# The EPA will allow OA to be used with honey supers present.



## ffrtsaxk (Jul 17, 2017)

Sources and documentation? please


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## username00101 (Apr 17, 2019)

*AGENCY:*
Environmental Protection Agency (EPA).

*ACTION:*



Final rule.


*SUMMARY:*
This regulation establishes an exemption from the requirement of a tolerance for residues of oxalic acid on honey and honeycomb. This regulation eliminates the need to establish a maximum permissible level on these commodities for residues of oxalic acid.

*II. Background and Statutory Findings*
In the *Federal Register* of September 30, 2020 (85 FR 61682) (FRL-10014-74), EPA issued a document pursuant to FFDCA section 408(d)(3), 21 U.S.C. 346a(d)(3), announcing the filing of a pesticide tolerance petition (PP 0E8824) by Interregional Research Project Number 4 (IR-4), 500 College Road East, Suite 201W, Princeton, NJ 08540 as an agent for the U.S. Department of Agriculture, Agricultural Research Service (ARS), Bee Research Laboratory, 10300 Baltimore Ave. Bldg. 306, BARC-East, Beltsville, MD 20705. The petition requested that 40 CFR part 180 be amended by establishing an exemption from the requirement of a tolerance in or on honey and honeycomb for residues of oxalic acid dihydrate. That document referenced a summary of the petition prepared by the petitioner, ARS, which is available in the docket, _http://www.regulations.gov._ There were no comments received in response to the notice of filing.

Section 408(c)(2)(A)(i) of FFDCA allows EPA to establish an exemption from the requirement for a tolerance (the legal limit for a pesticide chemical residue in or on a food) only if EPA determines that the exemption is “safe.” Section 408(c)(2)(A)(ii) of FFDCA defines “safe” to mean that “there is a reasonable certainty that no harm will result from aggregate exposure to the pesticide chemical residue, including all anticipated dietary exposures and all other exposures for which there is reliable information.” This includes exposure through drinking water and in residential settings but does not include occupational exposure. Pursuant to FFDCA section 408(c)(2)(B), in establishing or maintaining in effect an exemption from the requirement of a tolerance, EPA must take into account the factors set forth in FFDCA section 408(b)(2)(C) and (D), which requires Start Printed Page 10834EPA to give special consideration to exposure of infants and children to the pesticide chemical residue in establishing a tolerance and to “ensure that there is a reasonable certainty that no harm will result to infants and children from aggregate exposure to the pesticide chemical residue . . .”, as well as consider other factors.

EPA performs a number of analyses to determine the risks from aggregate exposure to pesticide residues. First, EPA determines the toxicity of pesticides. Second, EPA examines exposure to the pesticide through food, drinking water, and other non-occupational exposures that occur as a result of use of the pesticide.

*III. Toxicological Profile*
Consistent with FFDCA section 408(b)(2)(D), EPA has reviewed the available scientific data and other relevant information in support of this action and considered its validity, completeness and reliability and the relationship of this information to human risk. EPA has also considered available information concerning the variability of the sensitivities of major identifiable subgroups of consumers, including infants and children. The nature of the toxic effects caused by oxalic acid are discussed in this unit.




Oxalic acid is ubiquitous in the environment being found naturally in many plants and vegetables, as well as in honey. Oxalic acid is commonly used as an analytical reagent in textile finishing, in metal, wood, or equipment cleaning, in bleaching straw and leather, in removing paint, varnish, rust, or ink stains, in dye manufacturing, in chemical synthesis, in the paper, ceramics, photographic, and rubber industries, as well as _in vitro_ as a blood specimen anticoagulant in veterinary medicine. The available data indicate decreased body weight effects occuring only at high doses. Moreover, based on the literature and due to the lack of adverse effects associated with the long history of use in a number of manufacturing processes and goods, exposure to oxalic acid is unlikely to result in short-term, long-term, prenatal developmental, or mutagenic and/or genotoxic toxicological effects. A full discussion of the literature and background on the toxicological profile of oxalic acid can be found in docket number EPA-HQ-OPP-2020-0176 in the documents titled “Oxalic Acid. Label Amendment Regarding Use in Beehives with Honey Supers to Control Varroa Mites” and “Oxalic Acid. New Use in Beehives to control Varroa mites.”


