1. business and industrial
2. agriculture and forestry
3. crops and seed

Pollinator Stewardship Council
P.O. Box 304, Perkinston, MS 39573
www.pollinatorstewardship.org
832-727-9492
March 17, 2014
Contact: Michele Colopy, Program Director
832-727-9492 progdirector@pollinatorstewardship.org
Beekeepers Must Move Bees
Last fall the EPA published a new pesticide label originally for the foliar application of four
neonicotinoid pesticides. By December, the EPA stated this new pesticide label language would
be “harmonized” across all chemistries. The label was meant to protect pollinators.
The Pollinator Stewardship Council with the Bee Industry, sought a response from EPA’s
Assistant Administrator clarifying our concerns with the new label. The Pollinator Stewardship
Council received an answer from EPA, and Mr. Dave Hackenberg, representing the National
Honey Bee Advisory Board, received a different letter from EPA (even though both groups
along with AHPA and ABF signed the original letter). Both reply letters are attached.
The Office of Investigations for EPA stated in a letter to the Pollinator Stewardship
Council, they will review our concerns and “a determination will be made as to the most
appropriate course of action.” In the response to Mr. Hackenberg, Assistant Administrator
Jones clarifies that contrary to the December EPA webinar this new label language is for the
“four products formulated with the four nitroguanidine neonicotinoid chemicals (clothianidin,
dinotefuran, imidacloprid, and thiamethoxam) as well as two recently registered as active
ingredients: tolfenpyrad and cyantraniliprole.” These last two pesticides are an addition to the
original label adjustments presented August 15, 2013 by EPA for foliar applied neonics only. As
to the concerns beekeepers expressed about the five conditions listed on the label past the “do not
apply statement:” EPA stated to Mr. Hackenberg, “Both of the foregoing prohibitions, however,
are subject to the exception listed in the “unless . . .” clause.” “. . . application would be legal if
one of the five conditions is met . . .”
The Pollinator Stewardship Council’s mission is to defend managed and native pollinators vital to a
sustainable and affordable food supply from the adverse impact of pesticides.
The bee industry has its answer: any harm that comes to a beekeeper’s managed colonies
due to a foliar application of clothianidin, dinotefuran, imidacloprid, thiamethoxam, tolfenpyrad,
and cyantraniliprole is the responsibility of the beekeeper. If bees are damaged or die due to a
foliar application of a those products during bloom, and the application was made based on one
of the five conditions, the fault of bee deaths lies with the beekeeper. Beekeepers must move
their bees. No clarification was provided by EPA on what constitutes notifying a beekeeper to
move their bees, if a State has a voluntary apiary registry program, or for the loss of a honey crop
or crop pollination if bees are to be moved. The cost of time, labor, and loss of honey crop will
be shouldered by the beekeeper.
The Pollinator Stewardship Council has attached an analysis of the new pesticide label.
While EPA has clarified the “conditions” will supercede the “do not apply” statement, the label
still has undefined terms, features an icon that defies culturally accepted warnings, and native
pollinators will continue to be harmed and killed. Again, the EPA now states the new label will
only be required for foliar applications of clothianidin, dinotefuran, imidacloprid, thiamethoxam,
and the two new products tolfenpyrad and cyantraniliprole.
The Pollinator Stewardship Council encourages beekeepers to document their costs due
to moving bees in relation to this new label language for foliar applications of clothianidin,
dinotefuran, imidacloprid, thiamethoxam, tolfenpyrad, and cyantraniliprole. Also, document if
and when you are notified to move your bees.
The Pollinator Stewardship Council is a nonprofit organization whose mission is to
defend managed and native pollinators vital to a sustainable and affordable food supply from the
adverse impact of pesticides. For more information about the Pollinator Stewardship Council
visit www.pollinatorstewardship.org .
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Note: From the EPA’s EFED Risk Assessment of 2013, page 4, Cyantraniliprole, IRAC group 28, “is a systemic,
broad-spectrum insecticide that belongs to the diamide class of chemistry.”
Tolfenpyrad, IRAC group 21 “is a broad-spectrum pyrazole insecticide/miticide. It acts by impairing energy
metabolism in the target pest . . . including cessation of movement, lack of fecundity, and eventual death of the
pest.” (Page 3, EPA’s unconditional registration document for tolfenpyrad)
The Pollinator Stewardship Council’s mission is to defend managed and native pollinators vital to a
sustainable and affordable food supply from the adverse impact of pesticides.
Pollinator Stewardship Council
P.O. Box 304, Perkinston, MS 39573
www.pollinatorstewardship.org
832-727-9492
January 22, 2014
Jim Jones
Assistant Administrator for the Office of Chemical Safety and Pollution Prevention
Environmental Protection Agency
1200 Pennsylvania Avenue, N.W.
Washington, DC 20460
Dear Mr. Jones,
The Bee Industry is writing to express our concern over the new pesticide label language that is
being harmonized across all chemistries. The new label language was presented by EPA
personnel at both National Bee Industry Conventions this month implying two different
interpretations of the mandatory label language. We are seeking clarification of two points from
the recently published Admire Pro label quoted on page 6.
Directions for Use
It is a violation of federal law to use this product in a manner inconsistent with its labeling
FOR FOOD CROPS AND COMMERCIALLY GROWN ORNAMENTALS NOT UNDER
CONTRACT FOR POLLINATION SERVICES BUT ARE ATTRACTIVE TO
POLLINATORS
Do not apply this product while bees are foraging. Do not apply this product until
flowering is complete and all petals have fallen unless one of the following conditions is
met.




