Mr. Dan Rosenblatt
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 Thymol (Api-Life VAR - No EPA Reg. No.) in Bee Hives to Suppress the Varroa Mite 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 1).
This is the second year that we are requesting thymol (Api-Life VAR) for emergency use to suppress the varroa mite in bee hives in all counties of New York State. Varroa mites were first found in New York State about 14 years ago. At that time, they were effectively controlled using Apistan, but resistant mites began to be detected in this State as early as 1999. A second pesticide, Coumaphos, has been effective in the past six years and a Specific Exemption for its use has been requested for the 2005 season. As good as Coumaphos is, however, resistant mites have begun to be detected in Florida and Maine in the past couple of years. With the migratory nature of the beekeeping industry, we have to assume that some coumaphos resistant mites have entered New York State.
Toxicity issues and the development of resistant mites have been the impetus for research into alternative methods of control. Thymol, in a blend with other plant extracts, was highly effective in controlling Varroa (Appendix C). This product is most effective when less sealed brood is present in the hives and use of this product in mid spring or early fall will not disrupt honey collection.
For suppression of Varroa mite, a mid spring and/or early fall treatment with thymol is being requested. Effective control of Varroa mites may be achieved by two treatments of one tablet each, broken into two or three pieces and placed on the top corners of the hive body. Of the 66,400 colonies in New York, it is anticipated that 50% of the nonmigratory colonies (24,900) will try Api-Life VAR. Therefore, the total amount of pesticide to be used is estimated to be 547.8 kg product. Applicators and other handlers must wear the specified PPE, and all precautions, restrictions and warnings on the label must be followed.
Brushy Mountain Bee Farm, the U.S. representative of the registrant, fully supports our efforts to obtain an emergency exemption for the use of Api-Life VAR in bee hives in New York State. IR-4 conducted residue trials in three states in 2003, under PR# 08661. The data was submitted to USEPA on October 21, 2003 (Appendix F).
Cornell University is committed to training beekeepers in the proper use of Api-Life VAR. 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 proper pesticide application.
The use season for this product is listed as "any season," but with optimal average daily temperatures between 59 F and 69 F, the estimated use season in New York will be in mid to late spring, and then again late summer to early fall.
Please contact Robin Hackett, of our Pesticide Product Registration Section, at (518) 402-8768, if you require further assistance on this request.
Maureen P. Serafini
Bureau of Pesticides Management
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.