EPA Releases Guidance for Disclosing Antimicrobial Ingredients in Pesticides

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The Environmental Protection Agency has issued guidelines for companies that want to voluntarily disclose information on product labels and websites about antimicrobial ingredients in pesticides.

The nonbinding guidance, published July 15, was developed jointly by EPA and the Consumer Specialty Products Association (CSPA) in advance of an agency rule for publicly disclosing inert ingredients on pesticide labels.

EPA said the guidance is not a substitute for the inert ingredient rulemaking or a “prejudgment” on the rule.

EPA published an advance notice of proposed rulemaking for inert ingredient disclosure in December 2009 and took comments on the notice until April 2010. EPA is considering whether to require disclosure only of potentially hazardous ingredients or of all inert ingredients, regardless of hazard (244 DEN A-3, 12/23/09).

The July 15 guidance encourages registrants to:

• disclose all intentionally added ingredients on company websites and labels,

• link products on websites to EPA registration numbers,

• use bilingual and widely recognized chemical naming schemes on websites and labels,

• include PDFs of material safety data sheets for ingredients subject to Occupational Safety and Health Administration regulations,

• identify ingredients in their alternate formulations, and

• maintain websites for at least two years after a product is no longer sold.

The guidance also clarifies that if a product label contains a website address, the website becomes part of the product's labeling and is subject to misbranding provisions under the Federal Insecticide, Fungicide, and Rodenticide Act. FIFRA's misbranding provisions state that companies must not make false or misleading claims on product labeling.

Additionally, the guidance clarifies that under FIFRA, a company cannot make claims on a label that are substantially different from claims on its website.

Based on Industry Initiative

In developing the guidance, EPA and CSPA drew on an industry-led ingredient disclosure initiative that the trade association launched in January 2010.

Under CSPA's initiative, manufacturers of air care, automotive, cleaning, and floor polish and maintenance products voluntarily list product ingredients. Companies list ingredients that make up more than 1 percent of the product in descending order by predominance and ingredients that make up 1 percent or less in any order.

The CSPA program does not include incidental ingredients that have no technical or functional effect in the product.

By Avery Fellow

EPA's guidelines for voluntary disclosure of antimicrobial ingredient information are available at http://www.epa.gov/oppad001/voluntary-disclosure.html .