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## gww (Feb 14, 2015)

Wish I would have looked before I leaped in opening a thread on this topic.
Cheers
gww

[Moderator note: I have combined that other thread into this post. Here is the content:]

LISTSERV - BEE-L Archives - COMMUNITY.LSOFT.COM
Cheers
gww


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## JWPalmer (May 1, 2017)

It is indeed good news. Now we can openly discuss what most of us have known all along. Beesources's OFFICIAL position is to not advocate the illegal use of pesticides, so the new labeling will be welcomed.


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## crofter (May 5, 2011)

username00101 said:


> Effective Feb 23rd 2021 the EPA will be removing the restrictions for using OA with honey supers present.
> 
> As someone who's gotten some serious flack in my previous threads, illustrating the extremely small quantities of OA that would enter honey, I think this is an interesting development.  Seems that we were all correct about how harmless OA would be with regards to honey.
> 
> ...


That is good to hear. OA usuage with honey supers on has be allowed in many european countries for quite a while. The stipulation that it not be so ruled here was supposedly to expedite the approval process by removing the need to provide the independent testing and documentation mandated by the process.

Most people that you got flack from was not on whether or not it was safe but you certainly did get pushback for promoting the flaunting of the usage recommendations on a public forum. The pressure on the regulatory process has to be applied in the proper places or it can easily be counterproductive. Anyways that is only a bit of history.

The next thing we can look forward to which is also probably only a matter of time is the use of oxalic acid and glycerine solution suitable matrix placed on frame tops. Randy Oliver Scientific Beekeeping is doing approved testing similar to approved applications in use in South America and I believe also in Europe. The lifting of the cautions of OA vapor use can only improve the view on the OA/GLY contact applications. Timely too since bees in many areas are demonstrating tolerance to Apivar.


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## msl (Sep 6, 2016)

crofter said:


> Most people that you got flack from was not on whether or not it was safe


agreed, but he should take it as a "win" nonetheless and injoy the moment



JWPalmer said:


> so the new labeling will be welcomed.


we really need " the documents titled “Oxalic Acid. Label Amendment Regarding Use in Beehives with Honey Supers to Control Varroa Mites” and “Oxalic Acid. New Use in Beehives to control Varroa mites" referenced to know exactly what is going on.


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## GregB (Dec 26, 2017)

Yes, this is good news.
Time to reconsider things.


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## Woofee (Jan 31, 2021)

msl said:


> we really need " the documents titled “Oxalic Acid. Label Amendment Regarding Use in Beehives with Honey Supers to Control Varroa Mites” and “Oxalic Acid. New Use in Beehives to control Varroa mites" referenced to know exactly what is going on.


After the closing of objections which is April 26 2021, we should see the labeling on the product changed to reflect that the Supers no longer need to be in place during application of labeled product with active ingredient Oxalic Acid Dihydrate. 

People need to understand, if they are to follow the law exactly, that the label is the law, and until the labeling has changed, they must still follow that label on the package. One way around this would be to find the new label, and have it in hand when making the application. Sometimes a supplement label will be produced to indicate a label change, while still using the original printed label on the packaging, until they run out of the old label packaging.


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## msl (Sep 6, 2016)

much more interested in the OA-gly extended release that this is paving the way for


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## msl (Sep 6, 2016)

and here we go!!!





Regulations.gov







www.regulations.gov









Regulations.gov







www.regulations.gov





sadly the "new use" is an old doc and our old use


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## johno (Dec 4, 2011)

msl said:


> much more interested in the OA-gly extended release that this is paving the way for


What is all the fuss about, I believe the EU guys came up with the same conclusion in 1999. So I figure a new label should be all sorted by the employment prevention agency in about 20 years time


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## zabadoh (Jul 18, 2019)

The next headache is adjusting dosages of OA to account for the additional volume of the supers.

