The Standing of Our Business Relating to Varroa Administration

and

What Can We Do About It?

Half 2

First Printed in ABJ August 2023

Randy Oliver

ScientificBeekeeping.com

CATCH UP

Final month I wrote in regards to the choices (authorized or unapproved) that beekeepers are taking to take care of varroa because it evolves resistance to amitraz. On this installment, I’ll evaluate proposed choices for the beekeeping business may take on the legislative stage, particularly what we may foyer for within the upcoming Farm Invoice. I’ve spent a while reviewing every proposal, and recommend that we don’t waste our time on these with little likelihood of success — reminiscent of the two(ee) exemptions for extended-release oxalic acid handed by a number of states, after which later denied by EPA.

THE SHIFT FROM XENOBIOTICS TO “NATURAL” BIOCHEMICALS

A few of the earliest pesticides utilized in agriculture, reminiscent of copper, arsenic, mercury, creosote, naphthalene and nicotine, weren’t in any means ecologically “pleasant.” Because the Second World Warfare, these nasty pesticides have largely been supplanted by artificial artifical chemical substances (xenobiotics not present in nature), reminiscent of organochlorides, organophosphates, carbamates, and neonicotinoids ― to which organic methods had by no means been uncovered. Because of the persistence of a few of these xenobiotics, their damaging results upon off-target species and the setting, and their unknown long-term results upon our well being, there’s a push to as a substitute use biochemicals naturally produced by crops or animals, which shortly biodegrade, and to which our bodily detoxing mechanisms have tailored over the course of evolution.

The EPA and USDA are very a lot in favor of this shift, making a particular case for naturally-occurring “minimal threat” pesticides and “biopesticides” (naturally occurring substances that management pests by non-toxic mechanisms). Sadly, positive distinctions and arbitrary selections have led to together with varroa-toxic formic acid, menthol, and sucrose octanoate in EPA’s checklist of biopesticides [[1]], whereas excluding oxalic acid and thymol from each that checklist and the Minimal Threat checklist [[2]] (Desk 1).

OUR PROBLEM WITH CURRENTLY-REGISTERED PRODUCTS: VARROA CONTROL WHILE COLONIES ARE PRODUCING HONEY

In lots of areas, as a consequence of local weather or the timing of the nectar flows, there are not any sensible and efficacious registered therapies for controlling varroa whereas honey supers are on the hive. It is a drawback, since throughout this era mites proceed to breed at an exponentially-increasing price — resulting in severe, however preventable, colony losses later within the season.

There are three predominant points concerned:

• Because of the have to keep away from contamination, some merchandise aren’t allowed to be utilized in the course of the manufacturing of honey for human consumption.
• Label restrictions unreasonably restrict utility strategies of registered merchandise, regardless that they’ve tolerance exemptions in honey.
• Time-consuming labor or applicator questions of safety are concerned with the three pure therapies which are authorized to be used in the course of the nectar circulate (detailed under).

There is no such thing as a want for beekeepers to battle the EPA, however somewhat we must always ask EPA, and maybe our legislators, to assist us, as a minor business, to have the ability to legally use expanded utility strategies for the protected and non-contaminating pure therapies, notably oxalic and formic acids, and thymol. Sadly, the few registered merchandise available on the market could also be unreasonably costly, and their labeling too restrictive for the wants of beekeepers in numerous climates and operations.

THE RISK TO APPLICATORS

The EPA should take note of the danger to the applicator concerned with the applying of any pesticide. However not like a farmer who can spray a product onto their crop from the protection of the cab of an air-conditioned tractor, the beekeeper should apply varroa therapies — working within the full solar on scorching days — to the brood chamber of every particular person hive.

The applying strategies for the currently-registered miticides authorized for utility in the course of the nectar circulate aren’t solely unreasonably time consuming, but in addition contain unacceptable dangers to any beekeeper having various hives. There are three predominant dangers concerned are:

• The bodily exhaustion and likelihood of bodily damage concerned within the elimination and restacking of lots of or hundreds of heavy honey supers to be able to apply the product to the brood chambers beneath them (particularly when repeated functions are required).
• The warmth stress concerned with the above labor in the course of the typical excessive temperatures that happen in the course of the nectar circulate, particularly with the required Private Protecting Tools (thick vinyl gloves, heavy clothes, or masks) referred to as for by the label. The elimination and restacking of honey supers is difficult bodily work, which in scorching climate can simply result in warmth stroke.
• The publicity threat to the applicator concerned with the unavoidable fumes of formic acid and heat-vaporized oxalic acid, particularly when concerned when treating hundreds of particular person hives throughout scorching climate. The laborious bodily work and warmth stress enormously enhance the prospect for accidents resulting in acid vapor publicity.

