Re: Mold coating

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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...
>>
>> http://www.epa.gov/opppmsd1/PR_Notices/pr2000-1.pdf
>>
>> 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 www.biosafeinc.com
>>
>> 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 www.microbeshield.com. 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.