On August 27 (2015), we published an action alert asking consumers to ask Burt’s Bees to cut ties with the corporations that make neonicotinoid pesticides. Neonics are a class of pesticides implicated in the mass die-off of honeybees.

We also asked that instead of supporting research (through the Pollinator Partnership) on other causes of Colony Collapse Disorder (CCD), or research on alternative pesticides, Burt’s Bees use its corporate clout to demand that the U.S. Environmental Protection Agency (EPA) ban the use of neonics.

Our action alert prompted an angry phone call from the executive director of the Pollinator Partnership. Burt’s Bees also responded, by setting up an auto-reply email (which many of you received) defending the brand’s participation in the Pollinator Partnership, and insisting that the Burt’s Bees brand is dedicated to protecting pollinators.

We stand by the alert, which as of September 7, had generated almost 18,000 emails to Burt’s Bees. Here’s why.

Where OCA stands on pesticides and other chemicals

Before we get into the details surrounding this specific alert, or the angry and defensive reactions it triggered, let’s clarify the position of the Organic Consumers Association: Neonicotinoid pesticides specifically, and pesticides (and herbicides) in general, should be banned from the U.S. food system, as should most chemical fertilizers. Period.

To varying degrees, these chemicals all destroy soil health. They destroy water quality. (The Gulf of Mexico dead zone is now the size of Connecticut and Rhode Island, according to the latest estimate from the National Oceanic and Atmospheric Administration, and neonics were detected in half the sampled streams in the U.S., according a report released August 18, 2015, by the U.S. Department of the Interior, U.S. Geological Survey).

In addition to destroying soil health and polluting our water, chemical fertilizers also directly contribute to global warming.

The bottom line is this: Unhealthy soil produces unhealthy food; polluted waters and global warming are threats to human health; and toxic chemicals on our food aren’t good for us.

The Centers for Disease Control and Prevention report that there are traces of 29 different pesticides in the average American’s body. The government agencies that defend the widespread use of toxic chemicals in U.S. agriculture do so on the basis of what they refer to as “safe” residues, as determined by the regulatory agencies, often with input from corporations, and only by looking at each chemical independently. These agencies don’t study the impact of the toxic chemical cocktails resulting from exposure to multiple pesticides or chemicals.

We agree with Andre Leu, author of the “Myths of Safe Pesticides,” that there are, in fact, no “safe” limits of pesticides, especially when it comes to children:

Given the body of scientific data linking the additive and synergistic effects of chemical mixtures to numerous adverse health effects, serious concerns need to be raised as to why regulators allow these formulated mixtures to be used on the assumption that they are safe. There are no credible scientific data to determine a safety level for the residues of the actual registered pesticide products used in food production and found in food until whole formulations are tested. (p. 12).

For this reason, and because we believe corporate-controlled chemical-intensive industrial agriculture is at the root of many problems, including global warming, public health and global poverty, OCA advocates for chemical-free, organic regenerative (or agroecological) farming practices that foster biodiversity and protect crops naturally. These practices, which include crop rotation, cultivation of different plant varieties, stimulation of beneficial insects and natural predators, have proven successful and productive, according to many farmers, and as outlined in a report that followed from the March 2013 conference “Pollinator Friendly Farming Is Possible.”

Why We Targeted Burt’s Bees

Back to the Burt’s Bees action alert and subsequent fallout.

The once-beloved Burt’s Bees brand was purchased by The Clorox Company in 2007. Craig Stevenson, vice president and general manager of Clorox, who is also responsible for the Burt’s Bees product line, is on the board of the Pollinator Partnership.

Who supports the Pollinator Partnership? Many government and nonprofit organizations, and, in addition to Burt’s Bees, 33 other corporations—including Bayer, Syngenta and Monsanto, the companies responsible for manufacturing and/or selling the neonicotinoids that have been linked to the mass die-off of honeybees.

Do we believe corporate bean-counters at Clorox, Bayer, Syngenta and Monsanto are deeply concerned about the impact neonics, or other pesticides or chemicals, have on pollinators, or on human health and/or the health of the environment?

We don’t. More likely, Bayer, Monsanto and Syngenta support the Pollinator Partnership in the hope of furthering their own agendas, which include diverting attention away from neonics as the primary culprit in Colony Collapse Disorder environment and/or advancing research into alternative pesticides—from which they can profit.

We’re not alone in our thinking. In its 2014 Follow the Honey Report, Friends of the Earth documented how companies like Bayer have copied tobacco industry public relations tactics in an effort to manufacture doubt about the role neonics have played in decimating honeybee colonies.