Speaking level for our legislators: What our business wants are extra strategies for controlling varroa whereas honey supers are on the hive, notably cheap pure therapies or utility strategies that pose much less threat to the applicator.

UNDERSTANDING THE EPA

For us beekeepers to ask for any legislative motion, we gotta perceive the mandate that EPA works below.

The Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) was signed into regulation by President Harry S. Truman in 1947 to manage the distribution, sale, and use of pesticides. In 1972 energy was transferred the Environmental Safety Company (EPA) (which had been established by President Richard Nixon in 1970). The primary iterations of the regulation centered on labeling and making certain that chemical substances weren’t adulterated, however didn’t concentrate on the environmental and public well being results of pesticide use; this didn’t come till 1972. Congress has handed amendments to FIFRA quite a few occasions since then.

FIFRA now incorporates 284,623 phrases [[3]] and is enforced by the Workplace of Pesticide Packages (OPP).  Until particularly exempted, all pesticides distributed, bought, or used in america have to be registered by the EPA and controlled by the Workplace of Pesticide Packages (OPP). With the intention to achieve registration, a producer should present that the pesticide will usually trigger no unreasonable threat to man or the setting, whereas bearing in mind the financial, social, and environmental prices and advantages of use of the pesticide, dietary threat from residues, in addition to not endangering agricultural employees throughout their utility.

Sensible consideration: It might be simpler to get Congress to move an modification to FIFRA than to ask the OPP to approve a requested exemption.

USE, REGISTRATION, OR LEGISLATIVE OPTIONS ON THE TABLE

Beneath are the brief variations of my assessments of every possibility (you’ll be able to contact me for extra detailed variations).

Potential Motion Merchandise #1: Making use of for FIFRA Part 24(c) Particular Native Want Registrations

Particular person states are allowed to register a brand new end-use product or an extra use of a federally registered pesticide product to handle an present or imminent pest state of affairs. The pest state of affairs have to be a particular native want inside the state that can’t be mitigated by a presently registered product [[4]].

We may argue that varroa’s growth of resistance to amitraz is definitely an imminent drawback, and that the very restricted label instructions for the currently-approved varroacides that may be utilized throughout a nectar circulate are too restrictive and unduly dangerous to the applicator.

Professional: Would possibly work.

Cons: It will be an extended shot. An SLN designation requires the consent of the Registrant of the energetic ingredient, which Chemical substances Laif (Veto Pharma) will not be enthusiastic about giving, so so far as any SLN registration of various utility strategies for oxalic acid, this feature is Lifeless on Arrival.

My evaluation: Since at greatest this could solely apply to the usage of Api-Bioxal, it’s uncertain that it will be well worth the effort, particularly since EPA might reject the functions. Likelihood of success is low.

Potential Motion Merchandise #2: Make the most of USDA’s Workplace of Pest Administration Coverage (OPMP) to Assist Us.

USDA, below §7653, with regard to the particular function of collaborating with the EPA and agricultural stakeholders within the availability, and use of economically and environmentally sound pest administration instruments, practices, and insurance policies, established the Workplace of Pest Administration Coverage (OPMP), with the mandate to offer management to make sure coordination of interagency actions with the Environmental Safety Company, the Meals and Drug Administration, and different Federal and State businesses.

“The Workplace of Pest Administration Coverage shall seek the advice of with agricultural producers that could be affected by pest administration or pesticide-related actions or actions of the Division or different businesses as essential in finishing up the Workplace’s duties below this part.” [[5]]

Limitation: The OPMP can solely advocate, not regulate or approve varroacides.

My evaluation: The OPMP is already serving to us, however they don’t set precise pesticide coverage.

Instructed motion: Our business wants to interact in session with OPMP and recommend how they may advocate on our behalf.

