The Api-Boxal "liquid" product is going to need its own EPA approval
process, and its own EPA label. So, don't hold your breath.
I know that the nitty-gritty of EPA regs can make one's eyes glaze over, but
if beekeepers are going to play in this space, the context needs to be
better-understood.
The Api-Bioxal premixed oxalic acid and glycerol liquid:
https://alveis.it/wp-content/uploads/2022/08/API-BIOXAL-solution-EN.pdf
is said to be a 62mg/ml concentration of Oxalic in glycerol, to be applied
at a rate of "5ml for frame populated by bees".
The rescinded FIFRA 2(ee) letters in at least VT, NY, DE, and ID (did any
other states copy/promulgate it?) suggested a different dose than the
Api-Boxal powder label, which put those doses outside the bounds of FIFRA
2(ee). Only the use of the same pesticide, at the same dose, in a different
application or methodology is allowed under 2(ee).
The new suggested dose was 50 grams of OA per 50 grams of glycerin, applied
to a "cellulose pad" (not to be confused with a "shop towel"). This was
viewed by the EPA as a "higher dose". But one is forced to point out the
emperor with no clothes here, as dibbling directly onto the bees is going to
deliver a much higher **dose per bee** than the same bee would get from a
soaked cellulose pad. What is the actual dose per bee here, given the
different method of application? No one seems to care to examine this
issue, even though bees may be the only domestic animal where "treatment" is
applied at the "herd" level rather than the individual animal level, where
precision matters more. Heck, how many bees are being treated with the same
50ml of 3.5% oxalic when hive A has 50K bees and hive B has 70K bees? Any
what's the resulting dose per bee? Anyone?
To compare:
Marion Ellis (in the mid-2000s) originally settled on 35 grams per liter of
50/50 sugar syrup, applied at 5ml per "seam of bees" (between the frames),
and 50ml total per colony max
Api-Bioxal was (and still is) labeled the same as the Ellis recommendations.
But, but, but, BUT! There is a lot of variability in well-documented results
presenting contrasting views of what the "effective dose" might be:
https://doi.org/10.1051/apido:2001133 suggests 2.9%
https://doi.org/10.1080/0005772X.2002.11099541 suggests anywhere from 2.4%
to 3%
There are also beekeeper-drafted recipes floating around that suggest 45g
per liter and 60g per liter OA mixes, dismissing the EPA-approved dose as
"weak", and calling the others "medium", and "hot", as if we were discussing
salsa rather than veterinary drugs for animal husbandry. The recipes also
include a convenient mixing guide for a full 12-oz plastic tub of Savogran
10501 Wood Bleach from the hardware store. (Ahem....)
And then there's this:
https://doi.org/10.1080/00218839.2018.1486695 which suggests only 5 grams
per liter of oxalic, with 1.2 grams of thymol in one liter of pure water
alone is just as effective as higher doses of oxalic, but with the downside
of roughly double the collateral damage (3.2% bees killed by treatment vs
1.2% with the higher oxalic-only doses). So, maybe oxalic alone is NOT the
shizzle?
So, what's a beekeeper to do?
1) The exact "dose" of oxalic that any one bee actually receives seems to
matter a lot less to the EPA than the dose per hive. That's what those of
us in the physics wing call "B.A.D. - Broken As Designed".
2) Despite (1), the EPA's regs hold everyone's feet to the fire, as
controlling the "applied dose" is one of the things that feel important to
them, even though it PLAINLY matters a lot less with things like oxalic and
formic acids than it would with the neurotoxins and systemics that are the
EPA's usual stock in trade.
3) On the vaporizing front, there has been zero movement - 1 gram vaporized
per hive seems to be the standard, and no one says we can't do this every 2
weeks. What's the dose per bee then?
Can we get the EPA to allow some variability, given that bee colony
populations vary, creating room for "beekeeper discretion" when a treatment
is being applied to an entire hive? And can approval/registration in the
EU carry some weight towards approval at the EPA?
And nowhere on the oxalic label does the EPA give what should be the most
basic instructions possible - which respirator types will best protect the
beekeeper when vaporizing oxalic.
So, to summarize - what's the safe dose PER BEE?
And what's the safe dose per BEEKEEPER?
Until the EPA wants to address those questions, I don't think anyone is
going to get very far away from the recipes for the 12oz tub found at the
hardware store, as by now, we all own gram-accurate scales, and can do some
math, or find charts made by someone who can.
All of the above is one of the few real-world applications of those horrible
"word problems" we suffered through in 6th grade math, most of them about
trains traveling different speeds or about guards who always lie when
questioned.
New Yorkers must do such problems to merely get around town in the face of
constant breakdowns and changes - Example: "Passengers - This A train is now
a D train running on the F line between Canal Street and Jay St/Metrotech.
For service to York Street take the C Train to Hoyt-Schermerhorn..." But one
train always tells the truth and one always lies - Choose Quick ("Stand
Clear of the Closing Doors...")
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