>
> >There is a small problem with this thinking.  Right now not every farmer
> is a licensed pesticide applicator.  If you make the seed dressing a
> License issue,  then many farmers will have legal issues,  and many more
> will then become licensed applicators.


Charlie, once again you start a post by telling someone that they have a
problem with their thinking.  But since we are friends, I will nevertheless
reply politely : )

 My friend, you appear to forget that I come from the nation's main
agricultural state, in which nearly every pesticide application requires a
Pesticide Use Report, and even us commercial beekeepers carry Pesticide
Applicator's Licenses (in order to apply Apiguard and MAQS).  Yet
California farmers and beekeepers compete on the same playing field with
those of the other 49 states that are free of such regulation.

Thus I cannot agree with your argument that such regulation would be
competitively onerous.  Any Calif grower would like to have the playing
field leveled.

IMHO, no grower should be allowed to apply any highly-toxic restricted
pesticide to hundreds of acres without demonstrating knowledge, and being
held legally responsible for not following the label.

Most growers in Calif hire a PCA (Pest Control Advisor) who helps them to
practice some degree of IPM.

Anderson's lawsuit was supported by a huge loss that Brett Adee suffered
from a planting dust issue.  But he was not able to sue for damages due to
the "seed treatment" exemption.  The grower who filled the environment with
clothianidin was clearly irresponsible about pesticide drift, yet could not
be held accountable.  That drift not only killed Brett's bees, but covered
surrounding vegetation, and got into streams.  To me, this is unacceptable.

The exemption also means that there is little traceability of the amount of
seed treatment chemicals going into the environment.  In California, I can
trace most every pesticide application in the State via the public
database, but I can't trace seed treatments.

The seed treatment exemption would apply to fungicides or biologicals
applied to protect the seed.  But in my mind it should not apply to
insecticides which have nothing to do with the seed, but are rather
convenient prophylactic insecticide treatments for pests which may later
attack the plant itself.

-- 
Randy Oliver
Grass Valley, CA
www.ScientificBeekeeping.com

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