# Oxalic Acid - Comment period to the EPA now open!



## snl (Nov 20, 2009)

The public comment period opened today for the Agency’s proposed regulatory decision for oxalic acid.

There's a lot of information here folks.....I've not read it all since I wanted to post here quickly...



The comment period extends from today (2/18/15) through midnight on March 6, 2015. I’ve included a link directly to the document where the public can, and should, submit comments to the Agency.

http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OPP-2015-0043-0015

Additionally the docket (see the link below) contains the proposed decision document outlining the Agency’s evaluation and regulatory decision, as well as the human health and ecological risk assessments, and the draft label for oxalic acid dihydrate.

Link: http://www.regulations.gov/#!search...EPA-HQ-OPP-2015-0043;dct=FR%2BPR%2BN%2BO%2BSR


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## snl (Nov 20, 2009)

Sure hope Graham (Radar Sidetrack) is reading this, the skeptic that he is or now maybe was!


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## Rader Sidetrack (Nov 30, 2011)

Its RadEr, Larry! 


And I already acknowledged your virtues in the earlier thread where the Federal Register notice was posted ...
http://www.beesource.com/forums/sho...-in-beehives/page3&highlight=federal+register
... if the :thumbsup::thumbsup: posted there were not enough for you, then I suspect you will remain disappointed for a long time. 

I have not yet read though all the new EPA material - but I will.



... and I expect to remain a cynic regardless of whatever happens to oxalic acid ...


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## snl (Nov 20, 2009)

Rader Sidetrack said:


> Its RadEr, Larry!


Let's see, if I can remember my Latin reference the misspelling of your name................ Mea Culpa, Mea Culpa, Mea Maxima Culpa! .......


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## Rader Sidetrack (Nov 30, 2011)

Well, I read all the EPA documents posted at the link above.

No major surprises. Both the oxalic acid 'dribble' method and the 'vaporization' method are on track to be approved. In addition, spraying of 'package bees' (in their package) with an oxalic acid solution is also on track to be approved. 

Long sleeved clothing and long pants, shoes and socks will be required for the beekeeper, plus protective eyeware and a half-face particle respirator will be required.

If your don't want to read all the documents, the sample label pretty much covers everything:
http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OPP-2015-0043-0018
Once you click that link, look for the "View Document: PDF" link on left of the page. It doesn't open directly, you have to save it to your local device then open it (at least thats how it worked for me with Chrome).

While the draft label doesn't specifically _require _an acid gas respirator, one of the supporting documents does make that _recommendation_:



> HED recommends that the label additionally specify that the respirator used when applying this product be used with an acid gas cartridge and a particulate filter.
> 
> http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OPP-2015-0043-0017


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## shinbone (Jul 5, 2011)

Under DIRECTIONS FOR USE on the label:

"Do not use when honey supers are in place to prevent contamination of marketable honey." I vaporize after harvest, but I thought that honey supers could be in place when using OAV.

also

"Place 2.0g Oxalic Acid Dihydrate powder into vaporizer." Does not mention a dose-per-super amount. It appears to assume that all users hives will be the same size and require the same 2g dose.

Interesting.


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## dsegrest (May 15, 2014)

I look forward to approval, but does that mean my 2# $10 wood bleach will be replaced with 4 oz. $50 acaricide?


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## shinbone (Jul 5, 2011)

It is my limited understanding that a pesticide must be sold with an approved label attached to the container. Consequently, the wood bleach from Ace Hardware with its current label directed towards bleaching wood technically can not be sold for use against mites. 

I doubt this means OA sold for use against mites (meaning it has the EPA approved label attached) will costs much more than OA sold as wood bleach. Since it is common knowledge that wood bleach is OA, if OA labeled for use in hives becomes too expensive, anyone can easily buy wood bleach and then use it against mites. Such use may be a technical violation by the applicator, but it is such a minor technicality that the government is not going to spend resources enforcing that rule. Just the practical realities of the situation. 

Not to mention if OA for hives becomes more expensive than OA for wood bleach, the manufacturer of wood bleach can easily slap the EPA approved label on their same product and sell it for use in hives. In other words, market forces will keep OA for use in hives at about the same cost as OA for wood bleach.

JMHO




.


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## snl (Nov 20, 2009)

shinbone said:


> Under DIRECTIONS FOR USE on the label:
> 
> "Do not use when honey supers are in place to prevent contamination of marketable honey." I vaporize after harvest, but I thought that honey supers could be in place when using OAV.
> 
> ...


The ONLY person (known to me) that advocates using OAV with the supers on was the "The Fat Bee Man." He is incorrect. On the dosage, I suspect that may change to "one gram per brood chamber."


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## Hawkster (Apr 16, 2010)

Only 28 comments that's surprising


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## snl (Nov 20, 2009)

Hawkster said:


> Only 28 comments that's surprising


True, but maybe that's good as they will not have to wade through so many in the decision making process............


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## Mike Gillmore (Feb 25, 2006)

Larry, do you have a link to the comments submitted?


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## Rader Sidetrack (Nov 30, 2011)

Comments here ...
http://www.regulations.gov/#!docket...-OPP-2015-0043;refD=EPA-HQ-OPP-2015-0043-0015

Names I recognize at that link include Randy Oliver and Tammy Horn (KY state apiarist), both in favor of approval. Note that most comments are posted anonymously.


Current score: 26 in favor of approval, 1 opposed, and 1 with no visible comment but had a Word file attached, which I chose not to open.

.


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## Mike Gillmore (Feb 25, 2006)

Thank you


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## Mike Gillmore (Feb 25, 2006)

Very interesting. It appears at this time there is only one comment discouraging the use of OA, and that from a 1 year veteran beekeeper.


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## Hawkster (Apr 16, 2010)

word document was against as well

From: barbara sachau [mailto:[email protected]] 
Sent: Sunday, February 08, 2015 2:16 PM
Subject: Re: comment

public comment on federal register 

all of these applications should be denied. it is time to stop assaulting earth with these strong poisons. particularly when nobody does any combinant tests on them to see how they react with the l8,000 other toxic chemicals approved to assault eart6h. we need to stop assaultintg the natural order of things and sites. the precautionary principle needs to be put into place. I am so sick of people carrying around these toxic poisons in their stomach. these profiteers lie to make money. this comment is for the public record please receipt. jean public [email protected]


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## Bee Herder (Jan 26, 2014)

Rader Sidetrack said:


> Comments here ...
> http://www.regulations.gov/#!docket...-OPP-2015-0043;refD=EPA-HQ-OPP-2015-0043-0015
> 
> Names I recognize at that link include Randy Oliver and Tammy Horn (KY state apiarist), both in favor of approval. Note that most comments are posted anonymously.
> ...


There are now two with attached documents. One is from a beekeeping club in Idaho with 300 members seeking approval and one is from a well lets say a "tin foil hat" IMHO.

PS "tin foil hat" confirmed. WOW after googling her name WOW, WOW, Holy Cow


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## snapper1d (Apr 8, 2011)

Hawkster I looked up her name and I see why you are saying WOW WOW WOW! I am glad she is 2000 miles away from where I am! I feel bad for her ex husband also.


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