Grasshoppers, Mormon Crickets and Carbaryl (Sevin) Reregistration

U.S. Environmental Protection Agency (EPA) is conducting a re-registration process for carbaryl.  Detailed information is available at:

 http://docket.epa.gov/edkpub/do/EDKStaffCollectionDetailView?objectId=0b0007d4801eebd5

 http://epa.gov/redrgstr/EPA-PEST/2004/October/Day-27/p24038.htm

 http://epa.gov/oppsrrd1/REDs/carbaryl_ired.pdf

 The current proposal may severely impact the APHIS Rangeland Grasshopper/Mormon Cricket Suppression program.  Should you agree it is important for stakeholders to provide comments during the comment period which ends December 27, 2004.  EPA encourages submission of comments through the EDOCKET System which is located at the web site listed above.

 Here are what I believe to be the most significant issues in the current proposal:

 1.  The application rate of carbaryl bait is proposed to be reduced to 0.03 or 0.06 lbs active ingredient per acre with a maximum of one application per season.  I believe that it is critical that an application rate of at least 0.5 lbs active ingredient per acre should be maintained.  The proposed application rate of  0.03 or 0.06 lbs per acre would not be effective against grasshopper and Mormon cricket outbreaks in Idaho, and APHIS would not attempt a program that could not be effective.

 2.  Proposed label language includes, “Do not apply this product or allow it to drift to blooming crops or weeds if bees are visiting the treatment area.”  This language would be applied to all carbaryl labels.  The current bee warning on Sevin 5 Bait reads, “This product is highly toxic to bees exposed to direct treatment or residues on crops.  Protective information may be obtained from your Cooperative Agricultural Agent.”  The current bee warning on Sevin XLR Plus reads, “This product is highly toxic to bees exposed to direct treatment or residues on blooming crops or weeds.  However field studies have shown that SEVIN brand XLR Plus Carbaryl Insecticide is less hazardous to honey bees than other carbaryl products when direct application to bees is avoided and the spray residues have dried.  For maximum honey bee hazard reduction, apply from late evening to early morning when bees are not foraging.  Do not apply this product or allow it to drift to blooming crops or weeds if bees are foraging in the treatment area.  However, applications may be made during foraging periods if the beekeeper takes on of the following precautionary measures prior to bee flight activity on the day of treatment:  (1) Confine the honey bees to the hive by covering the colony or screening the entrance or; (2) locate hives beyond bee flight range from the treated area.  Precautionary measures may be discontinued after spray resides have dried.  Contact you cooperative Agricultural Extension Service or your local Bayer CropScience representative for further information.” 

 The proposed language would effectively eliminate all carbaryl treatments, including bait from the Idaho grasshopper/Mormon cricket suppression program because every treatment area has weeds blooming and bees visiting.  The language in the Sevin XLR Plus label seems to refer to liquid sprays and should not be inferred to reflect the effects of bait on managed or wild bees.  I believe it is in the best interests of beekeepers to urge EPA to adopt bee warning language that will not prevent use of carbaryl bait for grasshopper/Mormon cricket suppression.   Retention of the current bee hazard label language for bait and Sevin XLR appear to be the best solution. Substitution of other insecticides for carbaryl bait could lead to greater risk to bees and abandonment of the rangeland  grasshopper/Mormon cricket suppression program would result in less forage for the bees because of consumption of rangeland flowering plants by the grasshoppers and crickets.