How can a company in the United States do "well enough" by selling a chemical that is not EPA registered? Selling unregistered chemicals in the United States will get a company a gigantic EPA fine. Skeet, the cost of an EPA registration is, nor never will be, any where close to "chump change". EPA's registration daunting process has kept an unknown number of small companies from starting new businesses, thus an unknown number of jobs that could have been, but unfortunately never will be, at least in this country. - Millet (1,361-)

Compared to the billions of dollars in sales that many of the pesticides have regisistered, a few million that it cost to get a pesticide registered is chump change. In addition that chump change is jobs--often done by small independent companies that do much of the testing.

Joe's company is selling the product--not as a registered pesticide, but as a biostimulant which because it is a natural product and not being sold as a pesticide, does not have to go through pesticide registration require by FIFRA. Hopefully, the effectiveness of the product to stimulate healthy growth and resist disease and repel insects will result in word of mouth sales that will increase to the point that the registration as a pesticide and fungicide will be chump change. From what I have seen, it does repel insects--all kinds of insects, good and bad, start to leave as soon as the first mist hits the plant.

Word of mouth sales telling customers that it will control this and that without registration, will put Joe in EPA hell. Millions of dollar is certainly NOT CHUMP change - never ever. Only a hand full of companies that are forced to deal with EPA are in the billions of dollar category. Many are people trying to get started, and they don't have millions of dollars in their CHUMP CHANGE account..

EPA is always highly concerned with what a company puts out in the form of printed matter. If Joe's company puts on their product label ANY type of claim controlling any type of insect, or any claim of fungicidal action, even claiming to kill something as benign as powdery mildew, or any claim of bio-nutrition then it needs registration. If Joe's company passes out any sales literature to his customers that makes any type of claim on the effectiveness of his product, without an EPA registration, EPA's army of lawyers will pounce on him in a heart beat, and then he will have a year or two of legal expenses. Further, without an EPA registration, Joe's company better not make a single claim of effectiveness against insects, fungus, bacteria, bio-nutrition, and on and on and on, on the companies web site. It is EPA's same old game against American industry and therefore indirectly against American jobs. Than' the way it is. - Millet (1,360-)

We are registered with the USDA as organic foliar blend fertilizer, having bio-stimulant properties, phytohormones, vitamins, macro and micro nutrients. We are also registered with CDFA, and soon with OMRI, which is considered to be the most authoritative non-profit organization that certifies products for organic growing. Our product market is 80% for conventional farmers, and the other 20% insists that we undergo OMRI listing.

So far it is approved to claim the product as bio-stimulant which can result in the tremendous reduction of pests and diseases. It is also approved to claim the Systemic Acquired Resistance properties, from third party scientific data that we have. While we have direct evidences of third-party scientific data about the fungicidal, nematicidal and pesticidal properties, Millet is correct that we cannot print such things in our labels.

But we have already started the process with the EPA and they have sent us reduced data set requirements to be registered in the bio-pesticide category which should dramatically reduce the cost of registration, and hopefully the time it would take to do so. One of my friends is extremely knowledgeable about the regulatory registration process as he used to work for the California's Environmental Agency, and he is now retired, so he will just be helping us for some bottles of fine wines that I make.

Hopefully we should be able to keep our registration costs down, or were stuck in the fertilizer category.

Another approach that we can do is we could be pesticidal supplement where we can enhance the effectiveness of the existing pesticides out there. One is that the AZ41 has excellent sticker property, and it will also help reduce stress of plants that often accompany some of the harsher pesticides. This approach that has worked well in other countries and their regulatory bodies and so we have some partners in those field.

Glad to hear Joe. It sounds like you have a good plan. I hope you are very successful.

Millet, would you trust just any company in the US or anywhere else in the world to not sell toxic chemicals for application to our food without knowing how toxic they are to people and animals? I don't.

The cost of registration is only a few percent at most compared to the total cost of developing a typical pesticide with testing for efficacy, research and development, engineering and manufacturing process development and manufacturing and distribution cost. All of those cost are ultimately passed on to the consumer. And apparently it still cost less for farmers to use commercial pesticides otherwise Organic foods would cost less than regular food.

Skeet, do you actually believe that the cost of EPA registration, to register Joe's product is going to be just a few percent of his development cost? If so, you could be the only person in the U.S. that does so. - Millet (1,360-)

Yes, I do, by the time it becomes a registered pesticide with worldwide manufacturing, sales and distrbution. I'm sure they have quite a bit already invested.

You must be one of very few people that believe pesticide companies in the US or anywhere else in the world to not sell toxic chemicals for application to our food without knowing how toxic they are to people and animals.

I agree with you Skeet and Morphinelover. Millet has also a very good point when it comes to the registration process. My friend, who used to work at the pesticide regulatory board of California told me that if an inventor discover a super excellent product, by the time the registration is completed and done, his ownership and shares of the company has been diluted to insignificant levels. Most investors are in for the money and when there is pending approval that is most likely, too often, the big companies will court them, then they sell the company for a nice profit, and the big company will simply shelf the product if it is in competition with theirs, and lock away the intellectual properties after having bought them. They can always choose to profit, but often times, what they have in place is already very profitable, it is just cheaper to buy out the competition. So we are very cautious with our options at this point.

We need to research more on what can be printed on our website. For example we can have freedom of speech from various testimonials and peer-reviewed scientific journals indicating the properties of our products. The testimonials from independent people who had no ties with our companies, if those were taken down, it would violate the freedom of speech.

If EPA were to take down the publications of the favorable results from peer-reviewed scientific journals, it would cause an uproar in the scientific community.

Thus there are many options and am glad we have a few friends whom I have helped with their citruses, bananas, avocados and other fruit trees in their yard, and are returning the favor by giving free legal advise.

Millet's advise, Skeeter's, morphinelover's and from many other members here are excellent gems to take note of when we move forward with our baby steps.

In the final analysis, I wish Joe and his associates the very, VERY best of luck. I'm sure in the next 5 years the managerial personal of Greener Earth Tech, Inc. will grow to become very savvy in the world of self employment. - Millet (1,359-)

Thank you Millet, Skeeter, Morphinelover and all the others for wishing the well being of our new startup company, Greener Earth Tech, Inc.

The moment I stepped out of the scientific research organizations and the academe, I have chosen to be self-employed, and have been happily self-employed for the past 12 years. I have started a couple of other companies that got merged with another before they ever become profitable or forgotten.

Here are some links that may provide a little
more insight in regards to chlorpyrifos usage
on Citrus in California.

We start here with a UC publication link that
mr.shep posted in the UBC Citrus forum.. If
you scroll down you will see Lorsban 4E listed.

Asian Citrus Psyllid Provisional Treatment Guidelines for Citrus—UC IPM

A couple of Lorsban related links:

Lorsban Advanced Insecticide receives federal and California registration

Lorsban® Advanced insecticide

Jim