The application is made to the target site after sunset.
The application is made to the target site when the temperature is below 55 degrees F.
The application is made in accordance with a government-initiated public health
response.
The application is made in accordance with an active state-administered apiary registry
program where beekeepers are notified no less than 48 hours prior to the time of planned
The Pollinator Stewardship Council’s mission is to defend managed and native pollinators vital to a
sustainable and affordable food supply from the adverse impact of pesticides.

application so that the bees can be removed, covered or otherwise protected prior to
spraying.
The application is made due to an imminent threat of significant crop loss, and a
documented determination consistent with an IPM plan or predetermined economic
threshold is met. Every effort should be made to notify the beekeepers no less than 48hours prior to the time of the planned application so that the bees can be removed,
covered or otherwise protected prior to spraying.
1. Please clarify if the five (5) listed "conditions" below the word "unless" are mandatory label
directions for use.
2. Please clarify if a legal federal application can be made for Food crops and/or commercially
grown ornamentals not under contract for pollination services but are attractive to pollinators
WHILE bees are foraging AND/OR BEFORE flowering is complete and all petals have fallen
IF one of the listed "conditions" is met.
We are sending this request via email, as well as registered mail. We look forward to your
written response within five (5) business days.
Sincerely,
Bret Adee, President
Pollinator Stewardship Council
Randy Verhoek, President
American Honey Producers Association
Tim Tucker, President
American Beekeeping Federation
Dave Hackenberg, Co-Chair
National Honey Bee Advisory Board
Bret Adee, Co-Chair
The Pollinator Stewardship Council’s mission is to defend managed and native pollinators vital to a
sustainable and affordable food supply from the adverse impact of pesticides.
The Pollinator Stewardship Council’s mission is to defend managed and native pollinators vital to a
sustainable and affordable food supply from the adverse impact of pesticides.
The Pollinator Stewardship Council’s mission is to defend managed and native pollinators vital to a
sustainable and affordable food supply from the adverse impact of pesticides.
The Pollinator Stewardship Council’s mission is to defend managed and native pollinators vital to a
sustainable and affordable food supply from the adverse impact of pesticides.
The Pollinator Stewardship Council’s mission is to defend managed and native pollinators vital to a
sustainable and affordable food supply from the adverse impact of pesticides.
The Pollinator Stewardship Council’s mission is to defend managed and native pollinators vital to a
sustainable and affordable food supply from the adverse impact of pesticides.
The Pollinator Stewardship Council’s mission is to defend managed and native pollinators vital to a
sustainable and affordable food supply from the adverse impact of pesticides.
The Pollinator Stewardship Council’s mission is to defend managed and native pollinators vital to a
sustainable and affordable food supply from the adverse impact of pesticides.
The Pollinator Stewardship Council’s mission is to defend managed and native pollinators vital to a
sustainable and affordable food supply from the adverse impact of pesticides.
The Pollinator Stewardship Council’s mission is to defend managed and native pollinators vital to a
sustainable and affordable food supply from the adverse impact of pesticides.
The Pollinator Stewardship Council’s mission is to defend managed and native pollinators vital to a
sustainable and affordable food supply from the adverse impact of pesticides.
The Pollinator Stewardship Council’s mission is to defend managed and native pollinators vital to a
sustainable and affordable food supply from the adverse impact of pesticides.
The Pollinator Stewardship Council’s mission is to defend managed and native pollinators vital to a
sustainable and affordable food supply from the adverse impact of pesticides.