Have the Europeans and South Americans figured out that formula yet?


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## John Davis (Apr 29, 2014)

The links to the docs above seem to reflect the proposed changes, not the "old use doc" as msl commented. 
The use restrictions section in the old label which referenced using - only during periods of low brood and not using with supers on - has been eliminated. 
Not signed and delivered, there is still a 60 day period for comments so hopefully in April we will see something final and signed.


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## Surviving Our Bees (Feb 14, 2021)

The change was final and effective on Feb 23rd. From my understanding, it is signed and delivered.


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## clyderoad (Jun 10, 2012)

username00101 said:


> Effective Feb 23rd 2021 the EPA will be removing the restrictions for using OA with honey supers present.
> 
> As someone who's gotten some serious flack in my previous threads, illustrating the extremely small quantities of OA that would enter honey, I think this is an interesting development.  Seems that we were all correct about how harmless OA would be with regards to honey.
> 
> ...


I recall a thread where someone experimented with eating the OA to attempt to prove a point. Was that you? and the source of "serious flack" you refer to? 
Where is the link to that thread?


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## username00101 (Apr 17, 2019)

*Oxalic acid is harmless - I don't bother removing honey supers any longer.*

💪


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## Bogito Joe (Dec 10, 2020)

Well, I'm no Master Beekeeper by any means. This will only be my third season. Struggling with when and how to treat for mites and how to work around protecting my honey suppers has been a challenge to me. This news that the EPA considers using OA safe to use with the supers on , for me, is huge. I'm not commercial and I don't sell anything so *If it has already determined to be safe*, label or no label, my season just got a whole lot easier.


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## rdimanin (Jan 17, 2020)

crofter said:


> That is good to hear. OA usuage with honey supers on has be allowed in many european countries for quite a while. The stipulation that it not be so ruled here was supposedly to expedite the approval process by removing the need to provide the independent testing and documentation mandated by the process.
> 
> Most people that you got flack from was not on whether or not it was safe but you certainly did get pushback for promoting the flaunting of the usage recommendations on a public forum. The pressure on the regulatory process has to be applied in the proper places or it can easily be counterproductive. Anyways that is only a bit of history.
> 
> The next thing we can look forward to which is also probably only a matter of time is the use of oxalic acid and glycerine solution suitable matrix placed on frame tops. Randy Oliver Scientific Beekeeping is doing approved testing similar to approved applications in use in South America and I believe also in Europe. The lifting of the cautions of OA vapor use can only improve the view on the OA/GLY contact applications. Timely too since bees in many areas are demonstrating tolerance to Apivar.


Absolutely have developed noticeable resistance to Apivar. Just lost 2 hives that I treated with Apivar, last mite count 2 before treatment. Removed the strips 6 weeks later but it was too cold to pull frames & test. When I went thru the deadouts & did a mite shake (counted 300 bees), found 40 mites in one & 56 in the other. My other hives were treated with Apiguard are rocking. I learned my lesson. Just bought a roll of blue Scott shop towels & willl use 50/50 Oxalic acid/glycerine during the heat of the summer; alternating with Hopguard 3. I'll also alternate using Formic pro or Apiguard in the fall, with oxalic sublimation late fall/early spring as cleanups. No more Apivar.


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## psm1212 (Feb 9, 2016)

Woofee said:


> After the closing of objections which is April 26 2021, we should see the labeling on the product changed to reflect that the Supers no longer need to be in place during application of labeled product with active ingredient Oxalic Acid Dihydrate.


My question is whether EPA will make these changes to label unilaterally, or does this just open the opportunity for registrant of an actual product to apply for a new label? I don't see this as making OAD products labeled as "wood bleach" suddenly legal to use in hives. So will the very few (maybe 1??) actual product manufacturer (distributor?) in the US for OAD for use as a pesticide in honey bee hives actually spend the money and resources to go back to the EPA for a new label? Will they have to?

I don't think this is much of an IMMEDIATE game changer for me. I agree with many on this thread that extended release of OAD throughout the nectar flow is where the promise currently lies.


