Agenda 

January 29, 2013 

EPA Meeting with Bayer CropScience & TKI 

on Carbaryl Pollinator Study 

Room S-9671, 11:00 am 

I. Introductions – All 

II. Background and Overview(EPA/PRD) 

III. Review EPA’s Concerns for Carbaryl Exposure & Risk to Bees & Bayer’s steps to 

address concerns (Bayer CropScience) 

a. Risk Assessment Framework for Pollinators 

b. Existing Label Language for Carbaryl Products 

c. Discussion of EPA’s Concerns 

IV. Discussion of Specific Data Needs to Address EPA’s Concerns 

a. Larval study 

b. Tunnel Study 

c. Timeframe for Submission & Review of Protocol 

V. Summary, Conclusions & Next steps 

NOTES

Participants: Tom Steeger, Katrina White, Kris Garber, and Marietta Escheverria (EPA/EFED), 

Christina Scheltema, Tom Moriarty, Tracy Perry, and Patty Parrott (EPA/PRD), Meredith Laws 

(EPA/RD), Mike Gorrell, Dave Fisher, and Lisa Ortego (Bayer CropScience), and Jonathin Akins (TKI). 

Meeting Summary: The purpose of the meeting was to discuss a registration review data requirement 

for a pollinator field study for carbaryl. Bayer CropScience, the carbaryl registrant of record, requested 

the meeting to better understand EPA’s rationale for requiring the study. Bayer had previously 

conducted a field pollinator study for the Sevin XLR formulated product (to satisfy a Data Call-In for 

reregistration) and agreed to implement labeling to mitigate risk to bees as part of the reregistration 

process. 

Bayer gave a short presentation summarizing their perspective. This included a brief discussion of the 

recently developed risk assessment framework for pollinators, the existing label language for carbaryl, 

and existing pollinator field studies for carbaryl. This was followed by a discussion of EPA’s concerns 

for uses that were not addressed by the labeling as well as EPA’s data needs for registration review. The 

Agency is requiring additional data to fulfill the remaining data gaps and uncertainties regarding 

pollinator exposure to and risk from labeled uses of carbaryl. 

EPA staff clarified the rationale for the data requirement, as well as the specific data requirements for a 

larval study and a semi-field study on intact hives. EPA staff also clarified that the semi-field study 

should be conducted using a crop that is attractive to bees and is a good source of pollen and nectar1

, 

treated directly with carbaryl. Although the current carbaryl labels prohibit application to plants during 

bloom, the semi-field study should be conducted with a crop in bloom to evaluate the effects of carbaryl 

to a hive under worst-case conditions. Bayer requested until February 15, 2013 to submit a testing 

proposal. EPA agreed, provided that protocols follow shortly thereafter. 

 

1

 Such as buckwheat or clover 
Name 

January 29, 2013 

Carbaryl Meeting with Bayer CropScience and TKI 

to Discuss Pollinator Study 

Potomac Yard South 

11:00 am to noon 

Room S-9671 

Please Sign In 

Affiliation Phone/e-mail 

1-0 3 - 3oS-b:tl{li 

I 
lis exposure likely? No 

Tlert 

Tter 2 

Tter3 

Yes l 

Screening Assessment: Yes 

Does the proposed use "pass" the screen, which ~ 

indicates the risk Is minimal? .-P-re-s-um_e___, 

r--------11 No Minimal + 

!

Assess effects In a semi-field test. Do I Yes ._R_Is_k _ __, 

results Indicate minimal risk? ::J 

1---------J No 

I Assess effects In a+ field test. Do I Yes 

results indicate minimal risk? 

Apply mitigation I Yes I Can the risk be mitigated via label 

and reassess - warnings, restrictions, etc? 

Presume 

Significant 

Risk 

Carbaryl Bee Label Language 

Sevin XLR Plus, 4F 

• BEE CAUTION: This product is highly toxic to honeybees and other 

bees exposed to direct treatment or residues on crops or weeds in 

bloom. This product may show residual toxicity to honeybees, 

especially in humid climates or under slow drying conditions. 

Notifying beekeepers within 1 mile of treatment and at least 48 

hours before product is applied will allow them to take additional 

steps to protect their bees. limiting application to times when bees 

are least active, e.g., within 2 hours of sunrise or sunset, will 

minimize risk to bees 

• For crops in bloom (except soybean and corn): Do not apply this 

product to target crops or weeds in bloom. 

• For soybean and corn: If application cannot be avoided when target 

crops or weeds are in bloom, limiting applications to times when 

bees are least active, e.g., within 2 hours of sunrise or sunset, will 

minimize risk to bees 

1/28/2013 

1 
Carbaryl Bee Label Language 

Home and Garden Products: Sevin 

Concentrate, RTS, Garden Dust, RTU 

• BEE CAUTION: MAY KILL HONEYBEES AND 

OTHER BEES. This product is highly toxic to 

honeybees and other bees. Do not apply to 

plants in bloom. 

1/28/2013 

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