# Why are beekeepers not all using vaporized oxalic acid to treat varroa mites?



## rsjohnson2u

Well, it's illegal comes to mind, first and foremost.


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## RayMarler

Does not being "approved" for beekeeping uses make using it illegal? I would think not, but I'm not a lawyer or legal consult.


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## rsjohnson2u

I'm not either. Not approved=illegal will be a personal choice. We beeks seem to scream bloody murder when someone uses pesticides off label near bees, however. A devil's advocate might say "what's the difference, really?" Just because there's no bag limits or open/closed season for some species of fish and game doesn't make it legal for me to hunt and fish them, at least in my state.


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## BeeGhost

Its not legal to use is the only reason that a bee keeper wouldnt use it. I tend to speed, not fully stop at STOP signs, not use my turn signal all the time and I also talk on the phone while driving................and I also use OAV with good results. Am I worried about contaminating my honey............not at all. Id be more worried about the bees working Oleander and poisoning me than OAV.

As for pesticides killing my bees............I would rather use OAV which is SAFE for all stages of bees than to dust with Sevin!!


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## sqkcrk

1. All beekeepers don't do anything the same.
2. Education
C. Another new thing to learn how to do.
4. Gotta buy a new toy to be able to use the OA.
5. It can be dangerous if not handled properly. So some folks may be concerned enough not to use it.
6. Not approved for use in beehives, which will keep some from using it.
7. There are so many other miticides on the mkt easier to use.
8. Beekeepers can be independent minded.


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## Brad Harrison

Oh so its basically red tap. I looked it up and there seems to be no money in it for anybody so no company wants to spend the money to have it aproved by the government. I think dusting your bees with powdered sugar was or is also illegal for mite treatment. 
Well then I wasn't treating for mites I was just vaporizing oxalic acid to listen to my bees buzz, and if I was to take the time and effort to dust with powdered sugar, than I was just trying to sweeten them up a bit as they can get mean when your going through the hive. 
If that ticks you off than I hope you don't ever speed going down the road because that's illegal as mentioned above and proven to be hazardous for yourself as well as for others in the vehicle and those on the road with you.


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## sqkcrk

Brad, it costs millions of dollars and years of trials and studies to get a product approved and registered as a Pesticide. There isn't enough profit in it for the manufacturer. If OA were approved as a pesticide, or powdered sugar for that matter, then all OA and powdered sugar would have to be labeled as a pesticide. I don't think anyone in the OA and powdered sugar industries wants that.

So it isn't red tape at all, it's business.


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## BooneCtyBeek

Mark,

I believe OA has been approved for and used in Canada and Europe for quite some time (and they are more strict with pesticides, et. al. that the USA is). On the outside chance you might know, is OA labeled as you described in those areas?

For those interested, Randy Oliver's site scientificbeekeeping.com has a wealth of information on OA treatment.


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## Daniel Y

rsjohnson2u said:


> Well, it's illegal comes to mind, first and foremost.


Can you show on instance that anyone was prosecuted for using it?

I assume you are not a lawyer and neither am I . but here is a different take on the issue.

It is perfectly legal at least as far as I can tell to kill your own bees. I found this out by looking into if it is illegal to poison bees if they are in your house. it is not in that case. In fact from what I can tell if they are your bees you can do with them as you wish. I found nothing that distinguished between being yours because they are in your hive or being yours because they are in the walls of your house.

So although it would be illegal to use a pesticide in a manner that kills someone elses bees. it would not be illegal to use that same pesticide in the same manner if it only killed your bees.

So the use of OA as a pesticide. Is it in fact illegal to use it on your bees in a manner that will only treat your bees?

I understand the issue goes beyond these concerns and includes issues like what is being put in a hive that is used to produce a food product. The bees forage in the area where all pesticides are likely to be used. Adding OA to a hive arguably does not make much of a difference. It will mingle with the Round Up and Seven just fine.


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## JRG13

I thought approval was pending here in the U.S. It's an off label use which falls into that legal area which does make it illegal to use that way if you're talking pesticides, but if you're just bleaching your frames and the inside of your hive boxes, well, that's another story isn't it.


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## crofter

Being in Canada I can use it without feeling naughty in any way. It works well. I doubt there are very many bee inspectors that are working to the letter of the law on OA unless you have been diddling them around over one of the reportable diseases.


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## snl

Daniel Y said:


> So the use of OA as a pesticide. Is it in fact illegal to use it on your bees in a manner that will only treat your bees?


Per the EPA, OA is no longer registered as a pesticide. The company or companies that originally registered it as such let the registration expire. So OA right now is just OA. Using it as a mite control is an "off label" use of the product regardless that it works and is used successfully almost worldwide.


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## JWChesnut

Oxalic can be hard on bees and queens. I've posted the mortality curve before, so won't repeat myself. It is possible (in careless application) to OD the bees and possible to damage the queen. The minimum effective dos to damaging dose ratio is narrow.

The standard Oxalic use case has changed from once a season to a 3 week course of periodic treatments. This is because of the lack of efficacy under capped brood. The repeated treatments makes the queen death and OD more likely, and raises the labor cost.

Oxalic is irreversible, once applied the crystals reconstitute on the hive.

Formic penetrates caps, and in the case of OD, the hive can be ventilated (and the fumigant removed).


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## camero7

1. All beekeepers don't do anything the same. Agree
2. Education
C. Another new thing to learn how to do. Doesn't take long.

4. Gotta buy a new toy to be able to use the OA. Fun part of OA

5. It can be dangerous if not handled properly. So some folks may be concerned enough not to use it. I really think this is overblown. I've been using it for 6 years on all my hives in the fall. never had a problem.

6. Not approved for use in beehives, which will keep some from using it. So are shop towels.

7. There are so many other miticides on the mkt easier to use. I found OAV the easiest of all of them. 60 seconds or so per hive, no lifting, bees aren't disturbed much and no brood/queen damage

8. Beekeepers can be independent minded. Amen


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## peterloringborst

The following may shed some light on why the vapor is not more widely adopted: it appears to be no more effective than the trickle, and is much less safe for the operator:



> A review article by Rademacher and Harz (2006) summarizes over 50 references related to the use of OA in European countries. Their review article covers the efficacy of OA against Varroa and honey bee tolerance for the trickling, spraying, and evaporating application methods. The trickle and spray methods of OA application were employed in my dissertation research. I chose to exclude the evaporation method due to inherent hazards to the applicator. When OA sublimates, both OA and formic acid fumes are liberated and can permanently damage lung tissues if inhaled. Furthermore, the European literature regarding OA efficacy indicates that the trickle, spray, and evaporation methods of application are equally effective against Varroa mites.


Aliano, N. (2008). An investigation of techniques for using oxalic acid to reduce Varroa mite populations in honey bee colonies and package bees.


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## snl

"Furthermore, the European literature regarding OA efficacy indicates that the trickle, spray, and evaporation methods of application are equally effective against Varroa mites."

That's probably true in a broodless hive, but the trickle method does damage brood, OA vaporization does not.


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## peterloringborst

snl said:


> That's probably true in a broodless hive, but the trickle method does damage brood, OA vaporization does not.


It's my understanding that oxalic is used during broodless periods since it cannot kill mites inside the brood cells. What evidence do you have of brood damage using either method?


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## snl

peterloringborst said:


> What evidence do you have of brood damage using either method?


Per Randy Oliver:
Asking around, the jury’s still out, in my opinion as to whether OA summer treatment is worthwhile, due to relatively low efficacy, and demonstrated damage to the brood (see below). The later in the season, and the smaller the brood nest, the more effective the treatment is. In the short term, though, it sure causes a major drop of mites!
*Does It Harm The Bees?*
Ellis and Aliano found that OA is about 70 times as toxic to mites as it is to adult bees—which is a much greater spread than with either thymol or formic acid. The bees normally do not react defensively to being dribbled with syrup, but on rare occasions run out the entrance for a while. Occasionally one will notice a little adult bee kill after oxalic treatment. Adult bee kill does not seem to be an issue. However, there are questions about subtle effects, larval kill, and lasting suppression of brood development.
As far as winter broodless dribbling, it is absolutely critical to treat them only once, with exactly the right amount and concentration of OA. More than one winter treatment clearly hurts the bees. Charriere and Imdorf (2002) found that colonies treated with 5-6 ml/seam of 3% OA were only 85% the strength of controls by April 25. The best review is in Anonymous (1999). Typically, winter bees treated with OA start out a little slower, but catch up by the end of March.

