Hi Mike,

FWIW the method that you have just described is an illegal application of
a pesticide and is IMHO inconsistent with the labeling as approved by the
FDA and the state in which you reside. Illegal use of a pesticide is a
crime on both federal and state levels. This is no different than using a
witches brew such as I have described in the archives; the pesticide may
very well be approved for a particular application per the labeled
instructions; however, a target not on the list is a no-no. and would
require registration for that particular target; say, a small hive beetle.
And, AFAIK additional paper work, testing and creation of Material Safety
Data Sheets, MSDS, would be required at the federal level.

I throw caution to the wind as it is noted in the November 2005 American
Bee J, page 864, “EPA: ADMINISTRATIVE LAW JUDGE……” that a “civil penalty
of $14,850” for sale and distribution was ordered against an individual
who allegedly sold products illegally. Although, this is not the same as
using a product inconsistent with its labeling it nevertheless goes to
show that the government does not take the misuse of pesticides lightly.

Chuck Norton
Norton’s Nut & Honey Farm
Reidsville, NC 27320

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