I couldn't agree more with George, inspectors are the first line of
outreach and education, especially in areas with lots of small bee operations.

In our part of the world - west of the Mississippi, where bee operations
may range from 2500-60,000 colonies, inspection takes on an addition, vital
task.

Health certificates for migratory beekeepers are critical if you want to
cross state lines, and you want to be sure that the inspector knows
something about bees.  When I started in bee work (30 years ago), every
state had a full or part-time bee inspector.  Now days, you are lucky if
the person who checks out the spuds and cherries is also authorized to
check out bees. Many inspectors don't know how to inspect a hive, and some
are down right afraid of bees.

George may not know about this issue - Maryland is one of the last hold
outs with some very talented and committed people in a state-supported
inspector/education program.

Taken a step further -- without dedicated or properly trained inspectors,
essential concepts like basic orchard management (don't spray with
understory flower in bloom) fall out (e.g., Minnesota popular groves).

Some state inspectors don't recognize pesticide kills, and EPA thinks 25%
bee losses are acceptable!!  Even if the inspector does recognize a
possible pesticide problem, they don't know how to investigate, keep chain
of custody records, properly acquire, label, store, and handle samples.

State analytical labs are virtually out of business, and I and Dan Mayer
are probably members of a very short list who remember when EPA had a test
lab for pesticides in bees.  With respect to Imidacloprid, few labs are set
up to analyze for nicotinic insectides,  and getting a copy of the lab's
standard operating procedures is like pulling teeth.

The labs assure us that they follow Good Laboratory Practices.  That means
nothing to me unless you show audited results.  Anyone can claim GLP, but
if the lab won't produce evidence of performance, the claim and any
subsequent data is useless.

Since the beekeeper indemnity program vanished, getting any restitution for
bee losses is problemmatic and an expensive, drawn-out process.  One that's
futile if the state doesn't have someone who knows how to investigate the
alleged incident -- and I assure you, most don't.  There are some
exceptions - Washington, California are a couple that stand out -- they may
not be perfect, but they at least still have some idea of how to go about
it, and have someone to do it.

Its no wonder that EPA thinks bee kills from pesticides are something only
a few beekeepers experience, or that they are reading public comments from
6 years ago for the first time (they've been busy with other things), and
that states drag their collective feet when it comes to investigate alleged
bee kills.

Keep in mind, many inspectors are so poorly trained, they think a bee kill
must be from mites.

And, we've got beekeepers, big beekeepers, who are buying into the same
idea.  First bee drop and they worry about mites.  Maybe it is, maybe it
isn't.

Taken a step further, it shouldn't be surprising that we encounter
situations such as:

1) a state judge declaring pesticide labels are guidelines, advisory

2) a state attourney general trying to talk me into consulting for the
state AFTER I told him that I would represent the beekeepers.  He didn't
seem to see any conflict there - I could represent the beekeepers and
consult to him.  Somehow, I didn't agree.

3) a large beekeeper complaining about loss of 50% of his hives this year
from a plane spraying a new pesticide on cotton, who had no idea of why he
should be concerned that other beekeepers were complaining of suspected bee
kills from imidacloprid, one of the nicotinics.  That is, until he learned
that the new pesticide that killed his bees was another nictonic product
like imidacloprid.

4) bee and beekeeper research groups focused on mites to the point that
they haven't realized that pesticide problems are at an all time high.

None of this is to dismiss mites, SHB, killer bees, or dumping of honey.
But, I think its time that the industry took a deep breath, and looked
around.  Feuding over the honey board may be mute if mites, AHB, SHB, AND
PESTICIDES put everyone out of business.

And, with this posting, I expect to join George in being too blunt and
saying things that many won't like.  However, just answer my phone or
e-mails over the last two years, and you might understand why this issue is
taking on such importance to Dan and I, and we think, it should, to the
industry.

Thanks

Jerry Bromenshenk
Bee Alert Technology, Inc.
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