> I've been proposing to anyone who will listen that an existing or new
> beekeeping organization apply as a registrant for OA
Here is the basic approach the EPA forces upon us -
One registers a pesticide product, and a facility to make it. One does not register a generic chemical that one neither makes nor sells. A beekeeping organization is ill-suited to make or distribute a pesticide product.
But all is not lost - one can apply to merely distribute a product, and there is always FIFRA section 3(c)(7)(A), which allows "me too" products. This is good, because both leverage an existing approval, and avoid the bulk of the "registration" hassle.
So, as I mentioned before, we have two existing registrations on the books:
Chemicals Laif S.P.A (EPA Registration Number 91266-1-73291) in Italy
Brushy Mountain Bee Farm, (Registration Number 91266-1-91832)
And the "interesting" part here is that there are two "distributors" but no "primary manufacturer".
What I'd suggest as optimal would be for an existing bee supply company (there are over 300 in the USA at present) to inquire with Mr. James C. Lanik Esq of High Point, NC (the receiver/liquidator of Brushy Mountain) about purchasing the tiny bit of Brushy Mountain Bee Farm's assets that would include the EPA registration above, and the right to use the "Brushy Mtn" name solely in the sales of Oxalic Acid. This should be a nominal purchase, as the assets are intangible, and have no "book value".
One is then in the position of being the "new owner" of "Brushy Mountain Bee Farm - Oxalic Acid Division", with a pre-existing EPA registration to hang on the wall.
So far, so good, but you are not yet in business.
One has to undergo the whole "facility" approval process, so a corner of your warehouse is now EPA-regulated as a "facility".
Now you can buy Oxalic, do some tests to assure that it is pure, package it up, and sell it.
But now here comes OSHA, so you are going to spend some serious coin on worker safety, as well you should. Oxalic is nasty stuff. Respirations, googles, gloves, fume hoods... Its gonna sound like an Antonov AN-22 in there with all the fans you'll need.
***BUT*** after you spent all that time and money, will anyone actually buy YOUR branded product, or will they buy the generic Oxalic at the hardware store?
No matter how much whisky I throw at my higher-level cognitive function centers, I keep coming to the same conclusion - there just isn’t a business model here. I am anything but a pessimist - I am a guy who is only able to make a small profit selling to beekeepers because I run my entire operation with solar-powered steam generation, and I have had to rebuild it all twice (after Irene in 2011, and Sandy in 2012).
> Would Randy's data and research be useable or would it have to be replicated?
No need - Marion Ellis had more than sufficient data decades ago, and there are more than sufficient additional peer-reviewed studies since then to cite.
The problem here is not science, but profitability.
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