{Blogger’s note: This post was completed with the very welcome assistance of my colleague Jo Ann Baumgartner, director of the Wild Farm Alliance located in Watsonville, California. Jo Ann can be reached at wildfarms@earthlink.net}

I was honored to be asked this year to address the annual conference of the Eastern Apicultural Society (EAS) held in early August in West Chester, Pennsylvania.  With well over 500 professional beekeepers and bee scientists present, it was also a tremendous opportunity for me to learn something about a topic with which I had very little previous experience. I was both amazed and a bit alarmed with what I learned.

While the occurrence of Colony Collapse Disorder has captured the concern of the general public, very few people know just how complex the situation with honeybees really is.  I’ll add that even fewer have any idea how the viability of the bee population might be affected by the Food Safety Modernization Act (FSMA). Congress passed FSMA in 2010, and the Food and Drug Administration (FDA) has now issued proposed rules for its implementation, with a deadline of November 15, 2013 for public comment.

In brief, the situation for honeybees and other pollinators, already dire in some places, is likely to get worse as new regulations associated with FSMA take effect. It really comes down to loss of biodiversity in the diet of honeybees and potential destruction of the habitat necessary for their survival. To the extent that food safety regulations make these situations any worse, by promoting the separation – far away from food crops – of what also functions as wildlife habitat, so will the pollinators, and ultimately the crops themselves, suffer.

What I learned at EAS is that the real problem for honeybees in particular starts with the expectations of large agricultural operations (for example, those producing almonds) wanting the bees to do their jobs on a steady diet of just one thing, i.e. whatever the intended crop happens to be. Deprived of the benefits of a more diverse diet, our heroes are often then subjected to a barrage of pesticides used on those, and neighboring farms, including insecticides, herbicides and fungicides. Recent research has documented well over 100 different “cide” compounds present in beehives, including the continuing occurrence of DDT forty years after it was banned for agricultural use in this country. The trifecta of honeybee hazards is then completed by a host of natural threats in the environment, including various pathogens, parasites and viruses. It’s enough to make one wonder how any of our pollinator friends survive at all, let alone thrive well enough to help in producing food for a burgeoning human population.

So it’s not that FSMA would require the removal of wildlife habitat – which is also important to pollinators – from areas adjacent to produce-growing operations. But the proposed regulations do not require co-management of farmland for both food production and wildlife conservation, and they do nothing to prevent the unwarranted destruction of habitat. If significant intrusion of certain wild animals occurs on a farm, the regulations should limit control measures to exclude those pest animals, and not allow the incident to be used as a reason to exclude all wild animals and their habitat – and by extension, all pollinator habitat.

The trend in recent years has been toward removal of such wild areas, and while this might seem to be a positive short-term step in certain situations where wildlife are significantly causing harm (eating the crop and leaving feces), it is also true that over the longer term, wildlife must have adequate habitat in order to prevent them from spending more time in the fields, foraging for food they may not even prefer. As an illustration, I often observe groundhogs foraging among the multitude of “weeds” in my untreated and un-mown lawn, preferring them to anything found in my vegetable garden that is well within their view. Likewise, I have observed rabbits using my garden for mid-day shade, and then coming out in the evening to forage from the lawn and other wild areas along the edges.

This is really a reflection of the situation in other aspects of food production wherein “balance” is the key concept for achieving both profitability and environmental protection.  It’s also analogous to what we are learning about the balance needed to maintain health at all levels of the entire food system, from the soil right up to and including human beings. The tendency toward separating different parts of the system remotely across the landscape will almost certainly result in a less healthy system overall, including especially the more frequent occurrence of unwanted pathogens in the food we wish to eat.

It is known that the presence of pollinators and pollinator habitat is a boon to food production (seems funny to even have to say it), and there is evidence that honeybees do a better job when in the company of a healthy population of native pollinators as well. In fact in windy conditions, native pollinators can do a better job than honeybees. If it is also true that pollinator habitat can help to moderate the negative effects of wildlife on a farm, then any regulations aimed at improving the safety of food being produced should also encourage and even require the ongoing provision and management of such habitat.

Folks who believe that assuring biodiversity in the future is critical to our food system should weigh in on the matter in the context of written comments to the FDA concerning the proposed FSMA rules by the November 15 deadline.  For more information on making comments, please see the FSMA Action Center maintained by the National Sustainable Agriculture Coalition (NSAC) and the analyses of conservation practices and wildlife management in particular. There are also a number of important resources, both for your farms and your comments to FDA, on the website of the Wild Farm Alliance.

*                                                          *                                                          *

It is critical that the implications of FSMA for honeybees and other pollinators be understood, and well-informed comments need to be submitted.  Please share this with apicultural groups, both commercial and backyard beekeepers, and anyone who is interested in maintaining healthy ecosystems through enhanced biodiversity. Also, please see other related posts on the Write to Farm blog.