The observation that the EPA does not review efficacy, which was not in doubt, presents an intriguing scenario for the specific case of oxalic acid.

While no one ever suggested that the EPA would review/approve efficacy, it is (or was) a basic assumption that no one worth their salt would want to be associated with an effort to get an EPA-approved label for an application method that was not first shown to be effective at some acceptable level.  

Beekeeping has been subjected to many seductive-looking but infective treatments that were each shown by multiple legit controlled studies to be no more effective than doing nothing, and fared no  better than untreated control colonies.  FGMO, for example, attracted many enthusiastic beekeeper proponents.  Powdered sugar was promoted and fiercely defended, but then backtracking began, with revised claims such as statements that powdered sugar actually worked best in coordination with drone brood removal, which was well-known to work fine alone.  

But what it the minimum EPA-required tests for a "more benign" substance like oxalic acid (as compared to neurotoxins and organophosphates) were far cheaper to fund than the same tests and an controlled evaluation of efficacy?  We already know that there is a wide variation in both doses, and frequency of treatments for the established oxalic acid treatment methods. If it becomes clear that this treatment method is less effective than thought, one could simply "treat more often".

My initial thought was that reputational concerns would make it hard to recruit anyone, even with full funding, unless efficacy was first confirmed, but I may be incorrect:

a)  In over 20 years, no one's found a magic bullet

b)  This treatment, like everything else, is not going to utterly eliminate varroa from even a single yard, so "efficacy" is still a nebulous concept in the field of varroa control.

In an extreme example, one could go through the EPA processes, and get a very affordable set of studies done to gain EPA approval for putting crystals on one's bottom board, and incense on the migratory covers, as both would be clearly harmless to the bees and the ecosystem.  But would anyone want their name associated with the effort?

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