This note was sent to me by Bill Miller with permission to relay to
BEE-L.
In the interest of fairness, and because the letter makes a strong
point, I feel it should be posted.
Persoanlly I don't care one way or the other about ETO. Although I
have no personal use for it, I cannot see the need to deprive others
from having it available, provided that safety questions can be
satisfied.
Alberta discarded ETO some time back, since we came up with some
disturbing answers to these same questions and problems with its
efficacy, if I recall...
------- Forwarded Message Follows -------
Date: Wed, 5 Feb 1997 19:46:50 -0500 (EST)
From: [log in to unmask]
To: [log in to unmask] (allendick)
Subject: ETO Fumigation
Allen,
Thought you might be interested in the following from our Maryland
State Apiary Inspector (Bart Smith) on the subject of the EPA vs. ETO
fumigation.
I realize your experience with ETO has been less than satisfactory,
but I still think Bart's memo makes good reading.
ps. I still keep my bees w/o terramycin, relying on rigorous colony
inspection to keep foulbrood from becoming a problem.
pps. If you feel the memo would be of general interest to BEE-L, feel
free to publish it.
W. G. Miller
Gaithersburg MD
*****************memo follows************
OFFICE OF PLANT INDUSTRIES & PEST MANAGEMENT
PLANT PROTECTION SECTION
Phone (410) 841-5920 Fax (410) 841-5835 E-mail:
[log in to unmask] February 3, 1997
MEMORANDUM
TO: Charles L. Staines, Jr.
William F. Gimpel, Jr.
FROM: I. Barton Smith, Jr.
SUBJECT: ETO Fumigation of Diseased Beekeeping Equipment
Maryland is fortunate to have been the first state to use ethylene
oxide (ETO) as an alternative to destroying diseased beekeeping
equipment. During the 1970's, the USDA Bee Research Laboratory
conducted studies with diseased equipment from Maryland beekeepers
that proved the efficacy of ETO in destroying American foulbrood (AFB)
- the most serious bee disease. In 1978, the MDA purchased its own
ETO fumigation chamber which has been used each winter ever since.
Fumigation work for the current winter was completed on January 5,
1997. ETO fumigation has resulted in substantial savings to
beekeepers by allowing them to place diseased equipment back into
service that otherwise would have been burned. During a 24 year
period, the replacement value of fumigated equipment was almost
$435,000 while beekeepers only paid $28,000 for this service. It is
much easier to take regulatory action regarding diseased bee hives
when the inspector can tell the beekeeper that infected AFB equipment
can be saved and not destroyed.
On January 2, 1997, I spoke with a Vivian Prunier at the Office of
Pesticide Programs at the EPA. Ms. Prunier informed me that the
manufacturers of ethylene oxide (ETO) had changed their section 3
labels, at the request of the EPA, to exclude beekeeping equipment. On
January 15, I verified with one manufacture of ETO that the new label
that they would begin using on or before April 1, 1997, specifically
prohibited the fumigation of beekeeping equipment. Vivian Prunier also
told me that the EPA has requested several states with 24C special
local needs' labels (24C labels) for fumigating beekeeping equipment
to voluntarily cancel their labels. If labels are not voluntarily
canceled, a mandatory cancellation process would be initiated.
Maryland does not have a 24C label for fumigating beekeeping equipment
at this time. These changes have eliminated the use of ETO for
fumigating beekeeping equipment in Maryland and will shortly eliminate
its use in the US.
The EPA says that ETO fumigation of beekeeping equipment should be
eliminated because 1) some operations are not in compliance with
Occupational Safety and Health Administration (OSHA) regulations, 2)
only a few states use ETO, and 3) the burning of diseased beekeeping
equipment is a viable alternative.
It is my opinion that the above conclusions by the EPA are
incorrect. The fumigation operation in Maryland is in compliance with
OSHA regulations. The last visit by MOSHA, at my request, was made in
1992. At that time, our operation was found to meet OSHA standards.
The states of Maine and North Carolina have also indicated that their
fumigation operations are in compliance. The EPA is correct in
stating that only a few states use ETO to fumigate diseased beekeeping
equipment. Currently, there are only three states - Maine, Maryland,
and North Carolina - that use ETO. In addition, the states of
Arkansas and Tennessee are considering starting ETO fumigation. The
burning or land-filling of diseased beekeeping equipment is considered
an expensive alternative to fumigation by states using ETO.
The EPA initiated a review of the use of ETO in 1978. They have
never "closed the books" on this review. They are trying to complete
this review and apparently they feel like they have to do something.
They have decided to target the smallest user of ETO - state agencies
that fumigate bee equipment - and eliminate that use.
I think Maryland should challenge the EPA and request them to
reverse their decision regarding ETO. Specifically, the EPA should be
asked to request the manufactures of ETO to amend their labels to
include beekeeping equipment as an item that can be fumigated, OR to
allow the continuation of 24C labels for states that currently have
24C labels and to approve new 24C labels for those states that can no
longer fumigate under a section 3 label.
It would like Secretary Riley to send a letter to the EPA
requesting them to reverse their decision. In addition, Bill Gimpel
could address the problem at the National Plant Board Advisory
Council. The Apiary Inspectors of America have already passed a
resolution in support of the use of ETO for diseased beekeeping
equipment. This resolution was forwarded on January 15, 1997 to the
National Association of State Departments of Agriculture for action.
The American Beekeeping Federation may approve a resolution on the
subject this week (they are currently holding their national meeting).
The beekeepers of Maryland are quite upset about the loss of being
able to have their diseased beekeeping equipment fumigated and I am
sure they will confront the EPA.
Attached is an EPA document dated January 17, 1996 that reviews all
uses of ETO which was used to make their flawed decision. In
addition, attached is a list of contact personnel at the EPA, the
Apiary Inspectors of America's resolution on ETO, and a copy of my
correspondence to NASDA.
If you have any questions, please feel free to contact me.
IBS:idm:M-ETO
enclosures
----------------------- Headers --------------------------------
>From [log in to unmask] Mon Feb 3 10:41:55 1997
Regards
Allen
W. Allen Dick, Beekeeper VE6CFK
RR#1, Swalwell, Alberta Canada T0M 1Y0
Internet:[log in to unmask] & [log in to unmask]
Honey. Bees, & Art <http://www.internode.net/~allend/>
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