227.89.95 (talk) 13:09, 19 January 2011 (UTC)

EPA allows this toxin but it doesnt mean states cant ban it themselves
Too many times people and organizations in "america" always assume that they can only go to the federal government to change any significant laws.. so what if the PEOPLE at the EPA refuse to be responsible like france and germany and ban it, it doesn't mean that each individual STATE in the union cannot ban it!! Each state has the right to enact local laws that would BAN this horrible pesticide that is killing all of our bees, and probably all of us people too! Even undetectable amounts of it are destroying the bees immune systems. And detectable levels of this toxin have been found INSIDE american grown fruits and vegetables (not ON them, *IN* them), so who is to say that this stuff won't weaken and destroy a human's immune system too? thourough and comprehensive tests havn't even been done yet, and most other tests that were done were done by the biased manufacturers themselves!

To all governors of all states, especially those of california and florida: take action now to ban and illegalize this pesticide immediatly!

(ref: http://www.independent.co.uk/environment/nature/exclusive-bees-facing-a-poisoned-spring-2189267.html#disqus_thread) — Preceding unsigned comment added by Gawdsmak (talk • contribs) 08:44, 14 March 2011 (UTC)

Article
http://www.fastcompany.com/1709448/interview-with-a-bee-leaker-beekeeper-tom-theobald-discusses-the-epas-bee-toxic-pesticide-co Ocaasi c 02:49, 1 April 2011 (UTC)

How this pesticide is used.
The article states that "Clothianidin is absorbed by plants and then distributed in pollen and nectar, killing pests." This is actually not the intended use of the product. It's meant to kill chewing and sucking insects that attack the roots, stems, and leaves of the plants. Getting into pollen and nectar is a side affect. It actually kills beneficial insects, such as bees, in this manner. There are some exceptions as there are certain pest insects that also eat pollen, but this is definitely not the 'main' use for which this product or class of chemicals was designed. —Preceding unsigned comment added by Loki-dog (talk • contribs) 14:31, 13 May 2011 (UTC)

Proposal to almost completely rewrite the clothianidin content
Wikipedia's clothianidin content needs to be rewritten consistent with Foundation policies and guidelines (see WP:NOTGUIDE and WP:CHEMMOS) For comparison to topic headings and content on other pesticide chemical pages see Atrazine or 2,4-D, which I believe are better for providing encyclopedic content on specific chemicals than what we have for clothianidin now.

As currently written, the only content on the clothianidin page that is consistent with Wikipedia policies and guidelines is the chembox and the first sentence of the first paragraph. The second sentence of the first paragraph understates what plant parts are affected by systemic pesticides like clothianidin (for comparison see the description of the systemic nature of neonicotinoids elsewhere on Wikipedia). The second paragraph is entirely too U.S.-centric, especially since this chemical is registered for use as a pesticide in many countries around the globe.

The entire Criticism section is inappropriate, reading like a poorly maintained (and curiously selective) news reader (see WP:NOT). The first paragraph describes an acute poisoning incident in Germany, but the factors the author identifies as contributing to the incident are not inherently related to clothianidin. If a large quantity of insecticide dust was blown into the air on a windy day next to a field of flowering plants on which bees were foraging, it would be unfortunate but not surprising if the bees were acutely poisoned. Acute toxic chemical exposure incidents might be newsworthy, but that doesn't make them appropriate for inclusion on a Wikipedia page for a specific chemical. Per the WP:NOT, this entire paragraph about the German incident should be deleted or, in the very least, relegated to its own page. From WP:CHEMMOS: "Accidents and incidents occur all the time. While their scale and magnitude may merit inclusion in Wikipedia on grounds of notability, that such an accident has occurred is not sufficient justification for inclusion in the context of an article about chemicals.... Historic accidents and incidents may only be contextualized in the discussion on the specific hazards of certain chemicals, without serving as case studies in itself. To reiterate, if such accidents are sufficiently notable, they should have their own article (e.g. discussion in Bhopal disaster, not in methyl isocyanate)."

The Criticism section continues the U.S.-centric content by mentioning a Freedom of Information Act lawsuit against USEPA, another news item, but failing to mention that EPA responded to the records request as required by law, informing the complainant within 20 days of its request that, owing to the extensive number of records it requested, EPA would need additional time to prepare the records for release. Ultimately, EPA produced thousands of pages of regulatory records and environmental effects data in response to the 2008 Freedom of Information Act request. There was never a Court order requiring production. NRDC's case was dismissed by stipulation on October 27, 2009. This lawsuit text should be deleted entirely not because it creatively states only certain facts, which could be updated, but because it's old news and irrelevant to clothianidin per se.

The content related to the leaked memo is similarly more appropriate for a newspaper article than Wikipedia. If the concensus is that this content is noteworthy enough for publication in Wikipedia, I would recommend that someone who feels it is sufficiently noteworthy should move it to its own page AND update the content to include the facts USEPA provides about the agency reclassifying this supplemental study. Specifically:

"The reevaluation of the study in question does not change the Agency’s conclusion that the registered uses of clothianidin meet the FIFRA risk/benefit standard for registration. Clothianidin generally poses less risk to agricultural workers and fish and wildlife when compared to the insecticide alternatives." USEPA James (talk) 21:20, 22 June 2011 (UTC)


 * Hi James. Well I wondered when this day would come.  Of course, you are correct - the article, like a lot of Wikipedia articles, does not follow guidelines (and perhaps does not meet standards) at all.  It is the result of many editors sticking information here and there.  Major articles tend to have enough "watchers" to keep the article accurate and well-written.  This one does not.  I have a high degree of interest in children's health and I "watch over" several pesticide articles.  It is my experience that the EPA has been very slow, to say the least, to respond to apparent threats to the health of our children.  I have often suspected that the EPA, like many government agencies, is much too cozy with the corporations that make the many chemicals that our children are exposed to.  For instance, in March 2010 the EPA declared BPA a "chemical of concern", while in truth there is overwhelming evidence of the harm that this chemical is doing to our children.   I just shudder to think that you may go to that article and "improve" it. This sort of thing happens all the time on wikipedia.  I attempted to add information about Jack-O-Lanterns carved from turnips to an article and suddenly found that I needed (almost) peer-reviewed studies to get it in. Why? An editor had taken ownership of a seldom-viewed article and used wikipedia guidelines to revert any edits he did not like.


 * However, you are right about the Germany incident, for instance, and years ago I did my best to research it and found exactly what you are suggesting. But wikipedia editor is not my job, and like most editors  I need to focus my edits.  For me that is on what is often the non-corporation/governmental point of view - I hardly have time to defend the corporate truth as well - especially considering that it is usually not truthful but rather propaganda.  Frankly James, I consider you the enemy, though I consider the EPA less in the pocket of corporate business than most gov't agencies.  If it is your decision to go though all of the Wikipedia articles that the EPA is related to and change them to strictly meet wikipedia guidelines, well then so be it.  So it goes, I guess. Gandydancer (talk) 23:28, 22 June 2011 (UTC)


 * Well, I recommend that you revise the article following following your knowledge, basing the citations on good secondary sources, i.e. reviews and books to the extent possible per WP:SECONDARY. Many if not most of the pesticide articles rely excessively on anecdotal information provided by folks intent on offering advice or "setting the record straight", meaning supporting their perspective. A particular problem attends safety information for chemicals, which is readily Googled and is contributed by do-gooders who are intent on editing but who lack technical knowledge.


 * By digging into one article, you will at least learn something about the culture here, including the degree to which major edits sometimes result in no response because no one is watching or has the technical expertise. Good luck.  --Smokefoot (talk) 02:13, 23 June 2011 (UTC)


 * I second Smokefoot: go for it. Be aware though, that guidelines are just that - not rules - and subsections of WP tend to have their own interpetations and styles. If everything has got decent references, you'll be improving the article. Don't be suprised by the huge amount of vitriol you might encounter; as stated above, you are the enemy. Chris (talk) 09:47, 23 June 2011 (UTC)
 * James, I agree that this article could use a good rewrite. As it currently stands, it seems to put undue weight on specific aspects such as news events, rather than providing a more complete "top level" overview of the subject, which should be the goal of an encyclopedia. -- Ed (Edgar181) 10:47, 23 June 2011 (UTC)

Thanks for the comments, everyone. I apologize for not being bold but do appreciate your input and responses. Gandydancer, before you commit yourself to the notion that I’m your enemy, you might want to learn a bit more about why I’m here.

