Review of Bee Health

The Center for Food Safety’s Self-Review Is Not A Substitute for Peer Review

April 7, 2014

CRE

CFS’s Academic-Style Neonicotinoid Paper is NOT Data Quality Act Compliant

The Center for Food Safety’s report, “Heavy Costs: Weighing the Value of Neonicotinoid Insecticides in Agriculture” lists two External Reviewers on its Acknowledgements frontispiece along with reference to an anonymous reviewer. With respect to the independence of peer reviewers, OMB’s government-wide, binding Final Information Quality Bulletin for Peer Review[1] states that

 In its narrowest sense, independence in a reviewer means that the reviewer was not involved in producing the draft document to be reviewed. However, for peer review of some documents, a broader view of independence is necessary to assure credibility of the process.

 Thus, at a minimum, CFS’s External Reviewers should be independent of the document that they are reviewing. A review of the CFS report, however, reveals that both External Reviewers:

         —  had their published research cited in the CFS report,[2]

        —  had their unpublished personal communications cited in the CFS report,[3] and

        —  were prominently praised by name in the CFS report.[4]

 The CFS report also does not comply with other basic data quality standards. For example, the CFS report contains misleading and unsupported statements such as the assertion in its Executive Summary that neonicotinoids “are considered a major factor in colony collapse” even though the US Department of Agriculture (USDA) and the US EPA collaborated on “a comprehensive scientific report on honey bee health” unambiguously stating

 The parasitic Varroa mite is recognized as the major factor underlying colony loss in the U.S. and other countries.[5]

 The CFS report never mentions the USDA report, nor the Varroa mite, which is surprising since one of CFS’ named External Reviewers is a USDA entomologist.

 If CFS wants their study to be able to be considered by federal agencies under the Data Quality Act (DQA), their USDA peer reviewer should request that the Department of Agriculture conduct a full peer review of the document using the process and standards specified in OMB’s Peer Review Bulletin.