# OAV Finally registered



## mgstei1 (Jan 11, 2014)

OA is finally registered with the EPA as a treatment for honeybee colonies!!
250+ positive comments from beekeepers and still coming in with only 1/2 doz against!!

Thanks Brushy Mountain for your hard work!!

And also Meredith Laws!!


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## Lburou (May 13, 2012)

Sounds good. Where can one read an official announcement?


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## Rader Sidetrack (Nov 30, 2011)

Considering that the '_public comment period_' was open until March 6th, I suspect that it is a bit premature to assume that a final decision has been announced.

A search of the _Federal Register_ does not suggest a decision has been published yet. The most recent link is to the '_request for comments_' published on February 4 2015:
https://www.federalregister.gov/art...pt-of-applications-for-new-active-ingredients


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## knute (Mar 10, 2013)

It's official- it's been approved.

Here's the "Final Registration Decision" document:
http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OPP-2015-0043-0119

(click on the "pdf" icon in the middle of the page)


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## snl (Nov 20, 2009)

The effective registration date was yesterday March 10, 2015. The label should be available shortly in the online database, and the final decision document will be available in the docket this afternoon.

It's approved for immediate use............ Outstanding!


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## Rader Sidetrack (Nov 30, 2011)

Once you jump through the hoops at the link in post #4, here is a screenshot from the last page of the document ...








(click to enlarge, and read the last line)

:thumbsup::thumbsup:


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## snl (Nov 20, 2009)

This is just for Rader, our resident skeptic..............

Oh ye of little faith!! :no::lookout:


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## BeeGhost (May 7, 2011)

Awesome!!!!!!! Now we don't have to don black clothes and do it under the cover of darkness!!!LOL

Now, im waiting for more affordable options to apply the stuff at a quicker rate besides the wand and burn pot options, no offense to SNL or others selling them, just would like something that you can walk up, stick the tube in the entrance, give a dosage and go to the next hive........but doesn't cost a couple thousand dollars!!


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## Michael Bush (Aug 2, 2002)

>Oh ye of little faith!!

I don't think it was a lack of faith. I've been hearing that Oxalic acid was on the verge of being approved for almost 15 years now... It's a matter of crying wolf. It doesn't mean the wolf won't show up eventually...


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## Rader Sidetrack (Nov 30, 2011)

Well, Larry, I should believe you _just because you say so_?


... that would put you in the same group as a certain _notorious_ frequent poster on Beesource. Do you really want that?:kn: :lpf:


k: As they say, "trust, but verify". :digging:


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## Bob J (Feb 25, 2013)

This is awesome news!


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## snl (Nov 20, 2009)

Rader Sidetrack said:


> Well, Larry, I should believe you _just because you say so_?


But Graham, I just had to razz you .........


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## Rader Sidetrack (Nov 30, 2011)

Be my guest .... as long as you use some _smileys_. :shhhh:


My contract as the Beesource _Smiley Union_ *PR spokeshuman* will be up for renewal soon. Every smiley counts! 



... I'm also working on getting a PR contract from the Beesource _Fonts Union_, so I'm hoping for a good referral from the smileys.


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## Gypsi (Mar 27, 2011)

Nice view Rader!


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## Mike Gillmore (Feb 25, 2006)

Barry's probably relieved, his moderator is no longer an "outlaw".  I don't think anyone really bought the "bleaching the frames" song and dance. 

This is very good news. Thanks to everyone who kept pushing this and didn't give up.


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## mgstei1 (Jan 11, 2014)

I wont lose any more colonies to the mites any longer!!
It works and works well as I haven't lost 1 colony the last 2 years cause of Varroa. Now, SHB, that's a different story.
It's forced me to place ALL my hives in full sun and that's tough on them in SE Texas and started using SBB with mineral oil trays to at least give the bees a fighting chance.

Wish the good ol days of fretting over the wax moths would come back. But that aint gonna happen and I'm praying any new pests stay away.


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## knute (Mar 10, 2013)

I'm hoping that California plays nice with this. I've been lead to believe that Apivar still requires an applicator's license to be legal for use in California even though it's FIFRA section 3, and I'm hoping that oxalic acid doesn't get that restriction. (Am I wrong on Apivar? Was the applicator's license only required when Apivar was under section 18?)


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## AL from Georgia (Jul 14, 2014)

Great news, thanks to those that helped make it happen. :thumbsup:


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## beemandan (Dec 5, 2005)

I stand corrected....once again. I was certain that there'd be significant restrictions on application/methods. It doesn't appear so.


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## JRG13 (May 11, 2012)

Actually, you can buy the 10 packs here w/o license.


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## David LaFerney (Jan 14, 2009)

I'm still gonna stock up on wood bleach - just in case theres a tu..... something bad in the punchbowl.

But, yeah. This is good.


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## snl (Nov 20, 2009)

Mike Gillmore said:


> Barry's probably relieved, his moderator is no longer an "outlaw". This is very good news. Thanks to everyone who kept pushing this and didn't give up.


Mike, you're the moderator that ADMITTED to using it.....:lookout:


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## beepro (Dec 31, 2012)

Good news so far!

How is this going to affect the local OA price if at all?
Is there an anticipation on an increase in the demand of the OA locally?


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## snl (Nov 20, 2009)

beepro said:


> Good news so far!
> 
> How is this going to affect the local OA price if at all?
> Is there an anticipation on an increase in the demand of the OA locally?


