Ernie raised a number of concerns:

> “Tennekes says... that there 
> probably is no safe level 
> of application of this poison.”  

This is to be expected from someone in the business of selling toxicology
services to the EU community, as without a looming threat, there would be a
drop-off in R&D funding and test-services revenue.

> Tennekes, H.A., "The significance of the 
> Druckrey-Küpfmüller equation for risk assessment..."

Why not look at the paper before citing it here?  We addressed it here when
it first appeared,  so you can read all about it the archives. No actual
risk assessment was presented, no data was presented, no doses were
mentioned, and the paper isn’t even about bees at all.  It's about math,
nothing more.

In brief, the paper speculated about whether a "time-to-effect approach"
rather than a "dose-response approach" should be used as a basis for risk
assessment.  This is an old idea that has always had a small number of
proponents, but the consensus among the scientific community is that
dose-response is a more reliable basis.  There is a reason why consensus
tends to develop - people tend to use the tools that work best.

> I haven’t seen any serious attempt 
> to by other scientists to follow up 
> and prove or disprove Tennekes claims. 

This seems to be because Tennekes is somewhat outré in his claims, and the
reaction so far to his work among the scientific community as a whole has
been [...crickets...].  People simply go about their own work, and refute
Tennekes without making any direct reference to him.

As a general rule, someone who writes a book entitled "The Systemic
Insecticides: A Disaster in the Making", seems to have his mind made up
before he starts gathering data.
http://www.disasterinthemaking.com

Further, one who solicits donations for "independent" research on the same
website, seems to be lacking in credibility sufficient to attract the sort
of funding commonly available from grants and competitive-bid funding. 

I'm not sure where he fits in the spectrum between Dr. Lu, and the bulk of
the insect toxicologists who work in the field, but from the claims made,
Tennekes and Lu seem to be outliers.  I don't have the time, energy, or
biochemistry chops to go and fact-check everyone myself, so I am going to
have to look for a consensus among those who do the work, and accept the
scientific consensus as "proven", putting the burden of compellingly
refuting evidence on the outliers.

That said, I think Christina pretty firmly won the debate over the specific
issue of some small level of chemicals irreversibly binding to a site of
action (e.g. acetylcholine receptor of the post-synaptic neuron) versus the
flat Bayer claim of "100% removed or broken down by cytochrome-P450
detoxification enzymes".  

So, the actual question of value for beekeepers and regulators is this - if
neonics irreversibly bind to the AChE receptors of bees (and Christina would
say that they do at low levels), does this happen under field-relevant
conditions with field-relevant doses, and does it happen at a level high
enough to make a tangible difference over the lifespan of a worker bee?  A
queen bee?  An overwintering hive?  

I'd love to see the likes of Tennekes and Lu focus on THAT problem, but it
is easier for both of them to do things that are not really even relevant
to the issue, Tennekes waving around Druckrey-Küpfmüller, as if it were
something new and exciting, and Lu waving around doses that are at or only
slightly under the published LD50 for Imidacloprid.  Both have excellent PR
machines to spread their "discoveries" in the popular press read by
laypeople, so it really does not matter to them if their work fails to make
a contribution to the actual knowledge of value in addressing the problems
of bees and beekeepers
As one who has spent his own time and with his own dime training about 500
people on who are all still keeping bees in a neonic-free area, I would have
figured the world would have beaten a path to our rooftops to get us to be
the "control group" in exactly such a study.  So far, I hear
[...crickets...]

> Nobody has commented on the observation...
> the amount of dead bees found inside the 
> hives not account[ing] for the total numbers 
> of bees present prior to winter when they were alive

May I comment?  I did not, as I thought this would violate Bee-L's strict
prohibition against  necrophilaic equine sadism.  To gain perspective on the
issue, first point your web browser to the weather for Boston during the
period of Lu's study:

http://www.wunderground.com/history/airport/KBOS/2012/11/1/MonthlyHistory.ht
ml#calendar
http://tinyurl.com/lr48jd6

As one flips through looking for bee flight days (those with high tempos
above 50F)  during the winter of 2012-2013, one finds that only February
lacked good solid "bee flight days":

Nov - 10
Dec - 5
Jan -  5
Feb - 0 (One Day @ 47)
Mar - 8

So, where did the bees go?  They flew out the entrance and, as sick or dying
bees do, did not return.  

Why did some hives have more dead bees on bottom boards than other hives?
Better hive record-keeping during the study would have helped to answer the
question, but there is variation in the minimum temps at which entire hives
will "fly".  Everyone who keeps a notebook should have evidence of this
phenomena, even sister queens will head hives that fly at different temps.
Gotta be genetics.   

Also, there is always a larger number of dead bees on the bottom board in
cases where the hive population dwindles below the minimum "critical mass"
to keep warm and alive on the colder nights.  Yes, there is a tragic small
cluster of dead bees still on the combs, but many of the bees drop down to
the bottom board in this scenario when the last cluster fails to survive its
final night.

>  0.1  ng/g  LOQ being claimed by Lu’s 
> lab seems crucial for levels as low as 
> 0.25 ppB...

Obviously, if these lower levels have any impact at all on the bees, then
the detection and quantification of lower levels is of value.  But we
haven't answered the question for the higher levels that can be detected
with ease, so why get all worked up about lower levels?  

And remember, this is a fellow who fed a mere half-gallon of tainted syrup
per week to full-sized foraging colonies, and then divided the half gallon
by 50,000 "bees" for his "dose per bee", as if each and every bee in the
colony somehow miraculously shared equally in the tainted syrup provided in
each and every weekly feeding.   

Do I have to draw a diagram for anyone to illustrate just how brain-damaged
the assumptions are that leads to the "dose" claimed by Lu's paper?  I
thought not.

To quote Oscar Gamble of the NY Yankees, circa 1975: “They don’t think it be
like it is, but it do.”

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