SUPPLY OF FORMIC ACID THREATENED

[Bill_Ruzicka]

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.

DonÂ’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: jones.russell@epa.gov

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: reilly.sheryl@epa.gov


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%20A...20Response.pdf

Scheduling C94-05 – the most sensible way to regulate acid use LINK: http://www.pmra-arla.gc.ca/english/p...eg_c9405-e.pdf

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

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

NOD Application for 65% Technical Grade in Canada. LINK: http://www.pmra-arla.gc.ca/english/p...d2004-05-e.pdf


------------------
Bill Ruzicka
Bill's Honey Farm
MiteGone Enterprises Inc

[jfischer]

> NOD Apiary has applied for the unnecessary
> registration of Mite Away II in Canada.

If it was "unnecessary", then the Canadian
Pesticide Regulatory Management Agency (PRMA)
would certainly have told them so.

> public demand to register just formic acid.

This is also a good idea. Mite-Away should
be registered, Mite-Gone should be registered,
and plain formic acid itself should be registered
for those who wish to use the "blue shop towel"
method.

> 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.

I can't speak for Canada, but this is certainly
NOT this case in the USA, clearly illustrated
by the existing simultaneous registrations for
"FOR-MITE", a product that was never sold,
the Formic Acid Gel Packs, and the Mite-Away
product.

A registration is simply an approval that
the product is effective and safe, and
grants no rights of exclusivity. There
are very few pesticide products where there
are not multiple vendors offering similar
chemicals or technologies.

Merely registering a product does not
restrict other uses, and there is no possible
way that any one company can "corner the
market", as Bill himself has so creatively
shown with his own product, which he claims
to require no approval or registration from
any government agency.

[Ian]

>>Merely registering a product does not
restrict other uses, and there is no possible
way that any one company can "corner the
market", as Bill himself has so creatively
shown with his own product, which he claims
to require no approval or registration from
any government agency.


We are not talking about wheather or not the formic acid works, it has been proven around the world on both V and T mites, but rather the meduim used to administer it into the hives and liability here after on the sale of the formic itself. from My understanding NOD is trying to make it virtually imposible to sell acid dispensing equipment seperate from the acid itself, by which corner the current market place. By very design of Bills mitegone pad, the pad cant be sold "pre-soaked" and must be done int he bee yard. If you cant readily buy the formic, then how can you use the dispensing equipment?
I have used formic and understand and acknoledge the hazzards of the acid on my personal health and hive health, and really it is not as toxic and deadly as everyone is making it out to be!! I cant believe the fuss everyone is making with formic, and yet an actual personal and hive health hazard, like coumophose is readily available and allowed in our hives without any consideration to possible wax and honey contaminations concerns. What are the priorities in our market place here??
I cant believe that I am hearing sympathy for NOD aparies for what they are trying to pull here.

Ian

[This message has been edited by Ian (edited December 26, 2004).]

[jfischer]

> My understanding NOD is trying to make it
> virtually imposible to sell acid dispensing
> equipment seperate from the acid itself,

Why don't you contact PMRA ask THEM what they
are doing? I can't imagine that they would
fall for such a scheme as the one described
by Bill, so I can only conclude that Bill
is mistaken as to the intent of the registration.

It is my view that vendors SHOULD register
their products if they are required to do
so by the government. I am sure that MiteGone
can be registered, just as Mite-Away can.

I think that the basic problem here is that
if Mite-Away is registered, then the PRMA
will require MiteGone to also register,
something that MiteGone claims is "not required".

[roger eagles]

i BEING A TAXIDERMIST FOR OVER 30 YEARS HAVE ALWAYS GOTTEN FORMIC,FORMELDIHIDE,OXOLIC ACID AND MORE THREW THE TAXIDERMY SUPPLIES.hAVE GOTTEN SPECIAL ALCOHALS THREW A PERMIT AND FROM FEDERAL ALCOHAL AND TOBACCO.cOMES IN VERY HANDY IN MITE CONTROL ALSO.

[Jim Fischer]

> BEING A TAXIDERMIST FOR OVER 30 YEARS HAVE
> ALWAYS GOTTEN FORMIC,FORMELDIHIDE,OXOLIC ACID
> AND MORE THREW THE TAXIDERMY SUPPLIES...
> ...COMES IN VERY HANDY IN MITE CONTROL ALSO.