There is more on his website.


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## jim lyon

We used an oxalic trickle this spring on check backs at the 3 week mark after queen removal. They typically had 3 to 5 frames of open brood when treated. A month later these 10 frame singles were wall to wall brood. I wasn't gauging against control hives, of course, but it seemed a typical build up to me based on what we have experienced in previous years when we elected not to treat at that stage. I realize there is research out there apparently proving a reduction in brood volume. I won't dispute there are probably scenarios where this is true but I really wouldn't use it as an excuse not to use oxalic if you feel your mite numbers are high and you have a good treatment window. I have also experimented with trickling several times throughout the summer but I'm not sure it really had much meaningful impact on mite numbers. 
To answer the Question posed in the OP? I don't vaporize (sublimate) because trickling is so fast, cheap and effective. We do pallets of 4 singles in about a minute and doubles in a couple minutes and don't have to worry about a breathing apparatus or worry about which way the wind is blowing. Also no need to seal up the entrance and any other openings for a prescribed length of time. My question is why isn't everyone trickling in the fall or 3 weeks after a brood break?


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## sqkcrk

jim lyon said:


> My question is why isn't everyone trickling in the fall or 3 weeks after a brood break?


Now you are getting a little too personal there Jim. lol

Other friends who do also ask that question. Something for me to look into and get on board with. Folks I know w/ strong colonies when it comes to going to amonds mite treat when honey is stripped off in the fall and then trickle treat when they get the hives south for the winter.


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## sjj

Brad Harrison said:


> ... from what i can tell. Very effective, cheap, don't have to worry with contamination of my honey or wax, doesn't kill bees, its simple and easy and mites dont become resistant to it. ...


From what I can tell these presuppositions are not true. 
Cheers!


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## snl

sjj said:


> From what I can tell these presuppositions are not true.


Saying that is one thing, backing it up with research is another.......where is yours?


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## peterloringborst

I wrote:


> What evidence do you have of brood damage using either method?


Response:


> There are questions about subtle effects, larval kill, and lasting suppression of brood development.


Me: I know, _that is my question._ Again, no evidence is provided.


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## peterloringborst

> Liebig (1998) quantified the impact on colonies when
> applying OA solutions with concentrations greater than 5% and described significant
> adult bee mortality, poor over-wintering ability, and impaired spring development.
> 
> A single autumn spray treatment using a 3.0% OA sugar water solution (1:1
> by weight) and doses of 3-4 mL per comb side provided efficacies of 97.3 to 98.8%
> (Charrière et al. 2004, Imdorf et al. 1995). These doses were tolerated well as none of
> the experimental colonies lost their queen and adult bee mortality was not significantly
> increased.
> 
> There are several accounts in the literature of
> increased adult bee mortality as a result of OA application within hives (Charrière and
> Imdorf 2002, Imdorf et al. 1998), suggesting that OA may not exhibit its lethal effect on
> honey bees until more than 24 h after exposure.
> 
> I conclude that repeated applications of OA did not significantly reduce Varroa
> mite populations in honey bee colonies when brood was present. My results confirm the
> observations that OA is less effective when significant brood is present (Fuchs 1990,
> Gregorc 2001).


Aliano, Nicholas, "An Investigation of Techniques for Using Oxalic Acid to Reduce Varroa Mite Populations in Honey Bee Colonies and Package Bees" (2008). Dissertations and Student Research in Entomology.


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## mdax

Thanks for the Gregorc reference, found the article here 

(http://www.apidologie.org/articles/apido/pdf/2001/04/gregorc.pdf)

I'd love to read other studies related to vaporized oxalic acid treatments.

The only reason oxalic acid isn't a legal miticide is there is no money in it for anyone. Are we really supposed to obey purely because it won't make someone rich? 

There are many things that are technically illegal, in my state cohabitation without being married and kissing my wifes breasts put me in the law breaker category...I'm an unrepentant serial offender....


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## Mbeck

jim lyon said:


> My question is why isn't everyone trickling in the fall or 3 weeks after a brood break?


Those things don't naturally occur here. I know how to create a brood break, but have no idea what Fall is!


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## Michael Bush

>Why are beekeepers not all using vaporized oxalic acid to treat varroa mites? 

1) You are trying to solve a problem I don't have.
2) It will disrupt the microbes in the colony.


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## snl

Michael Bush said:


> >
> 2) It will disrupt the microbes in the colony.


I'm sure it does, but I'm also quite sure that they (microbes) recover very quickly from how the hive responds after treatment...which is very good..


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## snl

peterloringborst said:


> I wrote:
> Me: I know, _that is my question._ Again, no evidence is provided.


More from Randy Oliver's site regarding dribbling of OA:
Hatjina and Haristos (2005) is the only study I’ve (Randy Oliver) found that reports significant problems to brood development following OA dribble. The authors recommend against summer treatment. The study was performed in Greece, “during the summer, between honey flows.” A question that is begging to be answered is: whether OA efficacy or brood mortality is affected by the amount of nectar flow during treatment.


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## KQ6AR

What, you guys have mite problems? = reason #2


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## Brad Harrison

Well I don't know about research on bee mortality, brood mortality using vaporized OA. What I do know is I treated my hive that had mites a little after thanksgiving and afterwards had a lot of dead mites and no dead bees. The treated hive survived winter and was able to build up rapidly this spring and swarmed twice in April. I've inspected brood last week and have not found any mites in the original hive or the swarm hives that came from the original treated hive. I am pretty sure the mites are harder on the hive than me treating a hive with vaporized OA. I do know if I was to decide to treat this fall it would be at a cost of a few cents and would be quick and easy.


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## drtoddh

It is not illegal to use OA just because it is not approved for that particular purpose. We do it all the time in medicine. We know things work, we have studies to back them up, but our burdensome regulatory process makes it cost prohibitive for a drug company to go back and seek new indications for medicines. A small company making Oxalic acid certainly would not have the upwards of a billion dollars needed to grease the palms through the regulatory process. Take Ambien ( a sleeping pill ) for example, it is indicated for "short term treatment of insomnia" generally up to 10 days. We all prescribe Ambien longer, we know it's safe and it works. The drug company is not going to spend hundreds of millions of dollars to get an indication for "chronic insomnia treatment" when they have a limited patent time on a medicine. What they did was tweak the formulation, call in Ambien CR and this "new medicine" is indicated for "chronic insomnia." Physicians don't get put in jail for using regular Ambien for chronic insomnia (it's cheaper for the patient). The only time it comes into play is if a trial lawyer uses it to make you look like you don't know how to prescribe things to an uneducated jury. I would bet a huge percentage of anyone reading this is on a medication "off label" for something. 
I use OA off label. There's plenty of literature to support that it is safe and effective. No company is going to spend the millions to get the indication as a mite medication and subject themselves to the regulation of it. Especially when it is so cheap and so many companies make it.


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## Daniel Y

According to the illegal interpretation it would be illegal to water your lawn since doing so will surely kill insects making the water an insecticide that is not labeled for use as such.

I have a different interpretation and that is any product that is packaged and market as an insecticide is required by law to have a label and instruction as to how to safely use it. and by law those instructions must be followed. Not everything that will kill bugs is considered an insecticide, marketed as such or regulated as such.

I can think of many things used as an insecticide that are not marketed or labeled as such and no one makes a fuss about it. Tobacco leaves soaked in water is one example. used all the time, effective and unregulated.

I think the entire illegal thing is a bunch of garbage. Maintained by those that have a financial issue in other more expensive forms of treatment.


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## BernhardHeuvel

sjj said:


> From what I can tell these presuppositions are not true.


:thumbsup:

Here comes some practical experience from Europe. 

It is a cheap treatment, true. But it also is very time consuming, for example in comparison to dribbling. (At least if you do it right.) You need one minute for the device to heat the oxalic acid, four minutes for the acid to vaporize, another minute to let it cool down again a little before recharging the oxalic acid. You need to close up and open up each and every hive. I can do way more hives per hour when dribbling. 

It is not very safe for the user so more precautions have to be made. 

Oxalic acid does harm the guts of the honeybees and brood. Also it softens the chitin skin of the bees.

