March 25, 2019
So much of this journey so far has been us feeling sheepish, relating our ¾-baked ideas to experts we’re just sure will laugh us off the conference line. And every time, we’re met with real interest. When we run up against what seems like an insurmountable problem, and we feel like our dream of saving the bees might be over, someone not only gives us the answer, or validates our own, or points us in the right direction — they express genuine excitement and a deep desire to help.
This is what keeps us marching forward.
This week, it was the venerable EPA. The actual gatekeepers standing between us and releasing Everbee to the public. And we’re not going to lie. We were nervous. Really.
One of the questions that’s been hanging over us since we first met with Dick Rogers was whether or not we’ll have to register with the EPA as a pesticide. It’s not a minor concern, since pesticides require extensive chemical, toxicological, and field-testing before they can be registered. Even after that, the decision time is up to a year and the cost anywhere between $6k and $32k.
We reached out to Dick’s EPA contact, and we're expecting, honestly, a stone wall of intractably cold and terrifying bureaucracy. But what we got was an absolute wealth of support, enthusiasm, and encouragement. First off, the meeting was packed with six people from the EPA. There was an entomologist, representatives from the Environmental Fate & Effects division (we love that name), compliance experts...and every single one met us with such enthusiasm for our little idea.
That isn’t so little now.
First, the EPA thinks we do qualify as a pesticide device, which means we do not have to register, and we can get our product to market more quickly. That is HUGE, because it blows up the roadblock we thought was in our path. Even if it turns out we do need registration, they suggested we partner with another company who’s already made it through the process.
So, it wasn’t just that they were giving us answers; they were actively trying to think of ways to make this process work faster and better, so that we could manufacture this device they truly believe has enormous potential. We’re going to have to think of a different word than “validation,” because we’ll be using it a lot over the next few months and we don’t want future readers to get bored.
That’s a good problem to have.
It was a totally fascinating meeting in every respect, and after we learned the good news about our product classification, we talked about what essential oils would be most efficacious and safest for use in our device. The EPA has a list of minimum risk pesticides, and on it are some promising bee friendly EOs like peppermint and rosemary, cinnamon and lemongrass.
As always, we kept up a running commentary in Slack during the meeting.
These are exactly the oils we’ve been considering anyway. It’s chemical kismet.
After our meeting, our main EPA contact gave us some contacts at the USDA, and some ideas for testing facilities and even for funding. We don’t mean two or three tossed-off suggestions. He sent an entire, categorized list of resources.