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Thread: Sale of "professional use" pesticides.

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    Site Caretaker Dave A's Avatar
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    Sale of "professional use" pesticides.

    The debate on how pesticide sales should be controlled in South Africa has been quietly raging for some time.

    Here is a very interesting article on the same issue, except the battle ground is the USA and the internet! However, the fundamental issues apply locally.

    I'd suggest that if anyone wants to debate this issue, they read this article from PCT Online first.
    The trouble with opportunity is it normally comes dressed up as work.

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    Site Caretaker Dave A's Avatar
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    An update. The EPA has published a documented response which can be read here.

    The summary is as follows:
    Conclusions

    1. The use of pesticide products can be enforceably limited to specific groups of applicators provided they are clearly identifiable. Clearly identifiable persons include applicators defined in statute or regulation, or who can be identified by a license or other government issued credential, or who can demonstrate employment by an entity identified on the label, such as a vector control agency. However, it is not appropriate to include on the label of a non-restricted use product any language limiting use to certified applicators.

    2. Use and user limitations required by the Agency as terms or conditions of registration in order to mitigate risk must be stated in enforceable, mandatory terms.

    3. Advisory language -- such as “recommended (or not) for XXX use” -- is acceptable for marketing purposes, but is not enforceable and creates no obligations on sellers or enforcement agencies.

    4. For non-restricted use products, specifying allowable or prohibited use sites, including but not limited to “institutional use” and “residential use” (both defined in regulations) is generally preferable to limiting user groups.
    It is also worthwhile to note this part of the "Next steps" section:
    At this time, the OPP Labeling Committee is not planning regulatory action to address these issues, in part because another part of OPP is planning rulemaking that may have a substantial effect in this area. Under the auspices of the Pesticide Program Dialogue Committee (PPDC), a Worker Safety Regulatory Enhancement workgroup is considering substantial revisions to both the worker safety regulations (40 CFR Part 170) and the certification and training regulations (Part 171). The changes being considered for Part 171 would result in expanding the universe of occupational pesticide users that would be required to demonstrate competency in some form. If the Agency finalizes a rule to accomplish this, there would be many more commercial/professional pesticide users clearly identified in a manner similar to certified applicators, and who therefore could be designated on labels in an enforceable manner.
    The trouble with opportunity is it normally comes dressed up as work.

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