The dribbled oxalic acid is already liquid and the drops do not wet the whole hive. While the vaporized crystals contaminate the complete hive. The crystals do not break down as fast as liquid oxalic acid does. 

When dribbling for winter treatment, you dribble only one time. While with vaporizing it needs at least two to three times.

It is not as failsafe as you think. The oxalic acid must not be overheated. If the heat used is too high or too low, it doesn't kill mites properly. Ambient air temperature and humidity also makes the results vary. Winter cluster tightness, presence of brood and ventilating bees also are possible reasons for a fail.

All in all vaporized oxalic acid is not as quick and dirty and not as failproof as I need it to be.


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## BernhardHeuvel

http://www.beesource.com/forums/sho...brood-or-the-queen-quot&p=1066491#post1066491


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## firefly22

Michael Bush said:


> >Why are beekeepers not all using vaporized oxalic acid to treat varroa mites?
> 
> 1) You are trying to solve a problem I don't have.
> 2) It will disrupt the microbes in the colony.


Michael, I realize this was some time ago but I am working on ways to fight the mite with no chemicals. I am wondering what ur take is on this treatment? I know u don't have the issue due to cell size but for us new beeks who do have and are so green its hard to keep putting money into saving a dying bee hive each year.


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## Harley Craig

If you raise whitetail deer or even goats for that matter here in the US ALL medication / treatments have to be used off label, using stuff off label doesn't make it illegial unless there is some specific law preventing it specifically


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## Rader Sidetrack

> using stuff off label doesn't make it illegial unless there is some specific law preventing it specifically


There is indeed a law regulating 'off label' use of pesticides, its called the *Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), *administered by the EPA.


Under FIFRA, 'off label' use (_using a product in a manner inconsistent with the product label_) of pesticides is a violation of federal law. More on FIFRA here:
http://www.epa.gov/oecaagct/lfra.ht...l Insecticide, Fungicide, and Rodenticide Act


Note that true 'medications' are _not _pesticides, but are _drugs _and instead fall under FDA (not EPA) regulations.


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## Harley Craig

Rader Sidetrack said:


> > ousing stuff off label doesn't make it illegial unless there is some specific law preventing it specifically
> 
> 
> There is indeed a law regulating 'off label' use of pesticides, its called the *Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), *administered by the EPA.
> 
> 
> Under FIFRA, 'off label' use (_using a product in a manner inconsistent with the product label_) of pesticides is a violation of federal law. More on FIFRA here:
> http://www.epa.gov/oecaagct/lfra.ht...l Insecticide, Fungicide, and Rodenticide Act
> 
> 
> Note that true 'medications' are _not _pesticides, but are _drugs _and instead fall under FDA (not EPA) regulations.


. 


That very well could be, but it is my understanding (and I could be wrong ) that it would only apply to pesticides marketed as such it is also my understanding that that OA is marketed as wood bleach and is mot listed as a pesticide so it would not be covered by that act and if it was is the case it would also be illegial to use soapy water to kill bugs or a magnifying glass to fry ants


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## peterloringborst

Harley Craig said:


> .
> 
> 
> That very well could be, but it is my understanding (and I could be wrong ) that it would only apply to pesticides marketed as such it is also my understanding that that OA is marketed as wood bleach and is mot listed as a pesticide so it would not be covered by that act and if it was is the case it would also be illegial to use soapy water to kill bugs or a magnifying glass to fry ants


I obtained a license to apply pesticides as part of my job at Cornell University. This was required because I was 1) applying legal pesticides to bees at the University and 2) because I was at an educational institution. The laws vary from state to state, but basically a pesticide is anything you use to kill pests. So, yes, soapy water would be considered a pesticide under that definition. However, there is another aspect to this: no one would be cited for using soapy water as there is no danger involved. 

The danger is when people used untested chemicals for untested purposes. This can lead to injury and death, under certain circumstances. Obviously not soapy water, but there are countless examples. That's why these laws are written. Additionally, if you are producing a food product (honey) it behooves you to follow the law even if it seems stupid, to protect yourself and your customers. 

For example, if you pour oxalic acid on your bees, are you sure somebody eating the honey won't get hurt from residual acid? Or crude thymol? That's why carbolic acid is no longer approved for taking honey off, too much would wind up in the honey. But I know lots of beekeeper who still use it. A lot of beekeepers are scofflaws. Too bad, because that can give honey in general a bad name.


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## Harley Craig

FWIW I don't use it so I don't really have a dog in this fight, but it is interesting none the less. I read where it is approved for indoor use as a pesticide and as for disposal it breaks down when exposed to sewer water both aerobic and anaerobic in less than 24 hrs so poses no threat to the enviroment, so like soapy water it may be technically illegal, but I can't see it posing a threat. One of my favorite wild edibles lambsquarter is high in oxcalic acid and it has been consumed for centuries


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## Daniel Y

Just to broaden the subject a bit. If it is illegal to use home made concoctons as pesticides explain this.

http://www.motherearthnews.com/organic-gardening/homemade-pesticides-zmaz80mazraw.aspx#axzz34hzpBMp7

Not in searching for this I also found out that it is clearly and abundantly notes that it is illegal in the UK to make homemade pesticides. As far as I can tell it is not in the US or most other countries. In fact this article and many more like it make it clear it is not only legal it is common.

I seem to recall someone mentioning the Garlic thing on this site a year or two ago.


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## snl

Per the EPA, OA is no longer a pesticide. The company or companies that originally applied for it's use as a pesticide, let the application lapse. 

If I were a commercial beekeeper, I'd use the trickle method as vaporization in their environment just takes too long. As I hobbyist, working alone, I prefer the vaporization method. 
As far as safety, those who vaporize and follow the instructions on it's use and utilize safety precautions, will have not problem.


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## camero7

> I seem to recall someone mentioning the Garlic thing on this site a year or two ago.


Dave Miksa uses a garlic preparation for mites.


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## Jim 134

Do you realize Adee honey farms use a unapproved chemical in their hives about 3 to 5 years ago and got fine about $13,000 for doing it. 




BEE HAPPY Jim 134


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## sqkcrk

But it wasn't OA, it was an off label use of a registered pesticide, amitraz.


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## snl

And Jim,
OA is no longer a pesticide.............


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## Daniel Y

Jim 134 said:


> Do you realize Adee honey farms use a unapproved chemical in their hives about 3 to 5 years ago and got fine about $13,000 for doing it.
> 
> 
> 
> 
> BEE HAPPY Jim 134


Yes I do, And as is mentioned above it was due to an off label use of a pesticide. OA is not a pesticide any more than powdered sugar is. so if you are correct everyone dusting their bees with powdered sugar is just as illegally applying a pesticide to their bees. It is being applied for the sole and direct purpose of killing mites. But it does not make it a pesticide. and applying OA to a hive for the specific purpose of killing mites does not make it a pesticide either. And just because you think OA is worse than powdered sugar (hydroxymethyloxolan) does not make you right. I say it is the same thing different names.


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## Jim 134

Do you even know that the state laws are for beekeeping in the state where you live ???


One thing I do know in the state where I live which is New Hampshire it is off label these laws have been changed just about a year ago if you would like I can look them up for you. I will try the last time I did about 3 months ago the website was down for repair.
As far as a chemical company goes if it is not being used according to the label it is against the law.

BEE HAPPY Jim 134


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## Daniel Y

Note the comment under executive summary for OA on this document.

http://www.epa.gov/opprd001/inerts/oxalicacid.pdf

I have another document I found that explains how this exemption came about.
http://www.epa.gov/oppsrrd1/REDs/factsheets/4070fact.pdf

In short this document exempts OA from regulations regarding pesticides. As long as application does not exceed 2 lbs per acre. Note it not only refers to crop application but Raw Agricultural Products.


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## Rader Sidetrack

The first EPA document linked in the post above (and relinked here) does _not _exempt oxalic acid from regulations regarding pesticides. It clearly references the use of oxalic acid when used as an *INERT *component of pesticides. Clearly using oxalic acid vaporization or dribble method in varroa control would not qualify oxalic acid as an *inert *ingredient.


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## melliferal

peterloringborst said:


> The danger is when people used untested chemicals for untested purposes. This can lead to injury and death, under certain circumstances. Obviously not soapy water, but there are countless examples. That's why these laws are written. Additionally, if you are producing a food product (honey) it behooves you to follow the law even if it seems stupid, to protect yourself and your customers.


