# Section 18 Request



## TWall (May 19, 2010)

Mark,

Who worked to get the original Section 18? I believe they are typically done by larger grower groups or sometimes Extension. I have never been directly involved in the process. I'm sure you would need to document the need to for the special label.

Tom


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## Rader Sidetrack (Nov 30, 2011)

Here is the EPA page on Section 18 approvals. 
http://www.epa.gov/opprd001/section18/

The key phrase is


> Emergency exemptions may be requested by a state or federal agency. [HIGHLIGHT]Most requests are made by state lead agricultural agencies.[/HIGHLIGHT]


It looks as though you need to start with NY Department of Environmental Conservation here:
http://www.dec.ny.gov/chemical/298.html


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## sqkcrk (Dec 10, 2005)

Thanks. The person who has made these requests has retired from Cornell and has not been replaced. I have a call into NYS DEC. Thanks y'all.


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## sqkcrk (Dec 10, 2005)

On the Mann Lake Online Catalog Site it shows that only 6 States have Section 18 renewals for 2014. I wonder why?


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## wildbranch2007 (Dec 3, 2008)

I would think it would be Paul Cappys responsibility.


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## TWall (May 19, 2010)

Mark,

Since a Section 18 had been previously approved it may be easier to re-submit a request. If a local organization would do some of the legwork it may be easier to find someone at CCE to 'do' the work. You might see if there is anyone else with experience submitting Section 18's. They tend to be more common with minor crops like fruits and vegetables.

Tom


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## sqkcrk (Dec 10, 2005)

wildbranch2007 said:


> I would think it would be Paul Cappys responsibility.


It has always been something which Nicholas Calderone did. Nick is now retired and moved out of State. So I am doing what I can to see what can be done to get the renewal request passed on to the EPA by the NYS DEC.

In the mean time I am looking for and finding, thanks Rader, more info about Section 18s and how they are obtained. It does look like something which NY's Dept. of Ag should be involved in.

I talked to Paul Cappy this morning and may well be going back to him for further help and advice.


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## wildbranch2007 (Dec 3, 2008)

http://www.dec.ny.gov/chemical/8528.html

Section 18 Emergency Exemption Filed with NYSDEC at least 105 days before decision is needed. 30 days to determine completeness. Files with EPA at least 60 days before decision is needed. 

the dec needs to get the request, I have an email that says who did it last time but my mail system is down


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## wildbranch2007 (Dec 3, 2008)

If you ever figure out how to get someone to put in the request, even though the state has not updated any of there doc from last year the best I can see, you should also see about
amitraz.

hopguard and amitraz were on the expedited emergency list

http://pmep.cce.cornell.edu/regulation/sec18/2013/index.html

if I remember on MAQS's those are not section 18. apiguard I haven't found yet, got one of the containers around, I think it was also section 18, but still looking.

boy I'm glad I always buy enough in the fall for the following spring.


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## wildbranch2007 (Dec 3, 2008)

http://www.dec.ny.gov/docs/materials_minerals_pdf/pestprod.pdf

according to the dec as of 2/3/2014 amitraz, hopguard, and apiguard are still registered in N.Y., knowing how things are done here, I have this normal sinking feeling, that someone hasn't been doing their updates correctly.


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## sqkcrk (Dec 10, 2005)

Mike,
I talked to a person at the DEC who told me that when she gets what she needs from Cornell she will forward that on to the EPA and expects approval of the request. I will contact her again and ask about the amitraz.

I will also be talking to the person at Cornell who has been working to formalize the request. I'll let you know when I know of the approval. Thanks for the links.


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## themrbee (Oct 20, 2006)

Hi Mark
apivar has sec3 
http://apivar.net/epa-section-3-sta...can-now-be-sold-and-used-anywhere-in-the-u-s/


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## sqkcrk (Dec 10, 2005)

Thanks


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## BMAC (Jun 23, 2009)

Mark have you ever used Hopguard down south?


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## sqkcrk (Dec 10, 2005)

No. U?


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## BMAC (Jun 23, 2009)

I bought some two springs ago, but ended up handing it all over to Lynn as he needed to do emergnecy treatment to his queen yard. It's aweful expensive. Lynn said it made his bees run away from the strips after he put it in the hive.

Do we really need Hopguard in NY?

Would having it in NYS just add another option to the available mite treatments?

Personally I like Thymol treatments. Expensive but extremely effective. Though I still consider mixing it up a bit and using Hopguard as an early spring treatment while Im down south.

Why do you want it in NY?


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## sqkcrk (Dec 10, 2005)

Choice. That's the reason. So people have the choice.


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## BMAC (Jun 23, 2009)

Besides our wonderful apiguard what other "effiective" mite treatments do we have available here in NY?

If you need more votes for bringing Hopguard in let us know. Im not opposed to it, and am happy to support it, just curious on the motivation 2 years after it hit the market. As liberal of a state as NY is I was shocked it didnt instantly HOP on the Hopguard with section 18. I sent Paul Cappy an email the first year it was available and the reply I got back was we had enough miticides here for use. Apparently it also costs lots of MONEY to get it approved. hmmm. Interesting thought there.