Potential Motion Merchandise #3: Ask IR-4 for Assist

The IR-4 (Inter-Regional Analysis) Mission (aka the Minor Crop Pest Administration Program) develops information essential for the registration of protected pesticides with EPA. IR-4’s mission is to facilitate registration of sustainable pest administration expertise for fruits, greens, decorative crops, and different “minor” crops. IR-4 works in coordination with the Environmental Safety Company to help within the assortment of residue and efficacy information in help of the registration or reregistration of minor use pesticides and the dedication of tolerances for residues of minor use chemical substances in or on uncooked agricultural commodities. Since its founding, IR-4 has facilitated the approval of hundreds of pesticide registrations via EPA, lots of which give growers with revolutionary pesticide merchandise (together with varroacides) that decrease well being and environmental dangers.

There are artificial miticides already registered for makes use of apart from varroa management [[6]]. If a Registrant wished to develop its use for beehives, it will require solely a label modification. IR-4 may assist to gather required information, reminiscent of that required for a residue tolerance in honey. However our business has already proven the chemical corporations that if an already-registered plant-protection product (reminiscent of Mavrik or Taktic) is cheaper than a formulated product particularly for beehives (respectively Apistan or Apivar), that industrial beekeepers will seemingly purchase it as a substitute, so won’t justify the associated fee concerned in pursuing an extra registration.

Nonetheless, as we uncover different components on the Biopesticide checklist, new modes of motion towards varroa (reminiscent of RNAi, odorants, or behavioral disruptors), IR-4 would possibly assist get them via the regulatory course of.

Professional: IR-4 is prepared to assist us, though we’d seemingly have to pay them for the mandatory information assortment.

Cons: IR-4 is especially within the testing of novel energetic components and formulations.

My evaluation: IR-4 is generally enthusiastic about serving to to register biopesticides, however doesn’t set pesticide coverage. The method of registering new merchandise or utility strategies may take a while.

Potential Motion Merchandise #4: Shift regulation of Varroacides to the FDA

At present, EPA and FDA decide regulatory oversight of pesticides and new animal medicine primarily based on the rationale described in a Memorandum of Understanding (MOU) between the businesses signed in 1971 and revised in 1973. Parasite therapy merchandise utilized topically to animals (together with pets) usually are regulated by EPA if they continue to be on the pores and skin to regulate solely exterior parasites, and by FDA if they’re ingested and absorbed systemically into the bloodstream. Though this concept has been floated that varroacides would possibly higher be regulated by the FDA, both as over-the-counter merchandise, or by veterinary prescription,

• The registration necessities by FDA for parasite therapies could also be harder than these by the EPA for pesticides.
• Vets have extreme limitations for prescribing extra-label utilization, and it’s uncertain that FDA would look extra leniently upon alternate routes and dosages than the EPA.
• Since Api-Bioxal is already registered, FDA wouldn’t enable generic OA utilization.
• FDA would possibly revisit the residue issues for honey.

Execs: Not clear.

Cons: Of questionable profit to our business. Most stakeholders are opposed.

My evaluation: This feature seems to be a non-starter.

Potential Motion Merchandise #5: Petition the EPA to Add Honey Bees to the Minor Use Crop Listing

Designation of a pesticide for minor use is meant to determine conditions the place registrants of doubtless helpful pesticide merchandise (in our case, varroacides) might not want to use for registration as a result of the potential returns are low (This lack of financial incentive is a big challenge for us, enormously limiting the variety of registered merchandise obtainable for our use). Crops (in our case beehives) qualify if there are fewer than 300,000 acres in manufacturing in america.

It takes 19,300 beehives to cowl an acre. Thus the three million hives within the U.S. would cowl 155 acres. So we must always undoubtedly qualify for Minor Use registration.

Minor makes use of additionally embody pesticides utilized for management of illness vectors reminiscent of mosquitoes, ticks, cockroaches, rodents and disease-causing organisms (varroa is the vector for DWV).

In 2018, the EPA launched a Pesticide Registration Discover [[7]] to make clear and revise the EPA’s interpretation of “minor use” below FIFRA part 2(ll) because it applies to the registration of pesticides. Though there have been a number of feedback submitted to EPA, not one got here from our business representatives.

Suggestion: We beekeepers ought to be sure that our nationwide organizations submit feedback when EPA asks for enter on selections that could be of profit to our business!

Professional: If we have been profitable with this petition, it’d lower the prices for registering merchandise supposed for varroa management. So maybe price pursuing.