Bottom line, for me. We're talking about a chemical I'm unfamiliar with. Once it becomes approved, that means scientific questions like contamination risk and maximum safe dosages have been studied and addressed in a standardized way. 

I'm not risking contaminating other people's food purely on some assurance from a guy down the road who swears it works. There's people who swear that little copper bracelets cure arthritis and they're wrong.


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## melliferal

Daniel Y said:


> Yes I do, And as is mentioned above it was due to an off label use of a pesticide. OA is not a pesticide any more than powdered sugar is. so if you are correct everyone dusting their bees with powdered sugar is just as illegally applying a pesticide to their bees. It is being applied for the sole and direct purpose of killing mites. But it does not make it a pesticide. and applying OA to a hive for the specific purpose of killing mites does not make it a pesticide either. And just because you think OA is worse than powdered sugar (hydroxymethyloxolan) does not make you right. I say it is the same thing different names.


Well now wait - maybe, maybe not. I could be wrong, but it's not my impression that the reason powdered sugar isn't considered a pesticide is because the sugar doesn't actually do anything to the mites, it just prompts grooming behavior in the bees who end up pulling the mites off of each other as they groom. Please correct me if my impression about the use of powdered sugar is incorrect.

What is the exact mechanism by which the oxalic acid is supposed to eliminate mites? If the chemical itself is supposed to attack or affect the mites directly in some way, then yes it is most assuredly being used as a pesticide.


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## jim lyon

Frankly I could care less what the EPA designation is, I just think it annoys a lot of people who are fundamentally opposed to mite treatments per se that there could be a compound this cheap, safe and effective available that has NEVER been found to contaminate any hive product nor has there ever been any sort of legal repercussion for anyone that has used it. I have discussed its use with any number of bee inspectors and I have yet to find one concerned about its use. Be opposed if you wish, I totally get that, but let's not equate folks who choose to use it as doing some sort of illegal activity when no one or nothing is harmed. If you are opposed to dribbling a couple of tablespoons of a mild OA solution on a bee hive are you also opposed to putting a handful of dried oxalis or spinach leaves in your bee smoker? Who is hurt by this?Doesn't criminal activity require a victim?


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## sqkcrk

Jim 134 said:


> Do you even know that the state laws are for beekeeping in the state where you live ???
> 
> 
> One thing I do know in the state where I live which is New Hampshire it is off label these laws have been changed just about a year ago if you would like I can look them up for you. I will try the last time I did about 3 months ago the website was down for repair.
> As far as a chemical company goes if it is not being used according to the label it is against the law.
> 
> BEE HAPPY Jim 134


And if there is no label describing its use as a pesticide is that against the law? If there is no label describing its use as a pesticide how can using it as a pesticide be off label?


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## sqkcrk

melliferal said:


> I'm not risking contaminating other people's food purely on some assurance from a guy down the road who swears it works.


Fine. No one will make you use it. OA is best used when all of the honey supers are off the hive and when using OA vapor when there is no brood, both of these situations meaning in the Fall. So, there is going to be three or four or six months before any honey production occurs again. Therefore, how is OA going to get into any harvested honey?


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## wildbranch2007

sqkcrk said:


> Fine. No one will make you use it. OA is best used when all of the honey supers are off the hive and when using OA vapor when there is no brood, both of these situations meaning in the Fall. So, there is going to be three or four or six months before any honey production occurs again. Therefore, how is OA going to get into any harvested honey?


since there is no label, what makes anyone think that it will only be used properly(not sure properly is the correct word) as there is no label to tell you how to use it properly:scratch:


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## sqkcrk

Nothing. But that happens all the time w/ properly labeled pesticides all the time. People do what needs doing when they can, not always at the proper time. I saw some folks pruning apple trees when the trees were in full bloom one time. That didn't seem to me to be the proper time. It was when they could do it though. So I guess it was the proper time.


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## Daniel Y

Rader Sidetrack said:


> The first EPA document linked in the post above (and relinked here) does _not _exempt oxalic acid from regulations regarding pesticides. It clearly references the use of oxalic acid when used as an *INERT *component of pesticides. Clearly using oxalic acid vaporization or dribble method in varroa control would not qualify oxalic acid as an *inert *ingredient.


Start on Page 3 and read under executive summary. if you also continue reading the document you will see that it is an exemption of OA up to a certain application limit of 2 lbs of OA per acre. Nowhere in that exemption does ti say it is exempt if used as an inert ingredient. It only recognizes that use as an inert ingredient is on the list of it's uses. Notice it is also recognized as a product used by veterinarians so they are hardly ignorant of it's other uses while making this exemption.

Basically they are stating there known uses for the product so if later someone wants to come along and say. Hey they use it to gas mites on bees. they can look and say. nope we did not consider that application. Maybe we should reaccess.

Given the descriptions they use and still exempt it from regulation I do not suspect use on Honey bees will prompt such an assessment.


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## Daniel Y

I cannot copy and paste from teh document so I am retyping the quote here.

Executive Summary (meaning a summurization of the entire document, its findings and it's conclusions)

_This report evaluates Oxalic Acid, A Pesticide Inert Ingredient._ (note, this declares OA to be an inert ingredient. not that it is limited to or that it's use as an inert ingredient is subject to this exemption. It is exempt because it is considered an inert ingredient even if it is used in it's raw form)
_for which an exemption from the requirement of tolerances exists for it's residues when used in Pesticide formulations._

If you read the entire document you find they exempt it because it's residues cause no harm. Still they put a limit on the volume or quantity of OA that is exempt. over that limit and it again may be subject to regulations.

You could also argue that it is only exempt if used as a pesticide for crops. that is not what it is saying the document mentions many uses for OA including uses in medicine. Nowhere does it make an exception to this exemption for any of it's recognized uses.

Basically if you went to the EPA and said. Hey that guy is using OA on his bees. they would say we don't care.

Now I realize many think otherwise. What they do not seem to understand is I don't care what they think. Post documents supporting your argument. Show me on instance where anyone was even investigated for using OA on bees much less prosecuted for it. Show me one document that states it is illegal to use at all. Opinion is worthless misinformation and unreliable. I am certain the crystal balls of all those making their most rational guess is cracked. In other words I don't think for a moment all of you combined have enough intelligence to make an accurate guess at it. you want it to be illegal so you declare it illegal. and all you can offer to support that claim is what you think makes since.

Oh no they regulate pesticides. so anything that is used to kill bugs must be a pesticide. 

Okay lets start a campaign to educate everyone on the legal ramifications of dusting bees with sugar. care to take up that argument? if it is in fact illegal to use OA to kill mites then it is just as illegal to use sugar. The only difference is that you think OA is more dangerous for whatever reasons you think that. Others say that sugar kills far more people than OA ever has or ever will. I think both sides are full of it.


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## sqkcrk

Well sure Daniel. But sugar isn't being used as a pest control it is being used as a food, which eventually kills some people who get too much of it, making it a poison.

I agree, every time someone brings up powdered sugar dusting for mite control I think DanielY should remind them that it is illegal to do so because it is an off label use of a product used as a pesticide.


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## Rader Sidetrack

Daniel Y said:


> Start on Page 3 and read under executive summary. if you also continue reading the document you will see that it is an exemption of OA up to a certain application limit of 2 lbs of OA per acre.


Instead of starting on page 3, start reading on *PAGE ONE*! The _entire _document is about oxalic acid *when used as an inert ingredient*. For instance, the 'Subject' line states ...
_"SUBJECT: Oxalic Acid - *Inert *Reassessment (CAS Reg. No. 144-62-7)".
_
Similarly, the 'Action' line is ...
_"Action: Reassessment of one *inert *ingredient exemption from the requirement of a tolerance. Current exemption to be maintained."

_Yes, the document uses the word 'exemption' in connection with oxalic acid, however it is clear that is all a reference to oxalic acid being used as an _INERT _ingredient in a pesticide with some other active ingredient.



_Personally_, I think that vaporization of oxalic acid is likely to be _the most benign_ (from the bees' perspective) of any _effective _varroa control. However, vaporization of hundreds or thousands of hives (commercial beekeeping operation) is too slow to be practical, and the oxalic acid dribble method is more practical on a large scale. However, the dribble method carries a higher risk for the bees' health if it is applied improperly. On the other hand, vaporization, _when improperly done,_ carries a higher risk of health impact to the [human] beekeeper than does the dribble method.