It appears there is initial consensus, even from my newest self-professed enemy ;-), that the German incident was more of a news story than appropriate encyclopedic content for the clothianidin page. I’ll give this a bit more time to cook over the weekend, then, if no one raises any substantive objections, I’ll delete that text next week as the first incremental edit I make.

Regarding the NRDC lawsuit text, does anyone object to its removal as well? My thought was that updating the lawsuit text to reflect the facts I referenced above would make USEPA look great, but I’m concerned about an appearance of a conflict of interest. I feel the suit was more of a flash-in-the-pan news item and probably didn't belong on the clothianidin page in the first place. Deletion would be consistent with the WP:NOT policy and would help avoid the appearance of COI from me just updating the text. Thoughts? --USEPA James (talk) 21:13, 23 June 2011 (UTC)


 * Hi James. I'm certainly glad you were not Bold - no need to apologize for that!  Being bold does not  mean that it's OK to delete a great deal of information without prior discussion. I wish that I had more time to spend on this article right now but other articles take most of my time right now.  But in brief, I do not agree with  Smoke's assertion that, "Many if not most of the pesticide articles rely excessively on anecdotal information provided by folks intent on offering advice or "setting the record straight", meaning supporting their perspective" at all.  In my experience most editors are intelligent and intent on working for but not pushing their own POV.


 * As to your view that this article should not contain "news" related to this pesticide - that it should be avoided or have its own article, that is not my understanding of Wikipedia policy. For instance, the Germany incident - if this incident actually did result in the German decision to change their laws re its use, I would feel that that is notable information and within the guidelines of Wikipedia policy.  I do not have the time to again research the incident, but it seems to me that my concern was that the news hit the blogs and was widely circulated among the "anti-pesticide" (etc.) people as being factual as the way it was presented by them.  I found that it did not pass the smell test but I  was unable to confirm anything since I don't speak German. Since it is your job to know what is going on, could you please help with some information re the incident?  Did Germany ban or restrict the use as a result of the incident?


 * Please accept our enemy status in the spirit of friendship. Nothing is better for an article than opposing views as long as the editors play fair. Gandydancer (talk) 14:10, 25 June 2011 (UTC)


 * Couple clarifications and a question for James: When you mention all the European countries where clothianidin is registered, you should also note that  Italy, Slovenia and Germany have suspended certain uses of clothianidin and France never registered the pesticide so the reader does not get the false impression that all uses of this pesticide are used everywhere in Europe.


 * Your statement that clothiandin is a safer alternative to the organophosphates and carbamates is not true for pollinators. If you look at EPA and European assessments, you will find that clothianidin is 10-10,000 times more toxic to bees than the organophosphates and carbamates and is much more persistent in the environment.  It is also highly toxic to aquatic invertebrates and small birds.  When you say that clothianidin is safer than other pesticides, it sounds like you are trying to justify EPA’s decision, which is not an appropriate use of  Wikipedia.


 * If an additional pollinator field study is not required for registration in the U.S., why are you asking for this study? --JSimpson55 (talk) 00:08, 28 June 2011 (UTC)


 * I am having some trouble adding my thoughts to the talk page because the EPA rep is conducting the discussion on his talk page as well. Perhaps it would help if I were to add this comment I made on his talk page when it would be best here.  James says on his talk page:


 * 'The formulation of the pesticide clothianidin used to protect seed corn from corn root worm did not include a polymer seed coating known as a "sticker." This coating makes the pesticide product stick to the seed. Although the formulation used in the US also does not require a “sticker” on corn seed, it is typical practice to use “stickers” on corn seed in the US.'


 * I replied: As a matter of fact I have read that although a sticker is advised it actually is often NOT standard practice in the US. To assume that it is suggests that all or most growers go to the added expense and trouble to do anything that is not required by law. Has the EPA done studies so that it may say with integrity that it is actually standard practice? I would think that it should be simple enough to find out if enough sticker is being sold to cover the amt of clothianidin sold. However I do not like this sort of discussion re this article going on here in the back room, so as to speak. This discussion should not be a private conversation conducted on your talk page. Gandydancer (talk) 17:47, 26 June 2011 (UTC) Gandydancer (talk) 02:58, 28 June 2011 (UTC)


 * Gandydancer, on the text you copied from my talk page, those were the issues we at EPA felt were presented in a plainly biased fashion on Wikipedia's clothianidin page. After posting the issues and proposed edits and inviting discussion on my talk page, I dug further into Wikipedia policies and guidelines. It was then that I realized it made more sense to propose here just making the clothianidin page consistent with other chemical pages, the Chemical Project guidelines, and WP:NOT than to edit each biased point tit-for-tat. Which is why you'll notice I'm making suggestions here to delete the old news, since doing so makes all of the biased content moot. I am currently not advocating to make any of the edits I put on my talk page, so it will confuse things if you copy, paste, and then discuss them here.


 * Also, do you have a credible citation for your claim that Germany changed its laws because of the 2008 incident? You seem to be basing your position on an uncited assumption. USEPA has provided the information we gleaned from German pesticide regulatory agency staff on the agency's web page about the incident since shortly after it happened in 2008. We had German-speaking staff at USEPA actually call and talk to our counterparts in Germany, and what's on our web page is what we learned from them. But more to the point, the German incident seems little different from what happened in Bhopal involving methyl isocyanate (ie atypical chemical release resulting in harm), which is referenced in WP:CHEMMOS as an example of inappropriate content on a chemical page. Perhaps you could explain why the details of the 2008 incident in Germany warrants inclusion on the clothianidin page when the Bhopal incident is only noted (and linked) from Wikipedia's methyl isocyanate page.


 * JSimpson55, do you have a reference regarding France never registering clothianidin? Our counterparts in France have informed us otherwise (I just got the email now) and the French pesticide regulatory agency website shows active registrations for pesticides containing the active ingredient Clothianidine, which appears to be an alternate spelling of clothianidin. Sry, but the French site doesn't allow me to link directly. Go to Substances, click "C" and scroll to clothianidine. Specifically, if you scroll down to the table at this translation of one of the French government summary documents, you'll see that the active ingredient in the product Cheyenne is spelled "clothianidin" and it is one of several clothianidin pesticides currently registered in France.


 * I do agree with you that if the registration status in various countries is included it might be best and a more NPOV to include detailed information about registered and disallowed uses as well. I wouldn't object to you adding referenced notes about the status of uses. I would ask that you verify the current status, though, rather than relying on older reports. You also might want to check your sources on the status regularly, because these things seem to change very regularly and new uses are being added all the time. Also, keep in mind that EPA's list of countries in which we know clothianidin is registered is not exhaustive--it basically only covers the EU. A simple internet search shows that it's also registered in, for example, Japan.


 * With regard to the relative risk between different classes of chemicals, discussions of hazard alone can be misleading especially when risk mitigation or environmentally relevant (aka real-life) exposure scenarios are omitted, as you have done. Perhaps the clothianidin page would benefit from a Hazards and Risk Mitigation section, similar to the Hazard section that many other chemical pages use, to include human health and environmental concerns, as well as (in the interest of a NPOV) a summary of the label instructions that are designed to mitigate the concerns. Would you like to help put that together?


 * On your field study question, USEPA's clothianidin status page explains the situation. The bottom line is that even though the registrant has satisfied the fundamental requirements for registration, the agency reserves the right to ask for additional studies to answer questions that might (or in this case, have) come up. The registrant submitted a study that we later realized didn't answer the questions that remain. That doesn't change the fact that, for now, they've satisfied the fundamental requirements for registration. --USEPA James (talk) 21:52, 28 June 2011 (UTC)


 * James, thank you for your reply. You have asked me "do you have a credible citation for your claim that Germany changed its laws because of the 2008 incident? You seem to be basing your position on an uncited assumption."  Please do not misquote me because what I actually said was:


 * 'For instance, the Germany incident - if this incident actually did result in the German decision to change their laws re its use, I would feel that that is notable information and within the guidelines of Wikipedia policy. I do not have the time to again research the incident, but it seems to me that my concern was that the news hit the blogs and was widely circulated among the "anti-pesticide" (etc.) people as being factual as the way it was presented by them. I found that it did not pass the smell test but I was unable to confirm anything since I don't speak German. Since it is your job to know what is going on, could you please help with some information re the incident? Did Germany ban or restrict the use as a result of the incident?'


