Beekeeping Pesticide Policy Plan

To: Our Esteemed Congressperson
RE: Beekeeping Pesticide Policy Plan

While we sincerely apologize for the late request for help, this is a serious issue for our food security.

While most associate honeybees with a jar of honey, the real economic impact of U.S. beekeepers to the agricultural economy is for pollination services, resulting in billions of dollars annually from the production of produce and seed stocks. From apples and oranges, to brown mustard seed and canola, the range of critical honeybee services is much larger than most realize. Each year USDA estimates our value to agricultural production to be $30 billion, but it is actually higher as many products would simply vanish or be considerably higher priced.

In November of 2023, the EPA announced that the FDA is actively working towards assuming responsibility of ectoparasites this would by their own admission include honeybees. This decision was lumping an issue with dogs, cats and companion animals into an issue for an agricultural problem.

Since that time the FDA has announced a halt to this plan, BUT in this they have prompted us to propose a permanent solution to many of the problems facing us today. There are currently two real issues, one is the ping pong game of regulatory authority between EPA and FDA, as well as the inability of the EPA to make rules that only apply to apiculture. This issue is compounded by our need to kill a bug on a bug with both feed additives and directly applied pesticides.

A major portion of this ask is also based on streamlining our process thru the EPA. One of the major hurdles is that in apiculture we run faster than any other industry. We typically have 15 generations of bees in a single season, and an extremely short windows to respond to invasive pest. In this request, we are simply asking to allow the EPA to develop rules faster, and to eliminate the time-consuming processes of proof of finances for example. This will give the nations beekeepers easier and faster access to the treatments we need to keep our production in place.

Given the national losses are continuing to climb, and approaching 50% annually, we feel it is imperative.
While we in the beekeeping community understand this is a very difficult issue, but also recognize it has the potential to create significant problems for the industry responsible for a huge portion of agriculture production in the U.S.

We believe the following to be concise, simple and in no way controversial.

So as a solution we request the following amendments to FIFRA:

Proposed policy plan: Requested changes to FIFRA

1. Honeybees, and beekeeping to be officially designated, for pesticidal regulatory purposes only, by the EPA as a “Minor Use Crop” and by statute remain under EPA jurisdiction.
2. The designation of “in hive “use of selected low-risk biopesticides as approved by EPA to be designated as “Minimal Risk Pesticides” for this crop only. This would apply only to Active Ingredients that have been determined to be safe and have tolerance level exemptions. Minimal Risk designation would allow for generics from all suppliers who can establish purity levels as required.
   Any producer wishing to sell or market registered products, must still follow EPA all rules for registration
3. New pesticidal approvals for apicultural use be placed under Section 18 SEL standards for approval and processed within 24 months. Said approval to remain in place until full approval process is completed.
4. Grant an exemption of personal use by beekeepers of specified generic natural substances
   Since the use of generic oxalic acid, formic acid, thymol, or food-grade plant oils applied to bee hives poses no unreasonable risk to man or the environment, the use of these substances for parasite control in one’s own bee hives are not and shall not be subject to regulation under FIRA or by other regulatory agencies.  This exemption is limited to the preparation and application of these generic products by a person for their own use, and does not affect the requirement for registration of products to be advertised or sold for pesticidal purposes.
5. Pesticidal claims using feed as the preferred delivery method remain under EPA guidelines for approvals.
6. USDA shall be allowed to be certificate of registration holders on behalf of the beekeeping industry and sub licenses granted when appropriate. USDA shall bear no liability for efficacy or usage of said products. The USDA position to be only as that of certificate holder for the industry.
7. To ensure continuity of migratory beekeeping across the U.S. Federal EPA approval will be considered as the standard regulatory and enforcement process unless otherwise specified by state regulations.