Peter B wrote:

I know, but look at it this way: the maximum life expectancy of a human is
> what, 120? Has any of us ever met someone who lived 120? The average, of
> course is half that in most "under-developed" regions. And, in North
> America, where all the poisons are, it is nearing 80.


But 455 days was not an "outlier".  All the results from PEI were very
long.  It has to do with our soils here, which are low in organic matter
(where they have been mined for potatoes), very acidic and sandy.

Look at the half life results for clothianidin in soils.  They are all over
the place ranging up to several years.  They were discussed last year on
this list.   But in that case they were correlated with soil types around
the US.  So it might be fine to give an average half life for clothianidin
or a weighted average half life (averaged based on number of samples???),
but if you happened to live in the particular soil area of Virginia? where
the half life was 8? years (don't remember the exact location or years, but
think that might be right)  then in that area you would not like someone
regulating on the basis of averages.

And that is why our PMRA required a soil study here, and did not accept
studies from elsewhere.  They were very concerned with the results of the
soil study and required Bayer to do more testing.   That was done and Bayer
came up with different results, and then averaged them with the first
study.  I would love to look at the methodology of the second study, but
that is also proprietary.

Stan

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