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## Surviving Our Bees (Feb 14, 2021)

The decision is already final, was effective in Feb.


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## crofter (May 5, 2011)

It was kicked around at some length on Bee_L and seems lots is left up to speculation as to what it really means to us as beekeepers. I dont think there is much appetite for policing technicalities when the decision has come down that honey need not be tested for OA content since it is inherently present and deemed harmless.
It probably would be a good idea to have your Oxalic Acid stored in a moisture tight generic container but CYA with printing out the MSDS label for it. The Savogran container is a bear to open and close so not very practical anyways.


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## psm1212 (Feb 9, 2016)

Oh, I realize I am discussing technicalities. For me personally, I use Savogran and have for years. I used it prior to 2015 (legalization in US). But if we are to continue on with the mantra of "The Label is the Law" I suppose we need to see (or maybe I just want to see) if that actually holds true. 

I do not think that the new rule allows unregistered, unlabled OAD to be used in a hive as a pesticide. So we are still in the arena of being required to use a registered product that is labled with an EPA approved label (whether or not we abide by that requirement). While the EPA has seemed to say that they will not require research regarding impacts of in-hive use of OAD on honey, it does not state that the existing label will be modified by the EPA.

I am just wondering how the label gets changed. Does a Registrant have to apply for the change under the new rule? Does the EPA change it unilaterally?

If the former, we may be years away from a changed label. If the latter, maybe not. 

Is the label still the law, or is it not?


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## Surviving Our Bees (Feb 14, 2021)

From the language above, there's no residue limit, so basically, if someone uses OA there's no risk for contamination.


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## msl (Sep 6, 2016)

Surviving Our Bees said:


> there's no residue limit, so basically, if someone uses OA there's no risk for contamination.


arguably is says contamination is not a risk so there is no limit on the amount of contamination


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## GregB (Dec 26, 2017)

msl said:


> arguably is says contamination is not a risk so there is no limit on the amount of contamination


+1
This is similar to contamination by powered sugar.
Yes - there is contamination.
No - it is not harmful to humans in the general context (if you want to control sugar intake - look elsewhere first - e.g. donuts, muffins, white bread, etc).


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## crofter (May 5, 2011)

It is not going to change what I am doing either so I am not going to go demanding specific details. If cornered the powers that be may come down on the tougher side of what is questionable. I will take the point that it means OA is no longer considered a pesticide if it is generally considered as safe so not requiring treatment recommendations: same as a box of salt, baking soda, etc.


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## msl (Sep 6, 2016)

No its not *Generally recognized as safe* (*GRAS*) it's still a pesticide, It still has requirements and restrictions (low/no brood being one of them), and nothing has changed till a new label comes out.

believe it or not the EPA has exempted many pesticides under the "when used according to the labe" there is little risk ideal








Pesticide Registration Manual: Chapter 11 - Tolerance Petitions | US EPA


This Chapter provides information on definitions, interpretative regulations and procedures for filing a petition for establishment of a tolerance or an exemption from the requirement of a tolerance.




www.epa.gov





This isn't a free for all, and in realty little has changed


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## Surviving Our Bees (Feb 14, 2021)

This isn't very complicated, I sort of think beekeepers are making this way too complicated. It's a very simple decision made by the EPA.

OA can now be used with honey supers present. Just accept the new law and use OA when we need to use OA, don't worry about the honey, it won't get contaminated.


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## crofter (May 5, 2011)

msl said:


> No its not *Generally recognized as safe* (*GRAS*) it's still a pesticide, It still has requirements and restrictions (low/no brood being one of them), and nothing has changed till a new label comes out.
> 
> believe it or not the EPA has exempted many pesticides under the "when used according to the labe" there is little risk ideal
> 
> ...


Nah it is a rust remover and a bleach, not a pesticide. What really matters is how the powers that be decide to police it. Yours and my interpretation does not count except for entertainment. We are not sure yet how that is going to play out. I think we may find that in the aftermath of the Covid experience there wont be much funding to police victimless issues. This has changed.


