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Alastair

Is Oxalic Acid Legal in NZ?

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23 minutes ago, john berry said:

I have reported bayvarol as having failed but my test results were basically declared invalid as genetic testing on the mites said they were still vulnerable to it. It's a pity someone didn't tell the mites that. If a synthetic does fail then the manufacturer is required to inform MPI of this fact.

And like I said the answer to whether you can use oxalic strips or not is maybe which is not a good answer. Think about what happens if you sell some honey to a buyer who then makes up an order and sips it overseas only to have it rejected.

MPI must be aware that  current synthetics are failing and there is an urgent need for a fully legal Safe and effectivereplacements and oxalic strips seem to fit the bill  so why aren't they doing something.

 

Hi John

I understand the frustration.

I understand from Bayer that there are two known genetic mutations giving varroa immunity to fumethrin (bayvarol) one in North Amewrica and the other in Europe.

Neither of those two have been identified to date in NZ varroa analysed (which possibly includes your varroa?).

But that does not mean our varroa may have developed a third mutation giving varroa immunity......so my suggestion is we need more local NZ research

on the effects on NZ varroa.

This is why I strongly support the honey levy for this type of focussed research.

 

At a recent Conference Daimen O'Connor (may have been Rotorua) called for more traceability in the honey industry - "you could track the bees or the hives - whatever you do you need to do it extremly well".

There have been at least two cases I am aware of export shipments being turned back by overseas countries - Amitraz residues exceeding MRLs and AFB spores were detected.

I have also been told that ragwort pyrrolizidine alkaloids  residues have also been identified in NZ honey, and after driving through the Waikato last week I was surprised by the amount of flowering ragwort about. Pyrrolizidine alkaloids are the next toxic problem after Tutin toxin in honey. They are already a problem in Europe.

Every beekeeper needs to know that most of our major importing customer countries test every shipment that arrives on their border for toxic residues and biosecurity risks.

MPI does not test every shipment prior to export, that is dealt by the exporter. MPI has a shopping basket test for residues every two years. https://www.mpi.govt.nz/food-safety/food-monitoring-and-surveillance/food-residues-survey-programme/

I am aware of one buyer of honey who tests all purchased product and all blended export product. 

I am aware of hort produce exporters who test every shipment leaving their facilities - one exampe is Zespri.

 

If the syntehics are failing keep sending adverse event reports to MPI and a please forward copy to me c/- Apiculture NZ   info@apinz.org.nz   I will see that they are followed up.

 

MPI removed their ability to register products when they repealed the Animal Products Act 1999 in 2006.

MPI is no longer a problem solver for NZ Primary Industries.

If you want an Oxalic strip product registered it will have to be up to an overseas or NZ company. The applicant is ApiQuip Ltd.

But good news may not be far away. Aluen Cap was approved for importation and release on 31st August 2018.

The application purpose was; "To import for release Aluen Cap, an oxalic acid dihydrate diluted solution embedded in a cellulose strip for use as an in-beehive miticide treatment to control Varroa mite infestations". Source EPA Website https://www.epa.govt.nz/assets/FileAPI/hsno-ar/APP203653/APP203653-Final-Decision-Signed.pdf

The challenge is now to register this as a Veterinary Medecine under the ACVM Act, and then it can be advertised and sold as a registered pesticide.

 

 

 

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4 hours ago, M4tt said:

Is there any lab in NZ testing for oxalic residue in export honey and if so , does anyone know of any failing the test ? 

 

It would be interesting to see testing for Gl residue too. The discussion about higher strength brews has had this as one of its advantage - the less you put in the less that can contaminate.

Edited by cBank

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On 13/01/2019 at 9:05 PM, Philbee said:

Done

The only patent that come close to the Paper Tape Staple was registered in most countries except NZ

The Edge protected Staple is half way through the Patent process and IPONZ have agreed to the Claims in this regard.

I will pursue full registration ASAP and the cost is actually small fry as the industry has already been informed that the Staple will always be cheap but to expect the cost of compliance to be added on.
This could be 20 cents per staple 

For the record the process has started, a consultant engaged, trial being designed and provisional licence application being put together.

I have adequate personal resources to see this through.

I would estimate that the Paper Tape Staple is midway through it's journey

 

Edited by Philbee
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On 13/01/2019 at 5:39 PM, Don Mac said:

Guys, the following is a summary of where you folk are today;

1) MRLs. Oxalic acid and Formic Acid both have an MRL (Maximum Residue Levels) exemption when used as an veterinary medicine to control varroa mites in beehives.

This has been issued under sections 383(8)(a) and 405 of the Food Act 2014, recently updated on 5th December 2018.

PLEASE NOTE  LACTIC ACID DOES NOT HAVE ANY MRL EXEMPTION TO DATE so should not be used on beehives.

The MRL exemption applies only to bee hive products sold in NZ, it does not apply to exports of honey. If your honey is exported it has to apply with the MRLs applied by the importing country. 

2) GRAS. Glycerine (food Grade) is on the MPI GRAS Register. GRAS - Generally Recognised As Safe. 

This is authorised under the ACVM(Exemptions and Prohibited Susbstances) Regulations 2011, which you should consult to ensure your product is exempt from registration.