There are tons and tons of OA on the market for sale. It's used for many reasons. Go to Amazon and Ebay and search.........it's EVERYWHERE! So no, no price increase expected.


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## Specialkayme (Sep 4, 2005)

My understanding was, and forgive me if I'm incorrect, that even approved treatments needed to be followed by the manufacturer's label, and couldn't be "mixed" directly by the consumer.

For example, it was my understanding that while Formic Acid was an approved treatment, it was only approved in the form of MAQS, and it was still illegal for an individual to buy a gallon of Formic Acid, apply it to a shop towel, and throw it in the hive. Right?

If so, is the registration of OA any different? Legally speaking, do we need to wait for a manufacturer to "produce" an OA product with an approved label and treatment instructions/doses?

Practically speaking, I'm not sure if it matters. Legally speaking, I think it does.


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## shinbone (Jul 5, 2011)

Yes, the label must be followed. The label for OA allows you to buy oxalic acid dihydrate in bulk, scoop it into a vaporizer and vaporize it into a hive. No special product must be purchased. In fact, the approval document specifically mentions that oxalic acid dihydrate is commonly available as "wood bleach."

The label also allows for applying OA as a sugar solution to packages and as a sugar solution dribbled between frames.


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## Robbin (May 26, 2013)

Awesome news....:applause:


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## loggermike (Jul 23, 2000)

Beeghost. The one from Lega Italy looks like it will meet that expectation. I finally got one, but haven't used it yet.It was a process to go through to order it!


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## Specialkayme (Sep 4, 2005)

shinbone said:


> In fact, the approval document specifically mentions that oxalic acid dihydrate is commonly available as "wood bleach."


The approval document says: "In the U.S., oxalic acid is marketed for a range of non-pesticidal uses. On the general consumer
market, it is commonly _known_ as wood bleach." (emphasis not in original).

There is a difference between saying it's commonly known as wood bleach, and commonly available as wood bleach.

But, the approval document went on to say:
"Since Varroa populations have quickly developed resistance to registered chemicals, the Agency
required the following language on the label that advises pesticide users to manage applications
effectively to minimize the likelihood of developing resistance to oxalic acid or any chemical
used in hives to control Varroa mites."

It then went on to list, in italicized words, exactly what must be on the label. 

I don't do this sorta thing for a living, but my gut tells me the EPA would not have "required" language to be on a label, but would say it's ok to obtain a product that doesn't have a label. As a matter of fact, it's a violation of EPA and federal law to purchase an approved product _without_ having the label, or having the label destroyed. 

The approval document doesn't say OA needs to be purchased from an approved vendor, or in a specific format. But it doesn't say you can buy commercial grade OA and apply it.


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## snl (Nov 20, 2009)

shinbone said:


> Yes, the label must be followed. The label for OA allows you to buy oxalic acid dihydrate in bulk, scoop it into a vaporizer and vaporize it into a hive. No special product must be purchased. In fact, the approval document specifically mentions that oxalic acid dihydrate is commonly available as "wood bleach."
> 
> The label also allows for applying OA as a sugar solution to packages and as a sugar solution dribbled between frames.


_*This is INCORRECT! The label does not allow a consumer to buy in bulk and apply according to the label, technically this is a violation of FIFRA. *_


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## beekuk (Dec 31, 2008)

BeeGhost said:


> Now, im waiting for more affordable options to apply the stuff at a quicker rate besides the wand and burn pot options, no offense to SNL or others selling them, just would like something that you can walk up, stick the tube in the entrance, give a dosage and go to the next hive........but doesn't cost a couple thousand dollars!!


 I use a sublimox, 25 seconds treatment per hive, continuous, and not overly expensive. Made in Italy, but i bought the one i have from a dealer in France in the links below.

http://translate.google.co.uk/trans...LFO&rls=org.mozilla:en-US:official&channel=sb

http://www.icko-apiculture.com/fr/sublimox.html


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## Rader Sidetrack (Nov 30, 2011)

It is my expectation that Brushy Mtn will be buying 'commercial grade oxalic acid' and having it packaged and labeled closely following the 'sample label' that the EPA prepared (available for viewing at the EPA site). This packaged and labeled OA will nicely complement the vaporizer that I expect that Brushy will also sell. It will also be reasonable to expect that other beekeeping supply houses will follow suit.

I'm not worried that somehow a monopoly price will develop on oxalic acid 'labeled for varroa control' as its very easy for new entrants to that market to put a 'varroa' label on their own packages of commercial oxalic acid. While Savogran may not change the labeling on _their _'wood bleach' product, there are plenty of smaller sellers that I expect will change their labels to target beekeepers. Ebay and Amazon make those smaller sellers easy to find.  Perhaps an enterprising vendor might even put ads on Beesource.


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## snl (Nov 20, 2009)

Rader Sidetrack said:


> It will also be reasonable to expect that other beekeeping supply houses will follow suit.


From my understanding they will under the "Me Too" provision............


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## snl (Nov 20, 2009)

Rader Sidetrack said:


> Perhaps an enterprising vendor might even put ads on Beesource.


Music to my ears...


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## Specialkayme (Sep 4, 2005)

Rader Sidetrack said:


> It is my expectation that Brushy Mtn will be buying 'commercial grade oxalic acid' and having it packaged and labeled closely following the 'sample label' that the EPA prepared (available for viewing at the EPA site).


Good luck to them. The legal exposure would be massive, and the label approval and registration time/expense is nothing to balk at.