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## sqkcrk (Dec 10, 2005)

BMAC said:


> If you need more votes for bringing Hopguard in let us know. Im not opposed to it, and am happy to support it, just curious on the motivation 2 years after it hit the market. As liberal of a state as NY is I was shocked it didnt instantly HOP on the Hopguard with section 18. I sent Paul Cappy an email the first year it was available and the reply I got back was we had enough miticides here for use. Apparently it also costs lots of MONEY to get it approved. hmmm. Interesting thought there.


No votes are needed. It's just a matter of certain people doing their jobs, which it appears they are doing.

Motivation? For what? The seeking of Section 18 renewal?

Section 18 use permit aren't issued by NYS DEC or Ag&Mkts. EPA issues Section 18s. Individual States have to request the Section 18 for pesticides not released or approved by the EPA for use in all States.

"costs lots of MONEY to get it approved."? Maybe for the manufacturer/distributor, but not us.


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## BMAC (Jun 23, 2009)

Which in this case I believe it will cost Mannlake the bundle of cash to get it approved from state to state.


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## jim lyon (Feb 19, 2006)

BMAC said:


> Personally I like Thymol treatments. Expensive but extremely effective. Though I still consider mixing it up a bit and using Hopguard as an early spring treatment while Im down south.
> 
> Why do you want it in NY?


I was thinking of experimenting with it post check back down south if I dont like the mite counts I am seeing. Seems like hive sizes in the 4 to 5 comb range and April temps might well be ideal. Anyone actually tried this?


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## wildbranch2007 (Dec 3, 2008)

jim lyon said:


> I was thinking of experimenting with it post check back down south if I dont like the mite counts I am seeing.


I've never used it but I posted a link to a study done in Canada where they said it was only 40% effective, but I never could confirm if the 40% was for one treatment or the three treatments people that have used it recommend.

a post on bee-l from canada's Medhat Nasr, I'm not sure what the second 40% kill means for the method most people are using here ie 3 times at one week interval. 

http://community.lsoft.com/scripts/w...F=&S=&P=188880

Peter and others: I have a student just defended her M. Sc. last week. One experiment testing HopGuard showed that the efficacy is about 40% mite kill in the fall with a single application. Repeated experiment with 3 applications in the spring once every week yielded same efficacy (40%). Bees clean up and chew the strips within 4-5 days. Kill was high within 1-3 days max. HopGuard has potential if the application method modified. 

Medhat 

Dr. Medhat Nasr 
Alberta Provincial Apiculturist 
Pest Surveillance Branch 
Research and Innovation Division 
Agriculture and Rural Development 
17507 Fort Road NW 
Edmonton, AB T5Y 6H3 Canada


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## jim lyon (Feb 19, 2006)

If you are doing it at the 3 week mark after being made up a single treatment would suffice (I'm talking about qc's and brood breaks). 40% effective? Not sure what that means. Need to find that study.


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## beemandan (Dec 5, 2005)

jim lyon said:


> Anyone actually tried this?


Jim, I haven't tried it exactly as you are thinking....but I have tried it in several different applications and was totally unimpressed. it MIGHT be ok in a broodless colony but I wouldn't bet the farm on it.


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## jim lyon (Feb 19, 2006)

beemandan said:


> Jim, I haven't tried it exactly as you are thinking....but I have tried it in several different applications and was totally unimpressed. it MIGHT be ok in a broodless colony but I wouldn't bet the farm on it.


Thanks Dan. I wont bet the farm thats for sure....note the use of the word "experimenting" in post #22  Considering trying it side by side with OA, thymol and no treatment at all. Then comparing fall counts.


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## BMAC (Jun 23, 2009)

Jim as much of a PITA it is to properly administer and the cost of it, I think Hopguard would be most effective in treating 5 frame nucs just before they hit the road to go north. Pop lids and drop a single strip in the center. That was my intent, but I didn't actually do it. Maybe this coming spring I will do it.

However your experiment does sound good. Think you will follow thru and do it? We would all be curious to know the results.


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## jim lyon (Feb 19, 2006)

According to ML its currently available in California, Delaware, Iowa, Idaho, Illinois and Washington. Texas insp. was surprised the paperwork hadnt been done and is checking on it. ML says Hopguard 2 should be available very shortly (like weeks). We'll see.


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## sqkcrk (Dec 10, 2005)

BMAC said:


> Which in this case I believe it will cost Mannlake the bundle of cash to get it approved from state to state.


I don't think that Mann Lake will have to spend any more money than normal. ML won't have to spend money in each state, as far as I know. I don't even know that it costs a "bundle of cash" at all. Documentation and a show of need, but cash? I don't know.


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## wildbranch2007 (Dec 3, 2008)

jim lyon said:


> ML says Hopguard 2 should be available very shortly (like weeks). We'll see.


think that will require a new letter being sent in??


