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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:
Thu, 11 Jul 2013 17:54:18 -0400
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The quotes attributed to Dr. Whalon misrepresent the lawsuit's intent.

> “Here’s the crazy thing. We’re still using 
> organophosphates, nerve toxins, in the hive,” 
> he [Mark Whalon of MSU] said...

> “Do pesticides (like neonics) have an impact? Absolutely. 
> But how can we be talking about pesticides in the field 
> when we’re still using primitive chemistry to control 
> mites in the hive?”

Blaming the beekeeper for using organophosphates is misdirection.  The
Sulfoxaflor lawsuit is over lax bee protection language on the label of a
product that is acknowledged by the EPA to be "highly toxic to bees [when]
spray droplets are still wet".  So, at minimum, one would expect the same
sort of language that other such pesticides have, along the lines of "do not
spray blooming plants, or near blooms".  But this pesticide has NO SUCH
LANGUAGE. Both the AHPA and ABF are plaintiffs, and after seeing the
proposed labels, I'd happily sign on as a plaintiff, too.  

> the public shouldn’t accept simplistic platitudes and sound bites

And we shouldn't accept simplistic sound bites that are dismissive!  

The suit at issue is the only available method to get the EPA to at least
fix the label, add some "bee protective language" to the label, and hence
protect bees with the force of law.  The label contains no language
compelling mandatory compliance with prudent bee protection measures, such
as "do not spray under conditions x, y, or z".   See 
http://cdms.net/LDat/ldB67003.pdfý for a sample label.

Here's the relevant quotes cut and pasted from the label:

1) "This product is highly toxic to bees exposed through contact during
spraying and while spray droplets are still wet. This product may be toxic
to bees exposed to treated foliage for up to 3 hours following application.
Toxicity is reduced when spray droplets are dry.  Risk to managed bees and
native pollinators from contact with pesticide spray or residues can be
minimized when applications are made before 7:00 am or after 7:00 pm local
time or when the temperature is below 55° F at the site of application.
Refer to the Directions for Use for crop specific restrictions and
additional advisory statements to protect pollinators."

This is the mildest sort of Caspar Milquetoast "advisory" language, worded
in the passive voice to emphasize just how optional the mitigation steps are
for the farmer. "Risk can be minimized by x, y, and z" is optional for the
farmer, and if we have learned anything about the people who order around
teams of undocumented migratory farm workers with spray rigs and inadequate
safety gear, anything optional will be completely ignored.

2) "Wind: To reduce off-target drift and achieve maximum performance, apply
when wind velocity favors on-target product deposition"

But they just said that this pesticide was "highly toxic to bees exposed
through contact during spraying and while spray droplets are still wet"! How
can they then merely mention "reducing drift", and only in "advisory" rather
than "mandatory" language compelling compliance?

3) (Crop-Specific Instructions)
"Advisory Pollinator Statement: Notifying known beekeepers within 1 mile of
the treatment area 48 hours before the product is applied will allow them to
take additional steps to protect their bees."

This misleads farmers into thinking that mere notice to beekeepers of a
spray absolves them of legal liability (under FIFRA) to not kill
pollinators!  It even seems to put the responsibility on the beekeeper to
"take additional steps to protect their bees"! 

4) "Also, limiting application to times when managed bees and native
pollinators are least active, e.g., before 7 am or after 7 pm local time or
when the temperature is below 55°F at the site of application, will minimize
risk to bees"

Again, more passive-voice "advisory language". But wait a moment, sunrise
today was at 5:35am.  I know, because my bedroom windows face due east.
Sunset will be at 8:27pm.  Bees are often active before 7am and after 7pm,
even after the sun has (technically) set, at dusk. 

The specific science that refutes the claims attributed to Dr. Whalon is
simple - No one has ever claimed that bees or brood were harmed in the
slightest by the very tiny dose of Coumaphos administered when in Check-Mite
strips are properly used.  I've not yet even heard of any problems as a
result of bees foraging and encountering Coumaphos in the feild.   Further,
even though there is no protective glove that can truly keep a person
handling Coumaphos from absorbing a small amount of Coumaphos as a result,
no one has claimed that even a lifetime of handling the very low-dose
Check-Mite strips every year poses any tangible risk to a beekeeper.  

The risk posed by organophosphates at AGRICULTURAL DOSES is considerable to
farmworkers. Cumulative build up causes severe nerve damage to agricultural
handlers and applicators, no matter how robust their protective gear.  

While it is embarrassing that beekeeping is one of the last factions in
agriculture to move away from organophosphates, there is no reason to give
the false impression that per-label Coumaphos (or Fluvalinate) use has
anything to do with the problems of bees and beekeepers, other than being
less-than complete controls for varroa.

The punchline is that it is even misleading to classify "Sulfoxaflor" as a
"neonic", as it works very differently from known neonics like Imidacloprid,
but only the bio-chem majors will get the joke.

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