NOD Apiary has applied for the unnecessary registration of Mite Away II in
Canada.  This process requires public input.  As a result, the Pest
Management Regulatory Agency is getting an earful of protests to the
registration of Mite Away II and increased public demand to register just
formic acid.

NOD IS TRYING TO CORNER THE MARKET IN BOTH COUNTRIES THROUGH THE
REGISTRATION OF A PRODUCT THAT HAS MANY LIMITATIONS.  THE REGISTRATION
WILL MAKE OTHER USES OF FORMIC ACID RESTRICTED.

The use of formic acid by the beekeeper in the USA is legal.  Acid is an
unregulated product; however, several beekeepers were refused sale of
acid.  Someone is informing acid suppliers and telling them not to sell
acid to beekeepers otherwise they will be fined.  This is based on the EPA
ruling: “If the manufacturer or seller is aware of beekeepers using formic
acid as a pesticide then that manufacturer is obligated to register the
acid otherwise he will be subject of regulatory action.”  This makes acid
difficult to obtain.  Manufacturers avoid fines by refusing to sell
officially to beekeepers.  Chemical manufacturing companies will not
register formic acid.  There is no one to sponsor registration of formic
acid.  Beekeepers must buy the acid under false pretenses.  See the
article in Bee Culture March 2004 issue page 37, Status of Formic Acid in
the USA.

 WHAT YOU CAN DO ABOUT IT

Fortunately the NOD application EPA # 75710-R in the USA opens the door to
public and political pressure directly to the EPA.
Write to your senator, congressmen and anyone of influence.  Tell them
about your distress, situation, and your loss of hives.  Ask for the
exemption or full registration of 65% technical grade formic acid for use
in beehives.  The dispensing method must be left up to the beekeeper.

Don’t under estimate the possibility of exemption; it may be the best
way.  (See the link below)  That way, you will have the best solution to
the formic acid issue in the USA.  You will be able to buy acid that is
already thinned, in small quantities, and use any of the application
methods available today (that beekeepers are already using).

Make sure you copy the EPA on your letter.  Send it to:

Dr Russell Jones
Chair, Biochemical Classification Committee
Biopesticides and Pollution Prevention Division
(7511 C)9th Floor, Room 910
Office of Pesticide Programs
Crystal City, Crystall Mall
21921 Jefferson Davis Highway
Arlington, Virginia  22202
Phone:  703-308-5071
Email: [log in to unmask]

AND

EPA – Biopesticide Division
Attention:  Dr. Sheryl K. Reilly
7511CUSEPA Headquarters
Ariel Rios Building
1200 Pennsylvania Avenue, N. W.
Washington, DC 20460
Phone:  703-308-8269
email:  [log in to unmask]


All of the information on Formic Acid NOD registration and the Canadian
experience is available at the following links.  You are welcome to use
any part of them in your own submission or resolution.

Formic Acid Registration Response - includes NOD evaluation.  LINK:
http://mitegone.com/forms/Formic%20Acid%20Registration%20Response.pdf

Scheduling C94-05 – the most sensible way to regulate acid use LINK:
http://www.pmra-arla.gc.ca/english/pdf/reg/reg_c9405-e.pdf

Supporting emails RE FORMIC ACID USE THREATENED.  LINK
http://mitegone.com/forms/Supporting%20emails%20RE%20FORMIC%20ACID%20USE%
20THREATENED.pdf

Introduction and Status of Formic Acid in the USA LINK:
http://www.mitegone.com/forms/Introduction%20and%20Status%20of%20Formic%
20Acid%20in%20USA.pdf

NOD Application for 65% Technical Grade in Canada.  LINK:  http://www.pmra-
arla.gc.ca/english/pdf/prdd/prdd2004-05-e.pdf

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