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## snl (Nov 20, 2009)

Specialkayme said:


> Good luck to them. The legal exposure would be massive, and the label approval and registration time/expense is nothing to balk at.


Not sure why the legal exposure is massive........The label approval and registration as you say is already completed.


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## enjambres (Jun 30, 2013)

Approval is very good news for beekeepers (providing they protect themselves with adequate personal protective gear) and very, very, bad news for mites. 

Glad to be on the right side of the law, again, but not at all sorry about going ahead and using it in anticipation of legal status. Nor are my bees sorry that I used it last fall/early winter. They loved being so little troubled mites this winter. 

Enj.


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## Specialkayme (Sep 4, 2005)

snl said:


> Not sure why the legal exposure is massive........


The label has to properly warn of adverse risks, and the proper and improper application times, methods, ect. If you leave something out, and a consumer mis-uses the product and ends up getting hurt, lawsuit.

You've had the discussion over what type of respirator to use. What if you suggest the use of a particle respirator, but someone gets sent to the hospital because they should have used an organic acid respirator? What if they needed something stronger than an organic acid filter? Just one example.



snl said:


> The label approval and registration as you say is already completed.


_Edit_: Sorry, I stand corrected. The label was already approved.

I don't know enough about the subject area to say if further registration needs to take place.

The proposed label does have the Beltsville's name/address and their EPA Registration No. on it. I would suspect a separate label application would need to be made for a different manufacturer with their own EPA Registration No. on it. But I don't know.


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## shinbone (Jul 5, 2011)

snl said:


> _*This is INCORRECT! The label does not allow a consumer to buy in bulk and apply according to the label, technically this is a violation of FIFRA. *_



Okay. So the red letters in caps means I am certainly wrong and so I stand corrected. But, how do you reach this conclusion? I see no info in the announcement from the EPA identifying a specific source of OA that is required. The registration application was put forward by the Government itself, not a private entity who would be registering only their own product. It is not a patented formulation that can only be acquired from a certain manufacturer. As far as I can see, as long as it is properly labeled for the use, you can buy from anywhere.






.


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## Nabber86 (Apr 15, 2009)

snl said:


> The effective registration date was yesterday March 10, 2015. The label should be available shortly in the online database, and the final decision document will be available in the docket this afternoon.
> 
> It's approved for immediate use............ Outstanding!


This is great news to me, but one trivial point: OA is not registered yet. The EPA signed a "Registration Decision", which means that they "decided" to register it. The registration application is due December 8, 2016. 

(see the second to last paragraph on page 2 of 7)

Also as Radar pointed out in Post#6, the EPA has "granted unconditional registration of OA", not approval for immediate use.


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## Specialkayme (Sep 4, 2005)

Nabber86 said:


> This is great news to me, but one trivial point: OA is not registered yet. The EPA signed a "Registration Decision", which means that they "decided" to register it. The registration application is due December 8, 2016.
> 
> (see the second to last paragraph on page 2 of 7)


I think you read that incorrectly. 

The Pesticide Registration Improvement Act (PRIA) requires the EPA to publish a decision on an application for registration of a new active ingredient within 24 months of the application's submission. The application was submitted on November 14, 2014. Which, according to the deadlines imposed under PRIA, required the EPA to respond and publish a decision by December 8, 2016. Or, according to how they calculated it, 24 months after the application was submitted.

The EPA fast tracked the decision, and didn't wait the full 24 months.


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## Andrew Dewey (Aug 23, 2005)

From the label:

"Use only in late fall or early spring when little
or no brood is present. Oxalic Acid Dihydrate
might damage bee brood. Oxalic Acid
Dihydrate will not control Varroa mites in
capped brood.
Do not use when honey supers are in place
to prevent contamination of marketable
honey"

Is this the way OA usage has been promoted?


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## Nabber86 (Apr 15, 2009)

Specialkayme said:


> The label needs to be drafted, sent to the EPA for review and approved prior to it's sale.
> 
> "The EPA reviews the labeling to make sure it contains all information needed for safe and effective use of the pesticide. The EPA also ensures the information provided in the labeling is backed by reliable data, which is submitted by the manufacturer to the EPA."
> (http://edis.ifas.ufl.edu/pi203)
> ...


This is the truth. The label is in draft form until OA is registered.


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## beekuk (Dec 31, 2008)

Nabber86 said:


> This is great news to me, but one trivial point: OA is not registered yet. The EPA signed a "Registration Decision", which means that they "decided" to register it. The registration application is due December 8, 2016.
> 
> (see the second to last paragraph on page 2 of 7)


 Does Expedite not mean to do something sooner, to bypass the normal procedure, at the bottom of the same paragraph, and top of the next one, in the link 2 of 7.


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## shinbone (Jul 5, 2011)

The last line of the "Registration Decision" document says: "the EPA is granting the unconditional registration of oxalic acid under Section 3(c)(5) of FIFRA."

I read that to mean it is now registered.


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## Nabber86 (Apr 15, 2009)

Specialkayme said:


> I think you read that incorrectly.
> 
> The Pesticide Registration Improvement Act (PRIA) requires the EPA to publish a decision on an application for registration of a new active ingredient within 24 months of the application's submission. The application was submitted on November 14, 2014. Which, according to the deadlines imposed under PRIA, required the EPA to respond and publish a decision by December 8, 2016. Or, according to how they calculated it, 24 months after the application was submitted.
> 
> The EPA fast tracked the decision, and didn't wait the full 24 months.


