Bob said:

> As I posted treating ones own bees ( from 1  to a million hives) would not
> be against any label and as long as the beekeeper is  not selling to others
> a product advertised as a *pesticide varroa control*

> One is not breaking any laws I HAVE BEEN TOLD (by people which should know
> what they are talking about)  that using formic acid, salt or FGMO in his or
> her hive/hives as a homeopathic cure.

While this may well be strictly true for the special case of Formic Acid, I think it should
be made clear that Formic Acid has a number of very specific advantages over most all
other possible "alternative mite treatments" that might be used by a beekeeper in the USA:

a)  The U.S. Food and Drug Administration permits ethyl formate and its hydrolysis products,
     formic acid and ethanol, to be used as synthetic flavoring agents in foods per 21 CFR 172.515.

b)  Better yet, formic acid is "Generally Recognized As Safe" ("GRAS") in foods
     by the US FDA.

c)  Formic acid is said to occur naturally in honey at levels up to 138 parts per million,
     and is also found in vinegar, wines, beer, cheese, and even in the human body.
     (In biochem class, I think I dozed off when the instructor started droning on about
     "Formate pathways", so I don't know much more than the fact that formic acid is
      found in amniotic fluid in the womb.  At least our wives and kids are safe from varroa...)

So, we have a special case of a very volatile chemical where any residues in honey would be
hard to differ from "naturally occurring formates", and the chemical at issue is both "GRAS",
and an approved food additive.

The odds of this set of circumstances being true for other items are just about nil.

Peter Borst (who I agree with more often than he might like) said:

>> is the product a pesticide.

Bob answered:

> The correct question is:
> IS THE PRODUCT FORMIC ACID A REGISTERED PESTICIDE and the answer is NO.

I'll try to answer the question "as asked", rather than addressing different questions.  :)

In the US, the EPA decides what is and is not a "pesticide", and they can be very stubborn
about imposing their opinions on others.

In general, if something is USED as a pesticide, then it >>IS<< "a pesticide" under the EPA's
definitions.  To drive this point home, note that the EPA Office of Pesticide Programs was the
group that published the original "exemption from the requirement of a tolerance for residues"
for formic acid, which can be read here:

  http://www.epa.gov/docs/fedrgstr/EPA-PEST/1997/February/Day-05/p2712.htm

So, technically, it is possible to make an accusation under a strict reading of the law of
"using an unregistered pesticide" if one were to use formic acid as a pesticide against mites.

The good news is that you would have a very handy defense - you could claim that
your sole intent was to "flavor" the honey with the formic, and that any "pest impact"
from the process was an unintentional side effect.  If you could say this with a
straight face, the "pesticide" case would be dismissed hands down.

Also, formic acid is not "good" for the bees in of itself, and therefore, cannot really be called
"homeopathic".  When it kills mites, it also carries the risk of nearly unavoidable collateral
damage in the form some small percentage of killed brood and dead bees, even under
optimal conditions.


        jim (who is a "Keyboard Commando", and writes more
                  before 6:00 am than most people write all day)

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