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Subject:
From:
Gavin Ramsay <[log in to unmask]>
Reply To:
Informed Discussion of Beekeeping Issues and Bee Biology <[log in to unmask]>
Date:
Wed, 28 Mar 2007 23:13:53 +0000
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John wrote: 
> and the UK situation could change


I t
Hi All
 
John wrote: 
> and the UK situation could change


I think that it has.
 
There are three approved varroacides in the UK: Bayvarol (flumethrin), Apistan (tau-fluvalinate) and Apiguard (thymol), and beekeepers can legally apply them as long as they stick to the label requirements.  The advice on 'non-approved generic substances' is that, essentially, their use by beekeepers is illegal.  However Vets can prescribe the use of additional varroacides under certain conditions, and oxalic acid is one of these.
 
This document explains all, and is a good read anyway as it explains non-chemical methods of control too and has nice pictures and diagrams:
http://beebase.csl.gov.uk/pdfs/managing_varroa.pdf
 
The crucial text explaining the official position on the use of non-approved substances is below.  
FWIW many UK beekeepers have already adopted the use of some of these compounds and persuading them to give them up to meet the current regulations will be quite a challenge.  For example, oxalic acid is popular, and from extensive research on the continent dribbling solutions between frames while there is very little brood well away from the honey season has very little risk to the operator, to the bees, and is unlikely to leave significant residues in subsequent honey harvests.  When its use is unregulated things start to go awry, with mode of application, timing and amounts variable and sometimes posing a risk to bees or beekeepers.
 
all the best
 
Gavin.
 
Use of non-approved generic substances
In many European countries, including the UK, some beekeepers have used generic naturally
occurring substances including organic acids (such as formic acid, lactic acid and oxalic acid) and
essential oils (such as thymol) as part of their varroa control programme.
In most cases, no formal testing of efficacy or safety of these substances has taken place, and
therefore there is a danger that they might be ineffective, harmful to bees, the environment or
the user, or leave harmful or otherwise undesirable residues in bee products. Beekeepers
contemplating their use need to be aware that personal protective clothing (such as gloves, face
and eye protection, and respiratory protection) may be necessary. Beekeepers should also be
aware that they may be liable to be prosecuted should the routine sampling and testing of
products for residues find positive results.
The legal position relating to the use of such generic substances is complex, and is likely to be
affected by changes in the veterinary medicines legislation due to come into force in October
2005. This legislation controls the manufacture, marketing, supply, administration and residues of
veterinary medicinal products (VMPs).
 
Using varroacides
Under the existing legislation, it is not legal to market or to administer a VMP that is not
authorised by the VMD. However, an exception exists under the ¡prescribing cascade¢. Where no
VMP is authorised for a condition in a particular species this allows a veterinary surgeon to
prescribe or administer certain other defined categories of medicine under controlled conditions
of use. In circumstances where a veterinarian concluded, on the basis of his/her professional and
clinical judgement, that an authorised product was not appropriate in a particular case (because
of problems with resistance for example), this may currently allow the use of lactic acid, but not
formic acid and oxalic acid.
In the new legislation it is anticipated that a provision will be included to allow a veterinarian
acting under the cascade to use a product authorised in another Member State (subject to certain
conditions and restrictions) or to use an extemporaneous preparation provided the active
ingredient has a Maximum Residue Limit (MRL) defined. As lactic, formic, and oxalic acids all are
listed as not requiring an MRL (in Annex II of Council Regulation (EEC) No 2377/90) they will be
able to be used under prescription by a veterinarian in accordance with the prescribing cascade
provisions. Further information on administration controls and the prescribing cascade is available
on the VMD website (www.vmd.gov.uk). Advice on the current provisions is in AMELIA guidance
note no. 8 and on the new provisions in Veterinary Medicines Guidance Note 15.

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