Pollinator Stewardship Council P.O. Box 304, Perkinston, MS 39573 www.pollinatorstewardship.org 832-727-9492 March 17, 2014 Contact: Michele Colopy, Program Director 832-727-9492 [email protected] Beekeepers Must Move Bees Last fall the EPA published a new pesticide label originally for the foliar application of four neonicotinoid pesticides. By December, the EPA stated this new pesticide label language would be “harmonized” across all chemistries. The label was meant to protect pollinators. The Pollinator Stewardship Council with the Bee Industry, sought a response from EPA’s Assistant Administrator clarifying our concerns with the new label. The Pollinator Stewardship Council received an answer from EPA, and Mr. Dave Hackenberg, representing the National Honey Bee Advisory Board, received a different letter from EPA (even though both groups along with AHPA and ABF signed the original letter). Both reply letters are attached. The Office of Investigations for EPA stated in a letter to the Pollinator Stewardship Council, they will review our concerns and “a determination will be made as to the most appropriate course of action.” In the response to Mr. Hackenberg, Assistant Administrator Jones clarifies that contrary to the December EPA webinar this new label language is for the “four products formulated with the four nitroguanidine neonicotinoid chemicals (clothianidin, dinotefuran, imidacloprid, and thiamethoxam) as well as two recently registered as active ingredients: tolfenpyrad and cyantraniliprole.” These last two pesticides are an addition to the original label adjustments presented August 15, 2013 by EPA for foliar applied neonics only. As to the concerns beekeepers expressed about the five conditions listed on the label past the “do not apply statement:” EPA stated to Mr. Hackenberg, “Both of the foregoing prohibitions, however, are subject to the exception listed in the “unless . . .” clause.” “. . . application would be legal if one of the five conditions is met . . .” The Pollinator Stewardship Council’s mission is to defend managed and native pollinators vital to a sustainable and affordable food supply from the adverse impact of pesticides. The bee industry has its answer: any harm that comes to a beekeeper’s managed colonies due to a foliar application of clothianidin, dinotefuran, imidacloprid, thiamethoxam, tolfenpyrad, and cyantraniliprole is the responsibility of the beekeeper. If bees are damaged or die due to a foliar application of a those products during bloom, and the application was made based on one of the five conditions, the fault of bee deaths lies with the beekeeper. Beekeepers must move their bees. No clarification was provided by EPA on what constitutes notifying a beekeeper to move their bees, if a State has a voluntary apiary registry program, or for the loss of a honey crop or crop pollination if bees are to be moved. The cost of time, labor, and loss of honey crop will be shouldered by the beekeeper. The Pollinator Stewardship Council has attached an analysis of the new pesticide label. While EPA has clarified the “conditions” will supercede the “do not apply” statement, the label still has undefined terms, features an icon that defies culturally accepted warnings, and native pollinators will continue to be harmed and killed. Again, the EPA now states the new label will only be required for foliar applications of clothianidin, dinotefuran, imidacloprid, thiamethoxam, and the two new products tolfenpyrad and cyantraniliprole. The Pollinator Stewardship Council encourages beekeepers to document their costs due to moving bees in relation to this new label language for foliar applications of clothianidin, dinotefuran, imidacloprid, thiamethoxam, tolfenpyrad, and cyantraniliprole. Also, document if and when you are notified to move your bees. The Pollinator Stewardship Council is a nonprofit organization whose mission is to defend managed and native pollinators vital to a sustainable and affordable food supply from the adverse impact of pesticides. For more information about the Pollinator Stewardship Council visit www.pollinatorstewardship.org . 30 Note: From the EPA’s EFED Risk Assessment of 2013, page 4, Cyantraniliprole, IRAC group 28, “is a systemic, broad-spectrum insecticide that belongs to the diamide class of chemistry.” Tolfenpyrad, IRAC group 21 “is a broad-spectrum pyrazole insecticide/miticide. It acts by impairing energy metabolism in the target pest . . . including cessation of movement, lack of fecundity, and eventual death of the pest.” (Page 3, EPA’s unconditional registration document for tolfenpyrad) The Pollinator Stewardship Council’s mission is to defend managed and native pollinators vital to a sustainable and affordable food supply from the adverse impact of pesticides. Pollinator Stewardship Council P.O. Box 304, Perkinston, MS 39573 www.pollinatorstewardship.org 832-727-9492 January 22, 2014 Jim Jones Assistant Administrator for the Office of Chemical Safety and Pollution Prevention Environmental Protection Agency 1200 Pennsylvania Avenue, N.W. Washington, DC 20460 Dear