Thomas Brugato内部能源和环境 //www.ludikid.com/author/tbrugato/ 能源、商品和环境法律和政策开发 wed20232月15日14:59:56+00 en-US 时钟 一号 https://wordpress.org/?v=6.1.1&lxb_maple_bar_source=lxb_maple_bar_source https://insideenvironmentredesign.covingtonburlingblogs.com/wp-content/uploads/sites/47/2021/06/cropped-cropped-cropped-favicon-3-32x32.png Thomas Brugato内部能源和环境 //www.ludikid.com/author/tbrugato/ 32码 32码 万博体育app手机登录EPA发布新农药设备指南 万博体育app手机登录//www.ludikid.com/2023/02/epa-releases-new-guidance-on-pesticide-devices/ 托马斯布鲁加托 wed20232月15日14:59:41+00 化学类、农药类和塑料类 FIFRA Pesticide设备 //www.ludikid.com/?p=8453 2月14日EPA发布受Federal杀虫药法规范的农药装置守法建议不遵守例子包括未注册杀虫剂称为装置、带假和误导声明的装置万博体育app手机登录Continue Reading… system/files/documents/2023/02/peticdevicead万博体育app手机登录Examples of non-compliance include unregistered pesticides claiming to be devices, devices bearing false and misleading statements, and devices being sold and distributed that were not produced in an EPA registered establishment."  While the compliance advisory provides a helpful overview of requirements applicable to pesticide devices, it does not provide new substantive guidance, including on key questions facing many device manufacturers and distributors.  The advisory also suggests that EPA may increase its enforcement efforts in this area, so companies producing devices (or products that may arguably be devices) should consider taking proactive steps to ensure their product lines comply with FIFRA's requirements.

EPA's compliance advisory outlines the key requirements applicable to pesticide devices, including:

  • Devices must be produced in an EPA-registered establishment and bear an EPA establishment number.
  • Devices may not make claims that are false or misleading, including several categories of claims EPA has determined via notice and comment rulemaking are false or misleading.
  • Entities importing devices must ensure that appropriate Notices of Arrival are submitted to Customs in connection with each import.
  • States may impose their own requirements, and a number of states require pre-market registration of devices.

However, the compliance advisory does not break new ground, and leaves open a number of significant questions, including:

  • The precise demarcation between devices and pesticides, including how novel technologies are classified!万博体育app手机登录咨询不讨论先例或提供附加指导,设备制造商在评价产品是否适当归为设备时应该知道这一点。
  • 万博体育app手机登录
    • Notably, as part of the 2023 Consolidated Appropriations Act, Congress enacted the fifth iteration of the Pesticide Registration Improvement Act, which contains a provision requiring EPA "to develop efficacy test methods for antimicrobial pesticide devices making public health claims."  To date, EPA has not publicly released such test methods.
    • What testing or other steps device manufacturers should take to ensure that their devices are safe.

    Given EPA's continued focus on this area, as well as the lack of guidance on several key issues, companies should carefully monitor EPA developments and take affirmative steps to minimize the risk of a potential enforcement action.

    监管者和决策者日益关注室内空气质量 //www.ludikid.com/2023/01/a-growing-focus-on-indoor-air-quality-by-regulators-and-policymakers/ Sarah Wilson、Thomas Brugato、Brendan Parets、John Mizerak、Lindsay Brewer和MollyBrown 图族2023年1月19日22:38:29+00 空气污染和温室气体控制 油气策略 空气质量 建构代码 CPSC EPA公司 毒气炉 室内空气质量 天然气 污染 公共卫生 //www.ludikid.com/?p=8407 p对齐=scenter++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++1manbetx3.0

    Congress, the media, and the public have given significant attention to remarks this week by a commissioner of the Consumer Product Safety Commission ("CPSC") indicating that the agency would be considering a federal ban on gas stoves due to their health effects.  The suggestion of a ban on gas stoves has drawn comments from bipartisan policymakers in both chambers, and even the White House has weighed in against the prospect of a potential ban.

