>
> >Often missing from discussions about neonics and pollinators is whether
> the current neonic usage patterns actually benefit growers.  As we all know
> (but often do not discuss), it is not simply a question of either using
> them with no restrictions or banning them completely - the best approach is
> to use them in a way that maximizes the benefit while minimizing the cost.


The other point is that when neonics are applied as "seed treatments," they
are not considered to be a "pesticide application," so the seed and/or chem
companies can easily push them onto growers as part of the seed coating,
and the growers are not restricted by label restrictions with regard to
pesticide drift, etc.

In actuality, applying neonics to the seed is hardly a "seed treatment" (as
is a fungicide), but rather a prophylactic insecticide application, later
to be absorbed by the roots.

This unfortunate glitch in the regulatory system helps to make growers
unaware that they are indeed applying an insecticide, as well as helping
them to claim lack of responsibility for pesticide drift damages.  And in
states like California, absolves them from filing a Pesticide Use Report.

Beekeeper Jeff Anderson, with the financial support of myself and others,
is trying to resolve this loophole with a lawsuit against the EPA.

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

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