USDA to EPA: “simple use of LD 50 toxicity ratings for individual bees. . .provides an inaccurate measure of potential harm. . .”

September 18, 2015

Editor’s Note: The following are excerpts from USDA Office of Pest Management Policy’s “Comments on the EPA proposed rule: Mitigation of Exposure to Bees from Acutely Toxic Pesticide Products” [EPA-HQ-OPP-2014-0818]. USDA’s complete comments are attached here.

USDA also requests clarification as to why this is listed as a proposed rule in EPA documents posted in the docket in May, June, and July 2015? When this action was first published in the Federal Register on May 29, 2015, it appeared in the Proposed Rules section of the Register and not in the Notices section where four other EPA notices appeared that same day. If this is a proposed rule and not a notice, why did this not follow procedures as described in the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA)? An action such as this should be supported by an analysis of costs and benefits.

USDA does not agree with the complete prohibition of foliar applications of acutely toxic materials (EPA Appendix A) during bloom time when bees are on-site under contract pollination services, as proposed by EPA.

USDA encourages the Agency to carefully consider the economic impact (yield and market value losses) this proposal may have on numerous specialty crop farmers and the rural economies they contribute to across the US before enacting proposed label changes. Many seed, fruit, oil, and vegetable crop producers need to prevent pest injury at bloom time to produce marketable crops.

As such, simple use of LD 50 toxicity ratings for individual bees without consideration of application rate, product formulation, residual toxicity, and application timing provides an inaccurate measure of potential harm to bees from pesticides, since it fails to recognize that many formulations and use patterns may not result in any significant exposure of bees to the active ingredient.

It is USDA’s position that a current lack of peer-reviewed studies on the effects of fungicides tank-mixed with IGRs and applied during bloom period on overall honey bee colony health are an inadequate basis upon which to establish regulatory decisions.

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