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coumaphos
NYS DEC Letter - Specific Exemption Request for Use in Bee Hives to Control the Varroa Mite and the Small Hive Beetle in 2005 12/04

New York State Department of Environmental Conservation
Division of Solid and Hazardous Materials

Bureau of Pesticides Management, 9th Floor
625 Broadway, Albany, New York 12233-7254
Phone: (518) 402-8788     FAX: (518) 402-9024
Website: www.dec.state.ny.us

December 9, 2004

Mr. Dan Rosenblatt
Team Leader
USEPA/Office of Pesticide Programs
Emergency Response Team (7505C)
Document Processing Desk
Crystal Mall 2-- 2nd Floor
1801 Bell St.
Arlington, Virginia 22202

Dear Mr. Rosenblatt:

Re: Specific Exemption Request for Use of Coumaphos (Bayer CheckMite+ Strips - No EPA Reg. No.) in Bee Hives to Control the Varroa Mite and the Small Hive Beetle in 2005

    The New York State Department of Environmental Conservation, as the State lead agency for pesticide matters, hereby requests approval of the referenced application (see enclosure) under Section 18 of the Federal Insecticide, Fungicide and Rodenticide Act, as amended. The enclosed application includes the information required in 40 CFR, Part 166, Subpart B (166.20). Also enclosed is the use report from the 2004 Section 18 use (Appendix H). This is the seventh year that we are requesting coumaphos (Checkmite+ Strips) for emergency use to control the varroa mite and small hive beetle in bee hives in all counties of New York State. The anticipated total use is 84,128 strips (117,779 grams active ingredient) Statewide.

    As discussed in the submission, the Varroa mite is developing resistance to Apistan Strips, and is only suppressed by the Formic acid gel pacs that are the registered alternative. Also registered is the new sucrose octanoate ester product, Sucrocide. This solution must be sprayed on each bee of a hive, a labor intensive treatment that will likely be of interest only to the hobbyist, looking for a chemical alternative to Apistan and Checkmite. Of year-round colonies, 12% are estimated to be infested with Apistan resistant mites. Of migratory colonies, 90% are estimated to have some degree of resistance to Apistan. For small hive beetle, no other pesticide has been identified that will control this pest without also killing bees.

    For control of Varroa mite, twice a year treatments of coumaphos are being requested. Effective control of Varroa mites may be achieved by treating hives in the spring before the honey flow and in the fall after the last honey flow. Strips are to be left in the hive for at least 42 days (six weeks), but not more than 45 days. For control of small hive beetle, a maximum of four treatments, lasting at least 42 days (six weeks), but no more than 45 days, are being requested.

    Bayer Corporation, the manufacturer of CheckMite+ Strips, fully supports our efforts to obtain an emergency exemption for the use of CheckMite+ in bee hives in New York State. They submitted a request to USEPA, for a section 3 registration in October 2002. On August 21, 2002, IR-4 submitted the tolerance petition (Pesticide Petition No. 2E6504) for coumaphos in or on honey/honeycomb to USEPA for review (Appendix G).

    Cornell University is committed to training beekeepers in the proper use of Coumaphos strips. Through a combination of a nine-hour IPM course, talks with local beekeeper groups and programs at the State honey producers meeting, many of the State's applicators have had an opportunity to learn of resistance and residues in bee products if these strips are applied improperly.

    Use of coumaphos is needed by mid March due to the USEPA requirement to wait 14 days between the removal of the strips and the installation of the honey supers. Honey supers are traditionally added around the middle of May. Thank you in advance for your attention to this request.

    Please contact Robin Hackett, of our Pesticide Product Registration Section, at (518) 402-8768, if you require further assistance on this request.

Sincerely,

Maureen P. Serafini
Director
Bureau of Pesticides Management

Enclosures
cc: w/enc. - A. Enache, USEPA Region II
cc: w/o enc. - W. Smith, Cornell University, PSUR
R. Zimmerman\R. Mungari, New York State Dept. Of Ag. & Mkts.