> Bob wrote:

> I agree with what Randy posted about what Bayer said its position was.
> correct dosage is the answer.
> always has been.
> Perhaps??????? the dosage for imidacloprid  is now correct on certain
> problem crops?
>

Bob,

    If a chemical company changes the formulation of a registered  
insecticide, adds a host, or changes the method of deployment they  
have to request a change in the registration--which goes through a  
comment period & then is re-evaluated before the chemical is available  
on a state by state basis.

  So I get to see a continuous stream of requests for change in  
registration for pesticides in NY state. (nematicides, fungicides,  
insecticides, rodenticides, and herbicides) for my reading pleasure.   
List-servs anyhow!!!


Here is a sample of protocol for change with a time frame for reply!

New Active Ingredient (AI) --60 days, written notice to applicant

Major Change in Labeling (MCL) --60 days, written notice to applicant

Special Local Need Registration --60 days, written notice to applicant

AI already registered --60 days, written notice to applicant

Amended labeling, other than MCL-- 60 days, written notice to applicant

Section 18 Emergency Exemption Filed with NYSDEC at least 105 days  
before decision is needed. 30 days to determine completeness.


Some states are not as regulated as NY.  I commute to Mi for work with  
my day job and they are way more relaxed but are still mandated by  
federal regulations to require reporting in registration changes of  
pesticides.

The research to delineate mixed pesticide effects, much like the  
realization that homeopathic supplements can effect prescription  
medicine, or interactions amongst prescription drugs, is wide open  
with little know.  Field studies along these lines (multiple pesticide  
interactions)  will be very difficult to accomplish because of the  
immensely complicated world we live in.  The complexity of who is  
using what where, how and how much will make field studies difficult &  
many will not take on the funding of such a nebulous task.  Much  
theoretical work can be done in controlled situations in a lab.

Mike

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