> Some of us were talking last year about getting
> motions passed at the AHPA
> and ABF meetings to get formic and oxalic approved
> for use the USA.

An overview of the formic acid situation in Canada:

In 1994, on the initiative of the Canadian Association of Professional Apiculturists (CAPA), a PROPOSED scheduling of formic acid, PMRA document C94-05, was issued. It lays out the standards and the manner in which Canadian beekeepers may use formic acid to control tracheal and varroa mites. It is available on the web. Just type into a search engine "C94-05".

The beekeepers took this as an OK for legal use of formic acid, mostly by word of mouth. Many, if not most, have never even heard of C94-05, never mind having read or followed it.

The Pest Management Regulatory Agency (PMRA), the Canadian government agency that oversees pest control products, was shifted from being under the Agriculture Ministry to Health Canada in 1995. Since then all pest control products have been undergoing review. In 2001 formic acid came up and the PMRA reviewers were not impressed with what was going on in the beekeeping community.

The use requirements set out in C94-05 were not being followed. Provincial Apiarists were publishing their own recommendations with no scientific review of new application methods. Industrial grades of formic acid with excessive levels of impurities were being sold through bee supply outlets, and beekeepers were not training themselves or their staff in basic safety procedures for handling such a highly corrosive product. Reports were coming out of beekeepers losing the skin off their hands by not using the right gloves, skin off their legs and arms from splashes going through clothing. A friend working with Mite-Wipes had a bucket he was carrying slosh acid that struck him in the face, run down behind his goggles and into his eyes that led to permanent partial loss of vision as well as leaving extensive acid burns to his face.

PMRA had had enough. In November of 2001 the industry was told it would require the registration of formic acid products or permission to use formic acid in beehives would be officially removed. The agency was willing to work with the industry through a transition period. At that point Apistan was still fully effective and beekeepers did not have to rely on any other products or management for varroa control.

None of the bee supply outfits or Medi-Vet decided to pursue the registration of liquid formic acid. Mite-Wipes decided not to pursue registration. As far as I know, PMRA has not received any form of application for registration from MiteGone. NOD Apiary Products, producer of Mite-AwayII, has been working with PMRA since January of 2002, and submitted a registration package in January of 2003. The PMRA review was completed August 24 this year, they officially decided the application has "merit", issued a PRDD, and it will soon go into the public review process.

The Canadian Honey Council(CHC) and CAPA Chemical Committee have been kept informed of this process. January 2004 the CHC voted to request PMRA to have all non-registered formic acid applications off the market in two years. They realize in the era of resistance to hard chemicals, now spreading in Canada, beekeepers need formic acid applications that are proven to work, treatments the industry can rely on. It is not known what PMRA will do with this request, but it is likely that 2005 will be the last year any form of working with liquid form acid will be legal in Canada.

The Canadian beekeeping industry has managed its approach to varroa very well. The Canadian border closure since 1987 delayed the coming of varroa until 1992, and the emergence of hard chemical resistance until two years ago. It has had 11 years to work with formic acid, to work the bugs out. It has a proven soft chemical management strategy in place, with the full registration of Mite-AwayII imminent and for oxalic acid underway.

I was at the North Dakota Beekeepers Association meeting last week and there were commercial beekeepers there talking about the collapse of their colonies over the last six weeks. A lot of these colonies were to be heading to California for almond pollination, and now there were no bees. My heart went out to them as they struggle to keep these family outfits viable. Many were envious of the Canadian situation and are looking forward to the completion of the EPA registration of Mite-AwayII by the end of 2004. Hopefully an approach to registering oxalic acid for use in the US will be worked out by the US beekeepers.

yours truly,
David VanderDussen
NOD Apiary Products

---

And a reply...

In response to several beekeepers' calls regarding NOD's e-mail to Bee-L. I asked Heather Clay, Canadian Honey Council, National Coordinator to verify the published information. I included her reply at the end of this message.

NOD indicated in the post at Bee-L that Canadian beekeepers would lose formic acid applied with various methods in two years. The CHC did not vote in their resolution to have all none-registered formic acid application off the market in two years as indicated in NOD's post.

The CHC voted to ask the PMRA to maintain the existing C94-05 to permit using formic acid in bee hives for a further 2 years. As I understand and being with the rest of provincial apiculturists, representatives of the CHC on a conference call with representatives of PMRA, most of the provincial apiculturists requested from the PMRA to maintain the C94-05. This would allow beekeepers to use formic acid in forms that are effective and safe as at meet their own environment. Limiting the use to one method of application with a single recommendation will not fit a country of a size like Canada. Several beekeepers have experienced brood loss when applied MiteAway II in the spring as reported by New Brunswick, Nova Scotia and Quebec beekeepers. Beekeepers in the Prairie provinces have short spring and fall with quick changes of temperature. This change of temperature does not allow them to rely on Mite Away or any other type of single application of formic acid. In limited areas, beekeepers are using it, but so far the multiple application is the preferred method of application. The short season and intensive management would allow beekeepers to visit their hives in the spring once every week. Thus, beekeepers would be able to apply formic acid on regular bases.

With the same frame work in mind, the CHC is heading the way to register the oxalic acid with PMRA. It is always a good policy to give several options to beekeepers to choose from. This will allow beekeepers to adopt the method that fits their management system and their environment.

medhat

Heather Clay response:

Hi Medhat and John The CHC voted to ask PMRA to maintain the existing arrangement for formic acid for another two years. The intention was to allow beekeepers access to the various applications of the product during that time. The wording is below.

