>On  I don't see why it is acceptable to have standards in the US below the
European ones.

Gavin, I am in complete agreement!  As are the EPA and PMRA.  The problem
is that beekeepers in the US and Canada were not submitting adverse effects
reports to the regulatory agencies, so the agencies were not aware of the
problem (despite the dust kill in Germany in 2008) until relatively
recently.

By the time that the planting dust issue in North America came to the fore,
the agricultural industry had already widely adopted neonic-treated seed.
 This now meant that there was quite a bit of systemic inertia to overcome.
 I assure you that the regulators are frustrated by the fact that the
registrants did not quickly solve the issue, especially since it appears to
be mainly a mechanical issue.

I commend PMRA on their approach, and encourage beekeepers to keep the
pressure on EPA by submitting adverse effects reports to EPA.

The intertia of the system is frustrating, and the financial losses by
affected beekeepers are unacceptable.  There is currently a tremendous
amount of pressure on both the registrants and the regulators.  They have
heard it loud and clear.  I get the feeling that the problem will soon be
solved one way or another, as the regulators have reached the limits of
their patience.

-- 
Randy Oliver
Grass Valley, CA
www.ScientificBeekeeping.com

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