New treatment

[user 20297]

Ahh, but that's totally different and you will be told so in no uncertain terms if you dare to point this out

.....Yes, in the one case you would be using a non-approved formulation to kill varroa and in the other you'd be using a non approved formulation to kill varroa...so totally different!

Whilst I definitely wouldn't ever consider using a non-approved treatment such as "VarroaKO",I doubt that it is illegal to use it. Although it would be illegal to sell honey for public consumption from a hive which has been treated with that product.. But the same will apply to any honey from a hive which has been treated with a non-approved formulation of oxalic acid.

Although the primary constituent of ApiBioxal is oxalic acid, you can also be certain that it contains no additives or adulterants other than specified on the label. I'm sure that we can be pretty confident in the purity of any old oxalic acid, after all, it's not got the street value of cocaine; but you can't be sure of that. As a random member of the public I think I would be surprised to hear that local honey, bought by the roadside, had been produced by bees which had been treated using a bleaching agent used by woodworkers and for controlling the pH levels of the hydroponic solution used in cannabis farming.

 

[pargyle]

As a random member of the public I think I would be surprised to hear that local honey, bought by the roadside, had been produced by bees which had been treated using a bleaching agent used by woodworkers and for controlling the pH levels of the hydroponic solution used in cannabis farming.

Judging by the enornmous quantity of blended Non-Eu honey being sold on supermarket shelves, with little or no provenance, at anything from £1.50 a jar upwards, the fact that virtually every processed food you buy and most of the fresh produce on sale in supermarkets has been treated with some sort of reagent to either make it last longer on the shelf or be free of the sort of insect damage you get in home grown veg. Eggs from chickens that are farmed which are treated prophylactically with antibiotics as a matter of course ... do I need to go on ?

The average person in the street has little concern about how their food is produced and I rather doubt that the OA sold as 99.5% OA is any different to the OA resident in the licensed treatments.

This is a non-argument. Generic OA has been licensed in Europe (who allegedly have the same stringent laws regarding animal health as we have) and in the USA. It was perverse, when the EU licensed OA for varroa treatment, that the UK VMD did not follow suit. As has been said this was simply a financial decision made with little concern about what was right for our bees.

 

[user 20297]

This is a non-argument.

Oh yes it is! ...on reflection, oh no it's not!

 

[Mint Bee]

Phil, nothing to do with VMD. They only deal with whats put in front of them (as applications) and look out for non approved products being peddles as medicines. Its down to company's not applying for a license in the UK or not considering the the UK has sufficient market to be worth the return on investment. There is no money in a simple licensed OA powder (with nothing else in it) at the price that beekeepers will pay for it (e.g. non controlled material used for woodworking). No conspiracy, just simple market economics

 

[pargyle]

Phil, nothing to do with VMD. They only deal with whats put in front of them (as applications) and look out for non approved products being peddles as medicines. Its down to company's not applying for a license in the UK or not considering the the UK has sufficient market to be worth the return on investment. There is no money in a simple licensed OA powder (with nothing else in it) at the price that beekeepers will pay for it (e.g. non controlled material used for woodworking). No conspiracy, just simple market economics

Page 3:

"EU and national legislation permits the importation of other Varroa treatments (and medicines) not authorised in the UK for use in bees under the Cascade which requires a decision by a veterinary surgeon."

Page 6 - Last paragaph ...

"The limited treatment options available to beekeepers is recognised as a serious issue for beekeepers and , in response, the Veterinary Medicines Directorate (VMD) has developed an action plan on the availability of medicines for bees. This includes working with private vets to improve the availability of authorised treatments from other EU Member States (under the cascade) and reducing the fees to medicine manufacturers which submit bee treatments for approval."

https://assets.publishing.service.g...bee-health-consult-varroaprofile-20130110.pdf
So you reckon it's not down to the VMD ? The Study was done in 2011 and here we are - 10 years on and what have the VMD done about this ridiculous situation - sat on their hands. You can say that they are only responsible for approving applications but they have the capability to authorise a generic treatment if they wish - and they choose not to - so what's the other reason apart from financial gain ?

 

[jenkinsbrynmair]

And in this case it has nothing to do with argument - what we are discussing here is a known treatment versus a quack remedy- licenced or not, we know that OA is an effective treatment against varroa which, when sublimated does not harm the bees.
This other stuff though is just a snakoil concoction of unknown substances which, as far as we know could be harmful to the bees, and, if mixed with honey could be harmful to humans.
The licenced/unlicenced argument is just a dead cat

 

[Mint Bee]

Emyr, you have a wide range of interesting and useful knowledge that you freely impart, but an understanding of medicinal product licensing is not one of your strong points. It's a minefield and just because something would be beneficial or should be done does not make it happen or even a priority.
I've previously written extensively on the legal requirements and how a generic OA could be licensed in the UK, but ultimately was told I was petty. The law may be a ***, but its still the law. no cats needed

How many governments and their departments have said this idea or that would be nice to have and done sweet FA about it. The civil servants involved don't have the luxury of deciding which rules and law's they like and will work to, and which they don't. They are normally just following the whims of the current politician using the departments head office. Bees and their medicines are a very small part of the the VMDs work. Maybe try complaining to Useless Eustice and see how far that gets you

 

[jenkinsbrynmair]

Emyr, you have a wide range of interesting and useful knowledge that you freely impart, but an understanding of medicinal product licensing is not one of your strong points.

