> I understand that in June 2004 Gustafson LLC (Bayer CropScience)
> petitioned the United States Environmental Protection Agency (EPA) that 40
> CFR 180.472 be amended by establishing tolerances for residues of the
> insecticide imidacloprid in or on soybean seed at 1.0 ppm and soybean meal
> at 2.5 ppm. The proposed tolerance for soybean meal was subsequently
> revised by the petitioner to a proposed tolerance of 4.0 ppm.
>

Note, that is the seed, not nectar or pollen.

For example, 10% soybean meal at 4000 ppb (4 ppm) imidacloprid would result
> in a 400 ppb exposure level that may cause long term irreversibble damage
> to the consuming bees.
>

This is not addressing the concentrations found in the nectar or pollen.
Plus, at those concentrations  the bees would be dead not damaged.

Bill Truesdell
Bath, Maine

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