>  This spring the California
> Department of Pesticide Regulation (DPR) decided to request more
> information on the effects of the uses of the nitroguanidine class of
> neonicotinoids.

I think bowed to the increasing pressure would be more appropriate.


>  The decision to request this review was based on an "adverse effects
> disclosure" pertaining to imidacloprid.

What is interesting to me is the time it took for the DPR & the EPA to act.
The fact these products were allowed to be sold without the required testing
and Bayer was given years to come up with the required testing. No
independent testing was ever done. inert ingredients are not required to be
on the label.

When I see the first EPA person fired I will believe the EPA is taking the
situation seriously.

>  The bits of data that were coming in demonstrated that residues of
> imidacloprid in the blossoms of treated trees could exceed, in one case by
> twenty times, the LC 50  for a honey bee, which is estimated to be ? 185
> ppb.  An LC 50  is the lethal concern-
> tration that would be expected to kill 50 of 100 bees consuming that dose.

The above has been sent to the EPA for years . The above is not new news!

>  The major concern relates to pollinator exposure,

Not new! Pollinator exposure is simply collateral damage in the eyes of the
chemical companies and best handled by PR and spending 50 million on
Washington lobbyists like Bayer did in 2006.

Look at BP and the oil spill. The largest skimming ships in the world sit
while people wait on shore to clean up the oil. I would like a job working
20 minutes an hour (getting paid for 60 minutes ) thanks to OSHA! BP would
rather spend the money on TV commercials and PR.

>  DPR hopes to obtain residue analyses on nectars and pollens of treated
> agricultural crops that require pollination.

Why not simple go with the volumes of information you already have?

 DPR also is going to require results from
> studies designed to determine the consequences of having residues in the
> diets of various stages of honey bee development.

Why not have a 10 year study done and then decide? Let me get this right.
Bayer is allowed to market imidicloprid without the *required* testing.
Bayer keeps kicking the can down the road to produce such testing . All the
while imidacloprid is on the market.

The DPR wants additional testing to prove or disprove the testing all ready
on its desk.

current testing shows problems but instead of making label changes the DPR &
EPA wants more testing.
Why not a label change or two?


>  US EPA also has a review docket for imidacloprid under way.  In an
> attempt to better ensure a "level playing field" for the neonicotinoid
> class as a whole, EPA will be looking at the rest of the neonicotinoids in
> fiscal year 2012.

Why so soon! Two and a half years from now!

*In my opinion* this is simple EPA PR and displays there is really little
concern for bees & native pollinators. If the EPA was *really* concerned why
not a freeze on new products using these products until the review? Doing so
would cause Bayer to want to speed up the review instead of prolong the
review.


>  I have reviewed enough published information on neonicotinoids and honey
> bees to know that the findings are going to come in many shades of gray,
> not in black and white.

The EPA has enough facts on Imid buildup and in a couple other areas to see
changes need made. Beekeepers are simple a sandspur in the toe of Bayer. The
EPA & DPR are the only chance beekeepers have to get a few label changes but
we simply lack the clout to get things done.

My two cents worth!

bob

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