Dr. Janet Kintz Early discusses the concerns coming for 25’s from EPA Fifra to individual state registration requirements and limits and liabilities of product performance.Biography for Dr. Janet Kintz-Early. JAK Consulting Services
Dr. Kintz-Early received her B.S. in Biology from Ursinus College in 1993. She studied the behavior of azalea lace bugs in nursery settings while earning her M.S. in Entomology from Clemson University in 1998. In 2003, Dr. Kintz-Early received her Ph. D. in Entomology Clemson University. Her Ph. D. research involved fire ant colony movement behavior with respect to mowing frequency and golf courses.
Prior to owning her own consulting firm, Janet spent 12 years working with Nisus Corporation as an R&D Scientist and Regulatory Affairs Manager. During that time, Janet was responsible for technical support calls, quality assurance, continuing education classes, MSDS to SDS conversions, GLP research, competitor intelligence, data compensation, product development and EPA compliance. Janet also worked as a paid intern in the horticultural industry. She spent 13 months at Longwood Gardens and 3 months at Villanova University Arboretum, where she provided IPM education and implementation support to horticulturalists and fellow interns.
Dr. Kintz-Early and her best friend and business partner, Dr. Kristen van den Meiracker, BCE, bring a unique combination of experience to JAK Consulting Services and the pest control industry. An Easton PA native, Janet currently lives in Knoxville TN with her husband, daughter and three furry children. She is a member and former scholarship recipient of Pi Chi Omega and the Entomological Society of America.
Top 10 Concerns Coming for 25b’s
- History of 25bs
- FIFRA – Federal Insecticide, Fungicide, Rodenticide Act (1947)
- EPA – Environmental Protection Agency (1970)
- Evaluates risk, not safety
- Pesticide Definition -Anything that prevents, destroys repels or mitigates a pest.
- FIFRA 25b – (1996) – creation of “Minimal Risk Pesticides”
- Active and inert ingredients
- Reduces costs and regulatory burdens
- Allows more focus on pesticides that pose greater risk
- Federal/ State Requirements
- Do not require Federal registration
- Must comply with six Code Federal Regulations requirements:
- Limited choices of active ingredients
- Limited choices of inert ingredients
- Must display all ingredients on label
- Company & producer information on label
- No health-related claims
- No false or misleading claims
- Toxicity of 25b’s
- How is risk assessed?
- Is natural really natural?
- What is safe?
- What is non-toxic?
- What is a chemical?
- Federal/ State Registration Requirements
- Only 10 states do not require state registration
- Some states require efficacy data:
- South Dakota, Mississippi, Indiana, & Mew Mexico
- New Mexico – double-blind study and two independent peer reviews for claims
- States want EPA to be more involved in registration of 25b’s
- Challenge to create a product label to be used in all states
- Long registration lead times
- Regulation of marketing claims such as natural
- Can they be used in conjunction with or instead of traditional pesticides?
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