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    Re: Mold coating

    Posted by steve smith on 2/11/07

    On 12/29/06, Just Checking wrote:
    > You might want to seek the advice of the EPA or a qualified pesticide
    > attorney/consultant before rendering your opinion.
    > ALL antimicrobial products making an efficacy claim must be registered -
    > no exceptions. You appear to be making the typical “treated article”
    > argument. However, the treated article exemption can only be used if the
    > underlying antimicrobial is registered. If the antimicrobial is properly
    > registered, then the treated article can be exempt from registration.
    > You cannot legally circumvent EPA pesticide registration even with a
    > lose interpretation of the treated article exemption.
    > If you are attempting to use someone else’s EPA registered product with
    > your trade name on the label, then you need a sub-registration or a new
    > registration. If you are reformulating or diluting an EPA registered
    > product under your trade name, then you need a new EPA registration. You
    > cannot alter an EPA registered product and still call it "registered".
    > You can be in violation of FIFRA if you are relying on the treated
    > article argument as an excuse not to have your product registered. The
    > EPA is quite clear in this regard.
    > On 12/29/06, HM4100 wrote:
    >> BIOSAFE is not in violation of any FIFRA or EPA regulation.
    >> The EPA gives a list of OK claims in section IV-B-1 and 2 here...
    >> Such as- "This article has been treated with a fungistatic agent to
    >> protect the product from fungal growth"
    >> So yes, you can claim to protect the object the coating is applied to.
    >> Thank you for your interest, visit our website at
    >> On 11/29/06, WRONG wrote:
    >>> Bill Cook makes a lot of claims that he has "THE" antimicrobial
    >>> product and that it is EPA registered and that it is patented and
    >>> safe. I have researched his claims and have documented the
    >>> following:
    >>> -BioSafe, not bill cook have two patents on the use of a known
    >>> antimicrobial. What good is either of these patents since they
    >>> require the use of someone else's product.
    >>> -BioSafe claims to have a antimicrobial coating that contains EPA
    >>> registered antimicrobial. The antimicrobial that they claim is
    >>> Aegis 64881-1, -2, -3. This antimicrobial is owned by Aegis
    >>> Environmental not bill cook or biosafe.
    >>> -Biosafe and bill cook make illegal claims that violate several
    >>> FIFRA regulations. A coating that contains EPA registered
    >>> antimicrobials can only make claims to protect the surface of the
    >>> coating, not the object that it is applied to, only to surface of
    >>> the coating.
    >>> -The Aegis products that Bill Cook and BioSafe are claiming are not
    >>> EPA registered to Kill anything. Verify by calling Aegis or looking
    >>> on the aegis web site at The Aegis product
    >>> is registered to prevent and inhibit ONLY, not killOn 10/26/06, No
    >>> Dope wrote:
    >>>> Chris - Thanks for raising this question. I am a builder in North
    >>>> Carolina and I cannot tell you how many times a mold dude (as we
    >>>> call them) comes by to hawk some new product. When we ask for EPA
    >>>> registrations, they dance from one foot to another and hem and haw
    >>>> about they don’t need no stinking registration. We politely tell
    >>>> them that our insurer, lender, and mold inspector sure as hell
    >>>> does need the stinking registrations. We then bet on how quickly
    >>>> they can leave our construction site without hitting something.
    >>>> If you confront these guys, they quickly realize you are not some
    >>>> dope and find the door most ricky-tick. Mold prevention chemicals
    >>>> must be EPA registered no matter what stories you are told. Don’t
    >>>> be a dope... What are you doing to protect yourself or your company
    against mold infestations?
    >>>> On 10/22/06, Chris wrote:
    >>>>> 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.Again, what are you or your company doing?
    >>>>> 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.

    If a product states that it kills mold, a registration is required period
    the end.

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