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Posted 25 April 09

Section 18 of Federal Insecticide, Fungicide and Rodenticide Act (FIFRA)

(authorizes EPA to let individual States use a pesticide for an unregistered use for a limited time)

The below from the EPA website

From 1997 to 2001 there were 48 section 18's issued for imidacloprid (IMD). The number doubled to 115 section 18 requests from 2002 to 2007.

These old section 18's are important when looking at IMD because IMD can accumulate in the soil.

The web provides access to the EPA's own section 18 database. So anyone can see when the heavy build up starts in a state. Don't take my word for the above you can go look for yourselves.

The below states reported no CCD and also had no section 18's for IMD.

Consider the state of Vermont., with no reported cases of CCD, (according to the published CCD survey) even though surrounded by the CCD states of New York, New Hampshire and Massachusetts. The EPA section 18 database for Vermont says no issued section 18's for Vermont.

Consider Maine with no reported CCD cases. EPA website says no approved section 18's for Maine.
Consider New Mexico with no reported CCD cases. EPA website says no section 18's for IMD approved.
Consider Nebraska with no reported CCD cases. EPA website says no section 18's issued for Nebraska.
Consider Nevada with no CCD - no IMD section 18's
Consider Louisiana with no CCD -no section 18's for IMD
Consider Alabama with no CCD -no IMD
Consider Kansas with no CCD=no IMD
Consider Rhode island with no CCD -no IMD

Consider California which seemed to have the most CCD and was the state with the most section 18's issued for IMD. When you look at the CCD survey and then at the EPA website you easily see that the state with the section 18's for IMD are also the states with the most reported CCD.

Simply a coincidence or a smoking gun?

Consider many beekeepers from out of state sent hives they had checked for mites and strength into California and found those same hives dead or dying within two weeks. Nothing new was found in those bees. So what killed those hives? Many of us believe that only a pesticide could have killed a semi load of strong hives so fast. However with the bees dead in the field proof is hard to find. Many of us see a pattern of losing bees when we enter areas with the most section 18's for IMD. Now IMD has full registration.

IMD was brought into use through a much abused loophole in the pesticide law section 18.


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