Hello All,


 For those interested see the EPA factsheet on Spirotetramat and its
 by-products

 http://www.epa.gov/opprd001/factsheets/spirotetramat.pdf


 If you're looking for reasons for the knock-back on the product the
 following extract from page 44 of the EPA factsheet on Spirotetramat
 just about covers it in my opinion.

 "OPPTS Guideline 850.3040; Field Testing for Pollinators.

 Despite that the intrinsic hazard potential to bees based on the acute
 oral and contact studies with honey bees appears to be low, brood
 feeding tests with bees and acute toxicity contact studies with other
 non-target insects (e.g. parasitoid wasps and predatory mites) conducted
 at less than the maximum application rate suggest there is potential for
 mortality in adults and pupae, massive perturbation of brood
 development, and early brood termination as a result of spirotetramat
 use. This information, coupled with the fact that two other chemicals
 representing the ketoenole class of compounds (spiromesifen and
 spirodiclofen) have also demonstrated the potential for chronic effects
 on bee broods and development while displaying low acute toxicity,
 suggests that the mode of action of these compounds (i.e., inhibition of
 lipid biosynthesis) may adversely affect bee broods and development.

 Although a study has been submitted for spirotetramat under guideline
 850.3040, it was conducted at application rates approximately half of
 the
 label-recommended rates and it was not designed in such a manner that
 adverse effects resulting from treatment could be statistically
 determined".


Fungicides & organophosphates etc.
In my opinion beekeepers are seeing  losses now due to fungicides being
sprayed on blooms which bees are in fields. I have seen these losses and bee
problems myself. In apples for instance growers I pollinate are using
concoctions of three and up fungicides. Captan & nova two common ones but
some apple growers are using several new fungicides I am not familiar with.

My point is that a beekeeper would be stupid to think when a grower sends a
spray crew into the field *if* a fungicide is needed the fungicide will not
be added to the spirotetramat or similar pesticide spray if registered for
the crop.

Sprays are registered based on being sprayed alone. Not tested in
combination with other chemicals.

The concept put forward by sellers that they can place pesticides &
fungicides on plants while pollinators are working such plants will never be
embraced by beekeepers in my opinion.

Throughout history justice has always been the will of the stronger so
beekeepers are fighting an uphill battle.

Many organophosphates are excellent choices for apple growers. My growers
have never had health issues using the products . These growers are fighting
to keep at least some in use but in 2012 they say all use will be banned and
the reason for the banning is based on lobbyists from the companies selling
the replacement products. The largest grower in my state is very worried for
this reason he gave me:
Growers have seen they can not trust the products being sold by the chemical
companies. Switching to new untested controls could lead to a crop failure
( as product performance is not guaranteed by the makers). The switch in
2012 also is problematic for beekeepers as we have no way of knowing if the
products will be problems to bees.
My solution to my apple grower is this:
Pick a few thousand trees and use the new products in spring 2011. Then both
of us can see the results.

Sincerely,
Bob Harrison

I am only able to get email by driving a distance to a wireless hookup every
couple days. I
spoke by phone with Allen Dick yesterday. I am around 450 miles from Orlando
and doubt I will travel to the ABF meeting but sure Allen will ask the tough
questions of the presenters for us.

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