> will do nothing but more firmly cement the perception that it is far easier to just ignore the whole mess

The letter while not a surprise is still a disappointment. Bureaucratic compliance is the only issue addressed with only passing note that OAE would create a "chronic" exposure.

>The FIFRA 2(ee) bulletin instructs users to create and apply a product that will present chronic exposure of oxalic acid to bees and humans. The currently registered product results in acute exposure only.  Therefore, the EPA-registered product label may not be protective of chronic exposure. 

Compliance with the Api-Bioxal label is the law. However it is universally known, even shown in controlled university studies that it is not effective in controlling varroa as labeled. It is also unrealistic to expect any registrant to invest the considerable sums necessary to gain a new, or alter the existing label.

There is a body of research, products available legally in other jurisdictions, and widespread use by numerous beekeepers on hundreds of thousands of colonys over several years  that have shown the safety and effectiveness of OAE. To my knowledge there is no evidence of harm to humans or bees or the environment. 

The situation is left unchanged. I thank the researchers that have devoted no small amount of time and money in exploring this effective varroa control. I only wish that the product could be judged and tested on it's merits. It will no doubt shock the EPA but the cat is clearly out of the bag. 

"Brer bear he say nutin, brer fox he lay low"  Joel Chandler Harris

Paul

 

 

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