>A full discussion of the literature and background on the toxicological
profile of oxalic acid can be found in docket number EPA-HQ-OPP-2020-0176
in the documents titled “Oxalic Acid. Label Amendment Regarding Use in
Beehives with Honey Supers to Control Varroa Mites” and “Oxalic Acid. New
Use in Beehives to control Varroa mites.”

There are two tracks of this discussion. The first is the question of getting a label change for Api-Bioxal or the registration of a new product. In simple terms, don't hold your breath. The EPA is well entrenched in its operating protocols. Vermont's and the other states attempt via the FIFRA 2(ee) was a "hail Mary" attempt that provided some momentary excitement but alas, fell incomplete. There are efforts going on, best left to those involved, on both fronts and to them I say Gods speed and good luck. The Api-Bioxal label is the law. The fact that it does not effectively control varroa seems of little concern. I personally will sew a red "S" for scofflaw on my shirt and go about my bushiness. I think it is a cop-out to try to claim that one is only bleaching their wooden-ware but each to their own. IMHO the chance of regulatory enforcement to any individual beek at this point in minimal. 

The second and I think more informative track is a discussion of first hand experience. A search of the archives on the topic of OAE will yield accurate information by users under various conditions. Randy's articles in the ABJ and on his site give the definitive data of his extensive experiments. It has worked amazingly well for me here for 3 years. I know personally of a good many others, all with positive result. I have heard of it not working well only second hand and anecdotally. If more of us report with detailed data, including any harmful effects,  from various regions I think that that would be helpful in our quest of controlling varroa.

So pick your poison. Follow the label and live with high mite infestation or be a scofflaw and live with nearly mite free colonys. I am now 77 so waiting for the EPA to make a change will be for those younger then myself. I don't discount that other registered products can be effective. Here I refer only to oxalic acid.   

Paul
46N 118W 2200"

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