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coumaphos (Checkmite)
NYS DEC Letter - Specific Exemption Request for Use in Bee Hives 1/02

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

January 3, 2002

CERTIFIED MAIL
RETURN RECEIPT REQUESTED


Ms. Meredith Laws
Team Leader
USEPA/Office of Pesticide Programs
Emergency Response Team (7505C)
Document Processing Desk
Crystal Mall 2--2nd Floor
1921 Jefferson Davis Highway
Arlington, Virginia 22202

Dear Ms. Laws:

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 2002

    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 2001 Section 18 use, a statement from Mann Lake Ltd. verifying the number of strips in New York and a honey residue analysis performed by the New York State Department of Agriculture and Markets, after the conference call on Coumaphos on September 27, 2001 (Appendix P).

    This is the fourth 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 84,328 strips (118,059 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. 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 anticipate submitting a request for a Section 3 registration in the first quarter of 2002 (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 states' applicators have had an opportunity to learn of resistance and residues in bee products if these strips are applied improperly. Tests conducted by the Apiary Inspection program this past season show that New York State residues are well below tolerance levels (Appendix P).

    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
Division of Solid & Hazardous Materials

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