Re: No need for EPA registration?
Posted by Chris on 10/22/06
Henry - Thanks for the info. Since my post, I contacted a
pesticide consultant and he explained the exact same thing - If
a registered antimicrobial chemical is added to a sealer, then
the performance claim can only apply to the sealer in the can
and not to the surfaces the sealer is applied. Any product
making a mold prevention claim must be registered. The treated
article exemption cannot be legally twisted to avoid
registration.
As you recommended, I will reported the company to our
department of agriculture and see what happens next. I am tired
of being lied to by these companies. If they want to sell
antimicrobial products, then have them registered. I am
certainly not going to jeopardize my company’s reputation or
face potential legal expenses because some sales rep tells me
their product doesn’t need EPA registration. I might be a little
slow, but I’m not stupid.
Chris
On 10/21/06, Henry Z wrote:
>> The product as a whole does not need to be registered.
>
> The above is a common and very expensive mistake made by
> companies selling surface protection products that contain an
> EPA registered antimicrobial from another company. If a product
> makes claims beyond protecting the product it has been
> incorporated into then YES it does have to be registered with
> the EPA.
>
> In other words, an EPA registed antimicrobial can be added to
> paint with the claim that it helps protect the paint but it
> cannot make the claim that it protects the surface from
> contamination unless the entire product is registered.
>
> Do the EPA a favor and give them everything you have on the
> company that contacted you.
>
>
>> On 10/19/06, R Duso wrote:
>> Chris,
>>
>> EPA registration,
>>
>> It is necessary for all individual products in the
>> formulation to be registered.
>>
>> The product as a whole does not need to be registered.
>>
>> Dick D.
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