 * Thank you for your suggestion that I look at your website where I will find the information that I need and please understand how hard it is to find this sort of information for the casual editor. If I remember correctly from the research I did some time ago, the incident was the result of a perfect storm of mistakes and not at all proof that this chemical is harmful when used as recommended.  Never the less, if it did result in a German ban or partial ban, I feel that that information would be notable.  I will look at your site for more information.  As for the other issues that you have brought up, I will comment as I have time to look at them.  Please remain aware that it is unusual to have a editor that represents a government agency posting and a bit overwhelming for the average editor that may be watching over and posting on many articles.  You have had the time, in fact you are paid for the time you have spent while I work for free, so as to speak, to look into the finer dictates of Wikipedia policy.  In my experience Wikipedia guidelines, strictly followed, can often be used to delete content that one particular editor does not like = that is why I mentioned my wikipedia turnip experience.  But as time permits I will look at the policy issues you have supplied and try to understand how they apply to this article.  And again I ask, has the EPA done any studies to see if the sticker is actually being used in the U.S.?  Gandydancer (talk) 00:25, 29 June 2011 (UTC)


 * Thanks for responding, Gandydancer. No, EPA has not done "studies" to see if sticker is being used in the U.S. because doing so would be completely unnecessary and a waste of tax dollars. The fact that "sticker" controls dust in seeding operations is coincidental to it's primary function, which is efficacy: if the pesticide blows off the seed, the plant will be inadequately protected against pests. To confirm what we already knew, we checked with the nation's major seed distributors, agricultural stakeholder groups, and seed treatment registrants, all of which confirmed our belief about sticker use. The registrants even noted that they sell the pesticide and sticker in a "co-pack" to help ensure the efficacy of their products (and, coincidentally, provide an environmental benefit by greatly reducing the possibility of pesticide dust becoming airborne).


 * I'm going to tighten the focus here and will follow up on topic in the sections you've added below. --USEPA James (talk) 19:41, 29 June 2011 (UTC)

Regarding the NRDC lawsuit
It has been suggested that the entire section regarding the NRDC lawsuit be removed. I will quote the suggestion:

Regarding the NRDC lawsuit text, does anyone object to its removal as well? My thought was that updating the lawsuit text to reflect the facts I referenced above would make USEPA look great, but I’m concerned about an appearance of a conflict of interest. I feel the suit was more of a flash-in-the-pan news item and probably didn't belong on the clothianidin page in the first place. Deletion would be consistent with the WP:NOT#NEWS policy and would help avoid the appearance of COI from me just updating the text. Thoughts? --USEPA James (talk) 21:13, 23 June 2011 (UTC)

Yes, I do have concerns. It can not be argued that this is "old news" since most of Wikipedia is "old news". This editor feels that it was just a flash-in-the-pan item, however most news is of the flash in the pan nature - it becomes newsworthy and then after awhile it is no longer newsworthy. To suggest that a deletion would help avoid the appearance of conflict of interest of an EPA employee is very troubling to me. As one of the top contributors to the BP oil spill, I shudder to think how differently the article would read if the Coast Guard, NOAA, the MMS and the EPA could have had this same advantage. I remain very troubled that government agencies are allowed to post to articles in their own name. If that is policy I have no choice but to accept it, but I do feel that it will bring Wikipedia closer to an establishment-controlled encyclopedia rather than a people's encyclopedia. If they even must state, "I want to avoid a COI", is not this problematic? Gandydancer (talk) 16:19, 25 June 2011 (UTC)


 * Thanks for posting this under a separate heading.


 * Either I'm explaining myself inadequately or you are reading things into what I've written; I suppose it could also be a combination of the two. But getting back to basics, it's my understanding that Wikipedia aims for "encyclopedic," NPOV content related to each topic. What_Wikipedia_is_not makes it clear that "Wikipedia does have many encyclopedia articles on topics of historical significance that are currently in the news, and can be updated with recently verified information." I believe the key thought with regard to encyclopedic content is historical significance. So if you want to champion keeping the NRDC lawsuit on the clothianidin Wikipedia page, perhaps you could explain the historical significance of this lawsuit that was dismissed by stipulation. Is it historically significant that it took some time for USEPA to satisfy NRDC's very broad FOIA request after reviewing thousands of pages of material to make sure the release complied with federal law? Is it historically significant that we satisfied this extremely broad FOIA request when we don't have unlimited FOIA staff and many studies contain confidential business information that cannot legally be released? Show me the historical significance and I will happily keep it here, at your insistence, but update the content to reflect the actual outcome of the suit in a perfectly neutral, "just the facts" fashion. — Preceding unsigned comment added by USEPA James (talk • contribs) 23:18, 28 June 2011 (UTC)


 * Good grief! I am on no white horse mission here to prove that the EPA is a bunch of jerks and I'm going to prove it.  I would think that you would be glad to show that the EPA did in fact adequately answer any allegations.  IMO this was and remains news worthy to have one gov't agency to sue another.  If the blogs misrepresented what actually occurred, why not address it with adequate references and put the matter to rest?  (and here is a separate concern of mine in that you do not feel it would be proper for you as it may represent a conflit of interest.) Gandydancer (talk) 01:04, 29 June 2011 (UTC)


 * The historical significance of the NRDC lawsuit is not known...yet. At the end of the day it might just be dust. However, it is not the end of the day and the lawsuit is pertinent.
 * "...of this lawsuit that was dismissed by stipulation." Excuse me? I'm sorry James but you're not really telling whole story with the "stipulation" bit.


 * The FOIA request did cover a lot of ground and the EPA did comply and that should be fairly covered in the article. Considering the EPA's current position...
 * "Given the concern about clothianidin and other neonicotinoid pesticides and EPA’s dedication to pollinator protection, the Agency has accelerated the comprehensive re-evaluation of these pesticides in the registration review program. We are coordinating this re-evaluation with California’s Department of Pesticide Regulation and Canada’s Pest Management Regulatory Authority.  EPA’s registration review docket for clothianidin will open in 2011."- EPA: Clothianidin - Registration Status and Related Information


 * Dismissing the whole affair is not going to work. The NRDC lawsuit fits into the timeline. BTW: I don't think the EPA is evil per se, but that is a different topic. ArtifexMayhem (talk) 12:00, 29 June 2011 (UTC)

Bayer field study
I have been reading the EPA information and am trying to understand the Bayer field study which the EPA used to give clothianidin unconditional registration in April 2010. Perhaps James can help me to be certain I understand the information correctly. Am I correct in my understanding that 4 test sites each containing 2 plots, one treated and one not, and separated by "at least" 250 m., were used as the field study? And that no clothianidin-treated plots, no other blooming bee foraging crops, and no natural bee-feeding plants were located within 1 km. of the test plots?

Also, is this information correct? "When conditions for flight are not ideal, honey bees work close to their colonies. Although they may fly as far as 5 miles in search of food, they usually go no farther than 1 to 1-1/2 miles in good weather. In unfavorable weather, bees may visit only those plants nearest the hive. They also tend to work closer to the hive in areas where there are large numbers of attractive plants in bloom."

Also, you have said, "EPA reclassified the pollinator field study on November 2, 2010, to “invalid” after staff science reviewers discovered control contamination, inadequate pollen analysis, and other confounding factors while processing Bayer’s application for new uses on mustard and cotton." Could you please explain that statement more fully? Thanks. Gandydancer (talk) 12:57, 16 July 2011 (UTC)


 * I think you are jumping too far ahead, and you're persisting in incorporating into this chemical page a current event that (as written) is inappropriate per the community consensus reflected in the WP:CHEMMOS. In any event, you'll want to be careful when referencing USEPA science reviews on any Wikipedia page because they constitute a mixture of primary and secondary sources. Certain sections of our science reviews constitute reliable secondary sources though, because they are where USEPA gives its analysis of the primary source information also contained in the DERs. You can find examples of our secondary analysis of the methods, data, and submitted results in the DER sections entitled CONCLUSIONS, ADEQUACY OF THE STUDY, GUIDELINE DEVIATIONS, SUBMISSION PURPOSE, VERIFICATION OF STATISTICAL RESULTS, and REVIEWER'S COMMENTS. --USEPA James (talk) 22:33, 21 July 2011 (UTC)

Back to basics: appropriate section titles
The WP:CHEMMOS provides guidance for the basic structure of pages covered under the Wikipedia:Chemical Project, of which this clothianidin page is one. The recommended sections in WP:CHEMMOS are: compounds, reactions, methods of analysis, instrumentation/apparatus, techniques, significant chemists, branches of chemistry, and theories and principles. These recommended section titles might appeal to chemists in laboratories, but I would like to suggest additional, neutral subsections to better represent the fact that chemicals sometimes leave the lab and end up in use in the outside world. To kick off the discussion, I recommend the following:

Toxicity: This section would cover secondary source analyses of lab or field toxicity testing results.

