>
> > I am curious, Randy, the MRID # of all the studies are given.  Are all
> the
> studies available to the public from EPA?


Sorry Stan, I have no idea.  Should be IMO, since I would think that they
should be public docs.


> > No one has answered the question I posed regarding whether studies paid
> for by a company can be considered proprietary information


Again, don't know.  Sorry.

> >But many miss the point of these studies.  The only ones that really
> apply
> > directly to beekeepers are whether colonies survive and are productive.
> >  These are two very easy variables to measure
> > Any additional lab studies are merely scientifically explanatory, but not
> > necessary to determine the direct effect of a pesticide upon beekeepers.
> >
> >I don't think you really believe the above.
>

Why not?  For almond pollinators, frame strength Feb 15 would be another
measurement.  What other end results would you be interested in?  That is
not a rhetorical question--I really would like to know.


> > But it is easy to show the
> fallacy in looking just at a short term survival / productivity study (like
> Cynthia Scott-Duprees).


Stan, you are of course completely correct!  How many generations of bees
post exposure would you think appropriate?  My question being, if there is
no noticeable affect upon colony strength after several generations, why
would we expect it to occur later?  Any residue in the stored pollen, unless
there is evidence that it somehow degrades to something more potent, or
affects the fermentation of the bee bread (which is why I am concerned about
fungicides).

My point is that I really feed that from a beekeeper's perspective, colony
survival and production are easily measured metrics.

>
> >So say you are a beekeeper on Fugay soil where the half life is just shy
> of
> twenty years.


Stan, I am totally in agreement with you.  In our meetings with the Bayer
folk, this is exactly the sort of thing that *they* pointed out.  The
environmental safety of a pesticide is all about labelling, and proper
application by the end user.  So the buildup in clay soils is definitely
something that the regulatory agencies need to address.


>  >I just do not see how such persistent poisons can be considered an
> improvement.
>

Totally in agreement--would not be an improvement under those conditions.

>
> >I also should point out Randy, that it is not clay soils where
> clothianidin
> (and imidacloprid) are most persistent.  It is in sandy loams.


Thank you Stan, I was stating from memory.  Could you please send me the
soil breakdown times off list?

Stan, somehow it appears that you have the impression that I am defending
some chemical or another.  I am not at all.  What I am calling for is making
sure that the regulatory agencies receive rational beekeeper input and
suggestions for improved studies.  The regulatory process is just that--a
process.  No one expects that all future problems can be foreseen at first
registration of the product.  Issues such as soil buildup, and any resultant
effect upon nontarget organisms need to be documented and quantified, and
then the public needs to make sure that the regulatory agencies duly review
the registration or scheduling of the compound.

We are in the process of phasing out several of the persistent "bad actors,"
which were used in huge quantities only a few years ago.  It appears to me
that the process works, but not because of shouting on opinions, but because
of hard data.

Randy Oliver

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