EPA Posts Fact Sheet on Determining if Cleaning Products are Pesticides

EMSL Analytical’s Consumer Products Testing Division offers testing solutions for government agencies, industry and the general public.

Westmont, NJ

In March of this year the Environmental Protection Agency (EPA) released a fact sheet to help clarify when determining if a cleaning product is a pesticide under the Federal Insecticide Fungicide and Rodenticide Act (FIFRA). FIFRA’s definition of a pesticide is “any substance or mixture of substances intended for preventing, destroying, repelling, or mitigating any pest.”

According to the EPA website, “…products that claim to affect a pest’s habitat or food source are making claims to ‘mitigate’ a pest. For many years, EPA has held that including claims that a product ‘mitigates’ a pest subjects it to FIFRA registration requirements.”

The EPA states that pesticidal claims that require EPA registration include:

• removal of pest breeding sites
• removal of pest habitats, including, for example, removing nutrients from areas where insect larvae may mature
• cleaning claims that the product can be used where “contamination” is habitat or food for pests
• cleaning claims for direct removal of the pest
• removal of scum where pests breed
• claims the product works through out-competing the pest for nutrition or habitat
• removal of the pest through physical means such as by suffocating or drowning the pest (not a habitat claim) (products intended to exclude pests only by providing a physical barrier against pest access, and which contain no toxicants do not require registration)
• removal or digestion of biofilm
• claims that a product sanitizes or disinfects
• mention of a specific microorganism or “germs” or the removal of habitat where microorganisms can hide, thrive, or grow
• removal of bacterial odors
• removal of unspecified “allergens” or the habitat where “allergens” can hide, thrive or grow

EMSL Analytical is one of the nation’s largest consumer products testing laboratories and has expertise in pesticide testing. To learn more please contact EMSL Analytical at (800) 220-3675, visit www.ConsumerProductsTesting.com or email info@EMSL.com.

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Joe Frasca

Senior Vice President, Marketing

EMSL Analytical, Inc.

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