    The CPSC is unlikely to ban gas stoves in the near future, although it has the authority to ban unreasonably dangerous products that cannot be made safe, and has done so with toxic substances in children's products and other product categories in the past.   A CPSC rulemaking on mandatory safety standards for gas stoves, however, is a possibility, and that process may drive the establishment of voluntary industry standards by a standards-setting body.  Additionally, other federal and state regulators have recently sharpened their focus on indoor air quality and gas-powered appliances, for both health and environmental reasons.  The Environmental Protection Agency ("EPA"), for instance, is undertaking several activities related to indoor air quality.  And the California Air Resources Board ("CARB") recently adopted a plan that would effectively prohibit the sale of gas-powered space and water heaters in California by 2030.

    Particularly with regard to federal regulatory activity on gas stoves and other gas-powered appliances, potentially affected parties will have ample opportunities to help shape the outcome of any mandatory or voluntary product standards put in place or accepted by the CPSC, and to engage with other regulators.  This alert provides an overview of recent and emerging legislative and regulatory activity related to indoor air pollution, focusing particularly on activity by the CPSC and EPA.  Companies—both those with interests in gas stoves and those concerned with indoor air quality issues more broadly—should carefully follow indoor air quality developments, including in their interactions with regulators, given the increased focus on this area.

    Consumer Product Safety Commission

    The Consumer Product Safety Act ("CPSA") tasks the CPSC with regulating the safety of consumer products, which the statute broadly defines as products sold or used by consumers.  The CPSA exempts from CPSC jurisdiction most items subject to regulation by another federal agency, including food, drugs, tobacco, pesticides, motor vehicles and motor vehicle equipment, and firearms.The CPSC has five commissioners and is bipartisan by statute, although one seat is currently vacant.

    The CPSC has the power to promulgate product safety standards that are "reasonably necessary to eliminate or reduce an unreasonable risk of injury associated with such product."  The public, including industry, may offer written comments in a CPSC rulemaking on product safety standards, and the CPSC must "give interested persons an opportunity for the oral presentation of data, views, or arguments."  Additionally, if the agency receives a submission of a voluntary safety standard and determines that the standard is "likely to result in the elimination or adequate reduction of the risk of injury" and that "it is likely that there will be substantial compliance with such standard," it must terminate the rulemaking and rely on the voluntary standard. 

    The CPSC faces a relatively high bar to implementing a mandatory safety standard, including the requirement that it make a finding that "the rule imposes the least burdensome requirement which prevents or adequately reduces the risk of injury for which the rule is being promulgated."  There is an even higher bar for banning a product, which requires a finding that there is "no feasible consumer product safety standard [that] would adequately protect the public from the unreasonable risk of injury associated with such product."  Both mandatory standards and a ban could be challenged in federal court, and most courts considering CPSC mandatory standards or bans have subjected the agency's required findings to stringent scrutiny.

    Although Commissioner Trumka's recent remarks gained attention due to his reference to a potential ban on gas stoves, the adoption of voluntary or mandatory standards is a more likely outcome.  There is a clear CPSC interest in the topic.  The agency's fiscal year 2023 operating plan includes as a priority a focus on "chronic hazards, including hazards associated with ...万博体育app手机登录gas stoves" and sets a target date of March 1, 2023, for agency staff to provide a plan to the commissioners for seeking public input on the topic.  In considering the operating plan, the Commission unanimously accepted, as part of a larger manager's amendment, Commissioner Boyle's addition of "chronic hazards" to the agency's priorities.  During that meeting, Commissioner Trumka offered an amendment to begin rulemaking on standards for gas stoves, but he withdrew that amendment due to lack of support.  The instruction to begin seeking public input on gas stoves was a fallback, which the Commission adopted unanimously.

    The agency is also facing congressional pressure to begin promulgating safety standards for gas stoves.  In December, on the same day that a study was published indicating that gas stoves may be a major cause of childhood asthma, a group of House and Senate Democrats wrote the CPSC to urge the agency to begin a rulemaking to address health risks from gas stoves.  The letter included a focus on the impacts of indoor air quality on vulnerable populations, which is consistent with the priority listed in the CPSC fiscal year 2023 operating plan to "enhance agency data collection and analysis of product safety incidents, injuries, and deaths to identify vulnerable populations" and to "allocate safety work to better address any existing safety disparities among such identified vulnerable populations." 

