" I seriously doubt that European vendors are relying on individual beekeepers to request access to effective products. "

There are studies that are required by law to register a product.  It makes no difference if you are talking EPA, FDA or USDA.  None of those agencies either in the US or foreign have the capability to do almost all of those studies.  It is not their job to do those studies.  And if it was their job you would not like the result as nothing at all would ever get registered for bees as they would be far too busy working on more important projects for businesses that generate lots of dollars compared to bee keeping.  It is up to the product manufacturers to submit a data package and request registration.  Now, maybe you do not think this is the proper way to run things and that is your right.  But, it is still the facts of life.  Someone is going to ask why oxalic dribble and vapor and spray were approved in the US.  First of all Brushy Mountain submitted the request for registration.  Second, because it was widely used all over the world and oxalic acid is a product found in the normal diet and also a product your own body manufactures in small amounts it was viewed as very safe compared to most things.  Third Michelle Obama put great heat on the agency to approve the product regardless of the lack of a normal data package even for a natural product.  That third factor is the main reason it was approved.  But that approval was a very narrow approval in terms of how we could use the product legally.  As I have said before federal agencies are headed by political appointees and they have the right to approve or disapprove actions regardless of the law.  As a citizen you have the right to sue the agency if you disagree with some action that they have taken.  But, you can not sue them for not approving a product when no one has submitted a registration application as they are simply going to tell the judge that without a registration application they can not take any action so the suit should be thrown out on summary judgement.

Bee keepers have lobby groups.  For example the American Bee Federation.  Perhaps those lobby groups could put pressure on Mann Lake to cooperate with the European manufacturers to get a registration application submitted in the US?  Of course Mann Lake can very easy respond that there is no way they can recover their costs in submitting an application as everyone knows in the US bee keepers will simply buy oxalic acid labeled for wood bleach from their local hardware store just like we do now.  In fact the oxalic acid Mann Lake sells is labeled for wood bleach and has no mention at all of use to control mites.  In Europe it seems bee keepers are more willing to buy prepackaged products at a much higher cost than they could home brew the stuff for so the manufacturer can recover some profit.  Few people in the US would agree to pay more for the prepacked product.  In fact US bee keepers are notorious for breaking US pesticide laws including openly advocating applications that are unproven and often highly ineffective and on occasion highly dangerous.  Take the current hot fad of fogging oxalic acid in ethanol solution as an example.  There is no data at all that says it kills any mites.  My data of fogging water solutions of oxalic acid would say it is not going to work.  And when you run ethanol thru a metal tube at red heat you break the ethanol down into other products some of which are likely carcinogens.  Yet there must be 100 You Tube vids advocating this use.  In light of such dumb actions why do we deserve any gifts from the government?  Personally I would favor the government filing legal charges against every single person that has posted such a You Tube vid before US honey gets labeled as unsafe to consume by the people who buy our product.

Dick

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