From: ddhess@bellsouth.net
Date: Sun, 17 Jun 2001 02:02:32 -0000
To: BiologicalBeekeeping@yahoogroups.com
Subject: line-by-line: 61-63

Heres my attempt to start a line-by-line discussion. :)

The reference so we can all be on the same page:
http://www.beesource.com/news/article/cconorganic.htm

Dee had previously listed (post 1213?) a list of the lines that she
was aware of issues arising, 63 was included there. I'll try to touch
on 61-63.

61.
Hives for beekeeping shall be placed in areas where
cultivated and/or spontaneous vegetation comply with the
rules of production as set out in Section 4 of these
Guidelines.
62.
The official certification body or authority shall approve the
areas which ensure appropriate sources of honeydew,
nectar and pollen based on information provided by the
operators and/or through the process of inspection.

The official certification body or authority may
designate a specific radius from the hive in which the
bees may access adequate and sufficient nutrition that
meets the requirements of these Guidelines.
63.
The certification body or authority must identify zones
where hives, that meet these requirements, should not be
placed due to potential sources of contamination with
prohibited substances, genetically modified organisms or
environmental contaminants.

Requirements regarding bee forage strike me as being one of the most
problematic issues to assess and comply with. 61 and 62 basically say
that bee forage needs to be organic and the certification body can
approve the area and set a poison-free radius. I do think this makes
some sense. Putting untreated hives on farmer Joe's farm who
routinely sprays for every pest under the sun sounds somewhat contrary
to the goal of organic honey (so point 61 seems to say that the land
where you actually have the hive needs to be 'cide free). The
question I have is just how to define the forage radius. Bees
certainly forage over wide ranges, but the vast majority of their
foraging won't be at the farthest reaches. I would think that the
majority of foraging is probably within a 1mile radius -- anyone have
any data on foraging density/probability? Another way of making
forage criteria more achievable would be to specify something like
"within X radius no more than 25% of the land may be occupied by
non-organic agriculture." I think the thing we're trying to achieve
is preventing bees foraging primarily on chemical-treated agriculture,
while trying to call that honey organic. I think a combination of
radii and percentages would adequately achieve this.

In terms of specifying no-bees-land, to some extent that is redundant
to approving bee-ok areas. The times when specification of a no-bee
radius might be appropriate could include GMO's and if there are any
toxins known to be collected by the bees in significant ammounts; and
in order not to be completely redundant, these radii or tolerances
must not be identical to criteria for approving bee-ok apiaries.
"Zones where hives, that meet these requirements, should not be
placed" implies that there are two sets of criteria - one for
approving sites, another different one for excluding. Examples that I
could think of would be if you have a 1-mile organic radius for
approving apiaries, you wouldn't want _any_ bees foraging from land
contaminated by non-agricultural toxins, so the radius for these
particular contexts may be 4 miles, the same may apply for GMO's. In
general, it may be appropriate for the certifying body to keep its
zone-definition to a minimum.

Summary of issues:
-Is it appropriate to deny certification on the basis of forage?
-What criteria should be used:
what radius do we consider the bees to get the vast majority of
their forage?
given that bees can probably go outside of that radius, would it be
reasonable to set a tolerance percentage of non-organically produced
forage? if so, what percentage?
-Under what conditions should the CB's establish a !bee radius such
that it is different from site-approval criteria?

((is this the sort of treatment of the items you're looking for?))

-Don