Similarly, Bayer, Syngenta and Monsanto have deployed a mix of PR tactics to divert attention away from neonicotinoids as a key contributor to bee declines. They have typically promoted a “multiple factors” argument that downplays and manufactures doubt about pesticides’ role, while emphasizing varroa mites, pathogens, and bee forage as primary forces threatening bees.

For example, Helmut Schramm, head of Bayer CropScience Germany, explained: “It’s generally known that the varroa mite is the main enemy of the bee.” To further distract attention, Bayer has even erected a giant sculpture of the varroa mite on a bee at its “Bee Care” Center in Germany. As the New York Times notes, “Conveniently, Bayer markets products to kill the mites too.”

What Mr. Schramm doesn’t mention is that neonics weaken the honeybees’ immune systems, making them more vulnerable to varroa mites. Or that, as The New York Times pointed out, Bayer also conveniently markets products to kill the mites.

There are no doubt many well-intentioned organizations and staff members who support and work for the Pollinator Partnership. But the fact that the Pollinator Partnership takes money from the likes of Clorox, Bayer, Syngenta and Monsanto raises questions about influence. Those questions surfaced the minute we read this letter from the Pollinator Partnership’s executive director, the beginning of which reads much like Bayer’s propaganda.

Neonicotinoids come with a bee hazard statement on the label as they have been determined to have the potential to harm bees; but the question is, to what extent are these substances alone responsible for CCD? CCD has been shown to be the result of multiple factors, as detailed by the recent EPA-USDA report issued last week. CCD, however, is just one of the many problems that have beset honey bees; and there are considerably more issues that face the rest of the pollinating community including other bees, bats, birds, butterflies, flies and more.

The Pollinator Partnership feels that science needs to lead the discussion on neonicotinoids, CCD, and all pollinator health issues, and that decisions based on anything less have the potential to lead us into more, not fewer, problems.

Neonicotinoids were developed as a response to and as a replacement for previous chemicals that had proven risks associated with bee kills and human health concerns. With respect to neonicotinoids, we really do not know enough yet; and we are hoping that new science, including research we are conducting this year, will help clarify this.

Our response to these statements?

Labeling a poison doesn’t make the poison okay. It doesn’t matter if neonics are only part of the problem—the fact that they are part of the problem means their liberal use shouldn’t be allowed in the food production system. Science is leading the discussion, and yes we do know enough yet, even the EPA’s own scientists, according to internal documents, believe neonics are toxic to bees. And even if we’re still waiting for “new” science, we ought to be following the precautionary principle, which roughly translated means “better safe than sorry.” And that means halting the use of neonics.

We stick to our assertion that Burt’s Bees should disassociate itself with any organization or corporation that believes otherwise.

Do We Really Want Neonics on Our Food?

It’s great that we’re studying the impact of neonics on pollinators. Pollinators play a critical role in food production, and even if they didn’t, we ought to be concerned about the mass die-off of any species, as these events lead to loss of biodiversity and have serious implications for all life on earth.

But focusing exclusively on the impact of neonics on pollinators distorts the what ought to be the real debate around not only neonics, but all toxic chemicals used to grow food.

According to the Journal of Agriculture and Food Chemistry, which measured neonic residues on foods that humans commonly eat:

All fruit and vegetable samples (except nectarine and tomato) and 90% of honey samples were detected positive for at least one neonicotinoid; 72% of fruits, 45% of vegetables and 50% of honey samples contained at least two different neonicotinoids in one sample, with imidacloprid having the highest detection rate among all samples. All pollen samples from New Zealand contained multiple neonicotinoids and 5 out of 7 pollen from Massachusetts detected positive for imidacloprid. These results show the prevalent presence of low level neonicotinoid residues in fruits, vegetables and honey that are readily available in the market for human consumption and in the environment where honeybees forage. In light of the new reports of toxicological effects in mammals, our results strengthen the importance to assess dietary neonicotinoid intakes and the potential human health effects.

According to a recent article in Rolling Stone, a 2012 U.S. Department of Agriculture survey found neonics in 30 percent of cauliflower, 22 percent of cherry tomatoes and in more than a fourth of bell peppers. In 2011, the Food and Drug Administration found them in 29 percent of baby food, according to the article.

We’re talking about a poison, which works in the same way nerve poisons work, according to the “Myths of Safe Pesticides” (p. 15). And we’re allowing it on our food (and on the seeds used to grow that food), and on the food of vulnerable, toxin-sensitive infants and children, while we wait for “new” studies.

