Thanks for allowing feedback on the Best Management Practices.

Recommendation 1) I recommend limiting the document to those practices that will limit operator liability.  For example, the following items would not help limit liability:

I. An apiary operator shall only maintain a colony with EHB or EHB hybrid stock and shall:

1. Obtain queens, packaged bees, nucleus colonies, or established hives from suppliers providing EHB stock, or obtain a queen and bees from a local supplier;(A supplier could provide africanized stock so the provision does not help limit liability.  A beekeeper could also produce their own new queen without going through a supplier.)

2. Not obtain queens or bees from suppliers within 100 miles from known Africanized honey bee populations; (Does not guarantee that africanized stock will not be provided by a supplier)

3. Introduce queens from healthy stock when making divisions or splits of established colonies; (General statement which does not limit liability)

4. Replace queens in all captured or trapped swarms within 30 days of capturing or trapping swarms; (Step does not limit liability.  The existing queen may be adequate.)

6. Mark the thorax or clip a wing of the queens prior to their introduction to splits, swarms, and colonies.(This step will not limit liability)

Points B1, B2, B3, B4 and B7 will also not limit liability so should be eliminated from the document.

Recommendation 2: To receive limited liability a person is required to comply with the Best Management Practices provisions.  What type of documentation is going to be required to demonstrate compliance with the provisions and how long does it need to be maintained?  This needs to be defined in the document so beekeepers will know the requirements.  I recommend that the document state that that the beekeeper is not required to maintain compliance documentation to receive limited liability.

Recommendation 3: How is a beekeeper expected to "Prevent disturbance or injury to bee colony or hive by vertebrate pests"?  Are we expected to kill all the racoons, possums and other vertebrates in the woods to prevent injury to a bee colony?  This point should be dropped as it is impractical and does not limit liability.

Thanks,

Bill Sandel