Pesticide Regulation
Eliot Harrison is a humble guy. His regulatory consulting firm has a long and impressive list of client’s for whom the firm of Lewis & Harrison handles EPA regulatory affairs. Today Eliot shared with IAQradio listeners some of the history and inner-workings of the EPA’s Antimicrobial Division.
Our guest defined and clarified terms such as pest and pesticide. He explained that antimicrobial is a catchall term used by the EPA under which fall: sanitizers, disinfectants and sterilants. “The EPA doesn’t have a clear definition of the term biocide.” The EPA has no special designations or classifications for “Botanical” or “Natural Disinfectants”. Eliot clarified the EPA’s Treated Article Exemption cases where no registration is needed when a preservative is added to a product to protect and no implication is made that the treated article is active in protecting other materials.
Eliot outlined the costs and complexities of registration and regulatory maintenance of
EPA regulated antimicrobial products. The most frustrating aspect of dealing with the EPA for both Eliot and his client’s are inconsistencies situations where the playing field isn’t level, some of this is caused by grandfathering. For example, a product registered with the agency long ago with old claims appropriate at the time the products was registered and competitively advantageous now. The EPA won’t allow other products even those with similar formulations to have the same claims.
Eliot used the word tension to refer to the high level of stress which comes with interfacing with the EPA. Tension always exists between government regulators and those who are regulated. We can all appreciate our government’s need to protect their: citizens, their air, waters and land. Government needs to be careful, accurate and safe. I’m not so sure the Antimicrobial Division of the EPA can appreciate the business challenges encountered by the firm’s who’s products they oversee and regulate.
Today’s music:
Pesticide Song By: Terry Winchell
PS- Federal Insecticide Fungicide & Rodenticide Act (FIFRA) originated in 1947 when the word fungicide was included in the Act to protect growers and wasn’t a premonition to the products being used currently for mold remediation.
Z-Man Signing Off
