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August 3, 1999
Ms.
Dear Ms. Jensen-Pascarella: Your recent letter to Mr. Paul E. Heliker regarding the requirements relating to pesticide registrations and related investigation of your business activities by the Department of Pesticide Regulation (DPR) was forwarded to me for reply. The term ‘pesticide’ is defined in the Food and Agricultural Code section 12753, which states, in part, that a pesticide is any SUBSTANCE INTENDED for mitigating any pest in any environment (emphasis added). The term ‘pesticide’ does not describe any chemical class, nor does it reflect the toxicity of the product. It simply reflects the intended purpose of the product usually as demonstrated by labeling or advertising claims. Many substances that are registered and used as pesticides have other uses, and some even have food uses. DPR supports reduced-risk pesticides and the use of more environmentally friendly products. However, this must be done within the framework of existing legal requirements designed to protect the public and the environment. While ordinary cleaning products do not normally required registration as pesticides, any claims relative to control pests, including microorganisms, makes the product a pesticide and subject to registration. The effectiveness of an antimicrobial pesticide is of particular concern to both DPR and the U.S. Environmental Protection Agency (U.S. EPA) due to the public health issues surrounding that use. The claims made for the products “Not Nice to Lice” and Kleen Kill” manufactured by Get Set, Inc., 2530 Hayes Street, Marne, Michigan 494-9751, and distributed in California by you are being reviewed by DPR’s Pesticide Registration Branch. A final decision is pending. If it is determined that the claims made constitute pesticide claims, registration by both U.S. EPA and DPR will be required. You will be notified if further action on your part is required. DPR becomes aware of products that may be subject to registration requirements from many sources. DPR attempts to investigate all of these reports. The source of the report that triggers an investigation is usually not relevant and is often not even recorded, as is true in this case. No one stands accused at the initiation of an investigation. The purpose of an investigation is to gather information upon which to base a decision on the appropriate application of the law. If you need additional information on California's requirements for registration of pesticides, you may contact Mr. Barry Cortez, Chief of DPR’s Pesticide Registration Branch, at (916) 445-4377. Sincerely,
Paul H. Gosselin
cc: Mr. Paul E. Heliker, DPR Director
(1) Our Original 6/22/99 Letter to DPR after unannounced "Investigation"
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