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Subject:
From:
Peter Loring Borst <[log in to unmask]>
Reply To:
Informed Discussion of Beekeeping Issues and Bee Biology <[log in to unmask]>
Date:
Tue, 3 Sep 2013 11:19:58 +0000
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On Sep 2, 2013, at 10:41 PM, Bob Harrison <[log in to unmask]> wrote:

> In the U.S. the beekeeper is allowed to use less than label  but not a higher amount than label.

This is not quite correct. You may be "allowed" to under some circumstances, not others.

FIFRA regs state:

> TO USE ANY REGISTERED PESTICIDE IN A MANNER INCONSISTENT WITH ITS LABELING.-The term "to use any registered pesticide in a manner inconsistent with its labeling" means to use any registered pesticide in a manner not permitted by the labeling, except that the term shall not include (1) applying a pesticide at any dosage, concentration, or frequency less than that specified on the labeling unless the labeling specifically prohibits deviation from the specified dosage, concentration, or frequency



Many labels specific say not to use less:

> To delay development of insecticide/miticide resistance, the following practices are recommended:
> 
> • Base insecticide applications on comprehensive IPM programs. This program should include an insect management program that includes cultural and biological control where possible.
> 
> • Use good resistance management strategies established for the use area. This may include the use of insecticide rotations with other groups of insecticide and miticides in an IPM program.
> 
> • Always apply at the recommended rates and according to label directions. * Do not use less than recommended label rates *


This one includes the reasoning for staying with the recommended dose:

> Any insect population may contain individuals naturally resistant to pesticides. The resistant individuals will eventually dominate the insect population if these insecticides are used repeatedly over long periods or to consecutive generations. Pesticides may not control these resistant insects. Local experts should be consulted for resistance strategies and specific recommendations. It is recognised that resistance of insects and mites to insecticides and acaricides can also result from enhanced metabolism, reduced penetration or behavioural changes that are not linked to any site of action classification but are specific for individual chemicals or chemical groupings. Despite this, alternation of compounds from different chemical classes remains a viable anti-resistance management technique.
> 
> To delay insecticide resistance
> 
> •  Avoid the exclusive repeated use of insecticides from the same chemical subgroup.
> 
> •  Do not use less than recommended label rates of any insecticides.

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