OK you are on the dates, but they fast-tracked the _review of the application _and_ decided _that they would register OA (the PDF is a Record of Decision)_. _The application has not been filed and OA is not registered yet.


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## Nabber86 (Apr 15, 2009)

shinbone said:


> The last line of the "Registration Decision" document says: "the EPA is granting the unconditional registration of oxalic acid under Section 3(c)(5) of FIFRA."
> 
> I read that to mean it is now registered.


_Granting_ the unconditional registration. The final paper work (act of registration) has not been filed. There will be an official entry in the Federal Register (FR) when OA is registered. The entry in the FR will then appear as code in the Code of Federal Regulations (CFR). The CFR is the law and the final say so as to how OA is to applied, if there is a licensing requirement, product labeling, etc., ect. If you do not follow the CFR, you have broken federal law. 

I don't mean to poop on the party, but EPA speak is a lot like FED speak. Anyway, it's just a matter of a bunch of paperwork. The _Decision_ has been made so it is full steam ahead. They are not going to retract the _Decision._


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## Specialkayme (Sep 4, 2005)

Nabber86 said:


> The application has not been filed and OA is not registered yet.


I don't understand how you are coming to this conclusion.


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## Nabber86 (Apr 15, 2009)

Specialkayme said:


> I don't understand how you are coming to this conclusion.


It is concluded when OA registration appears in the Federal Register. Here is the latest entry in the FR (Vol. 80, No. 23 / Wednesday, February 4, 2015) concerning OA: http://www.gpo.gov/fdsys/pkg/FR-2015-02-04/pdf/2015-02209.pdf 

I don't find any mention of OA appearing in the FR in the last 30 days, so officially the only thing that has happened is the EPA has released a Record of Decision [to register OA].


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## Specialkayme (Sep 4, 2005)

That is not what I don't understand. I don't understand how you are coming to the conclusion that the application has not been filed yet. That's what you said right here:



Nabber86 said:


> The application has not been filed


You also allude to it here as well:



Nabber86 said:


> The registration application is due December 8, 2016.


Saying the application hasn't been filed, and saying it hasn't been updated into the Federal Register are entirely different statements, touching on different issues.

The application has been filed. OA has been approved. It takes time for the FR to update. That's a paperwork issue, not an application issue.


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## shinbone (Jul 5, 2011)

Nabber86 - Do you have special expertise in the registration of pesticides? I am just wondering if there is some specialized definition of terms that apply here that those who don't work in the field would not be aware of and thus would get tripped up by. I understand some of these government process can be quite complicated and not at all what they appear on their face, thus the need for special expertise to understand.

How does "granting the unconditional registration" mean the opposite, i.e. "it is not registered," of the common meaning of those words,

Are you saying that the ""Registration Decision" document is not legally effective until it is published in the Federal Register?

In the Summary of the Registration Document it says: "One product is registered under Section 3(c)(5) of FIFRA, "Oxalic Acid." Since the past tense of "register" is used, that makes it sound like OA has been registered . . . ?


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## BeeAttitudes (Dec 6, 2014)

Quote: You've had the discussion over what type of respirator to use. What if you suggest the use of a particle respirator, but someone gets sent to the hospital because they should have used an organic acid respirator? What if they needed something stronger than an organic acid filter?

May I ask which the filter is recommended for use with OA if not the organic acid filter?


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## libhart (Apr 22, 2010)

This is just me trying to interpret the interpretation of Nabber86 (please catch me if this is wrong). What happened so far is this:

Bee Lab to the EPA: "Please allow registration of OA as an active ingredient"
EPA: "Ok, we'll consider it."
<public comments>
EPA: "Ok, we've considered it, and we'll allow registration of products where OA is the active ingredient"

EPA now waits around for some entity, a company or whatever, to submit their application for registration of their product where OA is the active ingredient. This application will necessarily have the label that will be on that product and just that product. Every application for a new product has to have its own label. Once that application for registration for that product is then approved by the EPA, that product is registered as a legally allowed product for mite treatment. We still can't just go buy a bucket of wood bleach OA and use it.


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## snl (Nov 20, 2009)

BeeAttitudes said:


> Quote: You've had the discussion over what type of respirator to use. What if you suggest the use of a particle respirator, but someone gets sent to the hospital because they should have used an organic acid respirator? What if they needed something stronger than an organic acid filter?
> 
> May I ask which the filter is recommended for use with OA if not the organic acid filter?


Is Oxalic Acid safe for the beekeeper?
Yes, if the beekeeper takes adequate safety precautions. Keep a smoker lit in the beeyard and stand up-wind. Do not BREATHE the vapors! The EPA is stating that an acid gas vaporizer is sufficient, use a model 6211 which filters both vapors and particulates. In Europe a mask with an N95 particulate rating is the standard. OA vapors very quickly re-crystallize to cover all the surfaces in the hive making the breathing of the vapors unlikely. However, there is always the chance, error on the side of safety


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## Specialkayme (Sep 4, 2005)

BeeAttitudes said:


> May I ask which the filter is recommended for use with OA if not the organic acid filter?


Current suggested label recommends:

"Half-face respirator with cartridge and/or particulate filter"


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## Nabber86 (Apr 15, 2009)

libhart said:


> Bee Lab to the EPA: "Please allow registration of OA as an active ingredient"
> EPA: "Ok, we'll consider it."
> <public comments>
> EPA: "Ok, we've considered it, and we'll allow registration of products where OA is the active ingredient"
> ...


