> Bioaccumulation is something the 
> regulators have looked at very 
> carefully ever since the DDT days.  

The EPA is far less "careful" than one might think, as follows:

"The short-term acute and subacute laboratory studies provide basic toxicity
information that serves as a starting point for the hazard assessment. These
data are used to... indicate whether further laboratory and/or field studies
are needed."

https://www.epa.gov/pesticide-registration/data-requirements-pesticide-regis
tration#nto
https://tinyurl.com/y8mms7td

So, if the short-term tests don't raise concern, then there may not be any
longer-term tests done.   When one thinks about this, the error in reasoning
seems profoundly basic.  

Yet again, the burden of proof is on the public to prove that a corporation
is externalizing what should be its internal costs on the public.  This is
exactly why the EPA "Superfund" exists - it is common for a company to
extract the value from a product or process, and leave the taxpayer holding
the bag for the inevitable cleanup by going "bankrupt" after making the bulk
of the money possible.

> I have no first hand knowledge at all about fipronil 
> and how it behaves in the environment, nor how it 
> is degraded by non target organisms.  But, the fact 
> it got registered tells me those kinds of studies had 
> to have been done.  

The National Pesticide Information Center is a good reference, and does what
it says:

Here's their very good list of studies, seems exhaustive.  Don't see any
long-term studies.
http://npic.orst.edu/factsheets/fipronilrefs.html

The plain-english summary is here:
http://npic.orst.edu/factsheets/fipronil.html#wildlife

"fipronil is highly toxic to sea and freshwater fish, and highly toxic to
sea and freshwater invertebrates. Two fipronil metabolites were also tested
in freshwater fish and invertebrates and were more toxic than fipronil.  In
other studies, fipronil was found to be highly toxic to some birds, but
practically non-toxic to ducks. Fipronil was also found to be highly toxic
to honey bees, but not toxic to earthworms."

Metabolites "more toxic" than the pesticide itself as it is applied seems
pretty damning all by itself.

But the take-away here is that tests of chronic low-level impact on
non-target insects are rare, and are triggered only by short-term tests.
That's "reasoning" that defies polite description.
 

             ***********************************************
The BEE-L mailing list is powered by L-Soft's renowned
LISTSERV(R) list management software.  For more information, go to:
http://www.lsoft.com/LISTSERV-powered.html