There have been comments made about the EPA registration process and how that impacts our honey bees.  As I am likely the only person on this group that has ever registered any pesticide product or worked directly in the industry I think I may understand the process. The over view of what EPA does is really very simple to understand so let me try and give an outline of the requirements.

The US EPA has three general concerns in registration of a pesticide.  Those concerns are all equally important.  They are:1.  Safety to the environment when applied according to the label
2.  Safety to the consumer of treated products when applied according to the label3.  Safety to the applicator when applied according to the label

The potential registrant must supply studies to address each of these three concerns in detail.  The last time I was involved in a full registration the scientific reports submitted to EPA took up a volume of about 400 cubic feet.  That is a stack of file boxes eight feet by eight feet by six feet tall.  Any product which fails any of those three concerns will not be registered.  Also, by law, no pesticide can be registered that causes cancer in any test species unless it can be shown that the particular test species that does develop cancer has a unique metabolic pathway essential to cancer development and that metabolic pathway does not exist in humans.  This is why a bunch of the real early tox testing is designed to estimate the odds of the substance being a carcinogen.  If that early testing gives significant hints that the product is probably going to be a carcinogen the product is routinely killed before a lot of money is wasted.  I have personally sat in meetings where the decision was made to kill a developmental product on exactly those grounds and it would have likely taken another three years of testing and a bunch of millions of $ before we would have been positive it was a carcinogen.  No one wants to be riding a wounded horse when you know even if the results came out eventually that the product was not a carcinogen you would face an endless fight and endless required tox studies due to anti pesticide groups attacking the product on cancer grounds as long as it was registered.  It simply is less costly to kill the wounded horse and find another one to ride that is not sick rather than fight a near impossible fight that will end up costing hundreds of millions of $ even if successful.
So, how safe are bee keeping products?  Formic acid is the most dangerous that we widely use.  It can cause really severe burns if not washed of your hands fast and if you get it in your eye there is a half decent chance you will need a cornea transplant.  The rest of the things we use are really very applicator friendly.  If you are vaporizing oxalic acid you do need to make sure your face or body is never in line with the cap that some vaporizers use as if that cap blows off you are likely to be hit with really hot molten oxalic acid and get a nasty thermal burn.  While many worry about breathing oxalic vapor fumes in reality the danger of those fumes is close to nonexistent in the amounts you would be able to breath.  I do not recommend tempting fate so do not breath them.  The biggest risk is probably a really bad coughing fit that induces a heart attack.  In view of the age of beekeepers this risk might even be real.  The same active ingredient used in Apivar is also used in dog and cat flea and tick collars and lots of people sleep in the same bed with a pet wearing such a collar and there have been no reported deaths so I think Apivar is safe.  I still would not sleep with my dog if she had such a collar.  Hop extracts make good beer.  I personally do not know if they really kill mites.  Thymol is in my mouth wash so I am not going to worry about it very much.  The amounts of mitocides we use as beekeepers are so tiny I can not see any environmental issues personally.  The amounts found in honey are so small that I see no consumer safety issues.  So really applicator safety is the main issue.  Applicators are remarkably creative people and I know of situations where more than likely such creativity is putting carcinogens into hives and contaminating honey and the practice has been widely recommended on the internet. I know of creative people almost killing themselves by inventing novel ways to apply currently registered miticides to hives.  I suggest it is the beekeeping industries best interest if we are less creative and follow label directions.  We will be safer as applicators and we will not run the risk of honey getting the label as a dangerous substance to be avoided.

I should note that FDA when doing drug registration cares only a little and often not at all about environmental issues and in some cases is happy to register a carcinogen as a drug for humans.  They generally worry only a little about applicator safety.  What they do worry about a great deal is does the product work against the target pathology and is the risk/benefit of taking the product lower than the risk of not taking any product or the risk/benefit of taking some alternative product.  Not all federal agencies have the same motivations for very good reasons.

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