Cons: It’s unlikely that EPA would even think about granting exemptions for Minor Use Registrations of thymol, formic, or oxalic in generic kind. EPA would seemingly solely enable use of registered energetic components from authorized suppliers, new labels, and many others.

My evaluation: This can be price a strive, however we must always examine with EPA earlier than pursuing. Once more, the gears of EPA flip slowly, so this could not assist us within the brief time period.

Potential Motion Merchandise #6: We Petition the EPA to Embody Extra Energetic Substances to the “Minimal Threat” Listing

Particularly: Our business may petition the EPA so as to add sure extra generic pure substances to their Minimal Threat checklist (restricted particularly to utility to beehives).

In 2021 EPA solicited public feedback and ideas in regards to the petition course of for exemptions concerning pesticides from registration and different necessities below FIFRA, the place the pesticides are decided to be of a personality pointless to be topic to regulation below FIFRA. The Company was contemplating streamlining the petition course of and revisions to how the Company evaluates the potential minimal threat energetic and inert substances, components utilized in courses of exemptions, state implementation of the minimal threat program and the necessity for any future exemptions or modifications to present exemptions.

Some 39 feedback have been submitted, however not one got here from the beekeeping business. We missed our likelihood to have thymol and formic and oxalic acids added to the Minimal Threat checklist.

Suggestion: We beekeepers ought to be sure that our nationwide organizations submit feedback when EPA asks for enter on selections that may very well be of profit to our business!

One public remark made the purpose that:

One of many processes that wants probably the most enchancment is the associated fee and time burden on the implementation of choices. At this time, the present value to introduce a brand new substance [can be] over $900,000 {dollars} … It is a burden that many companies merely can’t afford. Second, the complexity of registering pesticidal merchandise is an excessive amount of for a small enterprise to deal with with out exterior steering. General, [our] recommended motion is to streamline the method … if the substance is extensively used within the public.

Formic, oxalic, and thymol are all pure parts of our meals, and in “chemical kind” are extensively and safely utilized by the general public (particularly by beekeepers). Though the EPA “promotes the usage of safer pesticides, together with biopesticides, as parts of IPM packages,” it hasn’t moved in a short time so as to add extra presumably protected components to its Minimal Threat checklist; actually they’ve added just one ingredient (chitosan) since publication of the unique checklist in 1996 (for the mathematically disinclined, that was 27 years in the past!).

Much like how EPA responded to a petition so as to add chitosan to the Minimal Threat checklist, our business may petition EPA so as to add extra energetic components already of their registry to the Minimal Threat checklist, together with thymol, formic and oxalic acids, and numerous fragrant plant oils which exhibit varroacidal motion. Because of the comparatively tiny quantities utilized by the beekeeping business, the applying of any of the above energetic components to beehives wouldn’t trigger any unreasonable threat to man or the setting. Beekeepers in New Zealand have set an instance of the way it works to permit them the liberty to use these generic pure chemical substances.

Execs: Since varroa is evolving extra shortly than new miticidal merchandise are being registered, it will be of nice profit to america beekeeping business for EPA to develop their Minimal Threat Exemption to incorporate formic, oxalic, and lactic acids, thymol, and extra plant oils which have proven promise.

If extra components have been added to the Minimal Threat checklist, we may instantly start experimenting with them, and sure shortly develop new varroa-control strategies and formulations. And since beekeepers are already accustomed to registered thymol and natural acid merchandise, it will be an enormous step ahead to permit us to make use of the off-the-shelf generic components along with registered formulations and merchandise.

Execs: The addition of generic thymol, and oxalic and formic acids to the Minimal Threat checklist would assist our business immensely, since beekeepers may customise utility strategies for his or her particular circumstances, and result in the event and advertising and marketing of recent formulated merchandise.

Cons: It can take the submission of a petition and follow-up. We might have to file toxicology studies related to utility to beehives. The present Registrants of formulated merchandise might object to their energetic components being given a “free move” after spending giant sums to get their merchandise registered by EPA. Every state has its personal statutes and laws regarding pesticide registration and regulation, and the states aren’t required to allow the sale of an exempted product just because it meets the 40 CFR 152.25(g) circumstances for minimal threat exemption. However the largest downside could be that it will seemingly take a very long time for EPA to undergo the method.

