Corrected URLs
Click Here to Add CommentSubject: Corrected URLs
Date: Sat, 20 Apr 2002 16:02:17 -0400
From: Stephen Tvedten <steve@getipm.com>
Organization: Get Set Inc. (www.getipm.com)
To: Paul Helliker <phelliker@cdpr.ca.gov>
Director, State of
California, Department of Pesticide Regulation
cc: Christine Whitman whitman.christine@epa.gov
Dear
Steve,
The
federal statute you mentioned in your email is an important one for people to
cite in their correspondence with government and/or private agencies in their
activism efforts. Please post the location where they can read all of the laws
relating to the marketing/labeling of pesticidal products. The text version can
be read in the Code of Federal Regulations. Go to that website database located
at:
http://www.access.gpo.gov/nara/cfr/cfr-retrieve.html
and
type into the appropriate blocks, title 40, CRF part 156 section 10 for the text
of the regulations.
Of
particular interest are the following portions of the law: A product is declared
"misbranded" if it utilizes
"...(v)
Any statement directly or indirectly implying that the pesticide or device is
recommended or endorsed by any agency of the Federal Government"
Personal
note: This is important since users generally misuse the term
"approval" for EPA registered products, to imply endorsement. This is
a very popular ploy among government officials involved in municipal spray
programs.
"...
(ix) Claims as to the safety of the pesticide or its ingredients, including
statements such as ``safe,创 ``nonpoisonous,创 ``noninjurious,创
``harmless创 or ``nontoxic to humans and pets创 with or without such a
qualifying phrase as ``when used as directed创; and (x)
Non-numerical and/or comparative statements on the safety of the product,
including but not limited to: (A)
``Contains all natural ingredients创; (B)
``Among the least toxic chemicals known创 (C)
``Pollution approved创
Personal
note: We are constantly bombarded with false claims of safety for these products
- get the perpetrators of such verbal fraud to put THAT in writing.
"...(g)
Ingredient statement--(1) General. The label of each pesticide product must bear
a statement which contains the name and percentage by weight of each active
ingredient, the total percentage by weight of all inert ingredients; and if the
pesticide contains arsenic in any form, a statement of the percentages of total
and water-soluble arsenic calculated as elemental arsenic. The active
ingredients must be designated by the term ``active ingredients创 and the
inert ingredients by the term ``inert ingredients,创 or the singular forms of
these terms when appropriate."
Personal
note: Inert ingredients do not have to be identified by name, only by percentage
of inclusion in the product. However, another section states that the EPA
administrator can require the name of an inert ingredient to be listed on a
label if he/she deems the ingredient to be hazardous. This is a good opportunity
to petition the EPA for inclusion by name of many highly toxic inerts currently
allowed to go unnamed.
"(6)
Deterioration. Pesticides which change in chemical composition significantly
must meet the following labeling requirements: [[Page 57]] (i)
In cases where it is determined that a pesticide formulation changes chemical
composition significantly, the product must bear the following statement in a
prominent position on the label: ``Not for sale or use after [date].创
Personal
note: Again, the degradation of these chemicals must be well documented in
toxicological data and it is likely that this is a little enforced part of the labeling
laws. Lastly, all products are supposed to say "keep out of the reach of
children". Now if we could just modify it to read, keep out of the lungs,
mouths, brains...
Regards,
Barbara Rubin Raisyl@webtv.net
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