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Subject:
From:
James Fischer <[log in to unmask]>
Reply To:
Informed Discussion of Beekeeping Issues and Bee Biology <[log in to unmask]>
Date:
Sun, 20 Sep 2015 15:51:14 -0400
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>> "The Label is The LAW" chant beekeepers 
 
> I was the one who made that statement.

Many others said it long before any current Bee-L reader.  :)

Regardless, the statement remains absolutely (dare I say "flatly" again?)
untrue in the context of the specific case at hand of Sulfoxaflor.  All
Sulfoxaflor labels are now, per court order, toothless sets of suggestions,
nothing more.

Despite the many attempts to hijack the thread for unrelated and/or personal
agendas, my point in posting was to simply point out that the Federal
Insecticide, Fungicide, and Rodenticide Act ("FIFRA") only allows the
regulation of REGISTERED pesticides, so revoking registrations is NOT a
smart approach if the goal is to restrict/restrain the use of the subject
pesticide.

While "unregistered" pesticides might seem illegal, those purchased under
color of a registration cannot be retroactively declared "unregistered".  

The obviously superior approach is to sue for revocation of "tolerances" and
"uses" as this does not hamper the EPA's ability to police the chemical at
all stages, from manufacture to end user.  

I fail to see why this is a controversial point, as I merely suggested that
one concerned about a chemical would not want to see their efforts result in
the unregulated and completely unrestricted use of that chemical by anyone
smart enough to stock up in advance of a court ruling on news of a
well-publicized set of legal motions in a high-profile case.

I have no idea if the amount of this pesticide "in end user hands" is a
single pound or several metric tons.
I don't care at all, as we must plan for the fellow who buys by the metric
ton.

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