My evaluation: It’s an extended shot, however maybe EPA would possibly add these generic substances to the Listing, maybe limiting their use to varroa management in beehives. It’s price formally petitioning them. However it will seemingly take a very long time for them to undergo the method, even when they determined to take action.

Potential Motion Merchandise #7: Ask our Legislators to Move an Personal Use Exemption Modification to FIFRA

I’ve saved what I really feel is our greatest possibility for final — it’s kinda a mix of Actions #5 & #6, however it will bypass the EPA by as a substitute asking Congress so as to add a tiny modification to FIFRA within the upcoming Farm Invoice.

Right here’s the issue: It’s fully authorized for a beekeeper to place generic oxalic or formic acid, thymol, or plant oils into their hives for the aim of colony well being, bee repellency, or the cleansing of frames or combs. Neither the EPA or FDA are involved about threat to the setting nor to the honey shopper. But when of their thoughts the beekeeper is utilizing them for pesticidal functions, it will be towards the regulation. I underlined the 2 key phrases —generic and use. That is not in regards to the sale of pesticides, solely with regard to use of off-the-shelf generic pure substances. Our predicament is that this creates a cloudy state of affairs for beekeepers and people accountable for the enforcement of FIFRA.

New Zealand’s Ministry for Major Industries, understanding this predicament, and realizing that (1) beekeepers wanted assist (and would seemingly assist themselves anyway), and (2) that these generic pure substances utilized to beehives posed no threat to man or the setting, correctly granted beekeepers an Personal Use Exemption [[8]] for “compounding of drugs for their very own use.” To wit: “(1) The exemption applies to a substance or compound ready by an individual to be used on animals or crops that they personal, or on any land, place or water that they personal or occupy. (2) In a beekeeping context, the ‘personal use’ exemption is often used when a beekeeper prepares and applies preparations containing generic substances, reminiscent of oxalic acid or formic acid, to their very own hives for management of Varroa mites.” The preparations can solely be made by the beekeeper for their very own use, and can’t be marketed or bought.

Pesticide regulation is completely different within the U.S. than in New Zealand, so (in my view) our greatest plan of action is to mix the weather of the “Minor Use” and “Minimal Threat” parts of FIFRA, and ask our legislators to position an modification to FIFRA within the upcoming Farm Invoice, granting an exemption to regulation for beekeepers making use of generic thymol, oxalic, formic, or lactic acids, or food-grade fragrant plant oils to their very own hives.

The logic for an exemption comes from the textual content of FIFRA itself:

7 U.S. Code § 136 – Registration of pesticides (a) Requirement of registration

“Besides as offered by this subchapter, no particular person in any State might distribute or promote to any particular person any pesticide that’s not registered below this subchapter. To the extent essential to stop unreasonable antagonistic results on the setting, the Administrator might by regulation restrict the distribution, sale, or use in any State of any pesticide that’s not registered below this subchapter and that’s not the topic of an experimental use allow below part 136c of this title or an emergency exemption below part 136p of this title” [highlighting mine].

I boldfaced the important thing phrases ― the Administrator might restrict the use of a pesticide provided that it causes unreasonable antagonistic results. Since use of the generic types of these pure generic substances inside the confines of beehives would clearly not end in any unreasonable results on the setting, it isn’t essential for the Administrator to manage their use (versus registration or sale of formulated merchandise), and such use needs to be exempt from regulation below FIFRA. We’d merely be asking for our legislators to codify that reality, not with an emergency exemption, however somewhat with a particular exemption modification to part 136a.

Our fallback plan:  If we are able to’t get Congress to move an exemption, we may as a substitute take the EPA to court docket to see whether or not we may persuade a decide to agree that for the reason that use of those substances by beekeepers poses no threat to the setting, that such use needs to be exempted by regulation below FIFRA.

For instance, teams supporting the event of plant biostimulants really feel that the Farm Invoice is “probably the most logical place for inclusion” of an modification to FIFRA [[9]].

The benefits of this feature are:

• This may very well be a minor modification to FIFRA included within the Farm Invoice, by merely including an extra exemption.
• EPA would proceed to manage the sale of any merchandise bought for his or her pesticidal results towards varroa.
• However beekeepers could be exempted from regulation for the usage of (versus the sale of) these particular pure substances.
• It will be restricted solely to functions to beehives by the beekeepers themselves.
• Any preparations of the generic substances may solely be made by the beekeeper for their very own use.
• It will be as much as the beekeeper to determine how to decide on and use every substance or product (in rotation), following steering by USDA’s Workplace of Pest Administration Coverage or by state agricultural extension.
• No ready merchandise may very well be marketed or bought for pesticidal functions except they have been registered with the EPA.