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## sqkcrk (Dec 10, 2005)

Hopgaurd was granted Section 18 last year and conditions haven't changed so in all likelihood the EPA will fast track approval of the renewal request.

Seems like maybe there is some confusion about this Thread. I didn't bring this up because I wish to use Hopgaurd or because I need EPA approval, but because for beekeepers in NY State to legally buy and use Hopgaurd a Section 18, issued by the EPA to the State of New York, has to be sought and granted. The seeking part of the process is underway. When the approval part happens I have been told I will be notified by those doing the seeking.

If anyone from another State other than NY does wish to buy and use Hopgaurd maybe you should be talking to the folks in your State who handle such things.


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## BMAC (Jun 23, 2009)

So NY'ers were able to legally purchase hopguard in NYS in 2013?


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## beemandan (Dec 5, 2005)

sqkcrk said:


> Seems like maybe there is some confusion about this Thread.


I don't know about that. I think many threads weave back and forth, occasionally crossing the original topic, at the same time picking up tidbits that aren't part of the initial intent. Sometimes those tidbits become the focus and that causes problems. I don't think this thread strayed too awful badly. I didn't lose sight of your purpose....although I did reply to some tids and bits. 
Just my opinion.


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## sqkcrk (Dec 10, 2005)

BMAC said:


> So NY'ers were able to legally purchase hopguard in NYS in 2013?


Yes.


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## sqkcrk (Dec 10, 2005)

beemandan said:


> I don't know about that. I think many threads weave back and forth, occasionally crossing the original topic, at the same time picking up tidbits that aren't part of the initial intent. Sometimes those tidbits become the focus and that causes problems. I don't think this thread strayed too awful badly. I didn't lose sight of your purpose....although I did reply to some tids and bits.
> Just my opinion.


I got a cpl of PMs which made me write what I wrote.


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## beemandan (Dec 5, 2005)

sqkcrk said:


> I got a cpl of PMs which made me write what I wrote.


What?! Are you suggesting that not everyone agrees with me?


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## sqkcrk (Dec 10, 2005)

Huh?


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## jim lyon (Feb 19, 2006)

wildbranch2007 said:


> think that will require a new letter being sent in??


I am guessing yes. 
An official I spoke to in Texas checked with their Dept. of Ag. Who handles this and they said probably another 30 days until its finalized because the request from the state beekeeping organization came in late. They also suggested buying it in my home state and hauling it down if need be. LOL. Ya gotta love how these various gummits work.


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## sqkcrk (Dec 10, 2005)

sent an e-mail about that to NYS DEC and to Nick Calderone asking whether the Section 18 is for the Brand Name Product or for the active ingredient. Hopgaurd 2 still has hops in it. Only more I think.


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## beemandan (Dec 5, 2005)

sqkcrk said:


> asking whether the Section 18 is for the Brand Name Product or for the active ingredient.


I bet it's the product. Premixed with a tested dosage.


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## TWall (May 19, 2010)

I would concur, the new product will have a new label. It is a different product even though it has the same active ingrdient.

Tom


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## wildbranch2007 (Dec 3, 2008)

sqkcrk said:


> A Section 18 for Hop Gaurd is needed in NY to renew approved use and sale of Hop Gaurd in NY.


looks like you got it done

Subject: FIFRA Emergency Exemption (Section 18) Approval - HopGuard/Varroa Mite

A FIFRA Section 18 specific exemption has recently been granted to New York State by the United States Environmental Protection Agency (EPA) for the use of HopGuard (EPA registration number not assigned) to control varroa mites (Varroa destructor) in honey bees in New York State during 2014. HopGuard contains the active ingredient of potassium salt of hop beta acids.

A copy of the Section 18 should be available through PIMS (http://pims.psur.cornell.edu) as well as the regulatory section of our website (http://pmep.cce.cornell.edu/regulation/index.html) shortly.

Users must have a copy of the Section 18 exemption in their possession at the time of use.


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## sqkcrk (Dec 10, 2005)

Yes Mike, it got done. Thanks for Posting the announcement. I accidently deleted the e-mail before I could copy and paste it. Darn you Yahoo E-mail!!


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## johng (Nov 24, 2009)

Nice work Mark.


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## sqkcrk (Dec 10, 2005)

Thanks, but I did little but contact the people that Nick Calderone asked me to, who were already doing the work. The folks at Cornell University in Ithaca,NY and at the NYS DEC in Albany did what needed doing to get the process completed.

It's nice when the system works.


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## Wisnewbee (Apr 8, 2011)

I'm just wondering why all the work for a product that does little more than a sugar dusting? The product is only about 30% effective when used as directed. Yes I used Hopguard last year, and the mites just laughed. Maybe when Hopguard II is released it will be better. The manufacturer of Hopguard knows the product doesn't do what they said it would do. Hopguard II is supposed to be much more effective. The goop is the same, just 3 times the amount, applied with a corrugated cardboard strip. This allows the good to stay moist longer to increase the effective time. I'm getting my Hopguard II info from a guy who talked to the manufacturer at the show in January.

The $200 spent on Hopguard last year was money flushed down the toilet.


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