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## msl (Sep 6, 2016)

follow up statement from the EPA cuirsty of Randy oliver


> The exemption from tolerance was issued under the Federal Food, Drug and
> Cosmetic Act (FFDCA). EPA was able to meet the requirements stipulated
> under the FFDCA to exempt oxalic acid from tolerances; however, the
> chemical still has to be applied as a registered product under FIFRA. The
> ...


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## crofter (May 5, 2011)

msl said:


> by the way, here is a follow up statement from the EPA cuirsty of Randy oliver


Yes, you are correct! I just finished reading it too. 
Seems that the stipulation will remain that only what is packaged and labeled as a pesticide will be approved procedure. How strictly it is enforced remains to be seen.


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## Surviving Our Bees (Feb 14, 2021)

The oxalic acid sold on amazon for decks, has zero quality control and it's probably not actually 99.6% OA.

What are the registered oxalic acid products?


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## johno (Dec 4, 2011)

crofter said:


> Yes, you are correct! I just finished reading it too.
> Seems that the stipulation will remain that only what is packaged and labeled as a pesticide will be approved procedure. How strictly it is enforced remains to be seen.


The more things change the more they stay the same, it always seems to me that the experts who make some of these laws rely on the expert opinion on others who generally do not have much practical experience in the area that they are advising in. First of all some of the labelled OA supplied by bee houses is only around 97% pure whereas most OA available that is not labeled by the EPA is 99.6%pure. Makes no difference you might say, well folks using the labelled product have had problems with the silicone caps popping off during treatment and when the 99.6% OA was used no more of the caps popping off so exactly what is in that 2 plus percent that is the difference between the two. But also consider the rules of the EPA in around 2002 when bees were dieing all over the states of course they said use the caumophos or the other miticide they endorsed that the mites were resistant was no excuse. Where would the industry be now if beekeepers themselves had not found a way to use Tactic and keep their mites under control. Live by the Government and die by the Government, not me for sure.


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## GregB (Dec 26, 2017)

Surviving Our Bees said:


> The oxalic acid sold on amazon for decks, has zero quality control and it's probably not actually 99.6% OA.
> 
> What are the registered oxalic acid products?


Look for ACS grade/Lab grade/Reagent grade - will be more expensive but quality/conformity tested (price diff for small scale setups does not matter much).

Like these:








Amazon.com: Oxalic Acid [C2H2O4] 99.8% ACS Grade Powder 1 Lb in Two Space-Saver Bottles USA : Industrial & Scientific


Buy Oxalic Acid [C2H2O4] 99.8% ACS Grade Powder 1 Lb in Two Space-Saver Bottles USA: Acids - Amazon.com ✓ FREE DELIVERY possible on eligible purchases



www.amazon.com







https://www.amazon.com/Oxalic-Pounds-Bottles-Reagent-Powder/dp/B088F5W35J


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## psm1212 (Feb 9, 2016)

Looks like USDA-Beltsville filed the petition to establish the exemption from the requirement of tolerance for residues of OAD. Beekeepers have yet another reason to be grateful for the work done at Beltsville on behalf of beekeepers.


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## bushpilot (May 14, 2017)

psm1212 said:


> Looks like USDA-Beltsville filed the petition to establish the exemption from the requirement of tolerance for residues of OAD. Beekeepers have yet another reason to be grateful for the work done at Beltsville on behalf of beekeepers.


You have a source? Not doubting, just interested.


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## psm1212 (Feb 9, 2016)

msl said:


> This isn't a free for all, and in realty little has changed


I agree with msl in that little, in reality, has changed. However, it is not insignificant (to me at least) that the EPA specifically found that OAD use with honey supers present is safe.

From the final rule: _* "Section 408(c)(2)(A)(i) of FFDCA allows EPA to establish an exemption from the requirement for a tolerance (the legal limit for a pesticide chemical residue in or on a food) only if EPA determines that the exemption is 'safe.' . . . [The EPA] defines 'safe' to mean that 'there is a reasonable certainty that no harm will result from aggregate exposure. . . [a]ccordingly, EPA finds that exempting residues of oxalic acid from the requirement of a tolerance will be safe."*_

Even though this is something most of us have known with reasonable certainty for a long time now, it is comforting to read those words from the EPA. At least to me it is.


