Thank you Peter You summarize it extremely well the situation in USA is in
detail on:
http://www.mitegone.com/pdfpages/Formic%20Acid%20and%20MG%20in%20USA.pdf

>By the way, it is pretty clear to me that using formic acid out of the
barrel to kill mites >is not really legally approved. 
>The loophole is that farmers, beekeepers, homeowners, etc. are not required
to be >licensed. All the same there are other laws that forbid the
introduction of non->approved substances into the hives, but these are not
routinely enforced.
>So really, beekeepers are on their own in most cases, and most probably
make >good judgments. 
>Better to avoid anything off label. Demand good products, and support the
makers of >these products. My $.02

Allow me to introduce you to another good product using already 3 times
REGISTERED FOFMIC ACID and the EPA ruling on it.

From:  [log in to unmask]
To: [log in to unmask]
Sent: August 15, 2002 7:24 AM
Subject: your device

It has been determined at the EPA that your product is an application method
of applying a pesticide.  As such, it is neither a pesticide nor a device
regulated by this agency.  Thus, you are free to market it in this country
as long as you do not include formic acid with it.

If you sold the product together with formic acid, it would be considered as
a pesticide and require registration.

There are however, a few concerns.  As you are aware, liquid formic acid is
not registered for use in hives against mites.  If the producer of this
liquid knows that bee keepers are using his/her product in hives, then
pesticidal intent comes into play and the producer would be required to
register the liquid for that use, and be subject to regulatory action.

Secondly, if there is any connection between you and the producer of the
liquid formic acid, that could be a potential concern, i.e. collusion.


EPA Ruling on Legality of Seminar

From:  [log in to unmask]
Sent: Tuesday, April 01, 2003 7:32 AM
To: Bill Ruzicka
CC: [log in to unmask]
Subject: Re: Registration of Formic Acid

The people who enforce the issue in question is our office of Enforcement
and Compliance Assurance (OECA), who I just spoke to.  According to them,
only advertising and sales of unregistered pesticide is considered illegal.
There is nothing preventing you from "promoting" the use of an unregistered
product.  All you are doing is giving advice, which is not considered as
advertising or sales.



Bill Ruzicka

Bill's Honey Farm - Home of the MiteGone Formic Acid Treatment
Kelowna, British Columbia,  CANADA
Tel/Fax: 1-250-762-8156 (the best way to reach me is by phone Pacific Time)
Email: [log in to unmask] Website: www.mitegone.com 

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