Human Health Effects: This section would cover secondary source analyses of human health effects determined in lab or field testing or from reported incidents that are discussed in proper secondary sources.

Environmental Fate: This section would cover secondary source analyses of lab or field testing showing what happens to this chemical in the ground, air, and water.

These three sections constitute the lab- or field-study determined “hazards” associated with the chemical. But hazards don’t actually exist without exposure, and exposure results from Uses, which I suggest as the next section.

But if you use a pesticide according to the label (as required by law in many if not most countries), exposure is limited because authorized uses result from risk assessments that balance hazards through Risk Mitigation, which I propose as an additional section.

I believe that using these headings (or something like them) would help reduce the tabloid scandal sheet odor of the page as-is, and focus it instead on the chemical per se. I believe it is possible to present NPOV information, including accidents and other current events in an appropriately limited fashion (per the WP:CHEMMOS ), under these topic headings.

I would recommend against "Environmental impact" as a section because it is already practically a term of art with a very particular meaning that is not relevant to chemicals or their use (see Environmental impact statements and assessments. It implies normal or expected outcomes even when examples given are the result of accidents, off-label uses, and other issues having nothing to do with the environment.

Thoughts? --USEPA James (talk) 22:22, 21 July 2011 (UTC)


 * I can't comment from a chemist's POV, however from the POV of one that makes health/environmental edits, it seems like a great improvement to what we're using, which is pretty much make-it-up-as-you-go-along. Gandydancer (talk) 16:17, 22 July 2011 (UTC)


 * Thank you. I will use the proposed subtopics above to rewrite the page. If anyone comes up with other suggestions, please leave a note on my talk page It will take a week or two develop the content. I'll respond here with a notification when it's ready to review in my sandbox. --USEPA James (talk) 16:07, 27 July 2011 (UTC)


 * Good proposal. Something more on uses would be appropriate too. For example, currently the article mentions seed treatment, but neither summarizes what seed treatment is (from the context, I imagine it is added to seed by the farmer during sowing), nor mentions other permitted, recommended or prohibited uses. --InfantGorilla (talk) 08:17, 29 July 2011 (UTC)


 * Excellent suggestion, InfantGorilla. I'm adjusting the text accordingly and will have something ready for the group's review most likely early next week. --USEPA James (talk) 22:14, 12 August 2011 (UTC)


 * Sorry for the delay updating this page. I got pulled into a project at work and wasn't able to devote any time to Wikipedia. Per the consensus reached in August 2011, I'm updating the page now to the text that everyone concurred on in my sandbox. --USEPA James (talk) 15:26, 9 January 2012 (UTC)

The lede
About 2/3 of the lede is devoted to a discussion of a comparison of neonicotinoids to nictine, which is then not even mentioned in the article. See copy below:

''Neonicotinoids are a class of insecticides that are chemically similar to nicotine, which has been used as a pesticide since the late 1700s. As with nicotine, clothianidin and other neonicotinoids act on the central nervous system of insects. Although nicotine has been used as a pesticide for over 200 years it degraded too rapidly in the environment and lacked the selectivity to be very useful in large-scale agricultural situations. However, in order to address this problem, the neonicotinoids (chloronicotinyl insecticides) were developed as a substitute of nicotine, targeting the same receptor site (AChR) and activating post-synaptic acetylcholine receptors but not inhibiting AChE. Clothianidin, like other neonicotinoids, is an agonist of acetylcholine, the neurotransmitter that stimulates the nAChR. The advantage of clothianidin and other neonicotinoids over nicotine is that they are less likely to break down in the environment.''

I can imagine that we might have one line of comparison, but 2/3 of the lede? To use the lede to devote so much copy to nicotine, which may be considered for use as a pesticide choice in organic farming, makes me wonder if there has not been an attempt to suggest that chemicals such as neonicotinoids are no more harmful than "natural" pesticides such as nicotine. Gandydancer (talk) 17:00, 8 February 2012 (UTC)


 * I fully agree with your suggestion that this and related articles have been edited in a pathetic attempt to obfuscate, and I hope you can delete the extraneous material and replace the summaries which have been deleted for the wholly unconvincing reasons above which are clearly contrary to the plain language of the conclusions of the secondary peer reviewed sources. I think what has been going on here is repugnant example of regulatory capture and I am considering discussing this matter with my congressional representation. 67.6.175.184 (talk) 20:01, 8 February 2012 (UTC)


 * So, in addition to tossing out CHEMMOS, does this mean you are also disregarding WP:AGF? This is absurd. The cited source is a fact sheet that made those points. I thought they were interesting and encyclopedic. Given the toxicity of nicotine to humans (at the very least), it would not have occured to me try and infer comparable safety. If you feel the intro is overly focused on nicotine, why not just suggest deleting some of the text? Then again, since I invited comment on the updated text back in August and had it posted for months prior to the actual update, why didn't you mention your concerns back then??? sheesh USEPA James (talk) 18:04, 9 February 2012 (UTC)


 * You might want to review WP:LEAD. The lead section is supposed to summarize the rest of the article, not be overwhelmed with large volumes of tangental information about different subjects. The assumption of good faith is subject to the lack of subsequent evidence of behavior to the contrary. 67.6.175.184 (talk) 19:24, 9 February 2012 (UTC)


 * I guess I missed that suggested updated text from last August. The last I heard was:
 * Excellent suggestion, InfantGorilla. I'm adjusting the text accordingly and will have something ready for the group's review most likely early next week. --USEPA James (talk) 22:14, 12 August 2011 (UTC)


 * Sorry for the delay updating this page. I got pulled into a project at work and wasn't able to devote any time to Wikipedia. Per the consensus reached in August 2011, I'm updating the page now to the text that everyone concurred on in my sandbox. --USEPA James (talk) 15:26, 9 January 2012 (UTC)


 * Exactly what text are you talking about? The only text I ever saw in your sandbox was the German incident article, which nobody commented on. Gandydancer (talk) 18:43, 9 February 2012 (UTC)


 * My apologies. I thought I had invited comment here. On closer review, it appears I only said I was working on the rewrite a few times and had indicated several times that I use my sandbox for drafts; I should have explicitly announced it when the draft was complete. I also misunderstood Gandydancer acquiescing to consensus on the German incident as concurrence with the overarching topic of the page rewrite. USEPA James (talk) 19:03, 15 February 2012 (UTC)

In any case, even with the disputed material removed from the article, more than half the text discusses honeybees so they should certainly be summarized in the introduction per WP:LEAD. 67.6.175.184 (talk) 19:53, 9 February 2012 (UTC)


 * Yes, I agree that the lede should mention bees, but where do you see that "more than 1/2 of the text" discusses bees? I see about 1 1/2 bees to 5 screens of other.  If more than half of the text talked about bees I'd strongly suggest it be cut back! Gandydancer (talk) 20:15, 9 February 2012 (UTC)


 * I was counting all the paragraphs after the Table of Contents which mention bees, including "Authorized uses," material directly under "Toxicity", "Data gaps", "Risk mitigation", and "See also". 67.6.175.184 (talk) 23:05, 9 February 2012 (UTC)

Request for comments on 1) chemical accidents (again) and 2) citing primary research
Two new sections were added to the clothianidin page on January 17, 2012. The first focuses on the most sensational aspects of the 2008 German beekill incident, which consensus in the Chemical Project MOS WP:CHEMMOS and community concensus here in August 2011 said should be on its own page. The 2008_German_Beekill_Incident page has been published on Wikipedia since August 12 and describes the incident from a NPOV. All of the previous arguments against having this accident highlighted on the clothianidin page, which are documented above, remain unchanged. I propose to delete this content (again) since it is already appropriately mentioned and the main artcle covering that topic is linked from within the clothianidin article.

