At 04:43 PM 2/23/2000 -0600, Bob Stevens wrote:

>Paragraph 8 of the exemption granted to the Florida Department of
>Agriculture  for the use of Coumaphos by the U.S. E.P.A. on January 20,
>2000  states: "Coumaphos has a high octano/water coefficient and is
>lipophilic, if residues were to occur they would be expected to be found
>in the beeswax.  To insure the use is non-food, a restriction is
>required prohibiting the sale of comb honey from treated hives.
>Therefore, the following statement should be added to the label:  "Sale
>of Comb honey from hives treated with coumaphos is prohibited."     The
>last sentence is in bold print.

Thank you Bob, for referencing the document in which the cited language
appears.  It seems clear that use of coumaphos obtained under the Florida
exemption as modified by the EPA on January 20, 2000 incurs the cited
prohibition in addition to the prior language present on the coumaphos
label.  It is likely that this prohibition will be added to each exemption
as it comes up for renewal, unless there was an error in the Florida
renewal, and that error gets corrected.  The language "added to the label"
shows that the additional prohibition is new, and the date of the addition
is stated.  I suspect that retroactive addition of that prohibition to prior
label coumaphos use would require publication of such added prohibition,
probably in the Federal Register.

It has long been required by law that pesticides be applied according to the
label that
must, by law, accompany the pesticide when it is purchased.  We are even
required to have that label on our persons applying pesticides.  The label
is "sacred."  The lesson here is "READ THE LABEL."  I also file all labels
from pesticides used here to establish a record of my legal obligations
thereunder.  Also, to avoid wasting money on pesticides that one might
decline to use because of label prohibitions, it might be wise to ask the
vendor about the label prohibitions prior to purchase.

The permitted uses of coumaphos in agricultural commodities cited in EPA
documents seems widespread, to an extent that causes me worry.  Meat lack
not in lipids, in fact chicken has been disgustingly fatty of late.  Unlike
beeswax, which often traverses the alimentary canal intact, animal fats in
food are digested.  One cannot but wonder if we beekeepers, being less
organized than the meat, milk, poultry, and egg (MMPE in EPA lingo)
industry, are being subjected to relatively greater rigor, perhaps being
thrown as a sop to the adherents of Green Religion.

Bill Morong