CRE Comments for FIFRA Scientific Advisory Panel Public Meeting on the Pollinator Risk Assessment Framework

August 24, 2012

Dear OPP Staff and SAP Members:


EPA has an excellent record in complying with the Data Quality Act (DQA), thus the first part of this document is aimed at educating the SAP as to DQA’s requirements.


Because the Risk Assessment Framework under discussion is intended to lay the foundation for, or be the first step in, what is almost certain to be a highly influential risk assessment that will eventually be peer reviewed by the SAP, CRE believes that the framework should incorporate, affirm, and apply the requirements of the DQA and its guidelines that apply to scientific assessments which will be disseminated by the Agency and that might eventually be used in regulatory proceedings.  Furthermore, since EPA declared that no imminent hazard exists, CRE will not be commenting on this matter.

CRE’s complete comments are attached here.

1 Comment Leave a Comment

  • 1. Anonymous  |  August 27, 2012 at 10:42 am

    Yes, Varroa mites are bad, but they are not the only form of pestilence afflicting honeybees. On this point I note the following American Scientific blog post linked to below discussing Apocephalus borealis, a type of phorid fly. The post links to a journal article. As the post relates,

    “The fly lays their eggs in the abdomen, or back end, of the bees. The maggots eat their way through the abdomen and thorax (middle) and exit below the head. Sometimes the head falls off.”

    Please see

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