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August 30, 2013
Bee protection language for pesticide labels

In an August 2013 letter, the EPA has informed registrants of a family of pesticides containing chemicals that are believed to be contributing to honey bee mortality that they must amend their product labels with instructions to applicators on minimizing exposure to bees. 

Affected products are described by the EPA as nitroguanidine neonicotinoid pesticides containing the active ingredients clothianidin, dinotefuran, imidacloprid, or thimethoxam, which have outdoor foliar use directions (except granulars) regardless of formulation, concentration, or intended user.  The EPA says it expects to see the new language on product labels by the 2014 use season. 

The letter follows up on a July 2013 letter, in which the EPA ordered registrants of these pesticides to submit performance (efficacy) data that document how testing has demonstrated that their products are efficacious when used according to the label instruction. 

Colony collapse disorder

Both orders are part of an effort by federal and state agencies to correct honey bee colony collapse disorder (CCD), which has ranged as high as 33 percent for commercial beekeepers in recent years.  According to the U.S. Department of Agriculture, an estimated one-third of all food and beverages are made possible by pollination, mainly by honey bees. 

In the July letter, the EPA noted that CCD has multiple causes and that the relative contributions of pesticides as well as pests, pathogens, nutrition, and bee management practices are not known. 

The July letter also “requested” that registrants submit a synopsis of their pollinator stewardship plans for both agricultural and non-agricultural registrations.  Registrants were also notified of the Agency’s intention to require specific labeling language to reduce risk to bees.

Three requirements

The August letter instructs registrants to electronically submit a fast-track amendment on EPA Form 8570-1 no later than September 30, 2013.  The amendment requires that the product label include three elements:

A pollinator protection box following the environmental hazards section.  The letter provides the language that should be contained in the box; the box includes a bee icon that may not be altered.

Directions for use.  In addition to the pollinator protection box, the pollinator language must be included under the label’s “Directions for Use” header directly following the misuse statement (“It is a violation of federal law to use this product in a manner inconsistent with its labeling.”).  At this time, these statements are not intended to be placed under each crop or site.

The phases “actively visiting,” “actively foraging,” or “visiting” on current labels must be replaced with “foraging.”  No other existing bee/pollinator statements may be deleted or changed.

Enforcement

The EPA notes that the above labeling changes are “generic” and may not be compatible with pollinator safety information on registered labels.  The Agency says it is not its intention to direct registrants to remove this language.  Also, the EPA says it will address other product- specific issues with individual companies during label reviews. 

In both the July and August letters, the EPA indicates that the labeling orders are consistent with its authority under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) and that it intends to take “appropriate action” to ensure that the orders are followed. 

Click here for the two letters.

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