It's not ironic at all that Dylan has US approval and AluenCap does not -
Dylan went to the trouble to actually apply for a registration, and slogged
through the process.

The Dylan AFB vaccine also has the advantage of several papers in
peer-reviewed journals that the EPA/FDA/USDA found acceptable:

 

https://doi.org/10.3389/fvets.2022.946237

 

https://doi.org/10.4161/viru.28367

 

Where have papers about AluenCap and similar Oxalic alternative applications
been published?  I don't know of any legit journal citations, or even
sketchy journal citations. 

 

I think the take-away here is that spending several years trying to create a
groundswell of support might work in a purely political environment, but the
barriers one faces with new bee treatments is entirely technocratic - the
need is for evidence-based statements, submitted on the proper forms, with
the proper fees, to the correct bureaucrats (at least in the USA).

 

Now, can we work for change, and ask EPA/FDDA/USDA to "get real", and
understand that beekeeping products are always going to be very niche
products? So maybe there needs to be some form of reciprocity, where
approval and regs in one country should go a long way towards approval here?
Canada seems to have adopted exactly such a reasonable approach, in many
areas they essentially free-ride on the US taxpayer-funded work that results
in EPA and FDA notices, regulations, and rules.

 

But it is almost impossible to get any regulator to ease regulations - they
think that they are protecting someone somewhere from something, and they
see their work as "for the good", so any effort that attempts to bypass
their process is going to look to them like a scenario where they need to
make some examples of a few of the more flagrant miscreants, just to remind
everyone that there are regulations, and that they exist for good reason. 

 

Is an AFB vaccine any more useful to the practical beekeeper than an IAPV
vaccine was?  It may not be my place to judge, or to even make such
comparisons, but I find the comparison apt, as both companies have a story
that seems very compelling to investors, press, and the public who don't
keep bees, but less so to beekeepers.   As an investor who knows a bit about
bees, I have invested in neither.

 

 

 

 

 

 

 

 

 

 


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