Anonymous public comment

This proposal will catastrophically inflate costs for minimum risk pesticide manufacturers! "USP grade" essential oils are about 5 times more expensive than generic or technical grade essential oils right now, and with this proposal, the price for "USP grade" will skyrocket because of a sudden industrial demand for a tiny supply of ONLY "USP grade" essential oils. Minimum risk pesticide manufacturers will be unable to compete with large manufacturers of "registered" chemicals because ingredients on the 25b list will be thousands of times more expensive! Levying requirements under the guise of chemical "quality" will exterminate the entire class of minimum risk pesticides. Furthermore, what is the rationale of using USP grade clove oil to kill weeds (for example)? Where does that quality really go? "USP quality standards" do not improve the efficacy, the safety, or any other quality of a minimum risk pesticide ingredient. In fact, I support broader definitions for the ingredients listed on the 25b and 4A lists. This proposal to add "specific chemical identifiers" and "include the specification of USP" greatly limits the availability of materials from the 25b and 4A lists, and what the industry really needs is more ingredients added to both lists; ingredients such as pepper oil, orange oil, limonene, oregano oil, neem oil, lavender oil, eucalyptus oil, acetic acid, butanoic acid, nonionic surfactants, and so many others! And regarding the pretext of this entire proposal, to "improve clarity on product labels" for "more informed" pesticide users: if it is indeed the honest intention of the EPA to better inform the public with respect to what they are buying, then please require EPA registered pesticides to disclose the inert ingredients on their product labels, not just the minimum risk products. In conclusion, minimum risk pesticide manufacturers need more resources, fewer restrictions, and equality among labels (registered products should disclose inert ingredient