During the past three weeks there have been several reports of the new
prohibition on comb honey production from hives treated with Coumaphos.  Bob
Steven's, today, was just the latest.  This restriction is now on the labels
for FL, GA, WA, and MN and will be on the labels for every state that gets a
renewal of their 1999 label.  Several days ago  in "Another reason not to
use Coumaphos", I asked Bee-L members how I could make contact at the EPA to
discuss this label restriction.

I received several private responses, which were of considerable help.  Of
great interest to me was that one response provided exactly the right person
to contact, but was sent via a web site that makes it impossible to trace
the sender!  Big Brother watching?

I had a long conversation with the EPA person, which I will share.  First,
however, I have to tell you that while my contact was at a very high level
and was very knowledgeable, I cannot directly quote this person.  After our
discussion, I specifically asked that question and was told that their
policy is that the only persons who can talk for attribution are those in
the EPA's press office.  So, you have to trust me, or not.

The exact wording in question is:  SALE OF COMB HONEY FROM HIVES TREATED
WITH COUMAPHOS IS PROHIBITED.  This wording was added at the request of
Bayer, as was the additional 14 day waiting period between when strips are
removed and when supers can be put back on hives.  It was explained to me
that Bayer has no data to support these restrictions, but they just wanted
to be very conservative.  However, during the summer of 2000 Bayer has
promised to do such studies, so the 2001 labels may again be modified (based
on the outcome of the studies).

I had three questions that were addressed in our conversation:
* The comb honey restriction seems to run "forever".  Was that intended?
* Does the label restriction concerning comb honey production apply if
Coumaphos was used in the fall of 1999, and not in the spring of 2000?
* Why does the label not contain a use restriction or limitation such as
"This product is only to be used for the control of small hive beetle and/or
when there is documented resistance of varroa mites to fluvalinate"?

Question 1. The comb honey restriction seems to run "forever".  Was that
intended?

No.  By law, Section 18 labels are limited to no more than one year.
Products sold with Section 18 labels cannot be used after expiration of the
label.  (A surprise to me, and I wonder how anyone is supposed to know that.
Does the label say, "This label expires on xxxx, and use of this product
after that date is illegal"?)  During 2000, Section 18 renewals for
Coumaphos are effective from the renewal date until February 1, 2001.  (In
2001 all the state labels will expire (and, presumably, be renewed) on the
same date.)  As a practical matter, the intent of the label was to say "if
you treat in the spring of 2000, you cannot produce comb honey during 2000."
Personally, I think this could have been said in a manner that was clearer.

Question 2. Does the label restriction concerning comb honey production
apply if Coumaphos was used in the fall of 1999, and not in the spring of
2000?

No.  My contact wondered why anyone would think this could possibly be the
case, as it was clear to him that the 1999 label could not possibly apply to
2000!  Hmmm, this gets back to the question of whether it is clear to a
buyer  (who reads the label) that the label has an expiration date and
products sold under that label are not to be used after such date.

Specifically, my contact told me that if Coumaphos strips were used in the
fall of 1999 and not in the spring of 2000, beekeepers were free to produce
comb honey from hives so treated.

Question 3. Why does the label not contain a use restriction or limitation
such as "This product is only to be used for the control of small hive
beetle and/or when there is documented resistance of varroa mites to
fluvalinate"?

Simply put, the answer to this is "Because no one ever asked for it."  The
EPA is convinced that if the label is followed, there will be no detectable
(or dangerous) levels of Coumaphos in liquid or comb honey.  As their job is
public safety, they would have no reason to ask for wording similar to that
mentioned above.  However, my contact acknowledged that there were at least
two good reasons for such label wording:
* Eventually, mites will (not may, but will) develop resistance to
Coumaphos.  Restricting use to only when necessary will delay such
resistance.
* If the label is not strictly followed (not only as to duration of
treatment, but also as to treatment methodology concerning number of strips,
use of gloves, removal of supers, etc.) there could be very severe effects
as Coumaphos is a very dangerous chemical.  This could lead one to say the
chemical should be avoided if at all possible.

My contact said that if they were to get such a request from beekeeping
organizations such as the ABF, EAS, state beekeeping organizations, and/or
state departments of agriculture, they would be taken very seriously.  My
impression is that it would be "easy" to get this kind of wording added if
groups such as those listed were to make such a request.

If asked, I can provide the name and telephone number of the proper person
to whom such requests should be forwarded.

I hope this information is helpful, and thanks again to all those who helped
me make the proper contact.



Lloyd
Lloyd Spear, Owner, Ross Rounds, Inc.  The finest in comb honey production.
www.rossrounds.com