Various USA state letters are going out to revoke state-level endorsements,
as the EPA has made a list of all the ways that the "extended release pads"
approach does not fall "within the scope" of the FIFRA 2(ee) language.  

 

Clearly the EPA letter attached has equal weight nationwide, unless some
state (or beekeeper) were to go to a court and get an injunction to hold the
letter in abeyance.  This would be a very high hurdle to jump, as one most
often must show "irreparable harm" as a basis for getting a preliminary
injunction with immediate effect.

 

The EPA now claims to have been "unaware" of the VT FIFRA 2(ee) letter that
is the subject to the critique and EPA revocation, saying "Previous to your
inquiry, EPA was unaware of Vermont's FIFRA 2(ee) bulletin."  

 

None of this impacts the existing label-designated application methods for
Oxalic, but the EPA letter, read with great solemnity at local beekeeper
meetings, will do nothing but more firmly cement the perception that it is
far easier to just ignore the whole mess, buy a tub of Savogran 10501 at the
hardware store, measure out the dose with the vaporizer scoop, and continue
to vaporize oxalic, with or without a respirator.

 

 

 

 


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