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Extended use Oxalic Acid for Beekeepers – An update from Randy Oliver

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Extended use Oxalic Acid for Beekeepers – An update from Randy Oliver

Last month, Randy Oliver sent out this email to his mailing list for Scientific Beekeeping.

News flash: EPA’s position on experimental use of EOA

I have received numerous requests from "citizen-science" beekeepers across the country, wanting to run their own field trials of extended-release oxalic acid in their particular environments. For my research, I obtain a “Pesticide Research Authorization” from my own State Lead Agency each year, but other beekeepers have reported that their respective SLA refers them to EPA to obtain an “Experimental Use Permit” (EUP). Gina Burnett, Senior Regulatory Advisor for the EPA’s Biochemical Pesticides Branch, was gracious enough to go over the regulations with me (relevant verbiage highlighted):

§ 172.3 Scope of requirement. (a) An experimental use permit (EUP) is generally required for testing of any unregistered pesticide or any registered pesticide being tested for an unregistered use. However, as described in paragraph (b) of this section, certain of such tests are presumed not to involve unreasonable adverse effects and, therefore, do not require an EUP. (b) Except as provided in subpart C of this part or as specifically determined by the Environmental Protection Agency (EPA), it may be presumed that EUPs are not required when: (1) The experimental use of the pesticide is limited to: (i) Laboratory or greenhouse tests, (ii) Limited replicated field trials as described in paragraph (c) of this section to confirm such tests, or (iii) Other tests as described in paragraph (c) of this section whose purpose is only to assess the pesticide's potential efficacy, toxicity, or other properties. (2) The producer, applicator, or any other person conducting the test does not expect to receive any benefit in pest control from the pesticide's use. (c) For purposes of paragraphs (b)(1)(ii) and (b)(1)(iii) of this section, the following types of experimental tests are presumed not to need an EUP: (1) A small-scale test involving use of a particular pesticide that is conducted on a cumulative total of no more than 10 acres of land per pest, except that: (i) When testing for more than one target pest occurs at the same time and in the same locality, the 10 acre limitation shall encompass all of the target pests. (ii) Any food or feed crops involved in, or affected by, such tests (including, but not limited to, crops subsequently grown on such land which may reasonably be expected to contain residues of the tested pesticides) shall be destroyed or consumed only by experimental animals unless an appropriate tolerance or exemption from a tolerance has been established under the Federal Food, Drug, and Cosmetic Act (FFDCA) for residues of the pesticide. Since the FDA has ruled that “Residues of oxalic acid in or on honey and honeycomb are exempted from the requirement of a tolerance when oxalic acid is used as a miticide in honeybee hives,” the EPA does not have any restrictions as to whether the honey can be harvested and consumed. Bottom line: Unless your State has more restrictive requirements, you would not need to obtain an EUP from EPA to run small-scale trials with oxalic acid. Be clear that this only applies to use for experimental testing!

Note from Randy: Thank you all for your generous support this past year. I've received enough donations to pay for my assistant Brooke to come back and help run a slate of research projects this season.
I'm continuing to work with EPA to get the extended-release application method of OA, approved, and have requested the paperwork to become a Registrant, so that we beekeepers can legally use this method. Wish me luck!
My email inbox is crazy — no need to reply to this update, thanks.

TLDR:

Unless your State has more restrictive requirements, you would not need to obtain an EUP from EPA to run small-scale trials with oxalic acid. Be clear that this only applies to use for experimental testing!

So, if you want to experiment with mite control in your hives using oxalic acid mixed into glycerin, and carried by a cellulose media, you can [provided your location does not restrict it specifically]. No Experimental Use Permit is needed.

Happy Beekeeping!

submitted by /u/bigryanb
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