To:   All state and local bee group leaders

                As most of us know,  the current rules for many of our miticides are way out of touch with reality and timing  with the varroa problems we face today.   

What you may not be aware of is that there is a strong push for our mite treatments to be switched  from the EPA to FDA control.   While we have been advised there are no “immediate plans”  none the less they have stated that is their intention.  A switch of this nature is going to make getting approved miticides almost impossible,  and with us also being on the cusp of a new mite problem in Tropilaelaps, many of us are deeply concerned. This is our chance to help the industry get into compliance, and ensure the process is optimized for the future.

Towards that concern we have over the last 8 months, crafted an actual legislative ask,  which we hope to push into the farm bill.  Since the current farm bill has been delayed, we have a small window.   Keep in mind this is a real legislative change to FIFRA we are proposing, not just a simple rule change which could be ignored.

We are asking for your help in this matter.  Please take a good look at the attached Legislative Ask.  Myself, Randy Oliver and several other industry leaders and experts have worked on this. It is the product of a lot of studying and discussion and believe we have refined it so it will be acceptable to all.

Here are the actual ASK.

Proposed policy plan:

 Requested changes to FIFRA
A: Honeybees, and beekeeping   to be officially designated, for pesticidal regulatory purposes only, by the EPA as a “Minor Use Crop” and by statute remain under EPA jurisdiction.
B:   The designation of “in hive “use of selected low-risk biopesticides as approved by EPA to be designated as “Minimal Risk Pesticides” for this crop only. This would apply only to Active Ingredients that have been determined to be safe and have tolerance level exemptions. Minimal Risk designation would allow for generics from all suppliers who can establish purity levels as required.
Any producer wishing to sell or market registered products, must still follow EPA all rules for registration
C: New pesticidal approvals for apicultural use be placed under Section 18 SEL standards for approval and processed withing 24 months. Said approval to remain in place until full approval process is completed.
D: Grant an exemption of personal use by beekeepers of specified generic natural substances Since the use of generic oxalic acid, formic acid, thymol, or food-grade plant oils applied to bee hives poses no unreasonable risk to man or the environment, the use of these substances for parasite control in one’s own bee hives are not and shall not be subject to regulation under FIRA or by other regulatory agencies.  This exemption is limited to the preparation and application of these generic products by a person for their own use, and does not affect the requirement for registration of products to be advertised or sold for pesticidal purposes.
E: pesticidal claims using feed as the preferred delivery method remain under EPA guidelines for approvals.
F: USDA shall be allowed to be certificate of registration holders on behalf of the beekeeping industry and sub licenses granted when appropriate. USDA shall bear no liability for efficacy or usage of said products. The USDA position to be only as that of certificate holder for the industry.
G: To ensure continuity of migratory beekeeping across the U.S.  Federal EPA approval will be considered as the standard regulatory and enforcement process unless otherwise specified by state regulations.


 We are asking for one more step,  we want and need an actual  support letter from your group or association.(word document preferred)  

Address it to ” Esteemed Representative or Congressperson”  and if possible in your own words describe the problems and difficulties  with current EPA rules.


The reason for this is simple.  Most of the time we hire a lobbyist to  present these things,  and of course their next steps are to “ask around” about support. This can take months.

Our plan is to hand them the request,  along with support letters from as many state and local groups as possible.  Quite simply showing them a solid and unified front.  This is in the hopes of a faster and more positive support program.  The Australians did this for the group and it worked great, so we are trying to emulate that.

We are hoping to put together a full packet  buy the 1st of June, so time is a bit short.  Once that packet is done, those who have written back will get a copy of all the letters also, which then they can share with their representatives. 

This is a grass roots project,  so please feel free to share it at will!


In addition,  if you have contacts with your representatives,  let us know,  we can use all the help we can get very shortly.

Feel free to call or write with any questions or suggestions.
Copies of letters should be sent to myself,  or Randy Oliver.


Charles Linder
618-572-0396
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