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## psm1212 (Feb 9, 2016)

Oxalic Acid; Exemption From the Requirement of a Tolerance

Bushpilot: It is buried. See "II. Background and Statutory Findings." First paragraph.

Edit: I originally thought I was responding to Frank, but it was Bushpilot.


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## msl (Sep 6, 2016)

> The amount of oxalic acid present in honey as a residue after application for varroa treatment in hives is negligible, approximately 60–80 ppm and is not expected to exceed the range (1-800 ppm) of naturally occurring oxalic acid concentrations found in honey


I will say the EPA may be abit off on the actually volume of use that some people are currently doing, maybe the new label will address that... ie 20 treatments, 60ppm = 1200 ppm.. or maybe they don't as leaving the broodless requirement would limit the ability to do a bunch of treatments all summer... 

But for those who are being overly cautious in what they put in their food, that ppm per treatment number might be a handy guide stick as to how much a treatment impacts them


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## psm1212 (Feb 9, 2016)

From Randy's EPA contact: _"EPA is finishing up the amended label to allow for use of the registered oxalic acid product year-round."_

So I guess I have my answer on that question. We will not have to wait for some registrant to petition for the new label. That is more good news.


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## John Davis (Apr 29, 2014)

Yes the request for the label change is already in the works.
If you read it it lists 2 application methods dribble and vaporizer.
Still has quantity limits but removes the other verbiage about brood less and honey supers.
Yes the USDA folks at Beltsville deserve our thanks.


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## squarepeg (Jul 9, 2010)

quoting from an email that randy oliver sent out today:

"I've received a lot of questions regarding the notice from the Federal Register that oxalic acid has been exempted from tolerance in honey. Beekeepers are asking me what this means.
The following is a direct quote from my contact at EPA (who checked with the Regulation Division):
"The exemption from tolerance was issued under the Federal Food, Drug and Cosmetic Act (FFDCA). EPA was able to meet the requirements stipulated under the FFDCA to exempt oxalic acid from tolerances; however, the chemical still has to be applied as a registered product under FIFRA. The whole exemption was to support the use when the supers are on; EPA is finishing up the amended label to allow for use of the registered oxalic acid product year-round. If the beekeepers don’t use a registered product, they would be applying an unregistered pesticide and would be subject to enforcement under FIFRA."

The above is great news -- that EPA is in the process of amending the label for application even if honey supers are on!

*That said, this announcement does not mean that there's yet been any change to the label -- it won't be legal to apply OA for mite treatment with honey supers on (or even during the summer) until the label has been changed, and even then, one would still need to only use OA registered for that specific use (with a label from EPA on the container). Currently, I believe that Api Bioxal is the only registered product in the U.S.*

Allow me to address a recent between-the-lines suggestion on another forum that beekeepers could act as scofflaws, by claiming that their "intent" for applying OA was not for mite control, that they might technically be able to avoid prosecution for illegal application of a listed pesticide (once any chemical is listed as a pesticide, it puts it into a new category, and OA is in that category).

This detail came up last year when I was on the phone with the person in charge of Pesticide Research Authorizations for California. I was discussing my research, and mentioned that I was doing titrations to track the distribution of OA within the hive. He/she said, that's not covered by your PRA! I responded that it didn't need to be, since I wasn't doing those specific applications for varroa control (which would have been considered as pesticide applications), but rather only to track how the chemical distributed upon the bees in the hive.

Similarly, there is no law against using OA as a wood bleach on hive components. But if one's intent was to apply it to the colony in order to kill mites, then that would then be considered as an application of a listed pesticide, and would therefore be illegal. So yes, what's in your thought bubble could make the difference between being prosecuted or not. I've yet to hear of a test case.