^ Yes, that is a pretty good explanation. 




shinbone said:


> Nabber86 - Do you have special expertise in the registration of pesticides? I am just wondering if there is some specialized definition of terms that apply here that those who don't work in the field would not be aware of and thus would get tripped up by. I understand some of these government process can be quite complicated and not at all what they appear on their face, thus the need for special expertise to understand.


I don't specialist in registering pesticides, but I work with the EPA and a host of State environmental agencies on sites that are contaminated with pesticides, and a bunch of other hazardous materials. I know how the EPA uses terms like Record of Decision, Granting Use, listing, and labeling. I go to the CFR to look up the federal codes and then consult with other people in my office to make certain (or reasonably certain) that I am correct before I tell somebody that they should be expecting an order of consent for a serious violation. Sometimes it is not clear to anyone and then lawyers get involved. 



shinbone said:


> How does "granting the unconditional registration" mean the opposite, i.e. "it is not registered," of the common meaning of those words


Think of "granting" as the EPA giving "permission" to the Federal Government to register a pesticide and codify it's use. Granting is not the act of registering. The EPA just gives the thumbs up or the thumbs down to get the process going (or stop it dead in it's tracks). So far the EPA has rendered an official opinion that OA should be listed specifically for use as a varroa treatment of honeybees, through registration. 



shinbone said:


> In the Summary of the Registration Document it says: "One product is registered under Section 3(c)(5) of FIFRA, "Oxalic Acid." Since the past tense of "register" is used, that makes it sound like OA has been registered . . . ?


OA was, and still is, registered for use for whatever use it was formerly registered for (how is that for confusing?). I don't know what the current registration is; could be for killing ****roaches under the kitchen counter when applied a certain way. OA has not yet been registered for use on honeybees; yet. The PDF gives a generic method of beekeeper use of OA (mix with a 1:1 sugar/water solution). They are going to need a whole lot more testing and instruction for use (finalize the labeling process) before the registration for honeybees is complete. None of that work has been done yet. Of course they have studies from Canada so it isn't like they are starting from square one.


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## wgstarks (Mar 3, 2015)

Wonder how long it will take the states to approve OA now that the EPA has?


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## DPBsbees (Apr 14, 2011)

wgstarks said:


> Wonder how long it will take the states to approve OA now that the EPA has?


I don't belive the states need to approve it since the EPA used what I think is Section 3 which approves it for the entire country. You might be thinking of stuff like HopGuard which has Section 18 approval in individual states.


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## wgstarks (Mar 3, 2015)

DPBsbees said:


> I don't belive the states need to approve it since the EPA used what I think is Section 3 which approves it for the entire country. You might be thinking of stuff like HopGuard which has Section 18 approval in individual states.


I think you're right. Been a lot of discussion about this in local email list servers. One of the commercial beeks had posted that it would also require NC approval just like HopGuard, but that's a different situation.


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## Nabber86 (Apr 15, 2009)

Specialkayme said:


> Current suggested label recommends:
> 
> "Half-face respirator with cartridge and/or particulate filter"


You probably want to go with an organic vapor/acid gas cartridge in addition to a particulate filter. It the US, it will be labeled with a yellow band. The cartridges are stackable so you use the 2 in combination. The recommendation will be finalized during the registration and labeling process.


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## shinbone (Jul 5, 2011)

Nabber86 - Thanks for the info about your background.





Nabber86 said:


> They are going to need a whole lot more testing and instruction for use (finalize the labeling process) before the registration for honeybees is complete.


More testing before it is legal to use?? Are you sure??


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## Nabber86 (Apr 15, 2009)

shinbone said:


> Nabber86 - Thanks for the info about your background.
> More testing before it is legal to use?? Are you sure??


Yes, but it is not that big of a deal. The hazards of OA to humans (and bees) are widely documented. It's not like Monsanto just developed a new molecule to bind with OA for delivery through some patented process. 

There will be some calculations so that a final decision as to how much OA to dissolve in what quantity of water, how much and how fast to apply the solution, how long to wait for whatever reason. How long to vaporize. Stuff like that. Maybe some field trails, maybe not. Since other countries have been using OA, they can relay on existing data. But this is new to the US, so the data will have to be validated and qualified by our scientists.

I guess I should not have said "a whole lot more testing". More like a whole lot of paperwork. Have faith, the government is good at paperwork.


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## libhart (Apr 22, 2010)

Nabber86 said:


> They are going to need a whole lot more testing and instruction for use (finalize the labeling process) before the registration for honeybees is complete. None of that work has been done yet.


I have a feeling some places (Brushy?) have been doing it for a while banking on this decision. I'm betting their years of research show up in a product registration application in a month or so....sort of like when Yuengling sent a truckload of beer that took weeks to produce to the Whitehouse the day prohibition was repealed.


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## Nabber86 (Apr 15, 2009)

libhart said:


> I have a feeling some places (Brushy?) have been doing it for a while banking on this decision. I'm betting their years of research show up in a product registration application in a month or so....sort of like when Yuengling sent a truckload of beer that took weeks to produce to the Whitehouse the day prohibition was repealed.



Yes and that is an excellent example of industry helping to influence the government decision making process. Funny how everybody demonizes industry input into government affairs, except for when it is for something they want. Here's a Yuengling toast to Brushy Mountain.:applause:


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## Michael Bush (Aug 2, 2002)

>Yes and that is an excellent example of industry helping to influence the government decision making process.

