James Fischer says "I'll bet you'd get an argument from them (Brushy Mtn) if
you were in a state with no known beetle infestation."

Actually James, EPA has issued Section 18s for Check-Mite to some states
only for use on Varroa because there was some evidence of the mites being
tolerant to fluvalinate.  In other states having the Small Hive Beetle,
EPA's Section 18 will specify use for Varroa and the SHB.

Brushy Mountain can get a list of the states having a label approved for
Varroa, the SHB, or both, from Bayer or EPA.  Then they can sell CheckMite
to those states with labels.

The Virginia State Apiarist was correct in saying that other states used
Florida's application for a Section 18.  What states actually did was to
write up justification for the granting of a S-18 in their state including
cost impact data and other information required by EPA.  Then the state
referenced the research data provided by Florida in their S-18 request.
This was allowed by EPA to reduce the amount of paperwork in each state that
would be required if each state had to acquire all the same information that
was required and that appeared in the Florida request.  It just made good
sense to EPA.

But each state didn't "gain approval 'just in case'."  Each state had to
provide data that there were either reported cases of tolerance (as in WA),
or that it was reliably reported in states from which they receive migratory
colonies.  WA receives approximately 50,000 hives from CA, ID, OR, SD and
ND.

I hope this will clear up some inaccuracies.

James C. Bach
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