The second new section from January 17 similarly focuses on the most sensational aspects of recently published original research out of Purdue University involving multiple routes of exposure to pesticides for honey bees. Its inclusion here exemplifies why Wikipedia encourages reliance "on secondary sources whenever possible. For example, a review article, monograph, or textbook is better than a primary research paper." Reliable_sources The cited article (in a Purdue University publication) simply introduces the new study from Purdue researchers (as do all similar articles in the mass media); it does not critically examine the research; the scientific community at large has yet to weigh in. Including this section on the clothianidin page also incorrectly associates the results of the study with this particular chemical even though the study authors themselves are quoted in the source news report (and in the new section) as saying "Whatever was on the seed was being exhausted into the environment." In other words ANY pesticide or other chemicals used for seed treatments might be expected in the talc emissions. The new section also fails to mention a solution suggested by on of the study authors: "efforts could be made to limit or eliminate talc emissions during planting."

I propose to delete both new sections. Thoughts? I'll check back on 1/24/12. USEPA James (talk) 23:34, 19 January 2012 (UTC)


 * I have read your post. I will reply ASAP - I am busy with other articles, but hopefully I can make a post before about 1/26/12. Gandydancer (talk) 23:20, 21 January 2012 (UTC)
 * I support User:USEPA James's suggested deletions. The reliance on WP:SECONDARY should trump sensational claims, regardless of the good intentions that led to their inclusion in the first place.  With regards to the first paragraph being deleted because the material is already covered elsewhere.  In my humble view, we want Wikipedia to be very sober source and the articles focused, not sprawling. There is a tendency for non-technical editors to "pile on" Googleable safety-health-environomental info in their quest to 'save the world" (an approach that I am sympathetic too, but try to resist to improve Wikipedia's reliability). Those are only my views of course. Nice to see editors be consultative about changes.--Smokefoot (talk) 14:01, 24 January 2012 (UTC)


 * I will reply to Jame's post. First, the German bee-kill incident. 1) While you are calling it "the most sensational aspects", at the article you wrote you called the same information the "Basic information".  When we split an article, we do provide our readers with the basic information with a link to the main article.  While you are encouraged to improve the information, it is not policy to remove it.  2) Re a "consensus" reached about including information about the incident in this article.  You have misrepresented the previous talk page discussion.  I hope that you will read the discussion and correct your statement unless it is your intention to misinform new editors who may be attempting to form an opinion on these edits.  No consensus was reached.  3) You continue to use the fact that the Bhopal Disaster has its own article to justify a separate German bee-kill article, and continue to insist that Wikipedia policy would apply to that chemical page in the same way that it would apply to this article. I find your reasoning...flawed. As I have previously said, and you have ignored, clothianidin is both a chemical and an insecticide.  As an insecticide the article needs to include information on health, etc., implications - unless we want to start writing two articles for all the other chemicals that carry health risks.  See, for instance, the DDT article for a much better comparison than the Methyl isocyanate / Bhopal Disaster article.


 * But at any rate, you did go ahead and write the German incident article, suggesting that the incident was notable enough for its own article, and said that you would appropriately link to it when you did your rewrite here. But as a matter of fact, that is not what you did at all.  The incident is barely mentioned here and none of the references are actually related to the German incident, but rather to France and Canada:


 * Honeybees and other pollinators are particularly sensitive to clothianidin, as evidenced by the results of laboratory and field toxicity testing and demonstrated in acute poisoning incidents in France and Germany in 2008, and in Canada in 2010 associated with the planting of corn seeds treated with clothianidin.[39][40][41][42]


 * As for your problems with the Purdue University study -- the information presented, the references, and the study itself. For comparison to other chemical articles, perhaps it would help if you would take some time to read other articles such as the Bisphenol A article. You will see that many studies are presented to back up information at that article.  While you may not agree with the inclusion of health risks other than those listed by the EPA, it appears to be a well-established Wikipedia policy. I will try to find more time today to discuss my references and other concerns you have mentioned. Gandydancer (talk) 14:36, 24 January 2012 (UTC)
 * FWIW: Bisphenol A is a weak article in my analysis. The weight allocated to the perceived problems reinforces the perception that many Wikipedia articles are often soapboxes for socially-conscientious editors of modest technical ability.  BPA has had huge technological impact, yet the article is mainly one-sided list of grievances.  We should probably create an article on Bisphenol A Controversy, as we have done with Water fluoridation controversy.  --Smokefoot (talk) 14:54, 25 January 2012 (UTC)
 * I don't agree with your assessment that the inclusion of health issues in chemical articles are "the perceived problems [that] reinforces the perception that many Wikipedia articles are often soapboxes for socially-conscientious editors of modest technical ability". If it your belief that the chemical articles be cleared of health and environmental issues, it will keep you busy for some time - see for instance, vinyl chloride, phthalates, organophosphates, PCBs, and many others.  While as a chemist I can believe that you may think of the chemical properties of PCBs (for instance), I'd bet that 99% of the people that look that word up here are more interested in the environmental/health effects.  Gandydancer (talk) 16:15, 25 January 2012 (UTC)
 * Not that the articles should not have any health/safety content, but the overall content should be balanced. When the safety aspects are much longer than the description of the item itself, then one has to be concerned about balance (or it is time to spin off an article about "health concerns of..." etc. A challenge facing Wiki-Chem is that health-safety content often overwhelms articles.  Such material is contributed by well-intentioned editors who, by my assessment are incapable of adding any other sort of content (they don't know what they are talking about really - they are not toxicologists or environmental health professionals or MD's). Such editors may think that they are doing good, when in fact they are often doing damage. My concern is not just that the information conveyed is distorted, but the conversion of Wikipedia from a sober NPOV source of information to a muddle-headed soapbox. My guess is that most such editors are adding safety content, just to make themselves feel good, which is unfortunate but understandable.  So again, as a chemist, I do not believe "that the chemical articles be cleared of health and environmental issues", but I do worry that the content in Wikipedia be balanced and that the health aspects follow very high standard for referencing.  Otherwise we jeopardize the credibility of Wikipedia.  I say these harsh words because I feel so strongly about the environmental-health issues, not because I want to suppress good people doing what they think good deeds (again, by conveying info they do not understand).  --Smokefoot (talk) 18:34, 25 January 2012 (UTC)


 * I'm having a hard time understanding your opinion of "balance". IMO, if a chemical article has "safety aspects [which] are much longer than the description of the item itself", to omit some of the concerns for "balance" makes no sense at all.  As for your concerns about non-professionals adding information, yes most of Wikipedia is written by non-professionals.  In the very early attempts at a Wikipedia the information was all checked for accuracy by professionals and after a year hardly more than a handful of articles were completed, so they decided to let editors edit each other and it has worked fairly well.  As for concerns about "high standards for referencing", the section I added uses a peer-reviewed study (as is common for medical articles) with corresponding media reports of the study.  Finally, please take a look at the Atrazine article which is approved by the EPA and yet about half of the article is devoted to hazards - do you find that article appropriate? Gandydancer (talk) 14:43, 26 January 2012 (UTC)
 * Thanks for continuing this conversation. here are my views:


 * "some of the concerns for "balance" makes no sense at all." The statement might make no sense to you, but maybe it has merit for others - that is kinda why we are having this conversation.  It's just my opinion,  but an article should --Smokefoot (talk) 15:08, 27 January 2012 (UTC)mainly be about the topic subject, not the bad things that can happen with the topic.  The article on automobile or hammer or sodium chloride should mainly be a description of automobiles, trees, hammers, and sodium chloride.  In my opinion, we would be giving undue weight if these article were mainly about automobile accidents, people hitting their thumbs and other people with hammers or people who ingest too much NaCl, respectively.  If the tangential aspects grow, then we start an side article on automobile accidents.  Similarly with BPA and most chemical compounds.
 * A lot of people add chemical content, and I spend a lot of time correcting it. So I am extrapolating to toxicology and environmental themes, which I think are more nuanced (trickier).  On the chemical themes, most editors just lack much perspective and make a lot of little mistakes.  So I worry about how common such problems are with the tox and health aspects.  Fortunately the formidable technical barrier prevents a lot of editors from contributing to chem articles, but no such barrier prevents them from adding potential cruft on health topics.  So this is a difficult problem.   The tox and environmental warnings accrete and accrete because do-gooder editors want to add the latest google bit because they think they are being socially conscientious and helping to save the world (good motives) but they might be discrediting Wikipedia.  Maybe we should enforce WP:MEDRS more stringently.  I just don't know.  Difficult problem.  Nice talking to you, --Smokefoot (talk) 15:08, 27 January 2012 (UTC)