Please keep this in mind. If we beekeepers feel that we can be pesticide scofflaws, how could we then demand that farmers follow the label to protect our bees? The EPA is well aware of this dichotomy. That's why I'm trying to work with USDA and EPA to add the extended-release application method to the label, and for our industry to register an inexpensive source of OA for us to use. If our industry were willing to put the effort and money into it, it would be a win all around -- effective, safe, and non contaminating varroa control, inexpensive and legal. I suggest that we put pressure on AHPA and ABF to do so."


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## msl (Sep 6, 2016)

John Davis said:


> Yes the request for the label change is already in the works.
> If you read it it lists 2 application methods dribble and vaporizer.


Got a link? I hadn't heard them dropping spraying from the label 

the label change has been on going... See the HED approval letter post #40 from nov


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## clyderoad (Jun 10, 2012)

With all due respect I will not be relying on Randy Oliver's' interpretation of these new developments, nor that of anyone else for that matter. I want to hear it straight from the horses mouth and will wait to alter any current procedure until then.


On a related matter I wonder what the "industry" could expect by throwing money, what ever that means, at regulatory approval of Randy Oliver's' extended release method. My gut tells me nothing more than not throwing money at it.


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## Surviving Our Bees (Feb 14, 2021)

OA cannot contaminate honey. We need to use a special "approved" Api bioxal brand.

Buy it here, for example from Mann Lake:









Api-Bioxal (Oxalic Acid)


Buy Api-Bioxal (Oxalic Acid) at Mann Lake. Best & Biggest Beekeeping Supplier - Best Service.




www.mannlakeltd.com





End of story....or so it seems. But if this approved OA is only 97%....then the laboratory grade OA is 99.6%...what the heck...


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## AHudd (Mar 5, 2015)

squarepeg said:


> Allow me to address a recent between-the-lines suggestion on another forum that beekeepers could act as scofflaws, by claiming that their "intent" for applying OA was not for mite control, that they might technically be able to avoid prosecution for illegal application of a listed pesticide (once any chemical is listed as a pesticide, it puts it into a new category, and OA is in that category).
> 
> 
> Similarly, there is no law against using OA as a wood bleach on hive components. But if one's intent was to apply it to the colony in order to kill mites, then that would then be considered as an application of a listed pesticide, and would therefore be illegal. So yes, what's in your thought bubble could make the difference between being prosecuted or not. I've yet to hear of a test case.


LOL, we're just cleaning the stains from the insides of our wooden beehives. 
Apimaya and BeeMax owners excluded.

Alex


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## jimpart (Jan 26, 2021)

username00101 said:


> Effective Feb 23rd 2021 the EPA will be removing the restrictions for using OA with honey supers present.
> 
> As someone who's gotten some serious flack in my previous threads, illustrating the extremely small quantities of OA that would enter honey, I think this is an interesting development.  Seems that we were all correct about how harmless OA would be with regards to honey.
> 
> ...


Good morning, I am new to all this. Could someone please explain all this in laymens terms. I'm just an old retired Marine, so try not to use big words LOL. Thank you


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## bricknerdn (Dec 5, 2020)

crofter said:


> That is good to hear. OA usuage with honey supers on has be allowed in many european countries for quite a while. The stipulation that it not be so ruled here was supposedly to expedite the approval process by removing the need to provide the independent testing and documentation mandated by the process.
> 
> Most people that you got flack from was not on whether or not it was safe but you certainly did get pushback for promoting the flaunting of the usage recommendations on a public forum. The pressure on the regulatory process has to be applied in the proper places or it can easily be counterproductive. Anyways that is only a bit of history.
> 
> The next thing we can look forward to which is also probably only a matter of time is the use of oxalic acid and glycerine solution suitable matrix placed on frame tops. Randy Oliver Scientific Beekeeping is doing approved testing similar to approved applications in use in South America and I believe also in Europe. The lifting of the cautions of OA vapor use can only improve the view on the OA/GLY contact applications. Timely too since bees in many areas are demonstrating tolerance to Apivar.