I have access to all sorts of things, including
uranium, plutonium, and a wide range of explosive
incendiary devices, but that does not give me any
license to use them in beekeeping, nor would I
violate the confidence and trust placed in me by
even thinking about using any of them in a manner
other than the legitimate intended use.

One either obeys the law, or one does not.
There is very little gray area in my view.

[Ian]

>>uranium, plutonium, and a wide range of explosive
incendiary devices

Last time I looked, those "things" werent known as food grade materials.
Your taking things way out of context

Ian

[Ian]

I treat my hives with menthol, to control my T-mites. They can pose a big problem, even in small numbers to wintering hives up here in the north. I also have a scoop of lard in my hives also for T-mite control. They work well and costs are cheap. Would you also consider these in your gray area?

[roger eagles]

Im green and don,t have mite problem yet but yew guys got me to thinkn better start wakn up.SO,what is a reasonable way here in canada to control before the mites start.

[Michael Bush]

The plutonium would probably work. Maybe Jim could get you some. (just kidding)

[MIKI]

>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.<

I'm still unclear about the issue but it sounds like we are being asked to get involved in some kind of private competition. Is this the case or am I off base here.

[Jim Fischer]

> it sounds like we are being asked to get involved
> in some kind of private competition.

Exactly.

[BubbaBob]

jfischer, I don't have a dog in the fight (yet) as the proposal is Canadian, but I am a curious sort, so I took your advice and contacted the PMRA.

Much to my surprise, as I had expected your point to be validated, Bill's assesment of the situation is right on. Under the proposal, there would only be one legal dispensing method legal and NOD holds exclusive rights to that method.

As I said, I don't have a dog in that fight. Also, I don't know or do business with any of you on either side of the discussion. I guess this could be called an unbiased assesment of the situation.

BubbaBob

[Ian]

jfischer

Why are you fighting against us? Your fight is to restrict the methods of administer formic to our hives?

Ian

[Jim Fischer]

> Under the proposal, there would only be one
> legal dispensing method legal and NOD holds
> exclusive rights to that method.

My understanding is that it would be possible for
Mite-Gone to register their product, and thereby
make their "dispensing method" also legal.

The problem is that Bill R. wants to posture that
regulation is not required, and has made no effort
to work with the authorities. Clearly, there is
no case where a regulator would ever admit that
there is no need to regulate when presented with
a question about a product, but I don't think that
the issue is open to debate or discussion at any
level lower than the Canadian Minister over Health
Canada.

So if only one product is registered in Canada,
only one would be legal. That's obvious.

Why do I care? As BubbaBob said, its a Canadian
matter, not a matter that a US beekeeper should
insert himself into without an invitation.

But Bill also sells his product to US beekeepers,
something that makes researchers, bee inspectors,
and elected leaders of beekeeping organizations
very uncomfortable. While the organic acids
are something that everyone wants to become
approved (as they have been in Europe), we
view Bill as making the process more difficult,
in that he encourages the beekeeper to ignore
the letter of the regulations, or worse yet,
argue with the regulators, rather than negotiate
to a reasonable compromise.

Bill R. wrote an article for Bee Culture, and
admitted in his own words that it was necessary
to lie, forge US federal documents, and defraud
the vendor in order to obtain formic acid to be
used in beekeeping in the US. This alone should
do more than raise eyebrows. This is a basic
ethics issue. One either obeys the law in regard
to what one puts in a beehive, or one does not.

There is no middle ground, there is no room for
compromise. If Bill were to register his product
(as Mite-Away did with the US EPA), I would have
no problem with it.

> Why are you fighting against us? Your fight is
> to restrict the methods of administer formic to
> our hives?

Not at all - if you think slowly and carefully
about the situation, you'll realize that I'm
trying to keep your options open, and keep Bill
"in business".

Bill needs to realize that his lack of attention
to registration issues was a big mistake. For him
to try to enlist beekeepers in helping to
"deregulate" formic acid in Canada is a waste of
his time, your effort, and will assure the failure
of the Mite-Gone product.

The only move on the board for Bill is to register
with Health Canada, and admit that registration in
the US is also a good idea. He will then be on
an equal footing with Mite-Away, and will not
need to go through so much long-winded hand-waving
and evasion about the legalities of his product.

