As a preface, let me stress that Bob's approach assumes that one
is using his "SOE car-wash" technique only AFTER removing one's
honey crop.  This eliminates concerns about impact on honey from
the equation up front.

> Moreover, SOE is known to be almost completely safe for the operator

What actual science was done to "prove" this?  The testing appears to
be limited to acute LD-50 mammal testing, which does not tend to reveal
the impact of long-term occupational exposure, which is how organophostphates
got started.  That said, SOE does look about as benign as one could hope
for in a varroacide, so I'd agree that it poses about the same risk to
the operator as HFCS might pose.

> and unlikely to contaminate honey.

I'd agree much less with this claim, given that one sprays so much
on the bees and comb.  One is left with a shere volume of residue at
least several orders of magnitude above the residues left by any other
process in beekeeping.  Where exactly does it all go?

> On the other hand, I am not as sure about Bee Quick.  Is it approved
> for use in bee hives?  In the USA?

Yes.
See USC 152.8, federal law which directly addresses bee repellents.
In the unlikely event that "non-contact exposure" becomes a spill into
honey, everything is FDA food-grade (USP) and all ingreidients are listed
in the FDA's "Generally Recognized As Safe" (GRAS) list, honored in
civilized countries planetwide.

> Elsewhere?

Also yes.
Everywhere on the planet except for, umm... Canada.  :)

Ooops!  I forgot New Zealand, who decided to write regulations to
specifically apply to Bee-Quick, as they discovered that their
existing regulations did not allow them to regulate Bee-Quick as
much as they wanted.  The importer is slogging through the process
with New Zealand's MAF on this, but everyone is being cooperative,
and I have not yet had to break up any fistfights.

> Last I heard from our co-op was that we are not to use BeeQuick
> or be at risk of having our honey rejected,

You mean Bee-Maid?  The folks who asked for an exclusive distribution
agreement for all of Canada two weeks after putting their membership
on notice to not buy a product that I had already ordered my dealers
and distributors to not sell to anyone in Canada?  Those guys?

Methinks that if I violated US law (the Robinson-Patman Act) and gave
Bee-Maid "an exclusive", I would suddenly find that the current
bureaucratic barriers to selling to Canada would disappear in a cloud
of greasy black smoke.  Where I come from, we call this sort of negotiation
approach "racketeering", and send people to jail for indulging in such
business practices, but perhaps Canadian laws are different.  :)

> and that butyric anhydride is the only chemical permitted for honey
> removal use in Canada.  Maybe that has changed?

This has not changed, despite intensive attempts to work with Health
Canada's PMRA group.  The PMRA group is being intransigent, having
done nothing but be non-responsive to specific questions about both
process and requirements.  So far, we have been able to gain an
admission that butyric was "approved" without any studies or data,
apparently simply at the casual request of "the Canadian beekeeping
industry".

Requests for documents related to exactly where, when, how, and why
butyric was "approved", in an attempt to voluntarily offer identical
documentation and data for Bee-Quick has resulted in excuses slightly
less creative than "my dog ate my homework".

We have better things to do with our time and money, so we have left
it to the bee supply houses in Canada (both FW Jones and Benson's
have expressed interest) to work on this issue with the appropriate
ministers, as the lower-level bureaucrats appear unwilling to give equal
treatment to butyric and non-butyric repellents, or may be unwilling to
give equal treatment to Canadian and non-Canadian products.

We have been told by some that working with individual provinces is a
legitimate way to "work around" foot-dragging by the Canadian federal
government, but we are not Canadian citizens, so we must leave this to
the dealers that have expressed interest in selling Bee-Quick and/or the
Canadian beekeepers who have asked us why our dealers won't accept orders
from Canadians.

A less charitable corporation would file suit against Canada under NAFTA
Chapter 11 and be awarded all of the profits that MIGHT have been made
since 2001 in a slam-dunk example of suing over arbitrary non-tariff
barriers to trade.  Lucky for Canada my firm policy is to stay away from
the courthouse, and that Canada is simply not a big enough market to be
worth the bother of paying my henchmen to do what I would rather not.

Don't think that I don't love Bee-Maid.  I do love them dearly.
Their honey is the bulk of the low-end grocery-store honey sold
around here, and this honey (heated to within a inch of its life,
filtered almost as much as if they were buying Chinese honey, and
blended to the point of blandness by experts in covering up the
"flavor profile" of canola honey), makes selling my honey simple.
I merely offer customers a taste of Bee-Maid's, and mine.
Thanks, Bee-Maid!  :)

> Beyond that, it seems to me that we are in a grey area that is subject
> to the whims and ad hoc judgements of various inspection and enforcement
> agencies.

Only if one is willing to tolerate such ad-hoc treatment.

Perhaps if a clear and compelling reason for "approval" is presented
that satisfies Canadian self-interest, someone in Canada will then decide
to honor the NAFTA agreement, and bring their environmental and health
regulations as they apply to beekeeping into compliance with the existing
regulations of other NAFTA members.

But I doubt it.  No one admits that NAFTA exists when they are "buying",
everyone pounds it on the table only when they are "selling".


          jim ("Coup d'etat?  No, I offered you a CUP of TEA!")

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