 * Yes, I agree that our talk page statements are a personal point of view and we are all encouraged to present our opinion here. Since the EPA spokesperson James finds your opinions on balance correct, I will reply to both of you in this post. You believe that to maintain balance in an article it should "mainly be about the topic subject, not the bad things that can happen with the topic".  You give several examples including automobiles and hammers, which James calls "spot on" as examples.  Certainly we all use Wikipedia for perhaps varied reasons, but I can't imagine anyone looking up "hammer" expecting to find out how often one hits their thumb or attacks someone with a hammer; not surprisingly there is no hazard section at the hammer article. However, I can imagine that one might be interested in automobile hazard/health issues.  Interestingly, looking back a few years I found that at one time these issues compromised about 1/3 of the article but as the article grew longer, more and more sections were split off to their own pages. But it's not a process of splitting off the "bad things" to their own articles, it's just that an article gets too long and needs to be split.  You also brought up sodium chloride; I'm not sure why...  As you know, it has its own article and table salt has a separate article which covers the "bad things" that can result from too much NaCl in the diet. Perhaps you are suggesting that the chemicals that are used as pesticides should have separate articles as well?


 * As for your mention of the need to watch the chem posts for misinformation, I can imagine that it is quite a job to keep up with the mistakes that non-professionals make. We are lucky to have somebody around that knows what the hell they are doing!  On the other hand, (IMO) even professionals can make mistakes about what we include.  For instance, see the talk page re Exercise at the Pregnancy article.  I had deleted the section saying that it was confusing and contradicting, and I could not locate the references.  A physician hunted down the references and returned the section.  I've had my talk page note up for about a week with no response, so I hope to find time today to again delete the section and rewrite it.


 * It is always good to talk to you Smokefoot - we don't always agree but I believe you are reasonable and fair and it is good to work with you. I will get back to the references issues as soon as I have time. Gandydancer (talk) 13:56, 29 January 2012 (UTC)


 * Thanks for continuing the discussion. Smokefoot, you raise valid points.


 * gandydancer, on August 5, after weeks of debate you wrote the following: "However, wikipedia edits are done through consensus, and except for a brief period of interest by one other editor, consensus appears to favor EPAJames edit plans. With no support for my viewpoint, I will no longer post my objections." Clearly, you acquiesced to the consensus. I did exactly as I promised, and I gave everybody MONTHS to comment on the updated text before finally posting it. But you've not kept your part of the bargain. Your arguments for putting it back in now (unannounced) are no more compelling than they were six months ago, and your editing is more than a bit disturbing. The facts you leave out are, to my reading, more indicative of bias than the facts you put in. When no less than three regulatory agencies on two continents all basically say that a large quantity of ANY powerful insecticide sprayed into the air in conditions like the German incident would result in lots of dead bees, how is it good for Wikipedia to have its editors disregard such a significant point and infer a connection to a particular chemical the authorities have repeatedly dismissed? Where are the published expert opinions refuting the regulatory agencies' conclusions?


 * We have a similar situation with your inclusion of the Purdue study, which examines multiple exposure routes associated with pesticide dust from seeding equipment used to plant treated seeds. The study authors in the article you referenced make it clear that the study is about seeding equipment-related exposure; as with the German incident, they make it perfectly clear that clothianidin is coincidental. It is an inappropriate use of Wikipedia to omit critical points like this from cited sources and focus instead on the parts of the article that fit your particular POV. The results of this study simply do not represent encyclopedic knowledge about clothianidin. Smokefoot's point about automobile or hammer or sodium chloride-related accidents/health issues was spot-on.


 * You are right, gandydancer, that there are many pages where advocates have posted newly published original research to support their beliefs since Wikipedia relaxed its rules; while this has no doubt increased the number of articles published, I believe I am not alone in feeling the quality has suffered. Reiterating yet another of Smokefoot's points, some pages are so overwhelmingly loaded with advocate messaging it negatively affects the credibility of Wikipedia as a source of unbiased information. But instead of challenging the inappropriate use of original research by advocates consistent with Wikipedia policies and guidelines, other Wikipedians tend to pile on still more original research supporting the opposing view. This is not NPOV -- it's haphazardly balanced biases. The benefit of adhering to Wikipedia's WP:SECONDARY is that all sorts of peer-reviewed work gets the boot once it's subjected to scrutiny by the scientific community. If it doesn't get the boot after a robust analysis, THEN it's reasonable to include references to the analysis it in an appropriate Wikipedia article. You jumped the gun by posting a reference to this Purdue study based on an announcement in Purdue's newspaper, in addition to the inappropriateness of putting the section on the clothianidin page in the first place. To second Smokefoot once more, perhaps you could start a new page on Agricultural Seeding Equipment Controversies and reference it there once a secondary analysis has been published.


 * As to the atrazine page being "approved by the EPA," you completely misconstrue what I actually wrote. I said some of the section titles were more appropriate to a chemical page than what was previously on the clothianidin page, which read like a scandal sheet from the blogosphere. Frankly, the atrazine article is a mess of references to original research too, but it's a case of balanced biases. It lacks neutrality and, therefore, credibility, and is absolutely not "approved by the EPA." For the clothianidin article, I feel it is best to avoid biases to the extent possible and shoot for a truly NPOV.


 * Ironically, the Purdue study was funded by two partners of USEPA in our efforts to better protect pollinators: the U.S. Department of Agriculture and the North American Pollinator Protection Campaign. We've been telling them for years the sorts of studies we need for regulatory purposes; even with its faults, we're happy to see this work out of Purdue. For more than six months we've also included a requirement for residue data on seeding equipment exhaust in our work plan for the neonicotinoid registration review that's currently under way. The publication of this Purdue study is timely from our perspective (though it has been entirely blown out of proportion by certain media outlets and other advocates who simply don't demonstrate a good grasp of the facts of the matter). But in spite of all that, until it undergoes critical review (which it likely will at the independent FIFRA Scientific Advisory Panel meeting we are convening later this year), it is inappropriate to be referenced anywhere on Wikipedia.


 * Please delete the sections you added, gandydancer, or come up with logical, NPOV justifications to not honor WP:SECONDARY and to break your part of the bargain from August. USEPA James (talk) 23:07, 27 January 2012 (UTC)


 * Yes, I did not see a good reason to split the German incident off to a separate article as you did. As you know, at the time you wrote the article you stated it was so important that it warranted its own article - it should be obvious that you can't now turn around and now say that its not important enough to mention in this article. At any rate, it seems that you incorrectly believed that splitting an article suggests that all mention of the split information is deleted from the main article. Please look at other articles and you will see that that is not how Wikipedia works.  That is why I returned the section that you called basic information to this article.  As I said, you are welcome (and in fact I encourage you) to improve the lede to the German incident article since that is what would be appropriate to include in this article.  I agree, as I have all along, that the German incident was caused by a perfect storm of application mistakes and was not a reason to fault the insecticide itself.


 * Next you say that I did not include the fact that it was the machinery used that was found to be at fault in the Purdue study. You are certainly welcome to include that information if it is sourced properly. From my reading it seemed that the insecticide was found to be on the talc being used as part of standard planting practices. As for my references, a government-funded, peer reviewed study done by a university, published in PlosOne, with three secondary sources, is certainly considered adequate. You can argue this, but this is the norm on all the other insecticide articles, so it would seem that you will need to argue against it at a higher level than on this article alone.


