It is important to make 65% formic acid available to beekeepers in the USA.

It is important to send your input to the government as well as to the EPA
before February 15th, 2005 as there is a decision deadline set on the acid
registration for late February.

At the American Honey producers association meeting in Tucson, we received
a “break” in terms of formic acid supply.  The Director of Marketing and
sales at Univar USA, had in his younger days two hives, and is sympathetic
to the beekeeping industry.

He, without immediate commitment, is very interested in producing 65%
formic acid for the beekeeping industry in large and small quantities
(packaging).  This is pending the beekeeping industry ensuring him
political support for the exemption of formic acid from the EPA’s rules
and obviously your commitment to use the product.

Please contact him with your supportive letters and copy him with any
resolutions you and the organizations you belong to pass.  These
resolutions and letters should be sent to your Congressman, Senator, and
Secretary of Agriculture.  Don’t forget to also send this letter to the
EPA and myself.

UNIVAR:  Ted Worster – Director of Marketing and Sales
11149 Research Blvd. Suite 260
Austin, TX
78759
[log in to unmask]   tel: 1-512-346-4569   fax: 1-512-346-6071

Make sure you copy the EPA on your letter.  Send it to:

Dr Russell JonesChair, Biochemical Classification CommitteeBiopesticides
and Pollution Prevention Division (7511 C)9th Floor, Room 910Office of
Pesticide ProgramsCrystal City, Crystall Mall 21921 Jefferson Davis
HighwayArlington, Virginia  22202Phone:  703-308-5071Email:
[log in to unmask] EPA – Biopesticide DivisionAttention:  Dr. Sheryl
K. Reilly7511CUSEPA HeadquartersAriel Rios Building1200 Pennsylvania
Avenue, N. W.Washington, DC 20460Phone:  703-308-8269Email:
[log in to unmask]

The following is a transcript of the resolutions passed at both national
conventions.  Numbers 1 and 2 are the demands.  65% dilution has the same
heavy metal content as the food grade formic acid.  Numbers
3 – 5 are the reasons and justifications; the 2 attachments explain the
status and situation of formic acid in the USA.




EXAMPLE OF RESOLUTIONS AND TECHNICAL DATA TO BE INCLUDED:

1. Whereas formic acid is an unregulated product commonly available
from many sources and used in many applications and whereas there is no
monetary incentive for any commercial entity to sponsor the registration
of formic acid.  Be it resolved that (A - State your organization name,
club, association, etc) ask Congress and the Secretary of Agriculture to
direct the EPA to release, register, or exempt from registration formic
acid in liquid form, at 65% dilution of technical grade formic acid, for
use in bee hives.

2. Whereas the US Beekeeping Industry is facing great losses of bee
hives, threatening pollination of agricultural crops including almonds and
many others, be it resolved that the above actions shall proceed
immediately without delay.

3. Whereas the varroa mite acquired full or partial resistance
against man mad pesticides - organo-phosphates like coumaphose, and
phyrenoids like fluvalinate and amitraz - that no longer work, and the
other known materials and products including tymol formulations, oxalic
acid, sucrocide, etc are either not registered, unavailable, or
unpractical in use.  Whereas all of the above pesticides act only against
the Varroa mite, be it resolved that (A) encourages and endorses the use
of formic acid, a natural substance capable of controlling parasitic mites
including Varroa destructor, the Tracheal mite, and diseases that the mite
can transfer, and for the control of bacterial, viral, and fungal disease
like Chalk brood, Nosema, and the Kashmir virus, and as a control and
repellant for the Lesser wax moth and Small hive beetle.

4. Whereas the man made pesticides and other substances that can
control the mite can cause contamination and residues in beehives.   Be it
resolved that (A) endorses the use of formic acid as both the EPA and FDA
exempt formic acid from tolerance studies.  Formic acid is a naturally
occurring substance found in many plants and foods, including honey.
Evaporation methods used with formic acid release only miniscule amounts
of acid into the hive, which do not cause dietary concerns.

5. Whereas treatments with formic acid must be adjusted to local
weather conditions, hive sizes, equipment, and colony strength, no one
particular method or final product will suffice and will work in all of
these many circumstances.  Be it resolved that only the active material,
as stated above should be released, registered, or be exempt from
registration, and the application of such active material should be left
up to the beekeeper to choose from many commonly known application methods
used presently around the world, including the USA, observing the safety
practices commonly used in handling acids including transport in
government approved containers shall provide the safest solution and shall
be at the beekeepers risk thus removing any liability from the government,
regulatory agency, and supplier of the active material.

If we all pitch in we shall succeed.

Yours truly,

Bill Ruzicka
2910 Glenmore Road North
Kelowna, British Columbia, CANADA V1V 2B6
Tel:  1-250-762-8156  Fax:  1-250-763-1206
e:  Bill Ruzicka - [log in to unmask]

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