Mr. Jones, The Bee Industry is writing to express our concern over the new pesticide label language that is being harmonized across all chemistries. The new label language was presented by EPA personnel at both National Bee Industry Conventions this month implying two different interpretations of the mandatory label language. We are seeking clarification of two points from the recently published Admire Pro label quoted on page 6. Directions for Use It is a violation of federal law to use this product in a manner inconsistent with its labeling FOR FOOD CROPS AND COMMERCIALLY GROWN ORNAMENTALS NOT UNDER CONTRACT FOR POLLINATION SERVICES BUT ARE ATTRACTIVE TO POLLINATORS Do not apply this product while bees are foraging. Do not apply this product until flowering is complete and all petals have fallen unless one of the following conditions is met. The application is made to the target site after sunset. The application is made to the target site when the temperature is below 55 degrees F. The application is made in accordance with a government-initiated public health response. The application is made in accordance with an active state-administered apiary registry program where beekeepers are notified no less than 48 hours prior to the time of planned The Pollinator Stewardship Council’s mission is to defend managed and native pollinators vital to a sustainable and affordable food supply from the adverse impact of pesticides. application so that the bees can be removed, covered or otherwise protected prior to spraying. The application is made due to an imminent threat of significant crop loss, and a documented determination consistent with an IPM plan or predetermined economic threshold is met. Every effort should be made to notify the beekeepers no less than 48hours prior to the time of the planned application so that the bees can be removed, covered or otherwise protected prior to spraying. 1. Please clarify if the five (5) listed "conditions" below the word "unless" are mandatory label directions for use. 2. Please clarify if a legal federal application can be made for Food crops and/or commercially grown ornamentals not under contract for pollination services but are attractive to pollinators WHILE bees are foraging AND/OR BEFORE flowering is complete and all petals have fallen IF one of the listed "conditions" is met. We are sending this request via email, as well as registered mail. We look forward to your written response within five (5) business days. Sincerely, Bret Adee, President Pollinator Stewardship Council Randy Verhoek, President American Honey Producers Association Tim Tucker, President American Beekeeping Federation Dave Hackenberg, Co-Chair National Honey Bee Advisory Board Bret Adee, Co-Chair The Pollinator Stewardship Council’s mission is to defend managed and native pollinators vital to a sustainable and affordable food supply from the adverse impact of pesticides. The Pollinator Stewardship Council’s mission is to defend managed and native pollinators vital to a sustainable and affordable food supply from the adverse impact of pesticides. The Pollinator Stewardship Council’s mission is to defend managed and native pollinators vital to a sustainable and affordable food supply from the adverse impact of pesticides. The Pollinator Stewardship Council’s mission is to defend managed and native pollinators vital to a sustainable and affordable food supply from the adverse impact of pesticides. The Pollinator Stewardship Council’s mission is to defend managed and native pollinators vital to a sustainable and affordable food supply from the adverse impact of pesticides. The Pollinator Stewardship Council’s mission is to defend managed and native pollinators vital to a sustainable and affordable food supply from the adverse impact of pesticides. The Pollinator Stewardship Council’s mission is to defend managed and native pollinators vital to a sustainable and affordable food supply from the adverse impact of pesticides. The Pollinator Stewardship Council’s mission is to defend managed and native pollinators vital to a sustainable and affordable food supply from the adverse impact of pesticides. The Pollinator Stewardship Council’s mission is to defend managed and native pollinators vital to a sustainable and affordable food supply from the adverse impact of pesticides. The Pollinator Stewardship Council’s mission is to defend managed and native pollinators vital to a sustainable and affordable food supply from the adverse impact of pesticides. The Pollinator Stewardship Council’s mission is to defend managed and native pollinators vital to a sustainable and affordable food supply from the adverse impact of pesticides. The Pollinator Stewardship Council’s mission is to defend managed and native pollinators vital to a sustainable and affordable food supply from the adverse impact of pesticides. The Pollinator Stewardship Council’s mission is to defend managed and native pollinators vital to a sustainable and affordable food supply from the adverse impact of pesticides.
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