 * You state, We have a similar situation with your inclusion of the Purdue study, which examines multiple exposure routes associated with pesticide dust from seeding equipment used to plant treated seeds. The study authors in the article you referenced make it clear that the study is about seeding equipment-related exposure; as with the German incident, they make it perfectly clear that clothianidin is coincidental. I don't agree with your reading of this study.  The German incident was the result of a perfect storm of planting errors, but the present study/finding was related to general planting practice and it was found that clothianidin, known to be extremely toxic even in very small amounts, was detected...I will quote from the study:
 * During spring, extremely high levels of clothianidin and thiamethoxam were found in planter exhaust material produced during the planting of treated maize seed. We also found neonicotinoids in the soil of each field we sampled, including unplanted fields. Plants visited by foraging bees (dandelions) growing near these fields were found to contain neonicotinoids as well. This indicates deposition of neonicotinoids on the flowers, uptake by the root system, or both. Dead bees collected near hive entrances during the spring sampling period were found to contain clothianidin as well, although whether exposure was oral (consuming pollen) or by contact (soil/planter dust) is unclear. We also detected the insecticide clothianidin in pollen collected by bees and stored in the hive. When maize plants in our field reached anthesis, maize pollen from treated seed was found to contain clothianidin and other pesticides; and honey bees in our study readily collected maize pollen. These findings clarify some of the mechanisms by which honey bees may be exposed to agricultural pesticides throughout the growing season. These results have implications for a wide range of large-scale annual cropping systems that utilize neonicotinoid seed treatments. It is interesting to note that the German incident was related to the fact that suggested practice of using a sticker was not used which (along with other factors) resulting in a massive bee kill.  But you have frequently said that in the U.S. a sticker is always used, hence we would not have this same problem here.  But in this study we learn that it is common practice to use talc  because the "stickered" seeds need to be treated to pass through the planting machinery properly, and they are finding insecticide  residue on the exhausted talc.  Gandydancer (talk) 10:42, 3 February 2012 (UTC)


 * Gandydancer, your analysis of this research almost perfectly exemplifies why Wikipedia emphasizes that great care should be taken when relying on primary sources. Did you notice, as just one minor example from what you highlighted above, that the claim in the PlosOne article that talc use is "typical" has no citation? Typical where? Says who? And when did it become typical? These are the sorts of questions the scientific community resolves when they have time to do a secondary analysis of original research. You are preempting that by rushing to promote science that has yet to survive the scrutiny of the true peer review that happens only after initial publication. This negatively affects Wikipedia's credibility. I am asking you once again to delete all of the text you have added that relies on primary research. USEPA James (talk) 23:10, 14 February 2012 (UTC)


 * You misunderstood my "typical" comment. I am not suggesting that using talc is a typical planting practice, only that talc was typically used in this two year study.  And, I am not rushing to promote anything.  Individual peer reviewed studies are frequently used in Wikipedia.  Look for instance at the Phthalate article.  As you know, most science today tends towards thinking that CCD is most likely a combination of factors, including pesticides.  And it is agreed that clothianidin is very highly toxic to bees.  This study does not claim that clothianidin is the chemical that is killing the bees, but it does show that high levels of it were found that were apparently being spread by the talc used during planting. As you know, what with bee keepers continuing to lose hives at a rate of 1/3 and even more than that a year since around 2006, the fear that we may lose our pollinators has a lot of people very worried.  It is not at all out of place to include this study in the article. Gandydancer (talk) 04:12, 15 February 2012 (UTC)


 * Gandydancer, this is beyond ridiculous. I was not quoting you. I assumed you read the article in its entirety and were conversant in it since you obviously feel qualified to summarize it here. I quoted the word "typically" from the article itself (PDF).


 * I will repeat this just this once more: the fact that Wikipedia policies are broken on other pages does not justify breaking them here. I recommend that you seriously consider your recent edits relative to WP:consensus: "Consensus among a limited group of editors, at one place and time, cannot override community consensus on a wider scale. For instance, unless they can convince the broader community that such action is right, participants in a WikiProject cannot decide that some generally accepted policy or guideline does not apply to articles within its scope." You have no business blatantly violating the Wikipedia and WikiProject Chemistry policies and guidelines Smokefoot and I have brought up in this discussion, especially since you make no effort to convince the larger community (or even those of us watching this particular page) why it benefits Wikipedia's credibility to break the rules. "Because we do it elsewhere" is not convincing and neither is op-ed commentary sans credible secondary sources.


 * I will not respond to any further discussion here since it's taking place in the middle of a discussion that has long since moved on. But I will be following up on a related note with a new discussion topic shortly. USEPA James (talk) 18:38, 15 February 2012 (UTC)


 * I am very short on time but will find time to respond this weekend. Gandydancer (talk) 15:38, 17 February 2012 (UTC)


 * (Followup note) Of course I have read the article. I will save my responses for the followup section you say you plan to post. Gandydancer (talk) 21:23, 18 February 2012 (UTC)

Many issues have been brought up and I will go through them as quickly as possible and reply. Gandydancer (talk) 23:27, 27 January 2012 (UTC)


 * gandydancer, your 13:56, 29 January 2012 response above does not provide a logical, NPOV justification not to honor WP:SECONDARY with regard to the Purdue study, nor does it justify breaking your part of the bargain from August on the German incident. I am deleting the section on the Purdue study because it violates WP:SECONDARY and Reliable_sources and might encourage a flood of other original research references to support biased POV like we see on so many other advocate-dominated pages. I am deleting the German incident section because it violates WP:CHEMMOS and for all of the other reasons discussed above and agreed upon by the group in August. In both the Purdue study and the German incident, the cited sources make it clear that the connection to clothianidin is coincidental. Having them on the clothianidin page infers inherent connections to this chemical that are not supported by the cited refs. This crosses the line into original thought or personal belief, which is, of course, a no-no. If in the future you would like to add new sections or make significant edits such as these, please talk it over here first and give some time before being bold. Because pollinator protection is a hot topic at USEPA, I may be able to provide context or background for you that sensational media articles frequently seem to lack. Thx USEPA James (talk) 21:12, 30 January 2012 (UTC)


 * I am doing my best to keep up with edits but I work on many other articles, so time is sometimes hard to find. I will continue to attempt to deal with these issues as time permits.  James, please keep in mind that in the past you have frequently gone for days and even weeks without posting and your posts seldom reply to any of the issues I have raised.  Furthermore, of course, I do my work here for free, while you are being paid for your time here. Gandydancer (talk) 15:16, 1 February 2012 (UTC)


 * Thanks, Gandydancer. Since you wrote "I will reply to both of you in this post" in your 13:56, 29 January 2012 response, I understood that to mean you were responding to the concerns raised and presenting your case for keeping the two new sections. You didn't respond to the specific concerns as far as I could tell, so I felt justified in deleting the sections. To me, the fact that advocates have been violating policies and guidelines to push their agendas on other pages is a completely unconvincing reason to do it here; it detracts from Wikipedia's credibility and (worse, to my way of thinking) misleads many thousands of people every month.


 * I appreciate the time it takes to write articles. You assume I get paid for being here, but having invested many tens of hours off-the-clock researching and rewriting the clothianidin article, I'd rather not have to keep coming back to revisit issues that were already settled. Let's not forget that Wikipedia has guidelines and policies and the Chemical Project has its own set of standards that, if adhered to, would have precluded the need for me to even be here in the first place. I also see there are many other related articles that have similarly inappropriate content, but for now my focus is on keeping this one article NPOV. Please talk it over here before making significant edits to this page in the future. I'm not opposed to new content that is written from a neutral perspective and consistent with Wikipedia policies, guidelines and consensus. I'd be happy to work with you to develop new content that meets the criteria.


