Pollinator Stewardship Council July 10, 2015
EPA released a New Rule for public comment, Bees; Mitigating Exposure from Acutely Toxic Pesticide Products (Docket #: EPA-HQ-OPP-2014-0818-0003; deadline for comments July 29, 2015). The Pollinator Stewardship Council will be submitting our comment to the public docket, and we will be seeking your comments as well in a separate email to you. 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 here)
In summary, honey bees need to be afforded the same protections, whether under contract, or not under contract for pollination services. No matter where the bees are they must be protected from all forms of exposure of acutely toxic pesticides. This proposed New Rule offers no protection from the synergistic effects of tank mixes upon honey bees while under contract, nor does it protect bees under contract from systemic pesticides. The bee kill incidents of the past few years were due to tank mixes including fungicides, yet the pesticide label offers no protection to pollinators from tank mixes of products with fungicides and insect growth regulators. The seventy-six acute toxicity compounds affecting more than 1,000 products are known and labelled as such. It is the tank mixed pesticides with synergized and unknown toxicities that this proposed new rule does not address, and needs to address.
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. Without pesticide label language, with defined terminology, pollinators will simply be “removed by mortality.”
Beekeepers should not suffer the loss of their livestock simply because they are not under a crop pollination contract. A soybean farmer would not appreciate a farming practice in corn that killed his soybean crop, or wiped out half of his field. Part “A” of this proposed new rule changes nothing for the beekeepers, and their honey bees concerning exposure to bee toxic pesticides. Part “B” of this proposed rule simply provides federal acknowledgement of the request of States to develop their own Pollinator Protection Plans. However, it provides no funding for apiary inspectors and lab testing of honey bees related to alleged pesticide bee kills, and it permits States to remove honey bees and native pollinators from the ecosystem; by forcing their removal or through the pollinators’ mortality.
EPA’s mission is to protect human health and the environment. This New Rule does not provide protection of honey bees and native pollinators from acutely toxic pesticide products under contracted pollination or not. State Pollinator Protection Plans tasked with effectively reducing the likelihood of bees being present in a treatment area is not protection of pollinators, but elimination of pollinators.