Let's hope the concept can continue so that one company doesn't have to bear the brunt of registering a simple, commonly available chemical as a pesticide and then have everyone just bypass them and buy it off the shelf, thus making it impractical to bother with it. Hopefully this idea of approving the product instead of the company packaging it will continue.


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## Nabber86 (Apr 15, 2009)

Michael Bush said:


> Let's hope the concept can continue so that one company doesn't have to bear the brunt of registering a simple, commonly available chemical as a pesticide and then have everyone just bypass them and buy it off the shelf, thus making it impractical to bother with it. Hopefully this idea of approving the product instead of the company packaging it will continue.


The brunt has already been born and will continue to be born by you and me, assuming we both pay taxes. Private industry does have not pay to register a pesticide, at least in this case of a common commodity. If Randy Oliver, Brushy, or whomever else spent money testing and promoting OA, they did it on their own accord, not because the government forced them to. I don't know what the motivation would be other than wanting to help the honeybee industry, maybe increase sales traffic, and garner good will (you can put a monetary value on good will). Surely nobody that has been doing this is expecting to corner the market on OA and become rich; only to have it yanked out from under them. Not a good business plan. 

Now if you are a large corporation that stands to make millions from a new pesticide, it would be in your best interest to spend as much money as possible on research to push it through. It that case it could be implied that the government is forcing you to pay, because otherwise, the EPA is not going to do anything on their own. But now we are talking about R&D budget and patents, which is the corporation's responsibility. That is a huge burden that is off-set by by the corporation's potential to make bank (risk/reward). Unfortunately you and I are still paying part of the burden by way of taxes. And now we have gone full meta.


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## BeeAttitudes (Dec 6, 2014)

So is this the 3M cartridge that should be used when vaporizing Oxalic Acid?

3M™ Organic Vapor/Acid Gas Cartridge/Filter 60923, P100 Respiratory Protection
Magenta and Yellow: 








http://www.shop3m.com/3m-organic-vapor-acid-gas-cartridge-filter-60923-p100-respiratory-protection.html


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## knute (Mar 10, 2013)

The draft of the required label for oxalic acid as a varroacide is at: http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OPP-2015-0043-0018

Down at the bottom right of the label is the registrant info, which is typically the manufacturer/distributor, and in this case is the USDA bee lab in Beltsville, MD. Below that is the blank for net contents, and batch code number, which makes it pretty clear that the intended use for this label is for a specific product container. (Other verbiage on the label states that the pesticide must be stored in the original container, which cannot be refilled or re-used)

So here's my question: is the USDA Bee Lab in Beltsville, MD. actually going to become a distributor, or if not, who picks up the ball (with permission from the original registrant) to package, label and accept liability for oxalic acid as a registered pesticide? 

In post #18 of this thread: http://www.beesource.com/forums/showthread.php?307210-USDA-applies-for-OA-registation-Feb-4-2015

JWChesnut states: 


> In my chem closet, the agricultural sulfur dust has EPA registration # and a URL to the application instructions printed on the sack. It is a registered pesticide and a bulk commodity. The diatomaceous earth has an EPA registration #, and some abbreviated application instructions printed on the bag. The dormant oil has an EPA # and very detailed applications instructions in one of the "pesticide" style instruction sheets folded in a pocket on the barrel (and printed in unreadable 5 point type). I would guess the Savogran folks will be able to label their tubs with EPA # without much difficulty, and generate an application instruction and safety sheet (as a URL or elsewhere).


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## snl (Nov 20, 2009)

BeeAttitudes said:


> So is this the 3M cartridge that should be used when vaporizing Oxalic Acid?
> 
> 3M™ Organic Vapor/Acid Gas Cartridge/Filter 60923, P100 Respiratory Protection
> Magenta and Yellow:
> ...


That will work just fine!


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## Nabber86 (Apr 15, 2009)

snl said:


> That will work just fine!


Exactly. The process has been standardized by NIOSH. Another thing that our government actually does right. Only 39 pages of "amazing done right" which is a record for our government. It may seem boring, but read more if you are interested. 

http://www.cdc.gov/niosh/docs/2005-100/pdfs/2005-100.pdf

I hate the government as much as any good Americn should, but sometimes they actually get their **** together. Good times in our history! For the uninitiated, note the reference to the Code of Federal Regulations (CFR), as I noted ealier as the law, as opposed to a "record of decision". 

Reference 29CFR1910.134 

https://www.osha.gov/dte/library/respirators/major_requirements.pdf


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## BeeGhost (May 7, 2011)

loggermike said:


> Beeghost. The one from Lega Italy looks like it will meet that expectation. I finally got one, but haven't used it yet.It was a process to go through to order it!


I checked that out on youtube, it looks interesting!! Just wondering though, it seems like it would be like blowing an inferno inside a beehive using that heat gun!! Have you performed a test run on it yet just to see how it works?? What did it run in American dollars??


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## loggermike (Jul 23, 2000)

Around $311 including shipping, bank wire fees and customs fees. That is just for the vaporizer WITHOUT the heat gun.Didn't want a 220v gun.
Then you need a generator and heat gun.I haven't had time to mess with it yet , still moving hives from the orchards. But it looks solid.


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## Phoebee (Jan 29, 2014)

BeeAttitudes said:


> So is this the 3M cartridge that should be used when vaporizing Oxalic Acid?
> 
> 3M™ Organic Vapor/Acid Gas Cartridge/Filter 60923, P100 Respiratory Protection
> Magenta and Yellow:
> ...


