While the active ingredient is NOT buried in the fine print of the product label, the reason for this quote was about the homeowner. In many cases, the homeowner is the reason for a product to become “restricted use” or to be banned completely. The old adage “more is good” comes to mind. In addition, anyone who apples this type of a systemic to a fruit tree is nuts. Afterall, it is a systemic product that attaches to the carbon cell to translocate through the plant. A quicker contact product or horticultural oil will suffice for most fruit tree pests.

Unfortunately, homeowners should never have access to most of the pesticide products on the market. Only a certified applicator should use these products. Trust me , I am an arborist and I have seen the devestation from ALB and from emerald ash borer as well as the haphazard use of pesticides by non-certified applicators.

The EPA’s primary recognized and funded studies on CCD are happening at Penn State. Penn State has been presented with many millons of dollars from Bayer (American headquarters in Pitssburgh, where 148 of just over two hundred Bayer Ag employees are Nittany Lions), with nearly two million directly given to the Agriculture programs. Bayer also bankrolled the rebuild of the Pesticide Research Lab at Pen State, which interestingly has been renamed the Chemical Ecology Lab. And the studies there continue to focus on the 50 PPB range and higher, a range detectable and avoided by bees. EU studies find bee injury and mortality have been found to start and culminate in the 2-6 PPB range, a fact convenient to Bayer, and continually misleading in it’s “studies”. And these are exactly the levels we expect to see after several years of degradation of this product. And as ALL plant life uptakes this chemical, concentrating it to flowering points (hence pollen), any pollen gathering insect can expect a nearly continual exposure ass this stuff is introduced and reintroduced by wave after wave of plants (so even hemlock application will eventually move it to the bees perview, and yes, Paul, this is a very commonly used pesticide for wooly adlegid).

Until sub-lethal testing is actually performed, one cannot rule out chronic neonicotinoid poisoning as a component of CCD. And considering that no actual EPA-mandated, required-by-law study has ever been performed, I am completely at a loss to see how EC determined neonicotinoids having been ruled out. Imidicloprid has operated under nearly 200 Section 18 emergency waivers since it’s introduction around 1997, despite the fact that Section 18 specifically states that such exemptions are to last “1) Specific or public health exemptions: no longer than one year 2) Quarantine exemptions: no longer than three years.” It is also interesting to note that any facts pointing to secondary poisoning or other environmental factor should immediately suspend a Section 18 waiver, hence the need for Bayer et al to squash any sign that there might be a connection. Also interesting in this regard is the EPA’s now seven year long refusal to honor an FOI request submitted by the NRDC

So we have a lab virtually built (and almost certainly named) by the manufacturer of said toxin, to study the effects of said best selling product, one on which said company has clearly bet the farm, and now said lab is returning a clean bill of health. What a surprise. Yet the EU finded studies, actually working with sub-lethal dosing found that Bayer outright lied on initial claims (saying it would never reach nectar or pollen despite no real supporting evidence, and that 5 PPM was the bee-lethal dose, despite the fact that it is 100 times more lethal than that) and that after 416 days of fallow conditions, 56% of the product was still viable in the soil and uptaken in a new crop. Perhaps most damning would be the company’s own text on a bag of their IMD product for termites “they stop feeding and are unable to maintain their colony.” and “This product makes termites susceptible to to infection by naturally occurring organisms.”

Perhaps we cannot yet clearly point to IMD as the single causal agent in CCD, but there is ample evidence to support it’s destabilizing effect on bee colonies. On this alone we have sufficient and legally binding cause to suspend Section 18 exemmption and subject all neonicotinoid pesticides to tha actual reviews demanded by our laws. As to why these are not already being enforced as enacted is another troubling conversation for another day, but IMD is clearly tied into CCD and should be disposed of on that alone…