 * If there are specific issues you feel I have ignored, let me say it's not intentional. Smokefoot mentioned above issues making sense to some people but making no sense to others. It could be that I simply didn't understand the relevance of the issue you raised or the way you describe it. If you want to discuss these issues more, why not start a new section here if it pertains specifically to clothianidin or on my talk page if it's of a more general nature? USEPA James (talk) 17:13, 1 February 2012 (UTC)


 * Unless I devote all of my wikipedia time to this article it will be difficult to keep up with your edits. Never the less, I will do my best.  Do I understand you correctly when you say that you represent the EPA in your edits and work both on company time and your own (unpaid) personal time? Gandydancer (talk) 18:28, 1 February 2012 (UTC)


 * My user page explains why I became a Wikipedian on behalf of USEPA, and Wikipedia's approval of me being here in that capacity. But since that topic and how I spend my time on and off the clock have little to do with clothianidin, if you want to pursue those topics please post your follow-ups on my talk page. USEPA James (talk) 20:03, 2 February 2012 (UTC)


 * I have again added information from the article split that was removed. As I have already stated, this is per common Wikipedia policy. When information is removed to its own page, we commonly write a short summary of the material with a link to the new article. Since editor James believes that the incident is so important that it deserves it own article, he can hardly now state that it is so unimportant that it not be mentioned in this article.  Note that I called the incident an "accident" to note the fact that failure to use proper planting policy may have been the underlying reason for the incident. Gandydancer (talk) 16:48, 7 February 2012 (UTC)


 * Gandydancer, the German incident was a chemical accident. Having a section on it here violates the WP:CHEMMOS and, by extention, the Chemical Project community consensus. I will follow up accordingly ASAP.USEPA James (talk) 16:53, 9 February 2012 (UTC)


 * Yes, it seems you are correct. The Methyl isocyanate article does not have a separate section.  I will include the info in a manner similar to the way that that article included an accident. They use this wording: The toxic effect of the compound was apparent in the Bhopal disaster, when around 42,000 kilograms (93,000 lb) of methyl isocyanate and other gases were released from the underground reservoirs of Union Carbide India Limited (UCIL) factory, over a populated area on December 3, 1984, immediately killing thousands and leading to the deaths of tens of thousands in subsequent weeks and months. Gandydancer (talk) 18:22, 9 February 2012 (UTC)

Peer reviewed secondary sources?
Does anyone know of a more recent peer reviewed secondary source on this topic than (full text)? I ask because, "the nitro-substituted compounds (clothianidin, ...) appear the most toxic to bees.... the extensive use of pesticides against pest insects for crop protection has contributed to the loss of many pollinators.... neonicotinoid insecticides were recently implicated by beekeepers ... due to a progressive disease in the hive populations, until a complete loss of the colonies," does not appear at all inconsistent with the contentious material which has recently been deleted here. I would also like to caution editors that news stories from reliable sources with editorial supervision and a reputation for fact checking and accuracy are in fact WP:SECONDARY sources, not primary sources as they have been referred to above. However, peer reviewed secondary sources are always preferred to news stories from any source. 67.6.175.184 (talk) 04:28, 7 February 2012 (UTC)


 * Hi! First, you might want to review WP:SECONDARY: "Material based purely on primary sources should be avoided." Newspaper articles introducing original research and interviews with the authors of the research cannot be considered secondary sources because there is no critical analysis of the data or conclusions involved. We've all read sensational media articles about NEW RESEARCH!!! that sometimes gets the boot or gets put in its proper place once the scientific community has an opportunity to review. I believe Wikipedia wants to avoid documenting the sensational journalism because it negatively affects its credibility.


 * Your specific question was about more recent sources than the ones you linked to, but both of them are from 2010 which is recent enough I think. I'm just not sure what additional information they bring to the table.


 * Your books.google citation above isn't opening for me in Firefox or IE and appears to be a different article than the one at . The google book appears to be entitled Insect Nicotinic Acetylcholine Receptors (Thany, Steeve Hervé, 2010), but from online summaries I'm not sure what new information it provides that isn't covered in the clothianidin article already. Toxicity to bees is already there, both from lab analysis and from practical use in the fields. The intro covers clothianidin's effects on insect acetylcholine receptors... What does the book explain that isn't covered already?


 * Your link goes to Ecotoxicity of neonicotinoid insecticides to bees {Decourtye A, Devillers J., 2010}, but I can't see the entire article there. It appears to be a secondary review, but from the pubmed article summary it appears as if they are comparing relative toxicity to bees of the various neonics, and that clothianidin is more toxic than some (but not all) of the others. But the clothianidin article already cites the Australian Pesticides and Veterinary Medicines Authority as saying 'that clothianidin ranks "among the most highly acutely toxic insecticides to bees" through contact and oral exposure.' I'm a little concerned about the value added to Wikipedia by basically repeating over and over again that it's very toxic to bees that come into contact with residues. Do you want to add something like "It is relatively more toxic to bees than some (but not all) other neonicotinoid pesticides?" and cite Decourtye and Devillers? USEPA James (talk) 15:12, 7 February 2012 (UTC)


 * I think it would be best if you can find that chapter somehow, read it, confirm whether or not there are any more recent peer reviewed secondary sources, and then consider whether the passages I quoted from it above should be included in the article. I would also like your opinion, please, on these recent stories from Grist and The Economist. 67.6.175.184 (talk) 20:02, 7 February 2012 (UTC)


 * If you want to have me read an article, please provide a useful link. But even without the link, it would be helpful if you could explain how Wikipedia benefits from repeating over and over again toxicity to bees when it's already clearly (and neutrally) stated in the text.


 * The point in the Grist article that is best supported by the available data is "...CCD — a still somewhat mysterious phenomenon...," though I feel the use of the word "somewhat" reflects creative license and/or beliefs of the author. The statement "research increasingly points to pesticides as the primary culprit" does not reflect the consensus of the top scientific and regulatory experts from around the globe. I don't see any evidence of critical analysis in the Grist article. Did you notice, for example, that they didn't bother to interview toxicologists, entomologists, regulatory risk assessors or anybody else that's looking at this from a stone-cold scientific standpoint? Is that not a concern for you?


 * The Economist article's take home message is "Whether [the study findings are] actually the reason for colonies collapsing remains to be determined." The study, which was done by one of USEPA's partners in trying to advance pollinator science, adds incrementally to one of many hypotheses about CCD, but none of the new research is a "smoking gun." USEPA James (talk) 17:37, 9 February 2012 (UTC)


 * The Google Books link works for me. I was just informed by the EPA Headquarters Reference Librarian that all EPA employees have access to SpringerLink, so you should be able to read the chapter at on your EPA computer. What evidence do you have that Grist "didn't bother to interview toxicologists, entomologists, regulatory risk assessors or anybody else that's looking at this from a stone-cold scientific standpoint"? Do you mean merely that no such people were cited in the article, and you actually have no idea whether such people were interviewed? Although your personal opinions about what portions of those stories are most important and what is or is not a "smoking gun" are interesting to me, I am much more interested in whether you are aware of any more recent peer reviewed secondary sources than the Decourtye and Devillers (2010) chapter, whether you object to the inclusion of the excerpts of it above, and if so on what grounds. 67.6.175.184 (talk) 19:18, 9 February 2012 (UTC)


 * The snippets you've chosen for your proposed excerpts seem to...how shall I put it...lean a certain way. I believe an objective, informed reviewer of the entire chapter--and I do mean the whole thing--would not come to the same conclusions you captured in your snippets. When the authors acknowledge throughout the chapter (but especially in the Conclusion) that "The causes of decline among pollinators vary from a species to another and are generally difficult to assign," they are not making an insignificant point. They're saying exactly what regulatory authorities and academics around the globe have been saying for years, which is still valid today. Also, the authors' use throughout the chapter of words like "could" and "is possible" with regard to neonicotinoid risks are consistent with the state of the science as USEPA understands it (i.e. there are lots of theories but not lots of good, consistent data to support any of them). Time and again the authors note challenges with available data (e.g. "these data are often inadequate to demonstrate causation unambiguously."); again, this is not an insignificant point (though it makes for lousy headlines). The bottom line is that your snippets infer far greater certainty of a link between clothianidin and bee declines than do the authors, which I feel harms Wikipeda's credibility.


 * For this clothianidin article, I don't see anything in the chapter you referenced that isn't covered from a NPOV in the version of the article I published on January 9. Since "redundancy within an article should be kept to a minimum," I think it would not be in Wikipedia's best interest to repeat the same basic information over and over again.


 * You asked for more recent, peer reviewed, secondary sources. My recommendation is to wait and see what the independent Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) Scientific Advisory Panel has to say. It is my understanding that the global pesticide regulatory and scientific communities are looking forward to a FIFRA SAP meeting that will be looking at USEPA's proposed risk assessment for pollinators in fall 2012. USEPA James (talk) 20:37, 14 February 2012 (UTC)


 * Also, User 67.6.175.184, please refrain from including personal details about me (e.g. my employment etc) on this chemical talk page or elsewhere on Wikipedia, since doing so does not help improve this article and it expressly violates acceptable behavior policies USEPA James (talk) 21:05, 15 February 2012 (UTC)


 * I note that you have made this same demand to another editor. I think you are going to have to clear this up with with a statement of some sort.  Gandydancer (talk) 20:48, 18 February 2012 (UTC)