    Environmental Protection Agency

    The EPA has also shown a growing interest in indoor air quality, including related to emissions from gas-powered appliances.  The EPA has expansive statutory authority to research, but not regulate, indoor air quality issues under the Radon Gas and Indoor Air Quality Research Act of 1986.  Despite lacking authority to regulate in this area, the EPA's research can be authoritative and lead to regulatory and legislative activity and industry scrutiny.  For example, the EPA's 1993 report on the risks of secondhand smoke exposure influenced public understanding of the dangers of secondhand smoke and the subsequent proliferation of smoke-free laws.  A recently published report by the National Academies of Sciences, sponsored in part by the EPA, stressed the importance of issues relating to indoor chemicals, and the effect of these chemicals on air quality and human health.

    As part of its efforts on indoor air quality, EPA has also become involved with indoor air quality sensor technology.  Most notably, the EPA recently published guidance on the benefits and limitations of low-cost air quality monitors.  While noting that air quality monitors may be helpful in measuring indoor pollution, the EPA also cautioned consumers that there is limited information as to the accuracy of these monitors and noted that there is "currently no widely accepted air concentration limits for most pollutants indoor."  The guidance also reflects increased concerns about indoor air pollution, including from stoves, stating that "[i]n some instances, you may wish to use one or more monitors to compare pollutant levels or environmental factors before, during, and after an activity like cooking."  The development of indoor air quality monitors may be significant to providing alternatives to simply banning products, by providing consumers with information they can use to respond to indoor air quality issues.  Similarly, enhanced research regarding indoor air pollution may provide greater clarity about pollutant levels of concern indoors.

    The EPA also has jurisdiction under the Federal Insecticide, Fungicide, and Rodenticide Act over air-cleaning devices if device claims include pest or other micro-organism mitigation (e.g., air filters, air purifiers).  The agency has significantly increased its focus on these devices due to the COVID-19 pandemic, and we can expect a continued concern with indoor air quality issues to result in continued EPA engagement regarding this category of products.

    As additional evidence of the agency's interest in these issues, the EPA published a request for information in October 2022, seeking input on "actions, strategies, tools and approaches that support ventilation, filtration and air cleaning improvements, and other actions" to promote indoor air quality, with a focus on reducing disease transmission indoors.  The request for information was prompted, in part, by the Biden Administration's Clean Air in Buildings Challenge, which calls on building owners and operators to improve indoor air quality and reduce the spread of COVID-19.

    Finally, in exercising its authority to address outdoor air pollution, the EPA may affect indoor appliances and indoor air quality.  For example, in August 2022 environmental groups, including the Sierra Club, petitioned the EPA to list heating appliances (including indoor appliances such as space heaters, gas stoves, and dryers) as a source category under the Clean Air Act and to issue performance standards.

    State and Local Legislation

    State and local regulators and legislative bodies have also engaged in activity related to gas-powered appliances.In addition to the California Air Resources Board plan that would effectively prohibit the sale of gas-powered space and water heaters in California by 2030,  amendments to the state's building code that strengthened ventilation standards and established requirements for single-family homes to be ready for electric appliances went into effect on January 1.  The Los Angeles prohibition on gas appliances in new buildings will be effective this month, and in November 2022, the largest county in Maryland passed a law requiring all new construction to be fully electric by the end of 2026.  Numerous other local governments have enacted their own gas bans, although there is currently ongoing litigation regarding whether these gas bans may be preempted under the Energy Policy and Conservation Act.  Additionally, these gas bans have prompted backlash from some state governments.  As of June 2022, 20 states have passed legislation prohibiting local communities from enacting gas bans, and legislators in states where such "preemption legislation" failed may try again in the coming year.

