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Subject:
From:
Peter L Borst <[log in to unmask]>
Reply To:
Informed Discussion of Beekeeping Issues and Bee Biology <[log in to unmask]>
Date:
Mon, 4 Feb 2013 22:56:51 -0500
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Sainath
Your reply is entirely disingenuous. There are concepts smuggled into your paper that are much more clearly espoused elsewhere, to wit:

> Practice policy has thus far not established a definitive role for imidacloprid in causing CCD. Accordingly, the EPA has refused to take imidacloprid and other similar agrochemicals off the market. 

> We suggest that given the commercial stakes for beekeepers and the health impacts on bees, the regulatory preference for false negative over false positive results is misguided, and serious consideration should be given to precautionary regulatory policy.

>  Several beekeepers observed CCD unfolding in the fields of the commercial growers with whom they contract. They consistently noted connections between the occurrence of CCD and the proximity of their hives to fields treated with relatively new systemic insecticides such as the neonicotinoid imidacloprid. 

> INSTEAD OF A SOUND SCIENCE APPROACH TO PESTICIDE REGULATION, WE ADVOCATE A BROADLY PRECAUTIONARY ORIENTATION. THIS ENTAILS A REGULATORY PREFERENCE FOR FALSE POSITIVES OVER FALSE NEGATIVES. REGULATORS MUST ACCEPT SUGGESTIVE DATA WHEN ALL UNCERTAINTIES ARE NOT RESOLVED.

> A precautionary approach in the case of CCD, in contrast, could hurt agrochemical companies, because indirect evidence of the sublethal effects might justify removing certain systemic insecticides from the market or, more likely, restricting their use in some fashion. 

> If certain agricultural systemic insecticides contribute to CCD, then beekeepers are helped by restricting bee exposure to these chemicals. If it turns out that the toxins of concern are not involved in CCD, beekeepers will be harmed less by the move to remove it from use than they would be if it transpired that they contributed to CCD, but exposure had not been restricted.

> More generally, the CCD case should lead us to consider the value and drawbacks of EPA’s sound science approach to pesticide regulation. If sound science is not inherently superior to a precautionary approach, why should we use it? Should the federal government have regulatory policies whose scientific foundations systematically support the interests of some economic actors over others? 

source: http://www.issues.org/27.4/p_suryanarayanan.html

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