Bruce,
 
The pesticide approval process is daunting but that is not to say that MO registration is unfeasible.  I recently worked with some people who wanted to get Quassia, a botanical insecticide, registered.  The EPA wants to register reduced-risk pesticides.  They were supportive and tried to help.  They waived a lot of studies but the costs were still expected to exceed $50,000.  
 
FGMO has the advantage of being accepted for use in food.  This means it should qualify for an exemption from having a tolerance established in honey or wax.  Formic acid may also share this advantage.
 
Some entity has to carry forward the registration process.  They must expect to make a return on their investment.  The fact that FGMO is available from other sources does not preclude making a profit.  There are many pesticides registered which contain widely available natural materials, for example garlic and red pepper.  I would hope that beekeepers would support having a legal registration by buying the registered products rather than using the bootleg stuff.  In the big picture, this is a small market, despite the value of beekeeping to U.S. agriculture.
 
Your research should lead you to information on Good Laboratory Practices.  This is a set of standards as thick as a phone book.  The U.S. EPA will probably not accept studies not conducted under GLP standards.
 
Bob Roach
 
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Bruce King wrote:
 
>I like that way some people are waking up to the 'power of the Internet'
>thing.  As individuals we don't have a chance of performing the type of
>study needed to get EPA/FDA approval, but as a group there might be a
>chance as long as everyone involved follows the same protocols.  It used to
>be that the Internet was for scientists and defense guys to share research
>results and information, but now everyone is on so let's take advantage of
>it.