    Product manufacturers, retailers, and consumers can expect continued state and local legislative activity on gas appliances in 2023.  For example, New York's Climate Action Council plan, passed in December, contains recommendations for implementing New York's 2019 Climate Leadership and Community Protection Act.  The plan calls for making buildings more energy efficient through a mix of adopting zero-emission building codes and standards and providing incentives to transition to energy efficient appliances.  Cities such as Denver and Eugene, Oregon, are also considering bans on natural gas in new residential buildings.

    Non-Governmental Organizations

    Non-governmental organizations are likely to continue advocating for regulation of gas-fueled appliances and indoor air quality.  For example, a 2022 study conducted by the U.S.公众兴趣研究集团教育基金和Sierra俱乐部发现,消费者在各零售商购物可能无法了解与燃气炉和通风需求相关的健康风险,此外,2022年6月,美国医学协会传递了分辨率..manbext网页版and asthma," and resolving to advocate for programs to encourage the transition from gas stoves to electric stoves.

    Opportunities for Companies

    Clearly, indoor air quality concerns are not going away, and we expect continued regulatory and policymaking focus on these issues.  Companies selling products that may contribute to indoor air quality issues should consider monitoring these developments, participating in rulemaking and legislative processes, and proactively taking steps to evaluate and mitigate any indoor air quality risks (e.g., enhanced ventilation, monitoring), and develop a legal and regulatory strategy.  Others may want to consider both the benefits and the risks associated with providing air-cleaning and air-monitoring technologies to consumers, which will continue to be an area of significant regulatory and legislative focus. 

    If you have any questions concerning the material discussed in this post, please contact the authors.

    万博体育app手机登录EPA提供新杀菌杀虫剂指南并征求室内空气质量问题评论 万博体育app手机登录//www.ludikid.com/2022/10/epa-provides-guidance-regarding-novel-antimicrobial-pesticides-and-seeks-comment-on-indoor-air-quality-issues/ 托马斯布鲁加托 卫星2022年10月8日 化学类、农药类和塑料类 化学类 环境保护局 EPA公司 Pesticide设备 杀虫药 //www.ludikid.com/?p=7953 p对齐=scenter万博体育app手机登录环境保护局最近发布两则反微生物杀虫剂公告 。第一,环保局发布对表面应用反微生物残留效果请求指南 。第二,环保局宣布它注册了第一个获准在空气中杀病毒请求的产品 。环保局还征求对改善策略的评论万博体育app手机登录Continue Reading… p对齐=scenter万博体育app手机登录Environmental Protection Agency ("EPA") recently made two announcements regarding antimicrobial pesticides.  First, EPA released guidance regarding residual efficacy claims for antimicrobials applied to surfaces.  Second, EPA announced that it has registered the first product approved to make claims to kill viruses in the air.  EPA has also sought comment on strategies for improving indoor air quality to reduce disease transmission, which could involve the use of air sanitization products or pesticidal devices.  This blog has previously highlighted these issues, including noting steps EPA could take to improve pesticide policy in the wake of the pandemic and the emerging focus on indoor air quality and its regulatory implications.

    Taken together, EPA's recent actions are significant and provide opportunities for companies to develop novel products that could have significant public health benefits.  But they also highlight that significant uncertainty remains in this area, which presents risks that companies must carefully navigate to ensure regulatory compliance.

    1. Residual Antimicrobial Products

    EPA's guidance regarding residual antimicrobial products sets out a new framework governing products that seek to make claims of residual efficacy against viruses or bacteria.  This is significant: in the wake of the COVID-19 pandemic, the ability to use a product to kill viruses and bacteria on a surface not only at the time of application, but for weeks, months, or even years thereafter, has the potential for significant public health benefits.  EPA had provided interim guidance in October 2020, but is now providing more detailed guidance and a test method.  EPA's new guidance distinguishes between three categories of residual products: (1) residual disinfectants, (2) antimicrobial surface coatings and films, and (3) fixed/solid surfaces, such as copper, or other impregnated materials.

    Residual disinfectants are essentially standard disinfectants demonstrating residual efficacy, and may make claims that they "kill" microbes for up to 24 hours after application.Coatings and films cannot make "kill" claims, and instead must contain disclaimer language, including the statement that the product is not a disinfectant but "can provide some additional protection against microorganism(s)] for up to X days."  Fixed/solid surfaces and impregnated materials—for example, a copper door knob—may make claims such as the following: "kills 99.9% of [insert microorganism/s] within 1-2 hours of exposure when used as part of a comprehensive infection control program/protocol."

