> I don't think you have been following the discussion closely.
I have not read things that seemed irrelevant closely, true. Allow me to
address the concern.
> Suet Kwan & Peter Sporns (1988) "Analysis of Bee Repellents in Honey"...
Such an old paper is utterly irrelevant now, as 28 years later, we have
parts-per-trillion detection and quantification.
Reagardless, in 1998, ten years later, the EPA revoked the tolerance,
leaving no food use for the formerly registered pesticide. See below for
links.
This leaves us with "No Food Use" for the Butyric Anhydride, and it does not
matter if residues could not be detected back in 1988. It still does not
matter if residues can be detected today to anyone except someone who
intends to violate the law by using a "No Food Use" Chemical in or near food
for human consumption.
Back in 2003, you demonstrated knowledge of the difference between the acid
and the anhydride and proved it here on Bee-L, but we were discussing how
formic acid was unethical (and illegal!) to use without an EPA tolerance,
and there was none of this argumentative insistence that something that used
to be legal was somehow still legal. I recall that the example of something
that "used to be legal in the past" was cyanide fumigation for wax moth.
There's something else that was claimed in the past to be "perfectly safe"
and "left no residue"!
How things have changed. In 2005, there was quite a fuss over a few drums
of cyanide that fell off the back of a truck in ND.
http://bismarcktribune.com/news/state-and-regional/illegal-sodium-cyanide-sa
les-centered-in-n-d/article_825881bd-d3dc-50df-8fc5-fe844b0d15ec.html
http://tinyurl.com/jqqtkvs
The quote at the end of the story by the fellow fined $34,000 for using a
substance for which there is no tolerance or exemption for use with honey is
very appropriate in this discussion:
"We didn't know if it was legal or not," Paul Roeder said. "We assumed that
since we could get it, that it was legal. This has been a big wake-up call."
=-=-=-=-=-=-=-=
http://web.archive.org/web/20030429143659/http://www.epa.gov/pesticides/tole
rance/tolrev.htm
http://tinyurl.com/gvugneh
"Tolerance Revocations Proposed
EPA is proposing to revoke 871 tolerances for pesticide residues on a
variety of foods..."
http://web.archive.org/web/20030429143659/http://www.epa.gov/pesticides/tole
rance/tolrev.htm
http://tinyurl.com/gvugneh
"Without a tolerance or exemption, food containing pesticide residues is
considered to be unsafe and therefore 'adulterated' under section 402(a) of
the FFDCA, and hence may not legally be moved in interstate commerce (21
U.S.C. 331(a) and 342(a))."
"the existing stocks of the chemicals are presumed to have been exhausted
more than a year ago, giving ample time for any treated food to clear trade
channels."
http://web.archive.org/web/20030528155501/http://www.epa.gov/fedrgstr/EPA-PE
ST/1998/January/Day-21/p1356.htm
http://tinyurl.com/zzrhtoe
(In the above, the government calls the chemical "Butanoic Anhydride", which
is a synonym. Same CAS number.)
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