Worth a look. I've used formic acid, and worn a respirator that would take those cartridges, but used a more common organic vapor cartridge. These things come with more paperwork than cartridge, and going thru them to find your particular hazardous vapor will give you a headache.

My rule is to wear the respirator but stand upwind anyway. I keep the cartridges sealed up between uses so they don't lose effectiveness.


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## Nabber86 (Apr 15, 2009)

knute said:


> The draft of the required label for oxalic acid as a varroacide is at: http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OPP-2015-0043-0018
> 
> So here's my question: is the USDA Bee Lab in Beltsville, MD. actually going to become a distributor, or if not, who picks up the ball (with permission from the original registrant) to package, label and accept liability for oxalic acid as a registered pesticide? :


Taxes fund the USDA for registration of the product. Nobody owns the rights to the use of the registration and you don't need any further permission. The registration is the legal documentation that gives you permission to use the product. In that sense, after the registration is final, it's use has been fulfilled. 

Since our taxes are used to create the lable, we are the ones who own the right to the use of the label. Anybody can slap the label on a package of OA and sell it as a pesticide. Of course there is more to manufacturing, packaging, and selling a pesticide than putting a label on it, and the goverment will get plenty more money out of you during that process. 

The USDA has the liability to make sure the label is correct. The Siearra Club could sue the USDA if they think the label is not sufficient to be protective of human health and the environment. But, we fund the USDA through taxes. 

The pesticide user is liable for application of the pesticide in accordance with the label. 
I think this part is clear, because as we all know, it's right on on the label
_
This product must be used strictly in accordance with this label’s precautionary statements and use directions, as well as with all applicable State and Federal lawsand regulations. _


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## Phoebee (Jan 29, 2014)

Nabber, you know how I feel about excess lawyers.

I have been known to use an herbicide to control crabgrass, a pre-emergent that prevents germination. Out in your area you use it as cattle feed: corn gluten meal. Sold as a pre-emergent herbicide, it has the customary warning labels as if it were 2-4-D. In truth, the two "dangers" of corn gluten meal are inhaling the dust too deeply (any grain flour has this problem, and baking bread is probably more hazardous), and putting excess nitrogen on your lawn.

Oxalic acid, by itself, is pretty commonly used. But the issue with it will be getting the right dose. There are a lot of discussions in this forum about home-made vaporizers, and other methods, which have the potential to be poorly controlled. Getting the means of application right would, to me, seem the more important thing than how to sell OA itself. Not that there isn't plenty of experience with the stuff by this point.


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## BeeGhost (May 7, 2011)

loggermike said:


> Around $311 including shipping, bank wire fees and customs fees. That is just for the vaporizer WITHOUT the heat gun.Didn't want a 220v gun.
> Then you need a generator and heat gun.I haven't had time to mess with it yet , still moving hives from the orchards. But it looks solid.


Wow, I thought that included the heat gun!! I also read about the 220v and thought that was a bit over powered myself. Have to drag out a big generator just to run the dang thing!!! Your hives pick up some good weight in almonds?? My hives packed the up deep plum full!! Picking up the pallet of doubles put some serious strain on my bee boom!! At least I know it can handle the weight now!! Take care bud and have a good one!!


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## Nabber86 (Apr 15, 2009)

Phoebee said:


> My rule is to wear the respirator but stand upwind anyway. I keep the cartridges sealed up between uses so they don't lose effectiveness.



:no:
All cartridges lose effectiveness with time and use, especially organic vapor cartridges. They are not reusable. I urge you to become familiar with the NIOSH guidelines. http://www.cdc.gov/niosh/docs/87-116/pdfs/87-116.pdf . The bottom of page 52 is specific to cartridge use in this regard, and the other 300+ pages of info could save your life. Now I know that you can say that the guidelines are a bunch of government/legal/CYA/nanny state BS and I would partially agree with you, but that is not the point that I am trying to make here. The point is that aside from the BS, there is a lot of very good information in there. I have re-used vapor cartridges at home (I would get fired if I did that at work), but at least I know that you should not do this and exactly why you should not do this, as well a lot of other very important information. Your post indicates that you are potentially exposing yourself to greater harm through a false sense of security, because you think that you are sealing and storing your cartridges safely. You may very well be safer (statistically) without a respirator. At least then you would realize a greater potential threat and modify your actions accordingly. That is what safety is all about.


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## Phoebee (Jan 29, 2014)

Nabber, I didn't say I don't use a respirator, but I do insist that I don't trust them entirely. The cartridge may be good, but if you don't have a good seal to your face, they are useless. The exception would be a system that uses positive pressure so a poor seal can't let air in, a type you find in mine safety applications, but never at Home Depot. Nobody who used a respirator that simply straps over the face and works by inhalation should EVER think they are 100% effective. Stand upwind from the source of the hazard and use the respirator only to reduce exposure from the stray wiff.

The best system uses a positive pressure clean air source remote from the hazard. There are some that use the filters on a battery-powered positive pressure fan unit on a belt.

Absolutely, absorbent cartridges lose effectiveness once opened. If your workplace rules don't allow reuse, follow the workplace rules. Personally, for short duration home use against a compound which is a tolerable irritant in low concentrations, I'm comfortable with reusing a cartridge providing it has not been exposed to open air between uses. Formic acid has a pungent vinegary odor, so if the cartridge were not doing the job you would start to smell it. I've never used OA vapor ... I imagine it has a smell.

My application is home use after all. When I've used formic acid, my exposure has been a couple of minutes. Professional beeks dealing with hundreds or thousands of hives and hiring a staff need to meet a higher standard, OSHA or whatever state regulations require.