So, if you think about it, I'm one of your biggest
allies. I'm also Bill's ally, as I am convinced
that he must lower the Jolly Roger, and stop
being a pirate before either Canada or the US
shut him down, fine him, and perhaps even
impose criminal penalties.

I'm trying to keep your options open.

[BubbaBob]

According to my conversation with Canadian authorities earlier today the proposed regulation, put forth by NOD, does NOT simply regulate a product, ie the organic acid Formic acid, it also regulates/describes the ONLY authorized dispensing method, one thar NOD holds patent on.

Interestingly, I just got home 5 minutes ago from a presentation to some Georgia beekeepers by Dr. Jamie Ellis, bee pest researcher with the University of Georgia's entomology department, and, as migh be guessed, Varroa Mites were the main topic.

Current research indicates that:

1. Varroa Mites are the number one problem for beekeepers worldwide, with only the Aisan strains of bees having a resistance.
2. For the beekeeper wanting to observe STRICT organic principles, there is only one option...the addition of a small or medium super that is allowed (guided?) to be strictly a drone brood chamber. It seems that Varroa Mites have a preference for drone brood. The ONLY reason to do this is to follow a belief in strict organic guides as this method of control only has a 50-55% effacacy.
3. Apistan, due to misuse has resulted in extreme levels of resistance, reaching 100% resistance in some areas of N America.
4. Bayer Bee Strips and Check Mite, while still somewhat effective, are showing signs of reaching, very soon, resistance levels equal to Apistan.
5. Formic acid, as discussed here, with the admonition that there is no application method presently providing reasonable effacacy results.
6. The best current method of control seems to be a combination of 3 techniques, none of which provide enough protection, but that when combined, give the best results of anything so far:
6a. Fume blocks consisting of a porus inert block (usually the material florists use in a vase to stick flowers in) soaked with a combination of menthol, camphor, eucalyptus, and thymol, all easily available as essential oils.
6b. Screened bottom boards, which incidentally, reduce the mites by 14% if you use nothing else.
6c. Re-queening at least every other year with resistant queens.

6c. brings us to two things in the, hopefully, not too distant, future, to alleviate Varroa Mite problems.

First, thru selective breeding, it is thought that sometime soon a resistant strain, rather than just resistant tendencies, can be developed. As I noted earlier, aisan honey bees have mites as well, but co-exist with them just fine. The same can happen eventually with european based stock through selective breeding.

More near term, (and you folks are the first to hear this besides the people in the room I was in tonite) there has been developed, and will be released for use by fall, strips, like Apistan, that are a fungus, ie no resistance development, that very effectively fight Varrosa Mites.

Sheese!!! Too much typing...fingers are tired.

BubbaBob

[Jim Fischer]

> the proposed regulation, put forth by NOD, does
> NOT simply regulate a product, ie the organic
> acid Formic acid, it also regulates/describes
> the ONLY authorized dispensing method, one that
> NOD holds patent on.

Do you honestly think that the Canadian government
would be so stupid as to endorse a patented
process as the ONLY "legal" approach?

Given 'em some credit. They are smarter than
you might think, and have had this sort of trick
tried before. There's a process, there's checks
and balances, and there's a lot more "common
sense" built in than you might think.

jim

[BubbaBob]

jfischer, I made no statement as to the likelihood, or absence of likelihood, of the proposals adoption. I simply stated what Canadian authorities told me was contained in the proposal.

As to whether or not government is stupid enough to do such a thing, well, I have found that governments only do two things well...defend borders and build roads. Beyond that, they do most things poorly yet insist on sticking their nose in anyway, so while I hope this proposal dies a quick death, history tells me not to bet the farm on it.

BubbaBob

[MIKI]

What happens when there is finally a way to control mites either with FGMO or this fungus thing? Will this make formic, OA and what ever else obsolete? There is a better way it's coming soon there are too many scientists working on it.
The total cure for all the problems is 1st to realize that its not us who have a problem with nature, its nature that has a problem with us. OK IÂ’m not going to rant IÂ’m too tiredÂ…where did I put that Tylenol?

[roger eagles]

I seem to understand canada allows 63% formeldehyd soaked sheets on top lids.Whats the scoop on this.Green on mites question.