Comment submitted by Erik Johansen

According to 40 CFR 152.8(b) a product intended to force bees from hives for the collection of honey crops is not a pesticide, because it is not intended for use against a pest. WSDA believes that benzaldehyde does not require registration as a pesticide, but would like to inform EPA that it is still being distributed for use by beekeepers. WSDA requests that EPA determine if revocation of the tolerance exemption for benzaldehyde would cause FDA to consider honey extracted from hives that were treated with benzaldehyde to be adulterated. If revocation of the tolerance exemption would cause FDA to consider honey extracted from hives to be adulterated, then WSDA requests that the tolerance exemption for benzaldehyde be retained. Please contact me at ejohansen@agr.wa.gov if there are any questions regarding these comments.