"Shah PhD., Hasmukh C." <Hasmukh_Shah@americanchemistry.com> 

08/12/2008 10:35 PM	

To

Jeanne Kasai/DC/USEPA/US@EPA, Nancy Fitz/DC/USEPA/US@EPA

cc

Subject

Example of pesticide-impregnated objects





Hello Jeanne Kasai:  The Panel believes it is important for the
Container Regulation to take into account that there is likely to be a
growing trend toward the registration of pesticidal articles and
objects.  There are currently few examples of articles that are
registered as pesticides.  For example, there are
insecticide-impregnated garments, mosquito nets, etc. that are
registered because they make claims of pesticidal activity.  In the
antimicrobial area, a number of copper alloys were recently registered
that can be fabricated into objects, for example, railing for hospital
beds.  This is merely one example of the types of registered articles
that may be developed in the antimicrobial area.  It is expected  that
the antimicrobial area will see growth in the number of articles or
objects registered because they make claims of pesticidal activity. 
Because of the pesticidal claims these articles are not  "exempt
treated articles"  and are subject to registration requirements. 

 

Because this is a foreseeable trend, the Panel submitted comments that
the final container regulation with regard to exemption of "if not
packaged" should not be limited to registered "pesticide-impregnated"
articles, but instead should be applicable to objects generally that
must be registered pursuant to FIFRA.  We believe that the copper
alloy registrations are good examples of the trend in the antimicrobial
area.  Again, the articles made from the copper alloys are not
"impregnated".  Nevertheless, they should be considered in the same
category as "pesticide-impregnated" articles with regard to exemption
from the container regulation. 

Thank you for your consideration of the Biocides Panel comments.

Has Shah

American Chemistry Council

1300 Wilson Boulevard

Arlington, VA 22209

Tel.: 703/741-5637

Fax: 703/741-6080

e-mail: has_shah@americanchemistry.com

-----Original Message-----

From: Kasai.Jeanne@epamail.epa.gov [mailto:Kasai.Jeanne@epamail.epa.gov]


Sent: Monday, August 04, 2008 12:49 PM

To: Shah PhD., Hasmukh C.

Cc: Fitz.Nancy@epamail.epa.gov

Subject: To Mr. Shah regarding comments on changes to
Container-Containment rule

Hello, Mr. Shah-

Thank you for the comment you submitted on July 11th concerning the

proposed changes to the pesticide Container-Containment rule.

We are in the process of working through the public comments in our

internal-EPA work group.

To help with our discussions and understanding of your comments, I am

wondering if you would be able to send us examples (photos, if possible)

of:  1)  pesticide-impregnated objects, and 2) other registered

pesticidal objects not packaged in containers.

Thank you for your time and consideration.

Sincerely,

Jeanne Kasai

EPA - Office of Pesticide Programs

tel. 703-308-3240   fax 703-308-2962

http://www.epa.gov/pesticides/regulating/containers.htm

