Hello All,
I want to thank all those which have sent me private email to improve my
knowledge of the subject. Especially those in high places which say I am
doing a great job and keep on with the formic acid discussion.

Peter said:
> My one and only point is that it is a mistake to use a product that is not
> approved or use an approved product in an unapproved manner.

Half the items in the kitchen have got homeopathic uses. in fact many books
have been written on their use. I use salt to get rid of ants and Oatmeal to
kill mice.

The problem comes I have been told when I want to sell  Oatmeal to kill mice
or salt  to kill ants on the open market. Then I need approval.
According to my emails I do not need any approval for my own use.

From a email I received on the subject:

"Therefore the EPA does not regulate pesticides made for your own use but
certainly DOES regulate *sales* of such pesticide products".

"Therefore the EPA does not consider it an illegal treatment for a beekeeper
to make or buy a device to despense formic acid in a beehive and  buy the
formic acid and use it for a mite control on their OWN BEES. THEY CANNOT
HOWEVER SELL THIS TO ANYONE ELSE WITHOUT PROPER APPROVAL AND LABELING FROM
THE EPA"

The sender then asked me:

If the above is correct is it really wise to persue label for use in
beehives  to treat for mites?

The motion to push for full registration for formic acid was already on the
table when I sat down in the commercial beekeepers sig at the ABF
convention. After hearing both sides of the issue I thought maybe we do need
formic acid as another weapon against varroa when our strips fail.

After reading the above I wonder if registration is neccessary.

Can any on the list shed light on the above?

Further clarification from an email:

"Now any use of an existing , registered and labeled pesticide in a manner
not given on the label CLEARLY IS an illegal use."

"WITHOUT FORMIC ACID BEING AN APPROVED ,LABELED PESTICIDE THERE IS NO LABEL
TO BE ENFORCED"

Further clarification from an email;

"We know from research that has been done that treatment during no surplus
honey production periods WILL NOT result in contamination of harvested honey
and the EPA has exempted formic acid from a residue tolerance in honey IN
PART because formic acid is normally found in many honeys."



Granted if I put large doses of salt in my hive and the salt gets into the
honey then the  honey can be deemed contaminated and pulled from the market.
This goes for any substance found in honey without a tolerance IF in a high
enough quantity . So a homeopathic control for varroa could cause honey to
be deemed unfit for human consumption if the PPB were high enough (even food
grade mineral oil).

What normally happens with chemical strips such as Apistan and Checkmite is
that the makers go to the  EPA and get a tolerance level established which
is what has been done with both Fluvalinate (Apistan) and Coumaphos
(Checkmite) when both started appearing in honey. Levels 38 times the
tolerance level were found in Florida in wax of a migratory beekeeper using
the illegal coumaphos product( source the former Florida Apiary inspection
service).  The EPA is  not stupid. No matter what your story might be
those levels can not be had using Checkmite strips.

Regardless of what you read in the bee magazines. I have been told privately
that a couple honey packers tried to get a tolerance for the antibiotic
found in Chinese honey.  In fact they might have succeded had not U.S.
beekeepers raised hell!

Bob

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