Tell EPA to Protect Honey Bees from Acutely Toxic Pesticides

 EPA released a New Rule for public comment, Bees; Mitigating Exposure from Acutely Toxic Pesticide Products (Docket #: EPA-HQ-OPP-2014-0818-0003) late last spring.  The deadline for the comment letter was extended three times.  The final deadline is this Friday, August 28, 2015.  

The New Rule has two parts: Part A. Label Language for Applications to Sites With Bees Present Under Contracted Services, and Part B.  State and Tribal Managed Pollinator Protection Plans. (read the text of the Proposed New Rule at our website)

No matter where the bees are they must be protected from all forms of exposure of acutely toxic pesticides.  This New Rule does not provide protection of honey bees and native pollinators, where the risk is incurred.  The situations in which pollinators are likely to be affected by pesticides (both acutely toxic and those having chronic effects) are not dealt with at all by the proposed rule.  State Pollinator Protection Plans, if they are adopted, must not undermine pesticide labels. They need to be adequately funded, have measurable standards, be reviewed in a timely fashion, and recognize the value of bees to all agriculture production.  Pollinator protection is a national priority, realized at the state and local levels.

Please submit your comment this week to EPA concerning Bees; Mitigating Exposure from Acutely Toxic Pesticide Products (Docket #: EPA-HQ-OPP-2014-0818-0003). 

Your comments must be received on or before August 28, 2015.

Send your comment today!  Thank you for making the beekeeper’s voice heard. 

Michele Colopy, Program Director

The process is fairly simple and we have drafted a letter for you with the 5000 character limit OR you can upload the PDF of a longer letter, adding your comments in the comment box separately:

1.    Copy the text of the letter below
2.    select the link to the Docket at Regulations.gov below

   Bees; Mitigating Exposure from Acutely Toxic Pesticide Products (Docket #: EPA-HQ-OPP-2014-0818-0003)

3.    select the COMMENT NOW button on the right side of your screen  
4.    paste the letter into the Comment box
5.    add your own comments

        OR upload the PDF letter to the docket  (you will have to save the PDF to your computer, then upload it to the docket)

6.    and follow the prompts to submit your comments at Regulations.gov
7.    your comment will appear within 24 hours in the docket.

Copy the text below, then paste it into the comment section at Regulations.gov (OR upload the PDF letter to the Docket)

Re: Bees; Mitigating Exposure from Acutely Toxic Pesticide Products

Dear Mr. Goodis and Ms. Echeverria,

I join with the Pollinator Stewardship Council applauding the EPA’s efforts to protect honey bees, but we do not believe the proposed New Rule accomplishes this goal.

Part A. Label Language for Applications to Sites With Bees Present Under Contracted Services
Applications of acutely toxic pesticides to managed honey bees under contract pollination are not the issue. Pesticide labels already have an adequately protective bee hazard statement, “do not apply or allow residues on blooming crops or weeds if bees are visiting the treatment area.” Growers who invest in renting bee hives for crop pollination understand the value of honey bees, and closely follow label instructions. Specialty crop growers will not intentionally harm the livestock that helps create their crop; some beekeepers have additional guidelines written into their contract which protect their rented bees. Beekeepers and growers can control foliar applications through grower agreements and the pesticide label. Growers rely on enforceable label language to protect honey bees. Honey bees are already protected now from foliar applications of acute toxicity pesticide products through crop pollination agreements and the pesticide label.

Honey bees face the following issues while providing crop pollination services:

  • Adjoining/adjacent/neighboring land in honey bee forage area of contracted crop:
  •       Off-site drift of acutely toxic products to blooming crops and weeds.
  •      Acutely toxic products being applied when honey bees are actively foraging.
    On land utilizing contracted pollination services:
  •      Application of extended residual toxicity products too close to bloom.
  •      Tank mixes of pesticide products with unknown synergisms.
  •      Exposure to pesticide products that cause chronic effects.
  •      Unknown effects of fungicides and Insect Growth Regulators (IGRs)

Off-site drift of acutely toxic products to blooming crops and weeds.
Beekeepers report the greatest risk to honey bees is by acutely toxic pesticide exposures from off-site drift of applications to crops near commercially pollinated crops or from poorly timed mosquito fogging operations.

Application of extended residual toxicity products too close to bloom.
Some acutely toxic pesticides are toxic for days or even weeks on the crop during bloom, in the field, and in water run-off from the field.

Tank mixes of pesticide products with unknown synergisms.
Pesticide products that have become problematic are those that create synergistic chemical interactions when mixed together in a tank, and this mix of pesticides is then applied to the blooming crop.

Unknown effects of fungicides and Insect Growth Regulators (IGRs)
Other products of concern from singular applications to crops in bloom are fungicides and IGRs. The proposed New Rule does not address the risk assessments of the colony at the organism level.

Part B. State and Tribal Managed Pollinator Protection Plans (MP3)
We are concerned the creation of Managed Pollinator Protection Plans may allow primacy partners to develop plans with guidelines that are less stringent than the federal pesticide label.
States are being tasked with creating Pollinator Protection Plans with little funding support. At a minimum, states need funding for apiary inspectors and lab testing of hive matrices and honey bees. Beekeepers should not suffer the loss of their livestock simply because they are not under a crop pollination contract.

This proposed New Rule addresses only those honey bees and native pollinators under contract for crop pollination services and continues the label language exceptions for honey bees not under contract for crop pollination. Science shows us whether a crop is 100% reliant upon insect pollination, or 10% reliant upon insect pollination, crop yield increases through pollination. Retaining a pesticide label with exceptions to apply acutely toxic pesticides to honey bees not under contract pollination is unacceptable. Clear pesticide label protection guidelines are integral to protecting pollinators.

In conclusion, this New Rule does not provide protection of honey bees and native pollinators, where the risk is incurred. The situations in which pollinators are likely to be affected by pesticides (both acutely toxic and those having chronic effects) are not dealt with at all by the proposed rule.
State Pollinator Protection Plans, if they are adopted, must not undermine pesticide labels. They need to be adequately funded, have measurable standards, be reviewed in a timely fashion, and recognize the value of bees to all agriculture production. Pollinator protection is a national priority, realized at the state and local levels.

We strongly oppose this proposed New Rule as ineffective and potentially damaging to pollinators.

Sincerely,