The sad part about Randy Oliver's efforts is that very few additional entities have obtained EPA permits to do field trials on the OA/glycerine shop towel method to validate everything Randy has seen. The persons at the top of that permit chain here in Tennessee could have encouraged such trials as I know several commercial beekeepers who have a sufficient number of colonies to perform valid tests and are willing to do it, but all we get from them is talk and no action.

As a scoffaw who has three successful years with no summer or winter losses due to mites, I can attest to the effectiveness of the OA/gly method. Average mite count for all my colonies the last 3 years is .7 mites/100 bees.

Using three 12 gram applications per season, if all of the OA had ended up in the extracted honey, that only amounts to .3 grams per pound. The EPA was correct in not applying a tolerance limit with the natural levels of OA seen in many of our vegetables.


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## psm1212 (Feb 9, 2016)

jimpart said:


> Good morning, I am new to all this. Could someone please explain all this in laymens terms. I'm just an old retired Marine, so try not to use big words LOL. Thank you


jimpart:
As someone who has had a military career, you should be able to understand all of the federal rule-making-double-speak jargon! Kidding.

Oxalic Acid Dihydrate was approved as a miticide by the EPA in 2015. The EPA approved the label requirements for registered OAD products. Among the limitations of use on the label was the condition that honey supers must be removed from hives prior to treatment.

Now, the reality of what was going on is that most beekeepers did not use the registered product with the label. They were using wood bleach from hardware stores which we believed was essentially the identical compound. However, this was (and remains) an illegal use of OA as it was not a registered product. So that is part of the confusion.

For those that sought only strict compliance, they purchased the registered product with the label and used only in accordance to the label. It has long been suspected, and often stated on this board, that the requirement of removing honey supers prior to treating was not necessary. That OA, which is naturally found in plants and foods (and even honey) could not be harmful to honey in hives.

Last week sometime, the EPA release what it called a "Final Rule" that will effectively remove the requirement of honey super removal prior to treatment with OA.

The discussion you have been following has largely been trying to understand the breadth and scope of this recent EPA ruling. From my understanding right now, which is subject to change and should not be read with any high regard, I believe the following points to be true:


The only legal use of Oxalic Acid Dihydrate is still limited only to the registered, labeled product.
Oxalic Acid Dihyrdrate has not been declared by the EPA as "Generally Recognized as Safe" (GRAS) compound. So we may NOT use this compound as we find it labeled for wood bleach in hardware stores.
The EPA is changing the label to reflect that removal of honey supers prior to use is no longer necessary.
ONCE YOU PURCHASE REGISTERED PRODUCT WITH THE NEW LABEL, you may legally use that product with in your hives with honey supers in place. (I will certainly get pushback on this last one)


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## Surviving Our Bees (Feb 14, 2021)

Api-Bioxal (Oxalic Acid)


Buy Api-Bioxal (Oxalic Acid) at Mann Lake. Best & Biggest Beekeeping Supplier - Best Service.




www.mannlakeltd.com





Above is the "approved" OA.


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## crofter (May 5, 2011)

$ Can 18.95 for 2.2 lb. bottle Canadian compliant. Innisfil Beekeeping Supply. Cheaper than hardware store generic.


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## msl (Sep 6, 2016)

__





What Does The New Ruling On Oxalic Acid In Honey Mean? – Bee Informed Partnership







beeinformed.org





I love that they put so much focus on the EPA label being the law, while showing picture of someone using unlabeled wood bleach that is illegal to use in the 1st place
*facepalm*


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## msl (Sep 6, 2016)

Offical EPA statment 


Oxalic Acid FAQ's : USDA ARS


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## psm1212 (Feb 9, 2016)

msl said:


> Offical EPA statment
> 
> 
> Oxalic Acid FAQ's : USDA ARS


Well, there you have it. All my questions answered. Thank you for sharing that msl.


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## clyderoad (Jun 10, 2012)

msl said:


> Offical EPA statment
> 
> 
> Oxalic Acid FAQ's : USDA ARS


Straight from the horses mouth. 
Just what I have been waiting for and glad I did, thanks for the link..


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## grozzie2 (Jun 3, 2011)

link deleted, already covered


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