At 12:22 AM 4/4/00 +0200, you wrote:

Peter, the guidelines are clearly spelled out in the Federal Register and
on EPA web pages.  We can argue at length about the appropriateness of the
required tests.  But what is more fundamental is that EPA has tended to
move from bees as the most important species to be protected (the only
non-target species named by the FR and EPA) to a generic non-target
organism (which they tend to translate as water fowl).  In the last year, I
have read over 1500 pages of EPA documents concerning test protocols,
guidelines, requirements, etc.

Two trends are disturbing - much more to me than the issue you bring up:

1.  EPA likes simplistic protocols - and ignores the advice of the people
who pioneered testing for bees and pesticide hazards.  This is confounded
by Congressional pressure to privatize testing.

Done right, these tests take time, cost $$, and should be available for
public and scientific review.  When Atkins and Johansen at Universities in
CA and WA were doing these tests, they recognized the need for colony
replication and publication of results.  But private firms have to make a
profit and often collapse the tests onto one colony - because of time and
costs.  They also tend to emerge brood to get bees of an even age - but
that's not what the pesticide hits.  Atkins and Johansen knew that colonies
vary in susceptability and that forager bees are not tenurial adults (just
emerged from the pupae).  So nowadays- hazard assessments for label
registration may be based on a single colony and young bees.

2.  Private firms generally do not publish results.  You have to go through
the freedom of information act to get the results (and to do that you have
to know the exact formulation tested).  Whether you agree or disagree with
their methods of testing, Atkins and Johansen published.   The remaining
academic doing this type of testing is Dan Mayer in WA, who worked with
Carl Johansen.

3.  When the beekeeper endemnity program was in place in the U.S. (before
Ronald did away with it), EPA and others had labs that could investigate
bee kills AND the beekeeping organizations made themselves heard load and
clear at the U.S. Congressional level.

With mites, africanized bees, etc., and the chemicals used to control hive
beetles taking center stage, many in EPA tend to think that by restricting
the use of methyl parathion, the pesticide issue and bees has been more or
less resolved (or at least is less important than mites and beetles).  But
EPA remains concerned about birds.  Why? Because the bird folks (those who
love birds and those who hunt birds are very vocal).

My opinion is that when the endemnity program ended, most beekeepers
started taking their lumps.  Only a very few strident voices told the
agency that pesticides continue to be a problem - and the agency tends to
ignore one or two vocal critics if they are not hearing from the beekeeping
industry (that is, the beekeeping organizations or lots of beekeepers)

As such, with the exception of beekeepers telling EPA why they need
chemicals (a pesticide) to control beetles, EPA will continue to focus its
non-target organism protection on the warm, fuzzy, or feathered critters -
rather than bees.

I have worked with EPA for over 27 years.  The agency is not indifferent,
but it does respond to the squeaking wheel - and the beekeepers have been
waving the flag for other issues - mites, beetles, africanized bees.  If
the agency does not get continual input about the critical need to
adequately protected pollinators, it is likely to assume that the
bee/pesticide problem is under control and that other issues, such as the
protection of birds is more important.

The good news is that the agency does respond to public pressure.  But I
can't speak for the beekeeping industry.

All of the above is my own personal opinion.  Many of you have heard me say
at meetings, that if you don't let the agency know your problems/concerns,
you have no one to blame but yourselves if the agency de-emphasizes
pollinator protection.

Cheers,
Jerry






>It appears to me that there is a serious lack in testing procedures - I
>say this because pesticides are put on to the market not having been
>tested regarding their toxicity when bees come into contact with the
>active molecule (or the resulting metabolites).
>Often an active ingredient in allowed and passes by so called
>controlling commissions due to the fact that it method of application
>does not bring it into direct contact with the bees.
>When this is the case, there are few, limited or no tests applied to the
>substance relating to effects on bees- a handy way of getting around a
>problem.
>E.g.. Systemic pesticides may be applied to a plant before flowering
>periods, therefore allowed, its target being aphids-nothing is mentioned
>about bees- NO NEED - WHY LOOK FOR  PROBLEMS.
>Companies wait until there is a problem, fight all the way, hoping that
>legal argument slows down the procedures until the material in question
>looses its efficiency and it needs to be replaced anyway
>Looking up legal requirements (and I do understand why) tests are
>required for human health, "animal health"- but bees- very little!!
>Are Beekeepers so easy to roll over?
>If a kind soul could indicate to me where I might find the regulations
>stipulating the basic steps-taken by the "authorities" when a company
>wishes to place a substance on to the market. i.e. what criteria decides
>which tests are to be applied and why;
>Peter
>
>
Jerry J. Bromenshenk, Ph.D.
Director, DOE/EPSCoR & Montana Organization for Research in Energy
The University of Montana-Missoula
Missoula, MT  59812-1002
E-Mail: [log in to unmask]
Tel:  406-243-5648
Fax:  406-243-4184
http://www.umt.edu/biology/more
http://www.umt.edu/biology/bees