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From:
James Fischer <[log in to unmask]>
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Date:
Sat, 26 Jul 2003 08:19:01 -0400
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>> Can someone point me to a website that has the standards for commercially
>> sold honey? I am specifically looking for standards for antibiotic residues
>> in honey either from the NYS Dept. of Ag and Mkts or the federal government.

> ...united states standards for grades of extracted honey...

Nope, that's just "Grade" and "Shade" standards.

  (Interesting how all honey sold at retail is claimed to be
  "Grade A", and "lighter" honey is somehow worth more than
  "darker", even though the only honey with any actual flavor
  are the darker varieties.)

If you want residue tolerances, this sort of information is not
compiled and made easily available in any one place, nor is there
any one "list" that would be applicable to everyone.  For example,
consider the situation with coumaphos (Check-Mite) when it was first
approved under "Section 18s":

  Section 18 "emergency" applications for the use of
  coumaphos were initially created, reviewed, and approved
  for some states, but not all. (By now, I assume that most
  all US states have Section 18s on file for coumaphos.)

  The "tolerances" for coumaphos in honey and wax were set
  ONLY for states where coumaphos use was allowed.

  So, if I was a migratory beekeeper (the few, the proud,
  the sleep deprived...) I would have been able to legally
  use coumaphos under a Section 18 while I overwintered in
  Florida, but unable to sell honey from those hives in any
  state that did not yet also have an approved Section 18
  for coumaphos.

Now, there may be ways to "avoid" such problems by holding
one's hand on a 1922 edition of "ABC & XYZ of Bee Culture"
and swearing that the bees made the honey only in states
with Section 18s, and providing some sort of proof of where
one's hives were at what times, but we have a confusing
morass of "rules" to slog through if we want to keep on
top of this sort of issue:

a) More than one agency that can set "tolerances"
   (The FDA regulates food, and the EPA regulates
   pesticides, and at least California seems to
   have their own state-level environmental regulations
   that are often at odds with the EPA regs...)

b) Specific times/places where such "tolerances" are
   valid, which means that eddies in the space-time
   continuum could create serious regulatory problems
   for some beekeepers.  (Who "Eddie" is, what he's
   doing in the space-time continuum, I don't know.)

c) A number of possible places where one might publish
   such a "tolerance", but on a federal level, this
   sort of thing ends up being published in the "Federal
   Register" ( http://www.gpoaccess.gov/fr/index.html )
   a periodical that no one really reads even though it
   has the net effect of changing the laws of the land
   in every edition.

As an aside, the tolerances for coumaphos were set at
0.1 ppm (100 ppb) for honey, and 100 ppm for wax.

I'd suggest asking the National Honey Board.
If anyone has a complete list, they should.

It appears that the only way to ask them a question is via
their web site's "feedback" page at
http://www.nhb.org/feedback.html
or by phone at (303) 776-2337.

                        jim

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