In a more perfect world, oxalic acid would be clearly stated as a legal varroa control under US law. But given the practical reality of how such things work in the current political/legal environment (follow the $$$ money), that has not happened.

.


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## melliferal

jim lyon said:


> Frankly I could care less what the EPA designation is, I just think it annoys a lot of people who are fundamentally opposed to mite treatments per se that there could be a compound this cheap, safe and effective available that has NEVER been found to contaminate any hive product nor has there ever been any sort of legal repercussion for anyone that has used it. I have discussed its use with any number of bee inspectors and I have yet to find one concerned about its use. Be opposed if you wish, I totally get that, but let's not equate folks who choose to use it as doing some sort of illegal activity when no one or nothing is harmed. If you are opposed to dribbling a couple of tablespoons of a mild OA solution on a bee hive are you also opposed to putting a handful of dried oxalis or spinach leaves in your bee smoker? Who is hurt by this?Doesn't criminal activity require a victim?


The idea of fear that people using unapproved products would get in "legal trouble" is entirely an invention of proponents of the products. No, I'm not afraid that the chemical police are going to come and arrest me for using oxalic acid in my hives. I merely have questions that I would like to see resolved in a scientific and objective manner, and I'm not going to use the product until those concerns are satisfied. Once they are, I'll have no objection to using it.

It makes no sense that beekeepers would be opposed to a cheap and functional product because it is cheap and functional; I don't understand what you're saying.


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## snl

melliferal said:


> I merely have questions that I would like to see resolved in a scientific and objective manner, and I'm not going to use the product until those concerns are satisfied. Once they are, I'll have no objection to using it.


Most of the rest of the world has successfully used it for YEARS. The Europeans (and others) have studied it, reported on it and approved its use.


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## melliferal

snl said:


> Most of the rest of the world has successfully used it for YEARS. The Europeans (and others) have studied it, reported on it and approved its use.


That's great, but I don't live in Europe and nor would any colonies I keep.

I'm sure it will only be a matter of time; just like with formic acid. In the meantime there's half a dozen different available mite control treatments and mechanisms to tide us over. Oxalic acid doesn't appear to be all that different from them, inasmuch as the hive has to be treated at least yearly just like with any other method; and despite "YEARS" of "successful" use Europe has not managed to eradicate varroa; so I'm not sure what the dire, urgent rush is for what seems to be just another mite treatment. It'll come soon enough.


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## sqkcrk

A. Who is rushing? What is being discussed is its use, currently.
B. When have we ever eradicated anything? Use of mite control mediums is not to eradicate, but to knock down numbers to a tolerable level.


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## melliferal

sqkcrk said:


> A. Who is rushing? What is being discussed is its use, currently.
> B. When have we ever eradicated anything? Use of mite control mediums is not to eradicate, but to knock down numbers to a tolerable level.


The thread is about why it's _not_ being used by people who aren't using it; both the title and the OP are asking non-users to explain themselves. Given that multiple approved mite treatments already exist which do the same job that oxalic acid is supposed to be doing, I'm questioning why I should be excited enough about this treatment to go ahead and use it despite its not having been approved or evaluated scientifically in the US (since that reason for not using it appears to not be a "good enough" reason in some folks' opinion).


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## sqkcrk

I don't think OA works the same as other miticides. You shouldn't use it until you see the benefit. It is beneficial, it works well. I don't see mites building a resistance to it like they have other materials. That's my opinion.


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## DPBsbees

sqkcrk said:


> I don't think OA works the same as other miticides. You shouldn't use it until you see the benefit. It is beneficial, it works well. I don't see mites building a resistance to it like they have other materials. That's my opinion.


It's also cheaper than any miticide that works.


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## sqkcrk

As inexpensive as it is, if it worked half as well as it does I bet a lot of commercial beekeepers would still use it. For the same reason Tactik is used.


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## DPBsbees

It's major downside is that it only kill the mites on the bees and not the ones on brood. It only works for the ten minutes the vapors are moving around the hive, if you are vaporizing. It also only kills the mites on bees in the hive at that time. This is why many recommend that you use it when brood is low, and most are home. I still think it's a great treatment for heading into winter if you have a mite issue. I takes time. I can do it with my hives, but the time involved would be a burden for commercial guys ( I think, but I'm not one). I wouldn't want to spend 12 minutes a hive if I had 10,000 hives.


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## jim lyon

DPBsbees said:


> It's major downside is that it only kill the mites on the bees and not the ones on brood. It only works for the ten minutes the vapors are moving around the hive, if you are vaporizing. It also only kills the mites on bees in the hive at that time. This is why many recommend that you use it when brood is low, and most are home. I still think it's a great treatment for heading into winter if you have a mite issue. I takes time. I can do it with my hives, but the time involved would be a burden for commercial guys ( I think, but I'm not one). I wouldn't want to spend 12 minutes a hive if I had 10,000 hives.


Good summary. It's no panacea but it is an excellent tool for greatly reducing mite numbers to near zero either in the late fall, early spring or after a brood break. As I stated a loooong time ago in this thread the question to me is why isn't everyone trickling not why isn't everyone vaporizing.


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## sqkcrk

IPM anyone? Like Jim writes, "it is an excellent tool". One of the tools one uses in the control of the target pest, used at the right time of year. A device. Use one miticide, say Apivar, in the Spring, to knock down the mite numbers then so their numbers aren't overwhelming come the peak of the annual varroa mite cycle. Then, when the last honey supers come off, hit them w/ Apiguard, September or October around here. Then ship hives South for the Winter in November when queens in the North have cut back on laying eggs and go through the hives once more dribbling OA to knock down the Adult mites again.

Other types of controls, like MAQS or other forms of control, can be plugged into the rotation where I wrote Apivar and Apiguard. The idea is not to use the same stuff twice in one annual cycle so as not to promote resistance to one material.


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## Ravenseye

I've always been a fan of IPM. Sometimes, I think we project too much into our keeping efforts. When we get an infection, we tend to take one type of pill and it goes away. We're accustomed to a direct cause and effect. As mentioned earlier in this thread, it's not about killing all the mites, it's about keeping them to a tolerable level. I'll save one shot remedies for the bears.


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## Daniel Y

Rader Sidetrack said:


> Instead of starting on page 3, start reading on *PAGE ONE*! The _entire _document is about oxalic acid *when used as an inert ingredient*. For instance, the 'Subject' line states ...
> _"SUBJECT: Oxalic Acid - *Inert *Reassessment (CAS Reg. No. 144-62-7)".
> _
> Similarly, the 'Action' line is ...
> _"Action: Reassessment of one *inert *ingredient exemption from the requirement of a tolerance. Current exemption to be maintained."
> 
> _Yes, the document uses the word 'exemption' in connection with oxalic acid, however it is clear that is all a reference to oxalic acid being used as an _INERT _ingredient in a pesticide with some other active ingredient.
> 
> 
> 
> _Personally_, I think that vaporization of oxalic acid is likely to be _the most benign_ (from the bees' perspective) of any _effective _varroa control. However, vaporization of hundreds or thousands of hives (commercial beekeeping operation) is too slow to be practical, and the oxalic acid dribble method is more practical on a large scale. However, the dribble method carries a higher risk for the bees' health if it is applied improperly. On the other hand, vaporization, _when improperly done,_ carries a higher risk of health impact to the [human] beekeeper than does the dribble method.
> 
> In a more perfect world, oxalic acid would be clearly stated as a legal varroa control under US law. But given the practical reality of how such things work in the current political/legal environment (follow the $$$ money), that has not happened.
> 
> .


Oxalic Acid is Inert. It cannot be used as any other sort of ingredient. So your "AS AN" is miss leading and inaccurate. Such as, Used AS AN Inert ingredient. Correctly and accurate phrased would be. Oxalic Acid IS AN Inert ingredient. This would explain why it is evaluated as an inert, and not as an active or any type of ingredient. IT is not used as an oxidizer, reagent, catalyist or any other sort of ingredient and is not evaluated as such.

I woudl not be connearly as concerned I beleived you where just not aware of these deatils. My problem is I thik you are perfectly aware of them and intentional deceprive in your presentation

Once again I understand your opinion. You seem to fail to understand I find your opinion worthless. Please provide the documents you offered to present indicating anyone being prosecuted or indicating it is illegal to use OA in a hive. That request is not met by siting prosecution for the use of some other product or chemical other than OA. We are not discussing the use of other chemicals. 

