Let me give some insight into the discussions going on.
Amitraz is starting to fail, so many beekeepers are looking for alternative
treatments.
It is totally doable to manage varroa, using only formic, oxalic, and
thymol -- all of which are already registered.
However, the legal approved application methods are neither optimal, or
always adequate.  But it is often illegal to even tweak them a little bit.
And the registered products are very expensive, relative to the
off-the-shelf generic ingredients.

So yes, many beekeepers, who need to keep their colonies alive, may choose
to skirt the law.
The point is, that if EPA were willing to work with us more closely (such
as by allowing an own use exemption), we could manage varroa without
skirting the regulations, as beekeepers are allowed to do in New Zealand.

Randy Oliver
Grass Valley, CA
530 277 4450
ScientificBeekeeping.com

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