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Informed Discussion of Beekeeping Issues and Bee Biology

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Subject:
From:
Richard Cryberg <[log in to unmask]>
Reply To:
Informed Discussion of Beekeeping Issues and Bee Biology <[log in to unmask]>
Date:
Sat, 11 Jan 2014 17:04:54 -0800
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I did not bother to try and look up the solubilities of all the pesticides used in this study.  However, since my people determined the water solubility of chlorothalonil that is used in all regulatory submissions world wide, I happen to know it is well below 1ppm.  Thus any feed dosed above this level is going to contain mainly solid chlorothalonil, even if it has 1% methanol or 1% acetone in it as the feeds used in this study contained.  As most of the chlorothalonil is solid I really have no idea what exposure the larva had.  Those solids could easy mainly collect on the solid surfaces of containers or transfer devices.  This would result in a considerable underdose from expected.  Or they could easy mainly collect on the surface of the larva during feeding.  This would result in an overdose from expected.  The study seems meaningless to me as dose is poorly defined.  Probably the only real way to do such a study and have a well defined dose would be
 to do carbon 14 labeled feeding studies to guide food preparation and administration.  Something along  this line would be an absolute requirement for any study submitted in support of a registration.  I can not imagine any of the agencies I have dealt with spending much time considering a study done the way this one was performed unless there is a well documented uptake study that validates the techniques used.

Dick


" Any discovery made by the human mind can be explained in its essentials to the curious learner."  Professor Benjamin Schumacher talking about teaching quantum mechanics to non scientists.   "For every complex problem there is a solution which is simple, neat and wrong."  H. L. Mencken

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