PESTICIDE LABELS AND BEES
   What the Labels Clearly Do and Do Not Say
  (- Often Misrepresented and Misunderstood)
  Along with Logical, Common Sense Implications
 
There are two types of  messages about bees on many insecticide labels, which
are placed under environmental hazards.  These give specific instructions
which are statements of the pesticide law for that particular pesticide.  One
indicates hazard by direct contact only; the other indicates hazard by direct
contact and by residues. Both types prohibit application while bees are
foraging. obviously the ones with no residual effect are safe for use around
bees, provided that they are not foraging at the time of application. Those
that are clearly marked as residual would logically be prohibited if bees
forage within the residual activity period of the pesticide, in other words
on any plant that is attractive to bees, during the bloom period of that
plant.
 
1.  It is the applicator's responsibility to comply with the label
directions.  This responsibility cannot be transferred to beekkeepers or any
other party.  The applicator has chosen to use a material with environmental
hazards, in this case hazards to pollinators, and it is his responsibility to
use it safely by complying with label directions.
 
2.  The directions refer to the foraging bees, not the bee hives.  It is
irrelevant therefore whether the hives are placed on the property to be
sprayed, or whether they come from other properties within foraging range of
the bees.  Removing hives from the property where application will occur does
not necessarily indicate compliance with label directions, bees may be coming
from adjacent properties or unknown colonies on the property.
 
3.  The label directions protect the foraging bees in the application area,
whether the bees are kept or feral, and they protect all bees, whether
honeybees, solitary bees, or bumblebees (non-Apis bees).
 
4.  Many crops and even weeds are highly attractive to bees during their
blossom period. Compliance with label directions would logically indicate a
necessity for applicators who use materials with bee protection directions to
have a minimum knowledge of what blooms are attractive, and to have some
system of monitoring to see if foraging bees are present.  Failure to
monitor, prior to application,  when there is bloom attractive to bees, is
negligent. The proper role of extension and other pesticide advisors would be
to educate the applicator on situations where bees will be foraging, and help
him monitor, so that he can avoid violations.
 
5.  Communication with beekeepers, while certainly a good idea, does not
release applicators from compliance with label directions, and demands that
beekeepers take the responsibility for protection of the bees indicates
intent to wilfully misuse a pesticide, which changes violations from civil to
criminal status.
 
6.  A public official, who encourages applicators to demand that beekeepers
take the responsibility for protection of bees is:
     a.  Recommending pesticide misuse - he is substituting an alternative in
lieu of compliance with pesticide label directions.
     b.  He is committing a malfeasance, in substituting a system that only
protects the bees which have a human defender.
     c.  He is seizing the property of the beekeepers involved, without
compensation, in violation of Ammentment V of the Constitution of the United
States of America.
It is the  proper and logical role of public pesticide advisors to teach
applicators how to comply with label directions, ie. how to establish whether
bees will be foraging in the application area.
 
7.  On crops which are known to be attractive to bees, it is a negligent
recommendation of pesticide misuse, to recommend use of an insecticide which
has a direct contact type of label direction, without a warning that use,
while bees are foraging, is in violation.  It is even more a recommendation
of
misuse to recommend a pesticide with a residual type of label direction at
any time during bloom, because bees will be foraging during the residual life
of the pesticide.
 
    I have seen hundreds of bee kills from pesticides.  Every single case has
involved a violation of label directions.  NO EXCEPTIONS.  If bee directions
on pesticide labels are scrupulously followed, the poisonings of our
pollinators will drop to negligible levels.
 
   The law is a good one, but it is given only lip service.  It has not been
implemented into pesticide recommendations, which often give applicators an
alternative to circumvent label directions - that of sloughing off
responsibility to beekeepers.  This is the pre-FIFRA system, which never did
work, and has cost billions in lost pollination by killing off feral bees and
making beekeeping unprofitable.
 
   FIFRA set aside the previous precedent.  It made the applicators
responsible by specific label directions, directions which they often find
inconvenient, and have sought to evade ever since.  They have been aided by
authorities, who advise alternatives to compliance, and who refuse to enforce
the clear meaning of the label directions.  It is time for reform.
 
    Public officials who advise applicators how to circumvent compliance with
label directions must be held responsible for this seizure of the property of
the beekeepers without compensation, a violation of Ammendment 5 of the
Constitution of the United States.
 
David L. Green                    Internet:  [log in to unmask]
Dave's Pollination Service                  Eastern Pollinator Newsletter
PO Box 1215, Hemingway,   SC   29554