You are legally required to confirm  that any additive in your product, animal feed or pet food is 'generally recognised as safe' (GRAS). Always use "Food Grade" glycerine.

https://www.mpi.govt.nz/processing/agricultural-compounds-and-vet-medicines/acvm-registers-and-lists/#sts=ACVM substances generally recognised as safe (GRAS)

3) Own Use.  It is legal to mix and make your own veterinary medicine for the control of varroa in your own hives.

The exemption is in the ACVM (Exemptions and Prohibited Substances) Regulations Schedule 2 Part A, 2..  Reccommended reference is The Beekeeper July 2018 edition.

Also refer to MPI Notice 794 Agricultural Compounds Exempt from Registration Requirements for conditions of exemption.  www.mpi.govt.nz/dmsdocument/21653

 

You have a legal responsibility to under take the following minimum steps if making your own product. Refer to MPI Notice 794 for the rest of the requirments.

a) You cannot sell the product to anyone, even if you mixed an extra bucket of strips.

b) You should be very careful promoting it - advertising is banned. Discussing on a website could be considered as promotion - MPI have not made web communications exempt from promotion to date - they are keeping their powder dry. Web promotion and discussion is a can of worms.

Randy Oliver's website can be discussed as he outside the reach of any NZ jurisdiction.

Some of this forum's members I believe have had conflicting communications with MPI about their comments.

c) You should have documented all batches with the amounts mixed, the date of mixing and the standards of product used and the hives applied to. Everything should be traceable. 

d) When purchasing raw materials always insist you supplier supplies a Techinical Specification (prior to purchase) and a Certificate of Analysis (CoA)  for the identified batch you have purchased and have had delivered. Always keep this information with your batch documentation which you are required to hold for 5 years! 

Reputable suppliers should have not problem meeting this minimum standard - go elsewhere if they cannot. 

Low price product is not worth the future problems you may have. 

Note your standard of manufacturing is measured exactly against that complied with by a commercial manufacturer. 

e) Adverse Events.  If you have 'stuff up';  the varroa did not die; you overdosed and killed the hive; or the person handling the product had a bad news event; or etc etc 

You are legally required to report this event to MPI as an adverse reaction https://www.mpi.govt.nz/processing/agricultural-compounds-and-vet-medicines/adverse-events-with-acvms/  .

Adverse Event Reporting is required for exempt non registered products. An MPI investigation may require a review of your documentation trail. 

If you or a worker has a 'bad news event' handling your veterinary medicine you have made you must report this to WorkSafe (you are working with a hazardous substance).

This is a legal requirement of the Health & Safety At Work Act 2015.   https://worksafe.govt.nz/notify-worksafe/incident/

4) Harvest Declaration - you must complete a Harvest Declaration for Bee Products if your product is intended to be exported to support the fitness for purpose and traceability of bee products intended for human consumption. That means you must declare the use of the organic acid used.

Note some large buyers for the NZ market may require a signed harvest declaration. In addition some large overseas corporate buyers may require a copy of the hive treatment diary in addition to residue testing prior to purchase. This is very common today in the NZ Fruit export industry. You must declare on the harvest declaration the use of own mixed varroa treatments. If worried always check with your honey buyer their specific requirements.  

5) Other options. To date MPI has registered one containing formic acid MAQS+ and one product containing oxalic acid - Api Bioxal.

If in doubt or not sure about own mixing and own use, see you beekeeping supplier and purchase one of these products.

 

 

Thank you for this post - I have had it bookmarked to read for ages and it is incredibly helpful and must have taken a long time to compose.
Please could you clarify point 1. I have read the actual document (also posted in this thread, but added here) and wondered if i was misunderstanding it. There really is no limit? What does this mean in practice as I suspect that it doesn't mean you can expected jars of OA with a hint of honey on NZ supermarket shelves.

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CBank - very good question.

I agree that there would be real stink if someone did offer "honey hinted oxalic acid".

There are two issues in the Food Safety Document Maximum Residues for Agricultural Compounds and they do require clarification from MPI Food Safety in my opinion.

  1. There is no MRL listed for oxalic acid, so the default limit would be 0.1mg/kg. See page 4.                                                                                This is in .Part 6 of the Food Regulations 2015 (the regulations)
  2. But it is listed as having an exemption  in Appendix 3 of the same document.

Now I have not seen any residue data showing the levels of oxalic acid that have been detected in honey. 

If I had access to residue data the questions I would ask: is the default level being exceeded by some types of OA treatment or not?

 

We also have to consider that oxalic acid is a common naturally occurring plant based product and if you seek on google you will find many foods contain oxalic acid. Rhubarb leaves have such high levels they are considered toxic to eat, hence we eat only the stem.

But it appears in a single serving we can eat 100mg - 900 mg / serving in beet greens, rhubarb stems, spinach,nuts and other foods safely and our body can synthesize it. 

 

Like much of what we eat we consume some bad actors with the good ones - which means there is no perfectly safe diet.

I am not aware of any evidence that OA levels are excessively high in honey or have caused a problem anywhere overseas.

 

So that is an answer which is not conclusive.......but we just do not know.

My advice do not put any honey in the OA jar or the OA/glycerine pot without thorough cleaning. 

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