If I understand the issues it seems to me that Bayer says this is merely sloppy paperwork by EPA. 

But other posters here are saying wait a minute. The EPA fact sheet says

"Although spirotetramat can be classified as practically non-toxic to honey
bees based on acute oral and contact studies, results of brood feeding studies
and tunnel tests suggest the potential for effects to broods following
spirotetramat applications at rates lower than the maximum proposed label
rates; significant brood effects including increased mortality in adults and
pupae, massive perturbation of brood development, early brood termination,
and decreased larval abundance were detected. Spirotetramat also had a
wide range in magnitude of acute effects on other various non-target
terrestrial arthropods" 

So its unclear to me and perhaps others on the list if Bayer tested this material at less then the  max rate advertised on the label.  Can Mr David Fisher please comment on what rate was tested on honeybee brood?  Max rate? Half Rate? 

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