" It is also unrealistic to expect any registrant to invest the considerable sums...."
If the honey bee industry really needed such labels the industry would be more than happy to invest the money.  In a worst case the cost would only be to do residue studies conducted in compliance with good laboratory practices where the field trials took place in half a dozen different climates plus pay any data compensation to the existing registrant plus perhaps some acute tox on formulations done in compliance with good laboratory practices.  The registrant would also need to package, label and sell a product but that stuff can all be contracted out to commercial  pesticide formulators.  I would guess you could be in business for a million $ tops and likely well below that figure.  If the honey bee industry can not afford that kind of very minimal cost they are not very hungry and do not have any meaningful problems that they need solved.  There are existing commercial labs that would be happy to conduct the residue work that are all set up to do good laboratory practice compliant studies.  There are field contractors all over the country that are set up to do field trials in compliance with good laboratory practices.  In those field trials the beekeeping industry would need to supply the bees used in testing and probably also need to supply man power to assist in conducting the studies because you probably can not find many field trial contractors who also have bee keeping skills.  I know some of those guys and they are used to running studies where they may not have all the expertise needed to run the trial.  What they bring to the table is the documentation and history of EPA inspections to do any field study with GLP compliance.  It would be no problem at all finding out what EPA would need to expand the registration label.  All that needs to happen is someone serious about being a registrant and with demonstrated financial backing to sit down with EPA and ask them what is needed.  In my experience they would be more than happy to talk to any serious potential registrant.  But, they are not going to waste their time having such a conversation with me or likely anyone else on this list.

If the honey bee industry does not have a problem that justifies them spending any money I see no reason in the world for the USEPA to do a single thing to help them.  They already went way out of their normal operating channels to approve what they have already approved.  If they had approved some insecticide for watermelons with the lack of data and documentation that they had to approve oxalic acid to kill mites the whole beekeeping community would be crying and screaming foul and accusing them of total incompetence.
Almonds alone amount to over $300 million a year income to the beekeeping industry.  How many million $ do hobby beekeepers spend each year on package bees? In my little dink county I estimate there are 250 packages purchased every single year.  If we are typical of Ohio that means state wide 25000 packages each year.  That is a fair hunk of money spent.  The amount of money it would take to get all the oxalic registrations beekeepers could dream up would only be a tiny fraction of those revenue streams.  Yet, were I a commercial beekeeper I am not so sure I would pay a penny to get such registrations.  Do I want more competitors in almonds and my other pollination jobs?  Do I want hobby people to have much smaller numbers of hive deaths each winter and cut into my package sales?  I think I just might be real happy with the present situation and not want any help.


             ***********************************************
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