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Re: [compost_tea] EPA



Bob,
 
Oddly, it doesn't matter what a product can do.  It matters what you claim a product can do.  For example, I know that Yucca can kill certain insects, larva, and even fungi and bacterial pathogens.  I know it makes a great sticker, surfactant, and wetting agent.  But to sell the product with those claims, it must be registered with the EPA and the State where it is sold as a pesticide before you can sell the product.  On the other hand, another person can sell the exact same product, but not have any of those claims and does not have to register the product as a pesticide.  It's the claims you make that determine whether or not registration is required.
 
I should add that if you make fertilizer claims on your product label, literature, or on your web site, you need to register your product as a fertilizer.  Every state where such a product is sold will require you to register your product as a fertilizer.  If you make no fertilizer claims, then your product is not subject to being registered as a fertilizer. 
 
I know this may seem strange, but that's the way the regulations work.  It's part of the law.  If you make such claims and don't register your product as a pesticide or fertilizer (depending upon what claims you make) then you are in violation of the law and can be prosecuted if you don't comply with the law.
 
So, one person can claim their compost tea has pesticidal properties and fertilizer properties and can register their product as such and can make the claims that their registration covers.  You can say your tea kills aphids and register it as a pesticide to do that.  If you then say your tea also kills mites and fleas and that wasn't part of your original registration, then you are in violation of the law for those new pesticidal claims. 
 
I can sell the exact same product and not make any pesticidal claims or fertilizer claims and I will not be required to register the product as a fertilizer or pesticide. 
 
An interesting example:  Water can be used to kill certain insects.  If I bottle up water for the purpose of killing a given insect and describe that on my product label, then that product must be registered as a pesticide.  I can take that exact same water and put it in another bottle and label it as pure, refreshing drinking water.  The first product is a pesticide.  The second product is not a pesticide. 
 
So, just because one person says their compost tea has pesticidal properties and registers it as such, that doesn't mean that other people selling compost tea who are not making such claims, will be required to register their tea as a pesticide.  The need for registration is tied to the claims that you make for your product. 
 
How do I know this?  I've talked to people at the EPA and State Department of Ag agencies who conduct pesticide and fertilizer registrations. 
 
--Thomas Giannou
 
----- Original Message -----
Sent: Friday, August 22, 2003 10:09 AM
Subject: Re: [compost_tea] EPA

Is the EPA such a threat that we can't openly enjoy the merits of ACT?  Here we have the solution for many of the problems that the EPA is searching for and we choose to hide it from them?  Maybe we need to be proactive.  Show them it has the answers they need.  Get THEM to PROMOTE ACT. That is their mission.

I can buy poisons to reduce aphids.  Or apply a non toxic ACT that has the natural bio preditors of soft bodied insects and aphids  are less a problem. 

I can buy and apply slug bait, a poison, and slugs leave slime all over the garden. It must be terrible way to die.  When I apply ACT the slugs are not a problem..  No evidence of poison.  My neighbors pets are not exposed to poisons,  Nor his kids. Nor my vegies.

I can buy poisons to kill caterpillars and spray gallons of it on my trees, kill everything, birds, bees, each other, the water, fish and fish food.   Or I can apply non toxic ACT and the pillars quit eating the leaves.  No poison. Just the natural bio that eventually slows them down.  They just quit eating.  The EPA should be delighted.

I can spray poisons on my lawn to kill the bugs there.  Kill the fish, poison the water, and the kids.  Or I can apply ACT and the grass is not affected by those bugs.  This is what the EPA, the county park dept. asked for.

The Strawberry  experience, the palm tree cure, the live oaks, the banana platation experiment, all these marvels of natures way to balance a problem with normal bio instead of chemical poisons IS WHAT THE EPA IS LOOKING FOR. 

All the results achieved by ACT support what the EPA aims for.   So we hide ACT behind a bush so they won't notice?  Is our government agency that hard to work WITH? 

Unfortunately.  But do we let that condition prevail?

Is this no longer the governent of the people, for the people, by the people   BY THE PEOPLE !

 Did all those millions who gave their lives to defend freedom do so,  so that we, in utter safety, would allow freedom to perish because we are proccupied, timid?   Not this kid, Bob

 

 




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