Re: [compost_tea] EPA

From: Thomas Giannou <thomas_at_tandjenterprises.com>
Date: Fri, 22 Aug 2003 11:17:07 -0700

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 st=
icker, surfactant, and wetting agent. But to sell the product with those c=
laims, 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 p=
erson 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, lite=
rature, or on your web site, you need to register your product as a fertili=
zer. 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 yo=
u are in violation of the law and can be prosecuted if you don't comply wit=
h the law.

So, one person can claim their compost tea has pesticidal properties and fe=
rtilizer 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 k=
ills mites and fleas and that wasn't part of your original registration, th=
en 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 fer=
tilizer claims and I will not be required to register the product as a fert=
ilizer or pesticide.

An interesting example: Water can be used to kill certain insects. If I b=
ottle 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 propertie=
s and registers it as such, that doesn't mean that other people selling com=
post 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
http://www.tandjenterprises.com

  ----- Original Message -----
  From: Robert Norsen
  To: compost_tea_at_yahoogroups.com
  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? H=
ere 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. S=
how them it has the answers they need. Get THEM to PROMOTE ACT. That is th=
eir mission.
  I can buy poisons to reduce aphids. Or apply a non toxic ACT that has th=
e natural bio preditors of soft bodied insects and aphids are less a probl=
em.

  I can buy and apply slug bait, a poison, and slugs leave slime all over t=
he 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 tree=
s, 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 q=
uit eating. The EPA should be delighted.

  I can spray poisons on my lawn to kill the bugs there. Kill the fish, po=
ison the water, and the kids. Or I can apply ACT and the grass is not affe=
cted 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 proble=
m with normal bio instead of chemical poisons IS WHAT THE EPA IS LOOKING FO=
R.

  All the results achieved by ACT support what the EPA aims for. So we hi=
de ACT behind a bush so they won't notice? Is our government agency that h=
ard 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 peo=
ple ? 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 pro=
ccupied, timid? Not this kid, Bob








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Received on Sat Aug 23 2003 - 01:03:22 EDT

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