Why would I tell people something is illegal when I clearly don't think it is? Are you even paying attention to this conversation? You are the one that thinks adding things to hives that are not an approved pesticide when they are being used to kill mites is illegal. You warn them. That you have to hide behind a lie about what you are really doing to avoid the law. it simply indicates that I am right and you think I am. So call it feeding if you like. that is nothing but a lie that you realize you need to tell to do something you know you shouldn't.


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## Rader Sidetrack

Daniel Y said:


> I woudl not be connearly as concerned I beleived you where just not aware of these deatils. My problem is I thik you are perfectly aware of them and intentional deceprive in your presentation.
> 
> Once again I understand your opinion. You seem to fail to understand I find your opinion worthless.



:lpf:  :s :kn:opcorn: 

I didn't quote DY's entire post - anyone who wants to can go read the entire diatribe in post #76. 

It wasn't me that offered to provide any documents regarding prosecution - I didn't even mention the subject. My point was simply that the EPA documents that DY linked did *NOT *say that oxalic acid was exempt from regulation as a pesticide. That EPA document in its entirety discussed oxalic acid WHEN USED AS AN INERT INGREDIENT as a component of a pesticide that has some other active ingredient.



> Oxalic Acid is Inert. It cannot be used as any other sort of ingredient.


_*Completely wrong*_. Of course oxalic acid can be a pesticide all by itself. It was at one time even _registered _as an approved pesticide. DY himself even linked to that EPA registration document in post #51. While the registration has since expired for non-payment of fees, that does not somehow magically make oxalic acid no longer an active ingredient when used as a pesticide.

As I said earlier, I think oxalic acid is one of the _least harmful_ varroa controls that are actually effective. Anyone who wants to use it should be able to. The fact that OA is not registered as a varroa control isn't something that would stop me from using it if/when I am in a situation where I think it would be a benefit to my hives. 

But anyone that chooses to use OA should at least understand its status as an _unregistered _varroa pesticide. Sticking one's head in the sand doesn't change anything! :no:


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## Daniel Y

Rader Sidetrack said:


> [/I]Yes, the document uses the word 'exemption' in connection with oxalic acid, however it is clear that is all a reference to oxalic acid being used as an _INERT _ingredient in a pesticide with some other active ingredient.
> 
> 
> .


Where, anywhere in the document does it state this. I clearly see where it states that in it's current uses it is used as an inert ingredient. that would be in the present products it is used in. but the exemption is not limited to it being an inert ingredient. OA is exempt up to an application rate of 2 lbs per acre. And that is clearly what it says and how it is phrased. You have to add your words to make your claim it is not anything they say. 

I say start at page 3 because that is where the exemption is declared. starting from the beginning you are reading the history and known uses of OA in various products. as well as an explanation of why an evaluation is even being made.

You then claim that this explanation of its history and use is now conditions applied to it's exemption. It is no such thing. Is is a record of factors that where considered in giving the exemption. Basically they are saying that they already know OA is used for this that and the other thing. And they still give it an exemption.

At most you can say. well they do not indicate that they know it is being vaporized in beehives to kill mites. Okay so inform them. see if they change their mind and decide this suddenly causes OA to be some substance that now requires regulation. Do you really think they are going to be surprised that OA can be heated and vaporized and that somehow they will be caught off guard as to the environmental hazard that now poses? If yo I highly suggest you take action. that is what they and the process is their for. Of course don't be surprised if the process is not exactly what you might expect.


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## Daniel Y

Actually Graham. page one of document one that I linked to states subject as.

*Inert reassessment- Oxalic Acid (CAS Reg. No 144-62-7)* 

Frankly I highly doubt you are qualified to interpreter that much of the document.

Page three which is what i was referring to is a completely different document. That would be why I directed attention to it. so if you want to argue some other document I would l suggest you establish that as the document being discussed and not attempt to be deceptive in your tactics. In fact if your opinion is correct why would you need the added advantage of deception to make it seem accurate? Are you possible more concerned with looking right than you are at accurately information others? I understand that people can simply be mistaken. I do not believe this is remotely true in this case given your past behavior and how you build up evidence for your twisted opinions.

So once again referring to page 3 a seperate document. subject being

Reassesment of One Exemption from the Requiremnt of a Tolerance for Oxalic Acid.

Further this assesment was made by the Inert Ingredient Assessment Branch (IIAP)

Which is the branch that is stated will regulate Oxalic Acid in the first document.

So once again these documents are not referring to regulation of OA when used as an inert ingredient. it is declaring OA an inert ingredient. It then renders a decision in regard to regulation.

And that decisions is found in summary on page three as I directed and posted earlier. Under Executive Summary.

Now I am not able to copy and paste from this document for unknown to me reasons so i am not going to set here and type it word for word. But for the purpose of promoting accurate information I will take the time to do so here. Unlike you who attempts to sight a seperate document to make an argument. I believe for no other reason than to argue and cause disruption.

Quote"
This document evaluates Oxalic Acid, a pesticide inert ingredient for which an exemption from the requirement of tolerance of its residues exists when used in pesticide formulations. (with no more Oxalic acid than is needed to chelate calcium. and no more than 2 lbs per acre) applied to growing crops or Raw agricultural commodities after harvest under 40 CFR 180.910

Now you can look up CFR 180.910 for yourself I have seen enough to consider OA something the EPA is not real concerned about.


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## Rader Sidetrack

> Where, anywhere in the document does it state this ....

You can refer back to my post #63 for my explanation of the inert references for OA in those EPA documents.


When reading those EPA documents linked in above posts, it helps to understand that a substance, in this particular case oxalic acid, can be *inert *in one pesticide formulation and an _active _ingredient in a different formulation. That is touched on in the section titled "Use Summary:" in the first EPA document DY linked earlier, and linked again here. 

In the case of OA vaporization, there is only one ingredient in the pesticide, and OA would be the active ingredient _if _it was a registered pesticide. In the case of OA dribble, OA would still be the active ingredient, but there would also be _inert _ingredients of sugar and water. In the "calcium chelating hard water inhibitor" referred to in the "Use Summary", (linked EPA document - bottom of page 1) oxalic acid is being use to neutralize the negative consequences of "hard water", and is _not _the active ingredient in the pesticide. In that situation, the oxalic acid is considered INERT, but that does not mean that OA is _always _inert.






Daniel Y said:


> I understand that people can simply be mistaken. I do not believe this is remotely true in this case given your past behavior and how you build up evidence for your twisted opinions.



Oh my!! :lpf:  :scratch: opcorn:Too much coffee, or not enough?


:bus


----------



## Daniel Y

melliferal said:


> I'm questioning why I should be excited enough about this treatment to go ahead and use it despite its not having been approved or evaluated scientifically in the US (since that reason for not using it appears to not be a "good enough" reason in some folks' opinion).


Show me where they have approved dusting with powdered sugar. but that argument is even getting tiring to me. they do not run around approving anything. they run around finding those things they say needs to be regulated. and those things they look at and say do not need to be regulated they say nothing about. those things that may need to be regulated but they decided not to they also record.

Things such as water. soapy water and powdered sugar I suspect will never come to their attention. Things such as OA that have been used and are currently used in pesticides they do look at. and they then render a decision in regard to it. In truth they probably have no interest in evaluating anything that is not submitted for evaluation. And since OA is an ingredient in products that have been submitted they have looked at it.

You will never find an approval for use of anything. They are not in the business of approving anything. they are regulating those things they determine need to be regulated. That distinction is important.

So no those reason woudl not be good enough reason because they do not in fact even exist. OA has been evaluated and the applicable regulation is in place. and it is

So is no restriction up to a certain amount (2 lbs per acre) good enough reason for me to use it? yep.

Still nobody has been able to show where use of OA on beehives is prohibited or has been prosecuted.


