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Date: | Fri, 5 Mar 2021 11:06:49 -0500 |
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> it does seem that OA/GlY is safer...
> Not quite sure how it plays into the whole legality issues with the new changes
OA/GIY is not listed as an approved application method on the current label, and was not made "legal" by the exemption from the requirement for an Oxalic Acid tolerance in honey.
All the current label allows is "35 g of Oxalic Acid Dihydrate in 1 liter of 1:1 sugar: water (weight:volume)"
21 CFR 182.1320 Lists Glycerin as "GRAS" in food, and it is a crop-sprayer humectant, but there's no mention of it in any bee miticide.
But where are the outraged cries of "outlaw" and "scofflaw" and the clacking of pearls being clutched in reaction to THIS particular departure from the existing label? I only hear crickets this time around.
The good news is that an application to allow an OA/GLY mixture is less tedious than one might think, see the EPA "Blue Book, Ch 4".
A "streamlined" registration amendment would be possible, as changing from OA/sugar/water to OA/GLY/(optional sugar)/water would come under:
IV. ACCELERATED REVIEW OF MINOR FORMULATION CHANGES
A. Minor Formulation Amendments
"3. Addition, deletion or substitution of one or more inert ingredients (other than fragrances or dyes) in a formulation"
I'd expect that EPA would consider glycerin to be "inert" in a miticide formulation.
The label is the law, except when the label has not yet caught up with the new law.
The proof of this is that even the revocation of the most horrible pesticide one could imagine invariably allows "all existing stocks to be used in accordance with CURRENT regs", meaning "do what we say here in the wind-down section of this revocation order, not what the label says."
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