From a legislative standpoint, this possibility will not be theoretical ― it’s already being efficiently utilized in New Zealand, and will merely be copied! The easy reality is that the usage of these generic merchandise in beehives needs to be exempt from regulation by FIFRA, since oxalic, formic, and thymol pose no unreasonable threat to man or the setting when restricted to utility to beehives, and all have already got exemptions from tolerance in honey.And there may be already a spot for exemptions in FIFRA.

An Personal Use Exemption would, much like as in New Zealand, enable beekeeping suppliers to inventory generic natural acids and thymol, however they may not make any pesticidal claims for them. The suppliers would proceed to inventory registered merchandise for beekeepers wishing to make use of conveniently-packaged, examined formulations (such because the currently-registered plastic strips, formic pads, and thymol gel).

Execs: This might be the only and most easy resolution, and permit beekeepers to keep away from being pesticide scofflaws. This feature would remedy our predicament instantly, and permit us to make use of these generic pure substances without having to attend for EPA to determine whether or not so as to add them to the Minimal Threat checklist. Including a easy modification to FIFRA to the farm invoice needs to be apolitical, and strongly supported since we beekeepers are a really minor business, however have some political clout as a consequence of our significance in crop pollination, plus the honey bee being a poster baby for the setting.

Cons: Our legislators would seemingly ask EPA for his or her opinion, and if EPA objects strongly, they could be hesitant to pursue it. Thus beekeepers would wish to request it much more strongly.

ACTIONS TO TAKE

On the state stage

A lot of beekeepers have requested me about actions to take on the state stage. Sadly, states are allowed to impose pesticide laws extra restrictive than the EPA’s, however not much less restrictive, so it could be a waste of time to move pesticide exemptions on the state stage, since (as with the case of the two(ee) exemptions) EPA will seemingly overrule them.

Nonetheless, normally, states (via their State Lead Company) have major authority for compliance monitoring and enforcement towards unlawful pesticide use. States can challenge bulletins to their inspectors concerning steering for discretion of enforcement.

On the federal stage

Our greatest plan of action could be on the federal stage, however we’ll want state legislators to help an modification to FIFRA within the Farm Invoice. Ought to beekeepers in any state have the ability to catch the ear of a supportive legislator, they may ask them to contact the agricultural committee staffs of the chairpersons of the Home and Senate Agriculture Committees.

A SUGGESTED AMENDMENT

I’ve posted recommended textual content for an modification to FIFRA, plus recommended wording for pitching it to our legislators at [[10]].

CITATIONS AND NOTES

[1] https://www.epa.gov/ingredients-used-pesticide-products/biopesticide-active-ingredients

[2] https://www.epa.gov/websites/default/information/2018-01/paperwork/minrisk-active-ingredients-tolerances-jan-2018.pdf

[3] I haven’t but learn each phrase, however it will be one thing to do if you happen to have been ever spending a number of years in jail as a consequence of an enforcement motion.

[4] https://www.cdpr.ca.gov/docs/registration/guide/steering.pdf

[5] https://uscode.home.gov/view.xhtml?req=granuleid:USC-2000-title7-section7653&num=0&version=2000

[6] Bahreini, R, et al (2020). Analysis of potential miticide toxicity to Varroa destructor and honey bees, Apis mellifera, below laboratory circumstances. Scientific Reviews 10(1) 21529.

[7] https://downloads.laws.gov/EPA-HQ-OPP-2015-0814-0016/content material.pdf

[8] https://www.mpi.govt.nz/dmsdocument/37901-Promoting-and-own-use-guidance-for-compounds-for-management-of-disease-in-beehives-Steering

[9] Farm invoice may embody FIFRA exemption effort for plant biostimulants

The textual content of their invoice is offered at To amend the Federal Insecticide, Fungicide, and Rodenticide Act to offer for a constant definition for plant biostimulants.

[10] https://scientificbeekeeping.com/suggested-wording-and-pitch-for-an-own-use-exemption/