--- allen dick <[log in to unmask]> wrote:
> > An overview of the formic acid situation in
> Canada:

> My source is very close to the CAPA, the CHC
> Chemical Comittee and PMRA
> discussions, and takes issue with the suggestion
> that these bodies intend to
> withdraw or limit the use of either formic by
> Canadian beekeepers.

CHC Resolution #15, January 2004 requested a 2 year
sunset for C94-05.  It's on the CHC website.  There
was no time frame closure recommendations for C94-05
until this resolution was passed after being debated
on the floor, including input from John Gruzka, chair
of the CAPA chemical committee, and PMRA people in
attendance. The original resolution was to keep formic
available as is.  After discussion it was amended with
the 2 year time frame and passed by the delegates.

Specifically, my source tells me that in a
> conference early last year, CAPA,
> CHC, and PMRA agreed to leave formic use as-is and
> also decided to work
> towards approval of oxalic acid for general use,
> employing data from Europe
> and also local experience from tests in Canada.
>
> I'm also told that it almost seems that several
> Canadian
> beekeeper/entrepreneurs are trying to gain control
> of formic and oxalic
> treatments and generate a profit by developing
> proprietary applications,
> then attempting to discredit and outlaw the
> inexpensive, effective methods
> that are proven and recommended in our different
> regions.  If there is any
> pressure to limit the use of liquid formic, I'm told
> that this is where it
> is coming from, not the authorities.

We strongly encourage, and have done so since 1997
when beekeepers got together to form NOD, anyone with
a soft chemical treatment, be it thymol, oxalic or
formic based, to register. If NOD Apiary Products(NOD)
had not started the registration process with PMRA in
January 2002 there was a good chance 2001 would of
been the last year for C94-05.  We probably extended
the umbrella of C94-05 for Canadian beekeepers by four
years by initiating the registration process.

PMRA was taking this very seriously.  They actually
sent two PMRA people from Ottawa to the NOD research
sites in August 2002 to examine our protocols and
familiarize themselves with the industry.  They spent
the day with us and Provincial Apiarist Doug McRory,
questioning all pesticide uses and fumigants used in
the beekeeping industry, as well as formic acid.  They
went right to the trial sites, and suited up to go
into the hives.  We opened bee hives for them and,
along with Alison Skinner of the OBA tech transfer
program, took them through what they were seeing. We
were then audited by a Health Canada auditor who came
down from Guelph to check out our tests sites, and
then were audited from the Research Auditors from
Revenue Canada in Ottawa and the local Revenue Canada
office here in Belleville, who again came on site, to
make sure the reports written up were valid. Over all,
just from the federal level, we had five different
experts come to make sure our trials were on the
level.

> Don't get me wrong, these proprietary methods
> certainly have their place,
> particularly for small operators or those who are
> not prepared to learn what
> they need to use formic safely or effectively, but I
> am also told that they
> do not work in all circumstances, and that, for
> example, the NOD treatment
> has problems where time is short, and a quick fix is
> required.  This is not
> to say that it is not good, but that the various
> other applications
> definitely have their place.

Mite-AwayII has the shortest varroa treatment time
frame, formic or other, and the shortest withdrawal
time.  It is designed for the commercial beekeeper.
Have you read the label?  Checked out the website?
www.miteaway.com

I am not sure who your source is, but there were two
national meetings in the summer of 2003 to try to get
oxalic acid (OA) available to the beekeeping industry.
 I was at both of them.  The first was a pre-meeting
to the meeting with PMRA, and the second was the
meeting with PMRA in September, which Provincial
Apiarists and industry representatives from across the
country joined by conference call.  For the meeting
with PMRA I took a bottle of OA with me purchased from
my local drug store, MSDSs for OA, and copies of a
data package from Europe.  I explained why no one
would be willing to take on the risks and cost of
registering an OA and suggested CHC hold the
registration (there must be a registrant, the
government won't end up holding the registration as
they ended up doing with C94-05, which they described
as a "mistake"), and the label could go out with the
annual Provincial Apiarist disease control
recommendations to registered beekeepers, as well as
being posted on the net.

PMRA seemed to think this was all possible.  In order
to get this all off the ground as soon as possible,
NOD offered to compile, submit, and do the follow up
for the OA registration on behalf of CHC, who would
remain the registrant.  NOD sent in an offer to the
CHC office to do this for $20,000.00, which, if anyone
is at all familiar with what has to be done for a
pesticide registration submission would realize,
doesn't even cover off the expenses.  This offer of
registration assistance should be seen as a service to
the industry, not an attempt to control or make money
off it.  If CHC had accepted our offer, OA would
probably be legal for use in Canada this fall, right
now.  There was the political will behind it, and a
person in place at PMRA to expedite it. As it is, CHC
had to decide if they wanted to be the registrant, and
then decided to do the fund-raising first, making sure
the money was in the bank before committing it, which
are solid risk-taking and business decisions on CHC's
part.

NOD has been working in the background for the
beekeepers for the last eight years, and will continue
to do so.  Beekeepers have not had to rely on soft
chemical treatments. We had to document what
Mite-AwayII will do for mite control. PMRA folks are
very nice to work with, they want to see a healthy
food supply too. The more options available to the
beekeepers proven to work the better.

yours in beekeeping,
David VanderDussen

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