I have not read the datasheet on the organic acid cartridge above. Does it have a color change indicator or some other way to tell if it is spent? If not, it should. It is all well and good to say that you use a cartridge once and throw it away, but if I were stuck using a respirator for hours at a time, I'd really want to know if it were losing effectiveness. 

For what it is worth, activated charcoal CAN be recharged by heating it, and before disposable cartridges it used to be routine to recharge charcoal filters for organic vapors (although not organic acids). There's probably a law against it now.


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## Specialkayme (Sep 4, 2005)

Nabber86 said:


> Anybody can slap the label on a package of OA and sell it as a pesticide.


I don't think this is correct.


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## snl (Nov 20, 2009)

Specialkayme said:


> I don't think this is correct.


Believe me, it's not..........or if they do, beware.......more details later.......


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## BeeGhost (May 7, 2011)

My yard seems to always be windy, and almost always blows in the same direction. I start on the upwind side of the hive configuration, turn the vaporizer on and walk away up wind until its time to shut it off. I don't wear a chemical mask at all and have only gotten a whiff of the vapor once to see what all the hype was about, lets just say I wont be smelling it again. This is with the wand and pan tool where I have time to walk away before sublimation. If I had a contraption where I walk hive to hive and jet the vapor into the hive, I would wear a respirator because I would be in the thick of things. Just remember, if you live in town, that vapor cloud can carry and effect your neighbors as well, so you better provide everyone on the block respirators............:lookout:

Unless you have your head in the hive at the time of treatment, its pretty safe stuff. I do wear chemical resistant gloves since I am a clutz sometimes.


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## snl (Nov 20, 2009)

Specialkayme said:


> Just remember, if you live in town, that vapor cloud can carry and effect your neighbors as well, so you better provide everyone on the block respirators...........


Let's be smart, if your neighbors are outside and close by, vaporize another time.............


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## Mike Gillmore (Feb 25, 2006)

Also, if there is that much vapor floating around in the breeze.... it's not being administered properly. If the the hive is sealed up correctly before vaporizing, very little vapor actually escapes.


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## BeeGhost (May 7, 2011)

Im not knocking the process at all, just saying that as long as precautions are being taken the stuff is easy to work around. As far as neighbors, i have no idea as my hives are out in the country and I don't have to worry about trying to time it perfectly, which isn't going to happen in town. 

If you have 1 or 2 hives its really easy to tape up every crack in the hive, but its also NOT necessary to do this to have a great effect on mites. I actually gauge a good treatment when the vapors come out the top cracks between the lid and the box. As for the vapor that is coming out, it doesn't go much farther than a couple feet past the hive before it crystalized. 

There is no way that a guy with 40 hives is going to spend the time sealing up the hives, not practical at all.


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## Mike Gillmore (Feb 25, 2006)

BeeGhost said:


> There is no way that a guy with 40 hives is going to spend the time sealing up the hives, not practical at all.


That's a good point. Thorough sealing is not always practical, or necessary. 

It's also not practical to set up 40 hives close enough to a neighbor where drifting vapor would be a problem. 1.2 million bees flying around is not likely to draw the neighbors in too close.


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## BeeGhost (May 7, 2011)

Mike Gillmore said:


> That's a good point. Thorough sealing is not always practical, or necessary.
> 
> It's also not practical to set up 40 hives close enough to a neighbor where drifting vapor would be a problem. 1.2 million bees flying around is not likely to draw the neighbors in too close.


There is a guy in town that has somewhere between 8-12 hives...........and no water source around the hives, guess where they go, yup, my friends pool!!! Looks like a giant bee water bowl in summer!! As much as I would like to have a hive in town, I just don't find it safe enough with neighbors in close proximities to me, I only get to bring a cooped up cell starter home for a few days each year!!


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## Mike Gillmore (Feb 25, 2006)

A few year back I kept a few colonies in my back yard for garden pollination. It worked out great, the crop yield was much improved. Until one of the colonies decided to cast a swarm and it landed in my neighbors shrub not too far from their back door. I was able to box it up, but they weren't hanging out or doing any grilling on the patio that evening. 

They never said anything to me, but I could sense that they were not very comfortable with the whole situation, especially after the swarm event. I moved all of my hives to out yards and never brought any back. In some cases it's just not a good idea to keep hives in your back yard. We get along very well with our neighbors, and I would like to keep it that way.


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## Nabber86 (Apr 15, 2009)

As an afterthought to this thread…

If everyone that is interested makes an effort check the Federal Register every once in a while, we can all stay informed on any new developments in the registration process. 

Just click on this link below and don't forget to sort by "newest" (over on the right hand side). 

https://www.federalregister.gov/articles/search?conditions[term]=oxalic

If you find anything new, please post it here.

Thanks.


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## shinbone (Jul 5, 2011)

snl said:


> Believe me, it's not..........or if they do, beware.......more details later.......


SNL - When will you provide those "more details"? Any reason why you can't provide them now?


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## Nabber86 (Apr 15, 2009)

Info from the Brushy Mountain newsletter:


Now that Oxalic Acid is approved at the federal level,* each state must also approve before it can be legally distributed and sold in that state as a miticide.* Further, if it is to be used to treat mites in a bee hive or package of bees, the product must be properly labeled with the EPA approved label and the application must follow the instructions on the label. *If these criteria are not met, it is an illegal use of Oxalic Acid*.


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