And in this case, you are so busy trying to once again push your opinion (which is what basically it is) on VMD/OA/whatever and whether your opinion is right or wrong in that particular case has no weight in this particular discussion.
You are missing the point in what we are discussing here is not whether or not anyone should be using an unlicensed but scientifically proven substance known to combat varroa and used as an ingredient in more than one licensed product (albeit with added fairy dust), but that whether someone should spray their bees with a concoction of unknown chemicals, not even listed on the bottle, which may/may not be harmful to the bees, may/may not be harmful to humans and may/may not have any effect on the varroa mite we are trying to control

 

[Erichalfbee]

deleted as I believe the edits made by mods changed context of response

No it didn’t. I simply removed your comment about JBMs behaviour in his professional capacity

 

[Mint Bee]

Emyr I have a successful career in pharmaceutical development and regulatory affairs. I get paid very well to have the right opinion in getting medicinal products licenced. I wouldn't presume to tell you how to do your job in border force or what ever you currently do

Dani stated in thread #4 - it's not approved so that means illegal. Forget it. This applies to all products that claim to exert a medicinal effect even if scientifically proven, but not licensed. that just the way it is. It is a fact. the science bit is irrelevant unfortunately in this context. it has every bearing on the legality of the case. Neither unlicensed OA nor the new concoctions from bee bay can legally be used to treat for varroa in the UK officially. If anyone choices to ignore this then a law is being broken. I have never argued the logic of this law or discussed the potential for or the consequences of anyone getting caught

Dani - you deleted the first paragraph in my initial response where I agreed with Emyr, but then I stated we shouldn't cherry pick which laws we abide by and that one would not expect any professionals to condone breaking the law in their job if they didn't agree with it. If it read any different it was not intended to be a personal attack on Emyr's professionalism, just a general comment and I apologies. Without that context I believed it read it very differently to the original as there was no introduction to the response and it felt confrontational - my opinion

I have only ever pointed out what the licensing guidance and laws says on this subject based on my professional knowledge. You don't have to agree with it, its just the way it is. I will refrain from adding this to the conversation in the future

 

[Erichalfbee]

I have only ever pointed out what the licensing guidance and laws says on this subject based on my professional knowledge. You don't have to agree with it, its just the way it is. I will refrain from adding this to the conversation in the future

Thank you Mint Bee
Whether either Oxalic or VarroaKO are legal is actually neither here nor there really and perhaps it was remiss of me to dismiss the OP’s question so simply.
The legality of Oxalic comes up regularly. The issue here as has been explained a few times is using a preparation with unidentified ingredients legal or not.

 

[ericbeaumont]

Generic OA has been licensed in Europe (who allegedly have the same stringent laws regarding animal health as we have) and in the USA. It was perverse, when the EU licensed OA for varroa treatment, that the UK VMD did not follow suit.

There is no money in a simple licensed OA powder (with nothing else in it) at the price that beekeepers will pay for it (e.g. non controlled material used for woodworking). No conspiracy, just simple market economics.

Mintbee,
If we accept that market economics determine the likelihood of licensing OA, why is it that the EU, the US (and others) permit its use, but not the UK?

We must conclude that others thought it would be profitable; if so, what is different about the UK beekeeping market that would make it unprofitable?

 

[mbc]

Judging by the enornmous quantity of blended Non-Eu honey being sold on supermarket shelves, with little or no provenance, at anything from £1.50 a jar upwards, the fact that virtually every processed food you buy and most of the fresh produce on sale in supermarkets has been treated with some sort of reagent to either make it last longer on the shelf or be free of the sort of insect damage you get in home grown veg. Eggs from chickens that are farmed which are treated prophylactically with antibiotics as a matter of course ... do I need to go on ?

The average person in the street has little concern about how their food is produced and I rather doubt that the OA sold as 99.5% OA is any different to the OA resident in the licensed treatments.

This is a non-argument. Generic OA has been licensed in Europe (who allegedly have the same stringent laws regarding animal health as we have) and in the USA. It was perverse, when the EU licensed OA for varroa treatment, that the UK VMD did not follow suit. As has been said this was simply a financial decision made with little concern about what was right for our bees.

Yup, one wonders how this was approved without opposition, my estimation of the head of the nbu at the time plummeted

 

[Wilco]

@Mint Bee based on your experience, how much do you think it would cost to get a licence for a generic OA for sublimation? I'm guessing that since it's licenced in the EU a MRL has already been calculated so surely this would bring down the cost?

Wonder if this forum clubbed together for a licence, should it be successful we could put a tiny markup (not a fan of companies licencing things to put a big markup on them once they have market monopoly) on the approved OA and any proceeds go towards maintenance costs of the forum?

Sorry to bump this old thread.