#15 Carried Whereas the treatments using formic acid fit within Integrated Pest Management and will be used on an immediate and long term basis. Be it resolved that the Canadian Honey Council asks the PMRA to maintain the existing C94-05 to permit using Formic Acid in beehives for a further 2 years"

http://www.honeycouncil.ca/users/folder.asp?FolderID=2725

Best wishes
Heather

> Is it possible to go over how Canada
> is handling the heavy metal side of the formic acid
> treatments and what they are doing and/or how regulating,
> to not worry about hive product contaminations of honey,
> wax, propolis, and pollen?

I recall looking at the chemical profiles of commercial formic some many years back, and concluding that the levels of contaminants in commercial formic are only slightly different from higher grades and negligible when considering the following:

1 how tiny an amount of formic is used
2 what a tiny part of that small amount of formic contaminants make up
3 the long period of time between treatments
4 that formic is used in the brood chamber only
5 the amount of these same elements that are in the surrounding environment
6 that the formic is diluted with water that may contain some of the same minerals,
7 bees may carry similar amounts of similar elements into the hive with water they gather
8 that most of the formic diffuses out of the hive
9 there is no proof that significant residues remain in the hive
10 the fact that bees consume most of the honey and pollen in the brood chamber

Of course, others might reach different conclusions, depending on their assumptions and what they need to believe.

Allen

And, after more thought...

Let me add several other things to my previous comments:

When we used formic, it was evaporated from pads, which were discarded.

1. I do not know if the minuscule amounts of impurities documented evaporate with the formic or stay in the pad.
2. Apparently the formic dissipates from the hive fairly rapidly, leaving no measurable residue after a time.

I do not know if the impurities leave with the formic, but if they are so bound with the formic that they have not been left behind to that point I wonder.

Any such question is a good question. Assumptions should be tested, and sometimes in the process, we are surprised by what we learn. Also, with the rapid expansion of knowledge underway these days, what was assumed correct ten years ago may be subject to reconsideration today.

allen

> Just a case of "shoot the messenger". NOD has only
> responded to the FA-PMRA situation, not caused or ever
> stirred it. They came to us in Nov. 2001 threatening
> to pull C94-05 unless registration took place.

Perhaps, perhaps not. These authorities seem to be attracted to any private party making claims. An oxalic promoter on the West coast got his wings clipped, too, by CFIA for making claims, but those doing research or responsible private treatment in consultation with provincial apiarists are left alone.

I suspect that, by attempting to create a commercial product that you have raised the bar, and attracted attention to, and endangered, a tacit working agreement made between those authorities and CAPA.

> CHC just didn't have time to deal with the offer...
> Due process is to draw up a resolution for the AGM,
> discussion, amendments and vote...

True, CHC is very cumbersome, and often has trouble making good decisions for those reasons. I do definitely know about that!

Personally, however, I think you are forcing the issue and bringing formic registration to the front burner by your activities, and in the process may well make it difficult for the many Canadian beekeepers who have a safe, effective, and inexpensive formic regime in place. Moreover, we know by experience that your product is not the answer for many of us in the West.

Maybe we do need to work together to get a formal general registration place to allow all existing formic use, but, to date, no one has had big problems with the status quo, and everyone was careful not to rock the boat and possibly bring on overregulation.

allen

I try to keep things level, so, after some thought, added this:

In reviewing recent discussion here and where the topic has gone, I realize that, perhaps I need to clarify my original intent when I wrote:

> Some of us were talking last year about getting motions passed at the
> AHPA and ABF meetings to get formic and oxalic approved for use the
> USA. Somehow, the idea came to nothing, and now, it is looking like a
> fumble that could lose the game for many.

I appreciated NOD's contributions, because it illustrates that there are numerous perspectives to the topic, and how the development of commercial product or products a situation can compete with and threaten non-proprietary applications using generic products.

Speaking very generally, the claims that developers of branded products need to make to differentiate themselves and to justify their 'value added' to what are often really commodity items, intentionally raise concerns in prospective customers, and the public, and can alarm regulators.

Marketers and developers of new processes typically emphasize safety, efficacy, and convenience in their own products, and, even if they do not intentionally denigrate the alternatives, this strong emphasis on the desirable properties of their product or process (even if they are marginal advantages) raises doubt about competing products or processes in the minds of listeners. The strong emphasis on safety, convenience, and efficacy, true or not, necessarily implies -- human psychology being what it is -- the lack of these characteristics in competing concepts or products. Otherwise, the listener thinks, why would anyone mention them?

Few really bother to check the facts, and most go along with what is most familiar. Since the promoter invests money and time into promotion, while others may not bother, we wind up with the best promoted product, and not necessarily the best product. I'm writing this on a Windows® computer, and I think that amply proves my point.

Anyhow, back to the original point: My friends who were discussing AHPA and ABF motions were not looking for a commercial sponsor, but thinking more along the lines of how formic and oxalic have been used in Canada and Europe and hoping that such use could be permitted -- or at least not prosecuted -- in the US. In actual fact, it very much appears that the several attempts to come up with a commercial formic product in the US, which have failed, have distracted the industry from what it really needs: a go-ahead to use the products as they are used safely and successfully elsewhere in the world.

That's where the motion came in: We think that the ABF and AHPC each must make it an official policy to work towards obtaining official approval -- or at least official indifference -- for (at least temporary) beekeeper use of formic and oxalic, without having that approval tied to any proprietary product.

Let's hope, for the sake of the bees -- an the almond industry -- that something makes people wake up and see that beekeepers need to do this for themselves. It CAN be done. Of course there are those who can make very powerful arguments that it cannot, but if they get onside and turn their minds and their writing skills to the job and prove of why it CAN be done, instead of wasting effort proving why it cannot happen, everyone will benefit.

After all, the US bee industry has put up the funds and willpower for countervail, and created the NHB. I cannot believe that they cannot manage to get approval for at least some generic formic and oxalic applications. I'm sure that the almond people would put up some bucks and pull some strings.

Anyhow, it is really not my business.

allen