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Subject:
From:
"NOD Apiary Products Ltd." <[log in to unmask]>
Reply To:
Date:
Wed, 27 Oct 2004 08:58:24 -0400
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 --- allen dick <[log in to unmask]> wrote:
>
> It almost sounds as if NOD is stirring up trouble
> where there was none.  I
> gather that emphasizing the risks and waking
> sleeping dogs is part of NOD's
> strategy to lock out competition from simple
> remedies.  Please tell me it is
> not.

Just a case of "shoot the messenger".  NOD has only
responded to the FA-PMRA situation, not caused or ever
stirred it.  They came to us in Nov. 2001 threatening
to pull C94-05 unless registration took place.

The PMRA "dog" has not been sleeping, and by giving an
overview of the Canadian FA history at this time, when
the Mite-AwayII application is in the final stages,
will hopefully wake someone up who is willing to
register liquid formic acid and keep it available to
the Canadian industry.  There are the bee suppliers,
Medi-Vet, the co-ops and others that could step in.
I'm sure PMRA will do their best to assist whoever
comes forward, but there are processes to be followed.
To anyone thinking about taking this on, go for it!

>
 If CHC had accepted our offer, OA would
> > probably be legal for use in Canada this fall,
> right
> > now.

> Allen says:
> Wonder why they did not jump at the chance?

I do try to keep things short but I should have put
more information here.  The PMRA OA meeting was
Sept.30, 2003.  Heather Clay had to leave right at the
end to catch a plane.  Several of the rest of the
industry folks stayed behind with the PMRA rep who
would be in position to help work the OA registration
through the registration process.

When I got home I considered different ways to try to
help to get OA available for 2004. NOD staff had just
worked through the application process for Mite-AwayII
for both PMRA and the EPA.  We were in the best
position, as far as I could tell, to quickly put the
application together and get PMRA reviewing it.
However, there was a catch.  I had to know by November
30, since I estimated it would take us three months to
get the data together, verified, compiled to PMRA
standards, and submitted. I'm a commercial beekeeper,
and come March preparing to start the season has to
take first priority, plus the time frame would be too
short to get it through the PMRA process for fall
2004, the goal being aimed for.

CHC just didn't have time to deal with the offer.
Heather Clay is always juggling a lot of high priority
issues.  Fall for beekeepers is very busy.  The
concept itself of the CHC being the registrant had to
go though due process. There were no funds allocated
for such a thing.

Due process is to draw up a resolution for the AGM,
discussion, amendments and vote, leading to:

#14 Carried
Be it resolved that the CHC proceed in having Oxalic
Acid registered for use in Canada with MRLs

Heather Clay could now officially start up the OA
funding account and CHC could chart it's course for
the registration process.

 best to all,
David v


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