----------



## Daniel Y

Rader Sidetrack said:


> > Where, anywhere in the document does it state this ....
> 
> You can refer back to my post #63 for my explanation of the inert references for OA in those EPA documents.
> 
> 
> When reading those EPA documents linked in above posts, it helps to understand that a substance, in this particular case oxalic acid, can be *inert *in one pesticide formulation and an _active _ingredient in a different formulation. That is touched on in the section titled "Use Summary:" in the first EPA document DY linked earlier, and linked again here.
> 
> In the case of OA vaporization, there is only one ingredient in the pesticide, and OA would be the active ingredient _if _it was a registered pesticide. In the case of OA dribble, OA would still be the active ingredient, but there would also be _inert _ingredients of sugar and water. In the "calcium chelating hard water inhibitor" referred to in the "Use Summary", (linked EPA document - bottom of page 1) oxalic acid is being use to neutralize the negative consequences of "hard water", and is _not _the active ingredient in the pesticide. In that situation, the oxalic acid is considered INERT, but that does not mean that OA is _always _inert.
> 
> 
> 
> 
> Oh my!! :lpf:  :scratch: opcorn:Too much coffee, or not enough?
> 
> 
> :bus


Graham, try reading it again. Possibly with a bit more understanding of what you are reading. document one determines OA as an inert ingredient.

for your benefit an inert ingredient specifically when applied to pesticides is:

The Federal Insecticide, Fungicide, and Rodenticide Act divides the ingredients in pesticides into two groups: active and inert. An inert chemical, under this context, is one that does not have a toxic effect on the species the pesticide is meant to combat, but that does not rule out that it may still have a biological activity on other species, including being toxic to humans. Solvents, propellents, preservatives, among others, are thus considered "inert ingredients"[1] in pesticides


In document one it is declared Inert (not toxic) and is then then passed on to the inert ingredient branch for evaluation. The inert ingredient branch (document starting on page three) then rendered its regulation. which is none up to an application of as much as 2 lbs per acre. You have to be able to understand the documents to be able to follow the trail. I am obviously attempting to give the highlights here. You either genuinely are missing the trail or are attempting to be disruptive. I have already stated what I believe on that issue.


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## Rader Sidetrack

Daniel Y said:


> for your benefit an inert ingredient specifically when applied to pesticides is:
> 
> The Federal Insecticide, Fungicide, and Rodenticide Act divides the ingredients in pesticides into two groups: active and inert. An inert chemical, under this context, is one that does not have a toxic effect [HIGHLIGHT]on the species the pesticide is meant to combat[/HIGHLIGHT], but that does not rule out that it may still have a biological activity on other species, including being toxic to humans. Solvents, propellents, preservatives, among others, are thus considered "inert ingredients"[1] in pesticides


I agree with your quote from the FIFRA document. But note the part above that I [HIGHLIGHT]highlighted[/HIGHLIGHT]. From that highlighted phrase, it _SHOULD _be CLEAR that INERT status of a given ingredient depends on the particular pest the pesticide is targeting.


When oxalic acid is the active ingredient in a pesticide - such as OA vaporization or dribble, it is not exempt and is subject to EPA regulation. When oxalic acid is merely used to deal with 'hard water' and does not target any pest, _*then *_it is an inert ingredient in a pesticide that has some _other _active ingredient..


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## Daniel Y

Graham, Yet the document being discussed approves application to Agricultural Commodities after harvest. do they think those will not be eaten?

Also notice the expansion on your highlighted portion. they recognize that the same ingredient may be toxic to other organisms including humans. In the case of OA this would have been considered evaluated and the regulation determined.

So at this point you can even claim that OA is poisonous to humans Okay that does not change the regulation. You may think that the inert ingredient branch is not aware of this fact Okay inform them and see it if changes there regulation determination. I suspect that even if it is toxic to humans they will say yeah we know. And we still choose not to regulate its use.

I woudl suspect that the inert ingredient branch exists specifically for this purpose of looking at what other things it may harm. The first evaluation simply determines it is not toxic to the target organism. it then goes to other to do more thorough evaluations. Now that is speculation on my part.

In regard to mites specifically. It is my understanding that OA is not toxic to mites, it does not poison them. it causes a physical injury to them that is fatal. This is not toxic so it is in fact inert even in regard to mites in a honey bee colony. So it does not crate an exception to the stated considerations and evaluation presented in these documents.

No they do not specifically say it is okay to use OA on beehives but notice it does not say it is okay to use it specifically on anything it says it is okay to apply it at a rate up to 2 lbs per acre for agricultural commodities. I doubt it will be some revelation to them to find out bees and honey are agricultural commodities.

Just because you and many other assume some ingredient should be regulated does not mean it is determined to need to be regulated. I realize you think your rational and assumptions are better than their evaluation, I disagree. It was looked at and determined that it does not need to be regulated. Specifically in regard to use as a pesticide. Specifically being applied to agricultural products.


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## Daniel Y

Rader Sidetrack said:


> When oxalic acid is the active ingredient in a pesticide - such as OA vaporization or dribble, it is not exempt and is subject to EPA regulation.



Please explain how the method of application causes the OA to become toxic. SInce inert in regard to pesticides means it is not toxic. yo uare now claiming that it has soemhowe become toxic.

It is my understanding that is not how OA works on mites either with dribble or Vaporization OA does not poison the mites. it causes a physical injury to them that is lethal. That is not an indication of toxicity.

Still I am wondering just how OA became more poisonous when applied to a different target? Or is applied by a different application. When it was never poisonous in the first place.


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## Rader Sidetrack

Daniel Y said:


> So at this point you can even claim that OA is poisonous to humans Okay that does not change the regulation.



:scratch: I made no such claim.


Since you are still having difficulty with the concept of a given pesticide ingredient being considered inert in one formulation and active in a different formulation, I suggest reading the entire EPA page at this link discussing INERT classifications:
http://www.epa.gov/PR_Notices/pr97-6.html

A relevant part of that page ...


> An active ingredient is one that prevents, destroys, repels or mitigates a pest, and each
> active ingredient must be identified by name on the label together with its percentage by weight. An inert ingredient is simply any ingredient in the product that is not pesticidally active.
> 
> http://www.epa.gov/PR_Notices/pr97-6.html


Clearly, by that explanation oxalic acid is an ACTIVE ingredient as a pesticide when targeting varroa. Inded, when using the OA vaporization method, oxalic acid is the ONLY ingredient, so it certainly cannot be classified as inert!

Note the word "repels" as part of that definition. An active ingredient does not even have to kill, injure or damage a pest in any way to still be considered active. I am not defending that definition, simply pointing out what the laws/regulations mean.


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## Ian

jim lyon said:


> the question to me is why isn't everyone trickling not why isn't everyone vaporizing.


trickling at the wrong time tends to hurt the bees. During a time of broodless is best, but conditons usually around those broodless times are harsh, the reason why the hive usually is broodless. If the bees injest the OA rather than distribute it around, it will scorch their stomach which cause problems. Vapourizing tends to side step that problem but the problem with vapourizing is it requires expensive equipment (commercial) and I have been told is very inconsistent. One more tool in our arsenal , yes, but that silver bullet, heck NO

Canada has gone through the process of approving OA as a treatment on honeybee hives. It is used quite a bit up here. Why its not catching on? Apivar still kills mites here...


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## Daniel Y

Graham, 

So you thik that the EPA has determined that OA is Inert. Ignorant of the fact that it is used as the only ingredient when applied to beehives. So there fore it must be an active ingredient and the EPA must be wrong.

If this is so at some point the EPA must have realized their error and corrected it. Can you find any document indicating that is so? Or they are still ignorant of their error and need to be informed of that. I will leave that up to you. let us know what they have to say.

Now I work for the government and I know for a fact that this would not be the most ridiculous thing they have done. In fat it seems pretty normal to me. Being ridiculous does not change that it is the determination. Does it break my heart that they got it wrong. No it does not I don't think the government should be regulating it at all. As far as I am concerned they are a collection of idiots that could not manage to write directions to tying shoes.

I do find it interesting that you will continue to make there conclusions make sense.

So present a document that indicates they ever changed their determination in regard to OA. I know that yours or anyone elses rational would not be applicable. because the determination is not rational. It is what it is and it has been made. And what I have found clearly states that OA is not regulated. Ridiculous or not.

Now I have shown documents where the EPA has determined OA to be an inert ingredient. You disagree. that does not matter. T Hey are the ones that make the determination. You can rant and rave and call them idiots all day long. they don't care. they still say OA is inert. Even if it is the only ingredient being used in a product it is still inert and it's regulation has been turned over to the branch that deals with inert ingredients.

