DB>Of the many users of ETO, beekeeping usage is THE smallest and is also the
>ONLY group that is being asked to stop using ETO. To the best of my
>knowledge there are only three states that are currently using ETO for
>fumigation of bee equipment. Two of these states have special/local needs
>licenses and are being asked to voluntarily withdraw their permits or be
>forced to do so by the EPA. The Maryland bee inspector uses ETO under a
>general license by interpreting bee equipment as inanimate objects, which
>is permissible under the general use permit.
Hello David,
Its called "overkill" a common problem in the government regulatory
business. You know its wrong, I know its wrong and anyone with common
sense knows it wrong. You can work to make change to protect the so
called minor interests of beekeepers and I can just about guarantee that
all you may get if you are lucky and work very hard and make some big
political contributions is some of the major uses added to the list, and
still have the beekeepers use finished for ETO.
DB>The EPA has asked ETO suppliers, who have already complied, to change the
>label and specifically prohibit the use of ETO as a fumigant for bee
>equipment. This action makes bee equipment fumigation illegal under the
>general use permit but permissible, for the time being, under the special
>needs permit. However, the ability to get a special needs permit is in
>question.
I would not rule out that "special needs permit", at least it sounds if
the door is still open.
DB>The bottom line is that the small beekeeping industry has borne the brunt
>of the 20 year review of ETO usage. In the opinion of the EPA, the value
>of the fumigation of bee equipment is outweighed by the health risks to the
>bee inspector who performs the fumigation. From what I have been told, the
>health risks were calculated by assuming exposure to ETO for 8 hours a day,
>40 hours a week, and 50 weeks a year - far more exposure than any bee
>inspector has ever had in Maryland.
This part for beekeepers health concerns IMHO is over stated but it is
well documented for the Florida Citrus Industry that has been studied to
the death of office workers who did not handle the material but after 40
years exposure developed various types of cancers. I believe that at one
time ETO was in common use in the citrus packing industry to sweat out
the color in oranges. Since the office workers did not work near or
handle the chemical it is easy to understand the concerns. At least for
me that was enough that I did not want anything to do with ETO and after
using my small supply never considered using any more.
I read all the maternal, no small job, on ETO many years ago when
the California Department of Agriculture purchased a portable ETO
chamber a'la Florida and were going to do field fumigations for
beekeepers. They never did other then a few tests and the California
State Beekeepers Association was out the cost of the chamber an
investment that would not have been made if they had listened to me
instead of the CDFA Chief State Bee Inspector who sold them a pig in the
poke.
DB>The bottom line is that the EPA will probably dissallow all fumigation of
>bee equipment by ETO. The alternatives are to burn hives, steam autoclave
>the boxes, scorch with fire, gamma irradiate, or dip in boiling lye.
What kills us here is that if only 3 states use this material then that
means that the rest of the states are either rotten with disease or they
have found alternatives and do not feel they need ETO. I suspect the
latter is the fact.
DB>In my opinion, isn't the EPA supposed to go after the largest users and
>hazards first? Shouldn't the largest user of ETO, the medical industry,
>be the ones to lose their permits? It is the medical industry that could
>afford to switch to gamma irradiation more easily than the beekeeping
>industry. Does picking on the bee industry seem like a political and not
>regulatory act? Am I so naive to think that the EPA would go after the big
>(ab)users first before the littel guy?
You are right about the political act, but this is the truth in all
government regulations which by design are political with a odorous
mix of science just enough to justify the rule. I personally don't like
it as I believe that many of the materials banned from beekeeper
use could be used and had been used without problems, and have found
many of the alternatives no safer then what they replaced.., But it has
not been going my way for several generations and I don't see much hope
for change except to back all efforts to reduce the cost of government
at all levels and pray for grid lock, but then that could eliminate
government bee inspection all together and place that burden on the
beekeepers for the health of their bees ware I suspect it has belonged
all along anyway.
ttul, the OLd Drone
(c) Permission is granted to freely copy this document
in any form, or to print for any use.
(w)Opinions are not necessarily facts. Use at own risk.
DB>David Bernard
>EAS Master Beekeeper
>President, Maryland State Beekeepers
>EAS Director for Maryland
>Damascus, MD
>USA
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