>  I still don't see beekeepers paying a markup for oxalic acid over and
above the lowest price that they can find in  a walk down the hardware
aisle, as they would do so even to avoid a shipping charge.

Exactly why I've been pushing for a generic "Approved application method"
submitted by either USDA or a third party not interested in making a profit.

Randy Oliver
Grass Valley, CA
ScientificBeekeeping.com


On Wed, Sep 2, 2020 at 3:35 PM James Fischer <[log in to unmask]>
wrote:

> > But when I did work in the area there was no production or formulation
> facility registration...
> > I find nothing on the current EPA pesticide registration web site that
> says production or formulation facilities require any registration today.
>
> FIFRA Section 7 says that production of pesticides, active ingredients or
> devices must be conducted in registered establishments. ("Production"
> includes formulation, packaging, repackaging, labeling and relabeling.)
>
> Production in an unregistered establishment is a violation of the law.
>
>
> https://www.epa.gov/compliance/pesticide-establishment-registration-and-reporting
> https://tinyurl.com/yypf87ss
>
> Here's the enforcement statute:
>
>
> https://www.govinfo.gov/content/pkg/USCODE-2011-title7/html/USCODE-2011-title7-chap6-subchapII-sec136g.htm
> https://tinyurl.com/y2pu2eu9
>
> But this is all a moot point - outsourced to a contract packaging house,
> or done in house by Oompa-Loompas, I still don't see beekeepers paying a
> markup for oxalic acid over and above the lowest price that they can find
> in  a walk down the hardware aisle, as they would do so even to avoid a
> shipping charge.
>
>
>
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