The Pollinator Stewardship Council seeks your support and comments concerning the Environmental Protection Agency review of regulations. Please submit your comments to support regulations which protect honey bees and native pollinators, or feel free to copy and paste our letter below and submit it by May 15. Let them know you want pesticides regulated, and protections from the impact of pesticides for our honey bees and native pollinators. Please submit your comments by May 15, 2017.
Copy and Paste Text of the draft letter below
At Regulations.gov, where comments can be submitted to the docket, there is a “5000 character with spaces” limitation in the text box. A sample letter below is available for you to copy the text, select the link to Regulations.gov, click on the Comment Now button, and paste the text (which is less than 5000 characters) into the text box. Feel free to edit the sample comments and type your own, just remember you are limited to 5000 characters including spaces.
Sarah Rees, Director
Office of Regulatory Policy and Management
Office of Policy
1200 Pennsylvania Avenue NW
Mail Code 1803A
Washington, DC 20460
Re: EPA-HQ-OA-2017-0190-0042—Evaluation of Existing Regulations
Dear Ms. Rees,
While awareness of honey bees and native pollinators has increased, and pesticide label language has been modified toward protecting pollinators, they are still not protected from the impact of pesticides. Communication across stakeholders has increased, and state pollinator protection plans have been created, but these efforts are best management practices and have no funding support or enforcement to encourage the best management to support the health of pollinators.
Yet last year’s winter loss of managed bees was nearly 30% with an annual loss of 44%. This clearly indicates the nations managed honey bees are not healthy, and nothing significant has been done to reduce the impact of pesticides.
The distinction between honey bees under contract and those not under contract is illogical. If bees are to truly be protected from pesticide exposure they must be protected from pesticides throughout the year. Contract or no contract, honey bees are not an expendable asset.
The recommendation to eliminate the “Do Not Apply to Blooming Crops or Weeds” pesticide label language from the environmental hazards section of the label will be detrimental to educating the reader / user of pesticide labels. The label is the law. And mandatory language such as this must remain to protect the beekeepers’ livestock. Some State Lead Agencies claim this label language is unenforceable. Is it really, or are they merely unwilling to enforce it?
All risk assessments should be conducted on formulated products, not simply the active ingredient. The risk assessments of insect growth regulators, fungicides, and common tank mixes need to be reassessed for their negative impact upon brood development. Every year damage to bee hives in the form of brood loss occurs. This unnecessary injury occurs due to the lack of appropriate warning statements on the labels of these products. Rick Keigwin and the EPA Office of Pesticide Programs staff have indicated that risk assessments should start later this year on common tank mixes. Pollinator Stewardship Council is supportive of risk assessments on tank mixes.
Managed Pollinator Protection Plans (MP3s) are good for establishing communication between beekeepers and pesticide applicators, but they are not the answer to solving honey bee/pesticide issues. Clear, enforceable label language which prohibits the application of certain bee toxic compounds to blooming plants is the basis for effective pollinator protection.
The label language for neonicotinoids which the bee industry challenged back in 2013 remains a very serious issue. The list of exemptions that allow applications to proceed in that label language are merely loopholes that allow bee kills to occur legally. The exemption of a 48 hour notification program should not be reason to allow legal applications of toxic products to blooming plants. It is impossible to move, cover, or otherwise protect all honey bee colonies within the area of pesticide applications to blooming plants. The California Dept. of Pesticide Regulation allows applications of bee toxic products 48 hours after notification as long as all label restrictions are followed. The 2013 EPA pesticide label language releases the applicator from liability as long as the notification is made! The exemption that a pesticide application is recommended based on the threat of significant crop loss, permits any application. The exemption of applications of long residual products after sunset may save a few bees, but will likely kill many bees in the ensuing days of residual activity.
Given all the bee health problems the bee industry continues to face, we need real protection from pesticide exposure through greater label restrictions, not less! We need clear, concise language on pesticide labels. We need the regulations which guide science-based data collection in the review of currently registered pesticides, and any proposed pesticide registrations. I join with the bee industry in supporting EPA regulations protecting honey bees and native pollinators from the adverse impact of pesticides.
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Please submit your comments by May 15, 2017