Document YGz4RNMjkz7wME9apMZqGR22D
TO:
Mike Fortier
TGG: JCL: IWMG: RF XF:___ riVq
FROM: DATE:
Interoffice Communication SUBJ:
T. G. Grumbles October 17, 1988
TSCA ALCOHOL AS PESTICIDES
VISTA
The regulatory definition of "pesticide" is very broad. the regulatory definition is as follows:
Specifically
The term "pesticide" means (1) any substance or mixture of substances intended for preventing, destroying, repelling or mitigating any pest, and (2) any substance or mixture of substances intended for use as a plant regulator, defoliant or desiccant:....
In summary herbicides are a subclassification of pesticides for the purposes of regulatory classification and any registration requirements. TSCA alcohols (810 and 10) were registered in 1978 as pesticides. No further registration is needed for those products.
As discussed in my 9/26 memo, the only real impact for us is having to report production volumes for products we know are put into "active" pesticide use in an unaltered state. If the products are from a plant other than LCCP or Hammond, we will have to register the plant. Registering the plant as a pesticide producing facility is a relatively simple paperwork exercise.
Perhaps an example would help. Several years ago we became aware of a customer registering LP as a pesticide. We did not register or market LPA as a pesticide. With the new regulation, we would now have to annually report the LPA sales to that customer. Also, if LCCP wasn't already registered as a pesticide producing facility we would have to do that.
Hopefully the above clarifies the situation.
T. G. Grumbles
dlj
cc:
Wayne Hilgers Dan Plummer John Stokes Russell Rose Rick Johnson
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