> when I wanted to test powdered sugar, I corresponded with my State Lead Agency until I obtained a written explanation that I could legally apply it to hives (since it was GRAS), but could not package and sell it for varroa control.
And this is exactly where we stand with Oxalic, if one dispenses with posturing on theoretical speculation, and views the facts with a pragmatic eye. After all, the EU, the home of "the precautionary principle" has EU Council Regulation, No. 1804/1999, which has held oxalic acid to be an Organic Treatment since 1999. Why ISN'T it GRAS in the USofA? Why doesn't someone do a fundraiser on this far easier and quieter GRAS approach? Could it be that the more complex approach permits more speechifying?
> We are all looking forward to hearing the verdict on your own test case.
First, this presumes that any law has been or will be violated.
As I explained, and the EPA confirmed, this is not possible - see "intent" in the prior posts in this thread.
Second, this ignores the multiple periods in time when there was no possible way to follow the regulations concerning Oxalic as worded, (a) initially, the years when there was no "approved product", and (b) later, the period of time when the only approved source had gone bankrupt, with no other approved source on the books. I think that any feigned concern and pearl-clutching over one is no different from any of the others, as I have already explained (c) the issue of "intent".
But those who wish to name-call others with "scofflaw" and "outlaw" should explain what "verdict" would be appropriate in each of the cases (a), (b), and (c).
To me, (a) and (b) look like prima facie violations with no excuse other than "we didn't care about the letter of the law", while (c) still looks not just legal, but also perfectly ethical (but I'm wearing the polarized Ray-Bans of self-interest when I say that, as I keep bees atop literal, actual, physical ivory towers).
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