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Aaron Morris <[log in to unmask]>
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Informed Discussion of Beekeeping Issues and Bee Biology <[log in to unmask]>
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Thu, 14 Dec 2000 08:27:49 -0500
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The following is reposted (with permission).  This is an important issue.
Spread the news, far and wide, and write your representatives in DC!

This article has been supplied by Tom Theobold, a commercial beekeeper from
Colorado. It is intended as a call to action by beekeepers for a problem
with pesticides, the EPA and what has been labeled as blatent pesticide
abuse and violation of the law. Bee Culture urges you to visit the EPA site
and comment on the proposed rules. But more importantly, by contacting your
congressperson, you will call more pressure on EPA to change what is
perceived as a serious and inflexible attitude toward pesticides and honey
bees.
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The EPA, Pesticides and Beekeepers. An Editorial and call to Arms. By Tom
Theobold


In an apparently inadvertent irony of timing, the Environmental Protection
Agency announced in the Federal Register its intention to seek public
comment on a draft Pesticide Registration (PR) notice entitled "Guidance for
Pesticide Registrants on Bee Precautionary Labeling". This announcement came
on November 22, the day before Thanksgiving. In the war movies, this moment
is typically accompanied by the panic cry "INCOMING"!
Pesticides hazardous to honey bees have carried a label restriction since
the early 1980s. It reads:
"[This product] is HAZARDOUS TO BEES exposed to direct treatment or residues
on blooming crops an/or blooming weeds. Do not apply [this product] or allow
it to drift to blooming crops and/or blooming weeds if bees are foraging the
areas to be treated."
The label restriction came about as a consequence of massive bee kills from
pesticides in the 1970s.
Unfortunately the chemical industry and State Regulators (the agencies
typically delegated the authority by EPA for pesticide regulation) found the
restriction cumbersome, problematical and inconvenient. While the label
restriction was frequently ignored or skirted, it nevertheless gave
beekeepers standing before the law when their bees were killed by illegal
pesticide use. Even under these conditions of unenthusiastic and even
hostile enforcement, commercial beekeepers in many parts of the country had
over 30% of their colonies killed or damaged by pesticides.
The current PR Notice would propose sweeping changes to not only the wording
but the intent of bee protection language.
New pesticides presented for registration which fail to provide residual bee
toxicity data automatically will be assumed to have a toxic period of 24
hours. This will encourage applicants to neglect this detail, and beekeepers
will spend years enduring bee kills and uncompensated damages as they
attempt to establish their case against new pesticides which may have
residual toxicity's of 1 to 2 weeks. In other words the toxicity data will
be generated at the expense of the beekeeping industry.
It dismisses the issue of drift, which is often the major culprit in bee
kills, by simply omitting any reference to it. By this logic, polluters in
other arenas would be free to release toxic substances into a waterway and
be held harmless for any damage done downstream. The only difference between
the two cases is that with agricultural pesticides it isn't a waterway but
an airstream which is polluted.
Perhaps the worst part of this proposal is its caveat to the chemical
industry, which says that an applicator is not responsible for following
even the feeble language proposed if they participate in a "formal,
state-approved bee protection program". The EPA plans to take no role in the
formation, approval or monitoring of the state approved program, despite the
clear evidence that it has often been State Departments of Agriculture which
are the problem in protecting pollinators. In 1997 AAPCO )the American
Association of Pesticide Control Officers), a professional organization to
which many state regulatory people belong, formally requested that the EPA
make bee protection language ADVISORY. This gives you an idea of the
philosophy of many of these states and what protections they might provide
given a free hand. The EPA proposed to not only put the foxes back in charge
of the chicken coop despite the loss of all these chickens, it proposed to
let the foxes make the rules a!
nd doesn't  even intend to ask what the rules are.
Beyond the specific labeling language, the EPA is failing to carry out its
basic responsibilities under the law (FIFRA). Ultimately Congress is
responsible for the implementation of FIFRA. It assigns this responsibility
to EPA, which in turn delegates the authority to another agency, typically a
State Department Of Agriculture. It is apparent that the EPA is not only
prepared to cave in to the convenience of the chemical industry, but they
are willing to sacrifice American beekeeping and violate the law in the
bargain. They are either incapable or unwilling to hold their delegees (the
states) accountable for administering the law properly, nor are they willing
to do so themselves.
Beekeepers are urged to familiarize themselves with this issue and contact
their Congresspeople immediately. This matter will effect all beekeepers,
large or small. The indiscriminate and uncontrolled use of pesticides around
bees, which is likely to result from the current posture of the EPA, will
result in enormous and costly losses for almost all beekeepers. The EPA must
be called to account by Congress and required to follow the law. The current
proposal provides little or no protection to honey bees or any other
pollinators, after years of input from the beekeeping industry.
More detailed information on the PR can be obtained at
http://www.epa.gov/pesticides/
The comment period ends Jan 22, 2001. In addition to anything you may have
to say to the EPA, you should inform your Congressperson or nothing will
change.
Tom Theobold is a commercial beekeeper, freelance writer and has been a
beekeeper's advocate in the pesticide arena for over 25 years. If you have
further questions please email Bee Culture Magazine at
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Kim Flottum
Editor, Bee Culture Magazine
http://www.airoot.com/beeculture/index.htm

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