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Bayer CropScience holding hands with US Government


RE: Asian Longhorn Beetle Eradication Effort

I’m sending this email out to individuals and organizations who might have interest in the fall application of imidacloprid by APHIS in Worcester County.

Today’s Boston Globe article on the subject can be found here:

My wife and I are beekeepers in Worcester County. Our colonies are outside of the current treatment zone, but not far away. I wouldn’t be surprised if the zone extended to some of our hives either in New Braintree or in Leominster.

I should also add the disclaimer that I am not a beekeeper who believes that imidacloprid is the cause of recent well publicized honeybee die offs. Imidacloprid does kill bees in isolated incidents, some of these are well documented, and there is no question that it is extremely toxic to bees if they encounter it. The issue with the ALB treatment is unique.

My wife and I attended the initial public meeting in Worcester when the ALB was first spotted. I participated in the forum, and made important contacts at APHIS, notably, Bob Baca, whose job is environmental compliance.

I made the first suggestions, and did extensive follow up to have APHIS fund a monitoring program for bees in and outside of the treated area. I put Bob Baca in touch with Ken Warchol, our county bee inspector who is working with Jeff Pettis (of the USDA Beltsville Bee lab), a graduate student, and our state apiarist, Al Carl, on this study (I believe they have setup 25 hives within the treatment zone, and 25 outside). I maintain that if APHIS does what they plan to do, that this study is imperative.

I don’t believe that the Environmental Assessment done by APHIS is sufficient to justify any treatments, because, as part of the assessment, they must determine if the bees will encounter enough imidacloprid to cause harm. The problem is, no one has data showing how much imidacloprid will end up in the pollen, nectar, and/or plant resins (that bees collect for making propolis) of the early blooming maple trees. Certainly not with the dosages used, and not over a 3 year period (which is the minimum treatment time being proposed by AHPIS).

Maple trees are an important early source of pollen for bees in our area, usually in February, when they need the protein to build up the colony, and there is little else available. APHIS has no data to show what the levels of imidacloprid will be in the maple pollen when they do the multi-year treatments at the level they are proposing. Without this data, any assessment from APHIS as to the impact on honeybees is impossible.

The current issue before us is fall treatments scheduled to begin tomorrow, September 17, 2009.

I’ve tried to make the case to APHIS that fall treatments violate the label requirements for imidacloprid. The response from APHIS includes:

"The imidacloprid treatments will continue to be conducted in accordance with the label, which allows treatments to occur any time of the year so long as bees are not visiting flowers while treatments are being conducted."

Please read the above, and consider the following.

1. Imidacloprid is a systemic insecticide. It is designed to spread to every part of the plant, and it does. This includes the pollen and nectar.

2. The requirement that treatments not be conducted while bees are visiting flowers is to protect bees from being poisoned by this product. The manufacturer feels that the product is toxic enough to require this in application.

3. The timeline for fall treatment is that first the trees are treated. The imidacloprid spreads to all tissue of the tree. The tree flowers in February. Bees forage and collect pollen and nectar contaminated by imidacloprid (the levels are unknown). Only after this, do the beetles start to emerge, and either get poisoned while chewing their way out of the tree, or when they try to chew their way in to lay eggs. This is a violation of the intent of the requirements. One cannot claim that the time period between when the pesticide is applied and when it is designed to be effective on the target insect (ALB) is not “the time period the treatment is being conducted”. These treatments are illegal, probably deadly to honeybees. To claim that the requirement only requires that bees not be visiting flowers would allow nighttime treatments, or treatments in the rain on any flower at any time. This interpretation is clearly not what Bayer intended when drafting this requirement.

4. Tree or soil injections of imidacloprid are not applications of topical pesticides that quickly break down. Imidacloprid is being used in the fall because it will keep the tree toxic through spring, past the time bees will be foraging.

I also would like to say that communication with APHIS (and Bob Baca specifically) has been easy and productive. I greatly object to what they are planning to do, and the justifications they use to do so, but nothing seems to have been secretive or done behind anyone’s back. I couldn’t be more impressed in this regard.

I believe the fall application to be illegal, and contrary to the label requirements. If you believe the same, please email the following people at APHIS, as these are the folks I’ve been corresponding with.


Dean Stiglitz


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