Re: No need for EPA registration?

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Thanks for bringing these issues up. I would hope that in an industry such as
this, professionals should be as skeptical as possible and find out as much as
possible about the products they are using before they offer them to the
general public and put their business name on the line. With that said, we're
pretty new at this and we obviously need to learn a lot in order to provide a
product that people will have confidence in and we’re looking for help from
professionals in the field.

I get the impression (from reading other comments posted by Just Checking) that
you are selling a product and you’re trying to discredit any other products
that are being mentioned. I hope I’m wrong. If I am, I apologize and if you
have some insight into the industry that you would like to share, we would be
very interested in talking with you. If I am right, eventually people will see
through it.

We have a product that we know works, the EPA has approved it, and we would
like to work with true industry professionals to make sure the product meets
their needs before we start actively marketing it. At this point we’re not
trying to sell anyone anything.

If you're reading this and you’re an industry professional that would like to
try the product, give us a call and we will be happy to send you free samples,
EPA documentation, lab results, MSDS sheets, etc. in exchange for your honest
evaluation. Don’t use it on paying customer’s homes, but put it through as
rigorous a testing process as you would do if it were being used on your home.
Tell us what testing criteria you consider to be most valid and credible and
we’ll go that route to give you the back up you need to confidently promote
this to your customers. If it doesn’t meet your expectations or requirements,
we won’t sell it.

“Just Checking”, I have addressed your specific comments below and would
appreciate any constructive feedback:

1) Copper Sulphate products have been around for a while for good reason. Do
you think that they're all the same if they have the same base ingredient? If
so, you are wrong.

We are in several industries such as Roof Cleaning, Agriculture, Property
Maintenance, and Aquatics among others and we regularly compete against other
copper, copper sulphate, quat, and peroxide products – and the way each is
formulated, combined with other ingredients, and diluted makes them radically
different from each other in terms of their safety, effectiveness, and
suitability for any given purpose. If you are looking at one ingredient and
making a blanket determination based on that, you’re probably selling yourself
short.

2) While they are different companies, Magna-Bon and Roof-A-Cide are owned by
the same people. If we need to sub-register, we will. Since we're not selling
it yet, that's not much of an issue. When the time comes, we’ll do what we need
to in order to be in compliance with the EPA and any states we distribute to.
For right now, the EPA has given us approval for Mold Treatment and we’re
evaluating the market potential. If the product meets the needs of the market,
is profitable, and we plan to sell it - we’ll cross that bridge when we come to
it.

3) Our Pro-Tek product has many uses and different dilutions and application,
but you're mistaken about having to reapply it every 3-6 months in the case of
construction materials – we only reapply every 6 months on Tennis Courts and
Orange Trees. For construction materials it is a one-time application. We don't
have 5 to 10 year testing data; we just have independent lab reports and EPA
approval right now and we will build the rest if the market justifies the time
and expense.

4) None right now. What would you recommend as an industry standard that has
the most credibility with professionals in the field?

5) Please explain why preventing any of these would be necessary.

If the product is safe enough too be used in swimming pools, water
purification, feed additives for farm animals, etc – in addition to being
approved by the EPA for construction materials, why should anyone be concerned
about any of these as it relates to our product?

6) It seems you are insinuating that the product is somehow unsafe. Please
correct me if I am wrong or explain why we might have to protect a builder if a
homeowner found out the product had been used as a pretreatment of the studs,
trusses, foundation, & plywood. If the product is safe enough too be used in
swimming pools, water purification, feed additives for farm animals, fruit,
etc – in addition to being approved by the EPA for construction materials, why
in the world would a builder need protection?

If your statement is asking if we will be able to protect builders that create
a structure that allows water intrusion, then obviously the answer is “No”. I
don’t know of any product that will. If you do, please educate us on it.

John Browne
Roof-A-Cide
Professional Roof Cleaning & Stain Prevention
"The Treatment is the Cure"
http://www.Roof-A-Cide.com/
Toll Free Tel: 800/806-6727
Toll Free Fax: 866/237-5855

On 3/12/07, Just Checking wrote:
> 1. Copper Sulfate Pentahydrate (CAS 7758-99-8) is a run-of-the-mill biocide
> and fungicide with many EPA registrations. It has been around for quite some
> time.
>
> 2. This registration is for Magna-Bon Pro-Tek not Roof-a-Cide Rid-A-Mold.
> You must have a subregistration if you intend selling under your trade name.
>
> 3. The product is for use in lakes, on plants, roofing material and building
> materials. Must be reapplied every 3 to 6 months. Where is your 5 to 10 year
> performance data?
>
> 4. What ASTM testing have you completed?
>
> 5. How do you prevent leaching, oxidation, human exposure, & potential
> indoor air quality pollution?
>
> 6. How do you legally protect the builders who agree to use the product from
> being sued by homeowners once they find out what’s in their house?
>
>
> On 3/11/07, John Browne wrote:
>> 66675-4
>>
>>
>> On 3/11/07, Jim wrote:
>>> What is your EPA number?
>>>
>>> Jim
>>>