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From:
James Fischer <[log in to unmask]>
Reply To:
Informed Discussion of Beekeeping Issues and Bee Biology <[log in to unmask]>
Date:
Tue, 4 Apr 2023 16:56:32 -0400
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I think it is important to point out that nothing has ever really "effectively controlled varroa".  Not ever.
What we have been offered is various treatments which strived to merely keep varroa from overwhelming colonies, and even that was a high hurdle for some treatments.

So, when a manufacturer submits all the required paperwork for yet another varroa treatment, the EPA is happy to approve it for use, but when:

a) beekeepers read yet another magazine article making yet another set of claims that an alternative technique is "better" 

b) the claims are based upon tests that may lack statistical significance and/or sample size significance

c) the beekeepers then cajole state apiarists into a reading of the regs that is most charitably described as "highly creative"

The EPA is simply not going to play that.

But we face multiple problems:

1) Very few people are buying the registered product due to cost, given knowledge of the purity of the generic hardware store product

2) Due to low sales, there is little incentive for any manufacturer to spend more money on additional registration work, when it will be years before the first registration is paid for with profits.

3) So-called "scofflaws" have a very plausible explanation for using "wood bleach" as they see fit on wood that the bees clearly stain with propolis and the dirty little feet that they never wipe on the welcome mats I install.  As both some bees die and some varroa die each time this process occurs, it is easy to describe the deaths as "collateral damage", and avoid a claim that one has any pesticidal intentions, as no beekeeper willingly kills any of his/her bees.

4)  So, what’s needed first is legit controlled studies to bridge the gap between what the beekeepers wish to be true, and what the EPA will accept as true.  Beekeepers can certainly take up a collection and fund some research to be published in legit journals, it's been done before.  

But the companies selling oxalic know that their sales will not significantly increase as a result of any additional registrations, so they see no incentive to throw more money into the pit in hopes that they will sell more tiny pre-measured packets of a readily-available generic chemical.  They might sell "convenience" in the form of a prepared "pad", similar to the formic acid pads, but beekeepers are well-known for spending more time and incurring more operational costs in attempts to avoid spending hard-earned cash on packaged products than the packaged products would ever cost - it is comical in many cases I have witnessed.

But with some solid science, one might be able to get the "new and improved kinder, gentler" EPA/FDA to perhaps waive some fees for such "minor use" and "specialty crop" applications, moreso, when the use is down near the "food grade range" of concentrations. But first, we'd need some very bulletproof studies published under the names of some world-class R&D folks.  The good news here is that the former head of the USDA Beltsville Bee Lab is a free agent, and works for a US-registered 501(c)(3) charity group to which one can donate money, and deduct the money from one's US taxes.  One suspects he might be able to assemble a rag-tag band of misfits and malcontents that can take up the challenge, and publish something.

Or, we could just continue to continue as it was, and has been, for decades.  (Before "was" was was, was was "is".)

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