Now why woudl there even be an branch that deals with inert ingredients? because the EPA recognizes that even though an ingredient is not toxic to a target organism. it may be harmful to the environment or other organisms. So the very branch that is given the task of checking into these "Other potential harms" has in fact looked at OA and rendered their decision concerning it. They are not looking at OA as an ingredient among other ingredients. they are looking at OA all by itself. And they have determined that no regulation is necessary up to the limit they set. Now that you want to disagree once again does not change the fact that is their determination. they have determined it is inert and they have determined no regulations are required. period end of discussion. Your opinion changes neither.


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## Rader Sidetrack

Daniel Y said:


> Graham,
> 
> So you thik that the EPA has determined that OA is Inert. Ignorant of the fact that it is used as the only ingredient when applied to beehives. So there fore it must be an active ingredient and the EPA must be wrong.


:scratch: :s

Nowhere did I say that the "_EPA has determined that OA is Inert_". 

What I did say is that the inert/active status of a specific pesticide ingredient changes depending on the targeted pest. 

I have provided all the links and explanations appropriate to understand that concept. I can see that some people may not want to accept that idea, but that is the FIFRA law as it is currently written.


The alternative is to adopt PLAN B ....


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## Daniel Y

I did not have a lot of time to do a search. but I did search for OA as an active ingredient in Pesticides and came up with nothing not even from a site that is supposed to have information on any chemical used in pesticides as an active ingredient. As ar as i can tell nowhere is OA listed as an active ingredient.

My understanding of how thois coudl be is.
1. OA has not been evaluated when applied as a vapor to Honey Bee hives. (Not LIkley since such use is well known).
2. that even though certain ingredient may repel or even be lethal to an organism. even a targeted organism. such as water being lethal to aphids. It is not active "Enough" to be considered Active. This only brings us back to my pint that not everything that will kill insects is considered a pesticide. it may well be it is also not considered an active ingredient. even on it's own water would not be considered an active pesticide ingredient. So where is the line between say water and DDT. DDT being listed as an active ingredient. I intentioanly used extremes in this case.

From what I can find OA falls one the non active ingredient side of that line. Right along with water and a long list of thoer ingredients that woudl also fall on the non active side of the line.

I did find one reference to OA as an active ingredient in regard to control of peach borers or something like that. Btu that reference woud be on parr with Grahams opinon that the ingredient is active becasue it is the only ingredient beig used. so it must be active. 

I disagree. It only means an inert, unregulated ingredient can control mites and not kill bees.


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## Rader Sidetrack

Well, that certainly makes the situation perfectly clear ..... .... :lpf: :lookout: :gh:


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## Axtmann

I think you guys make your own problems with all the back and for, filling up pages after pages. If you get your honey tested from the government and they find OA in you honey, how can they prove the acid is from an treatment and not natural?

Would be different if you have a government regulated amount of OA in food, like beans, spinach or even rhubarb or all the other vegetables. Most of them contain more OA in a single meal you ever have in your hive during the whole year, whether treated with OA or not.

OA is an natural ingredient in honey, sometimes more sometimes les, depends on the plants the bees collect the honey from. There is NO MRL on OA in food, the same with formic, menthol and thymol. It is always possible, that your untreated hives have more OA in honey than treated hives.


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## melliferal

Daniel Y said:


> Show me where they have approved dusting with powdered sugar. but that argument is even getting tiring to me.


Dusting with sugar is a mechanical treatment, not a chemical one. The sugar doesn't actually do anything to the mites.

Still waiting to hear what's so special about _oxalic acid_ that I should be using it, rather than other chemical treatments that also work just fine.


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## Daniel Y

melliferal said:


> Still waiting to hear what's so special about _oxalic acid_ that I should be using it, rather than other chemical treatments that also work just fine.


You shouldn't use it. It is a choice and you have made yours. Stick with it.


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## Jim 134

Maybe you should know your state laws before using anything in a beehive !!!!
Of course this is just a suggestion and you may regret finding out the hard way. I do see there are a few people here who do not like doing their homework 


BEE HAPPY Jim 134


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## Mike Gillmore

jim lyon said:


> As I stated a loooong time ago in this thread the question to me is why isn't everyone trickling not why isn't everyone vaporizing.


Jim, 

Every region is different, but in this area we usually experience peak mite numbers in our colonies in late August. Nectar is scarce and the brood nest has contracted to the lowest amount of brood of the active season. 

Starting in late August with 3 OA Vapor treatments, one week apart, most of the mites are eliminated from the colony. This gives the colony at least 2 full brood cycles during the fall flow period to build up a healthy bee population free of mites before winter brood shut down.

If that same colony which had high mite counts in August was not treated until the winter broodless period with an OA dribble, most of the bees treated with dribble would already have been compromised by mite pressure. I would be treating a colony filled with weak or unhealthy bees that have been struggling for months with high numbers of mites. 

I think that's the main benefit to vaporizing over dribble. Perhaps using both methods would be the best approach. Knock down most of the mites in late Summer with OA Vapor treatments to give you a robust mite free colony going into Fall, then clean out the remaining mites with a single OA dribble treatment during the early Winter broodless period.


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## Juhani Lunden

Answer to the thread question: because dropping is as efficient and much simpler and faster, does not need any equipment. 

I used dropping for many years and made some research of it too.


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## BeeGhost

Jim 134 said:


> Maybe you should know your state laws before using anything in a beehive !!!!
> Of course this is just a suggestion and you may regret finding out the hard way. I do see there are a few people here who do not like doing their homework


Ive done my homework, and I still choose to use OAV in my hives because it does work. Is it illegal, well, its not approved, but is it a huge enough problem that they are sending OAV police around to cite people?? Nope. 

Im not one of those people that live my life by everything the government says, if I was, I would live in a food grade plastic ball with super ultra-filtered oxygen pumped into it, because according to the government, the very air we breathe and the water we drink is not god for us. The funny thing is, we are all going to die someday, some sooner than others, and in ways different from others.

I just read that Fumigilin-B is legal in the USA, but not legal in European countries because it can cause birth defects in mammals or something?? Hmmm.........yet OA is legal in Europe AND our neighbors to the north in Canada!!!

The laws in the USA are not put forth to protect people, they are put forth to make certain companies rich!!! 

Case in point, Particulate traps for diesel trucks. To comply with California standards, one has to have a PT installed on their big rig, at the price of $15,000.........plus all the electricity it takes to clean one that isn't on the road 12 hours a day!! The one company I know that installs the PT is doing very well, infact they have to almost turn away business because they don't have the room to store the vehicles for service!!!

So don't think for a moment that the government is looking out for you, and don't make me tell you that in order to keep a CDL in California you have to be as in shape as an Olympic athlete, and no, im not kidding.


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## beeman2009

To start with my intent is not to offend ANYONE! So all you guys just waiting to pounce on someone for daring to think different than you do please just chill. As for OA, I believe the operative words here are "not approved". That's not illegal! Putting cinnamon in your hives to help control ants is not approved, so is it illegal? Nope. I could go on but I won't. Let's just say each to their own & leave it at that. :banana:


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## Santa Caras

BeeGhost said:


> Im not one of those people that live my life by everything the government says....
> The laws in the USA are not put forth to protect people, they are put forth to make certain companies rich!!!
> Don't think for a moment that the government is looking out for you.


Not trying to jump into this war of words on OA but the above qoute is the best thing I've read on this thread so far and agree whole heartedly with it with all things that pretain to government.

Probably the only thing to do here is "Lets all agree to disagree!"


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## Robbin

Santa Caras said:


> Not trying to jump into this war of words on OA but the above qoute is the best thing I've read on this thread so far and agree whole heartedly with it with all things that pretain to government.
> 
> Probably the only thing to do here is "Lets all agree to disagree!"


I've discovered that when I clean my hives with vaporized wood bleach, the bees react to the clean hive by becoming much more hygienic and they proceed to clean themselves up to the point where large numbers of Varroa mites are removed. So I decided to bleach the wood in my hives several times every summer during the dearth when I've removed my supers.


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## shinbone

jim lyon said:


> . . . it annoys a lot of people who are fundamentally opposed to mite treatments per se that there could be a compound this cheap, safe and effective available that has NEVER been found to contaminate any hive product nor has there ever been any sort of legal repercussion for anyone that has used it.


This.



In other words, one identifier of an anti-treater is that he says you shouldn't use OA because it is illegal.


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