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Subject:
From:
James Fischer <[log in to unmask]>
Reply To:
Informed Discussion of Beekeeping Issues and Bee Biology <[log in to unmask]>
Date:
Sun, 26 Feb 2006 20:49:31 -0500
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> Fume boards, when used properly, do no harm.

Quite true.

> ...butyric acid occurs naturally in honey,

The statement above echoes a misconception.
Butyric Acid is not sold as a "bee repellent".
Butyric Anhydride is what is in bottles of
"Bee-Go", "Honey Robber", "Bee Repel", and so on.
Butyric Anhydride is anything but a
"natural chemical that occurs in honey".

Butyric Acid is C3H7CO2H
Butyric Anhydride is C8H14O3

Very different chemicals.
Butyric Acid does not have nearly as objectionable an
odor as Butyric Anhydride, nor does it carry anywhere
near the hazard warnings, health warnings, and Haz-Mat
transportation restrictions.

While some percentage of Butyric Anhydride hydrolyzes
to butyric acid when exposed to air (and/or with the
application of heat), not all of it does, and the Butyric
Anhydride can be directly detected in bottled honey so
harvested by anyone who bothers to run the tests.
(I think Bee Culture ran an article on the issue of
trace-level contamination in honey in 2005.
I think it was Mark Winston who wrote it.)

> That's why these particular chemicals were selected:
> because they are already in honey.

There is no possibility at all for the synthetic chemical
Butyric Anhydride to ever naturally appear in honey.
It only exists as a ***synthetic*** chemical.

More to the point, at least in the USA, there is no
excuse for letting Butyric Anhydride anywhere near any
food intended for human consumption, as outlined here:
http://www.mdbee.com/articles/diseasecontrols.html
(Scroll down to the section on "Bee-Go")

Butyric Anhydride simply is no longer permitted in any
"food-use" application.  There was an EPA "exemption from
the requirement for a tolerance" (much the same as a
tolerance) for Butyric Anhydride in honey, but this
exemption was revoked by the EPA back in 1998.

As Butyric Anhydride is not "food grade", nor is it
"generally recognized as safe", any human food exposed
to any amount of Butyric Anhydride in any way would be
considered "adulterated" under FDA rules, and cannot be
sold for human consumption. Further no honey adulterated
by Butyric Anhydride be "processed" in an attempt to
remove the adulteration (such as by heating), as this
would be "criminal fraud" atop "adulteration".  The honey
would only be suitable for animal feed.

So, for those who might still use Butyric Anhydride, what
part of the statement "No Food Use" is unclear?  :)

The only good news is that the EPA and FDA under the
current US administration are not about to "enforce"
much of anything.  The EPA is much more likely to
approve drilling for oil in your beeyard.  :)



Details For The Picky
=====================

The EPA revoked the specific "exemption from the requirement for
a tolerance" for butyric anhydride, and this left butyric anhydride
with no "approved food use", as the EPA and FDA list it only as a
"pesticide used in animal feed".

The EPA issued final rules that announced the revocation of
tolerances for residues of pesticides associated with canceled
food uses. Notice of the proposed actions for these final rules
were published in the Federal Register on 1/21/98 and 2/5/98,
and the final rule became effective on 1/25/99.
(The EPA persisted in using the synonym "Butanoic Anhydride"
for the name of the chemical, but it is the same stuff, regardless.)
http://www.epa.gov/pesticides/tolerance/pdf_files/revoked_tolerances.PDF
(page 8)

The purveyors of Butyric Anhydride might do some hand-waving and point
to the language that still exists in the EPA regulations stating that
a product intended to force bees from the hives for the collection of
a honey crop is not a pesticide.  While this certainly is true, this
language does not give anyone permission to use anything other than a
food-grade or "generally recognized as safe" (GRAS) substance unless
there is a specific tolerance established for the substance by EPA or FDA.

So, while Butyric Anhydride may not be "a pesticide" in the context
of honey harvesting, it is also not permitted for use in any
connection with food for humans unless someone overtly says so.

In the interest of full disclosure, I do run Fischer Alchemy,
makers of a product that raises funds for the Eastern Apicultural
Society Bee Research Fund named "Bee-Quick", an all-natural, 100%
food-grade, 100% "GRAS", non-toxic, honey harvesting product that
obsoleted the smelly and toxic Butyric Anhydride. http://bee-quick.com

But not to worry, there is no conflict of interest here.
I don't care what you use, I am a strong supporter of "to each
his own". If it ever starts to make any serious money, I'll drop
the price rather than pocket any profits myself.

-- Visit www.honeybeeworld.com/bee-l for rules, FAQ and  other info ---

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