Pesticide Action Network North America (PANNA) describes the cumulative and chronic effects of neonics on bees like this:

Neonicotinoids function by binding to nicotinic acetylcholine receptors in insects’ brains, receptors which are particularly abundant in bees,  increasing during development from larval to adult stages. This binding leads to an over-accumulation of acetylcholine, resulting in paralysis and death. The most recent scientific observations point to a long-lasting effect in which molecules unbind from receptors, but  remain in the bee brain, possibly rebinding multiple times before metabolization occurs. Whether this constitutes effectively irreversible, cumulative toxicity remains unclear; but  chronic toxicity effects over time are a likely result.

Can we safely assume humans are immune to these “cumulative and chronic” effects? Especially infants and children, whose smaller body mass and rapid physical development increase their vulnerability to toxins?

Here’s the Kicker—Neonics Don’t Even Work!

As PANNA points out, neonics can be applied as a spray, but are more commonly used as systemics, or seed coatings:

Systemic pesticides are applied as seed coatings or soil drenches and are taken up through the plant’s vascular system and then transmitted to all parts of the plant, including pollen and nectar. Neonicotionids are very persistent and therefore accumulate over time in the environment. Most neonicotionoids are classified as acutely toxic to bees. But single, high-dose (i.e. acute) exposures are likely less common than are the chronic, sublethal exposure levels faced by bees over time as they forage in the field.

Rolling Stone cited conservative estimates showing that neonics are used on 100 million acres of U.S. farmland.

According to the Institute for Agriculture and Trade Policy (IATP):

Seed treatment applications are prophylactic, meaning they are used whether or not there is any evidence of pest pressures. At least 30 percent of soybean seeds planted annually (approximately 22.5 million out of 75 million acres) are pretreated with neonic insecticides (two of the primary four being imidacloprid and thiamethoxam). But corn has the highest use and acreage with around 94 percent of U.S. corn treated with a neonicotinoid. That widespread use has quickly elevated the Midwest to the highest levels of neonicotinoid use in the country. These neonicotinoids don’t stay in the plants and soil however, but find their ways into the water as well. A recent U.S. Geological Survey report confirmed this, finding neonicotinoids were common in streams throughout the Midwest.

So we’re killing the bees, polluting the water, and for what?

Here’s the kicker: According to numerous studies, pre-treating seeds with neonics provides little or no benefit to farmers. The IATP, which produced a paper http://www.iatp.org/documents/unknown-benefits-hidden-costs on the use of neonics as seed coatings says:

Despite their widespread use, there is surprisingly little field trial research available on the efficacy of neonicotinoids in providing yield benefits. A series of recent reports are actually pointing in the other direction, with evidence that indicates that neonicotinoids are of dubious value to farmers and in fact, under certain circumstances, may even inhibit yield. A review of 19 studies in scientific journals looked at how neonic treatments affect yields of major U.S. crops: corn, soybeans, canola, dry beans, and wheat. The review by the Center for Food Safety (CFS) found that in most studies, neonic treatments did not increase yield. This was particularly the case when there was only moderate or low pest pressure, which is the reality on the majority of crop acres. European reports of crop yields before and after neonic bans were in place additionally show no discernable difference, further confirming the lack of measurable yield benefits.

The conclusions drawn by these studies bring us back full circle to our position that neonics ought to be banned. That’s what the European Union did in December 2013, after the European Food Safety Authority said neonics posed an unacceptable danger to bees. The ban was subsequently (and temporarily) lifted in June 2015, amid loud protests from consumers and environmental groups. Before the ban was lifted, and while corporations were working to overturn it, a reporter for The Guardian wrote this, which pretty much sums up what we think:

The EU’s ban on neonicotinoids has removed a band-aid from a suppurating and seemingly incurable wound – the reliance of agriculture on chemicals that harm the environment. Should Syngenta’s appeal to the government be accepted, then neonicotinoids may assist some farmers to bring in the yields for this year. But should the ban continue, what happens next year? Will we simply be having this conversation again?

Non-chemical alternatives exist that could support farmers to cost-effectively move away from their near total reliance on pesticides. But you cannot patent a parasitic wasp. So their development is stalled and apart from some small exceptions, research ignores biological pest management. This means the agriculture industry is mostly one vast train trapped on a chemical track.

So to Burt’s Bees, we reiterate our call to sanity. We don’t need more science, more alternative poisons, more years of wavering and vacillating, more stalling. What we need is to end the rampant and reckless use of poisons that profit-seeking corporations have falsely led us to believe we need, and return to organic, regenerative farming practices that heal the earth, and all that inhabits it.

We ask that Craig Stevenson, and everyone else at Burt’s Bees ponder this question, posed by Jane Goodall:

Someday we shall look back on this dark era of agriculture and shake our heads. How could we have ever believed that it was a good idea to grow our food with poisons?

Katherine Paul is associate director of the Organic Consumers Association.