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Informed Discussion of Beekeeping Issues and Bee Biology

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Subject:
From:
James Fischer <[log in to unmask]>
Reply To:
Informed Discussion of Beekeeping Issues and Bee Biology <[log in to unmask]>
Date:
Sun, 2 Apr 2023 08:03:53 -0400
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One hesitates to take anything one reads on April 1st seriously, as anything
might be a prank, but I'll play along.

In terms of miticide doses, the term "approved" in the USA is solely
reserved for the published regulatory rulings and letters from the EPA.

There is no "approved" OA "dose per bee" in any EPA-issued document, and one
struggles to think that anything more than an estimate could ever be guessed
at, as there is no consistent number of bees per hive or "bees per seam"
between frames.  One can certainly calculate the dose "per bee" from the
approved dose, but this would require one to estimate/guesstimate the number
of bees in a typical "seam" of bees.  

Example - Assume that I judge that I have "4 seams" of bees that justify a
5ml dribble dose each, where the next beekeeper might judge that the same
hive has "5 seams" of bees.  Either I under-dosed or the next beekeeper
overdosed, and one of us was off by 20% to 25%.  Given the fairly broad
range of OA concentrations each shown in controlled studies to perform
acceptably, one would expect that there is some flexibility in dosing, but
even then the "dose per bee" is going to vary widely due to the two
different evaluations of the number of bees CURRENTLY visible between top
bars, which can, of course, vary over time-of-day for any one hive, swaying
even a completely precise count of visible bees, as one can only count the
currently-visible bees.

The NY Bee Wellness program is a good one, and provides a big tent for a
wide range of opinions, but nothing said at any such event changes what is
"approved"  by the EPA, or  any veterinary authority.  The suggestions of
beekeepers are not the instructions on the pesticide label, so beekeepers
should confine themselves to explanations of what the labels actually say,
rather than presuming to "interpret" the labels and say things that the
labels don't.

The discussion subject line only exists because beekeepers and some state
apiarists decided to get "creative" and ignore the plain language of EPA
regs, in this case, FIFRA 2(ee).  Let's quit while we are ahead, as no one
got fired or demoted over this, 

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