>>> ...I've been pushing for a generic "Approved application method"
>>> submitted by either USDA or a third party not interested in making a profit.

The OA label already approved has approved application methods, but I don't know how EPA might isolate "a label" from a specific registered product.
Has this ever been done before with an EPA-registered pesticide?  

I would think the primary concern would be for a beekeeper to (somehow) be assured of buying the "correct product", in this case a "pure OA".  Sounds simple, until we remember the dog food that had the Melamine in it, and killed dogs left and right.  I'm not saying the idea is a non-starter, I just don't know how anyone might shoehorn something like that into the existing regulatory scheme.  


  

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