    For second and third categories of products (surface coatings and fixed surfaces), a "stewardship plan" must be included as a condition of registration.  The stewardship plan must address "the proper sale (including advertising and promotional materials), distribution, and responsible use of the supplemental residual coatings and antimicrobial surface products."  EPA suggests that plans could include elements such as outreach to infection-control specialists regarding product efficacy and appropriate use!万博体育app手机登录development of a website to convey accurate information about the product and to "correct any false or misleading third-party statements or publications," and participating in regular meetings with EPA and others to discuss the product.

    In requiring a stewardship plan, EPA is signaling that it intends to closely monitor these products, likely in part out of concerns that end users may view these products as a substitute for standard disinfection and thus not take adequate precautions.  By making the registrations conditional on implementation of a stewardship plan, EPA has the ability to cancel the registration in a more streamlined fashion as compared to an unconditional registration. 

    Accordingly, companies developing products for which a stewardship plan will be required will need to carefully develop and robustly implement their stewardship plan, to mitigate the risk of a potentially abrupt registration cancellation.

    Companies interested in developing these types of products, or adding claims to existing products, will need to generate appropriate data and secure registration with EPA (and the states) before making these claims.  Applicants may also need to develop and secure EPA approval of test methods if they wish to make differing claims or seek to use products on use-sites not within the scope of EPA's guidance (for example, EPA's guidance for surface coatings and fixed surfaces does not cover porous surfaces).  Ultimately, while this guidance provides a significant amount of information regarding these product categories, numerous questions remain about how EPA will implement it.

    1. Air Sanitization & Indoor Air Quality

    The registration of the first product approved to kill both viruses and bacteria in the air (rather than just bacteria) is also significant: EPA has now approved a product that can kill 99.9% of viruses in the air if used as directed, and so there is now an opportunity for pesticides to be developed to directly combat the spread of viruses in the air.  That said, significant challenges likely remain in developing products that are both effective and easy to use to treat the air.  That is demonstrated by the instructions for the approved product, which may pose some practical issues—they call for closing or covering "all doors, windows, air vents and returns" in the room, spraying for 30 seconds, and then leaving the room for 12 minutes.  The instructions also note that there is "no residual effect after room is reopened."  Still, this product provides a novel use, and may pave the way for other types of registered pesticides that kill airborne viruses and bacteria.

    As to the other category of EPA-regulated products that are intended to kill viruses or bacteria in the air—pesticide devices—EPA has not provided additional guidance.  However, on October 5, 2022, EPA's Office of Radiation and Indoor Air requested comment regarding indoor air quality matters, and announced its intent to "promote and advance the widespread adoption of actions that lead to improvements in indoor air quality ....  to help mitigate disease transmission (e.g., COVID-19)."  Among other issues on which EPA seeks comment are (1) what the federal government can do to help improve "ventilation, filtration, and air cleaning practices to reduce the risk of disease transmission," (2) whether and how to develop a building recognition program relating to "ventilation, filtration, and air cleaning," and (3) "qualitative or quantitative features could be helpful in assessing or describing ventilation, filtration, and air cleaning parameters in a building." Because many of these cleaning and filtering technologies are pesticide devices, stakeholders may want to submit comments to EPA, which are due by December 5, 2022.

    EV和清洁能源化学品审查过程精简 //www.ludikid.com/2022/10/epa-to-streamline-the-review-process-for-certain-ev-and-clean-energy-chemicals/ 泰勒威廉斯和托马斯布鲁加托 2022年10月5日Wed 电池回收 化学类、农药类和塑料类 电池组 清洁能源 气象学 气候变化 电动车辆 锂离子 半导体 TSCA系统 //www.ludikid.com/?p=7938 2022年10月5日 美国环境保护局宣布计划精简混合Oxids(MMOs)典型评审过程,包括某些阴极活性材料,它们是电车锂离子电池的关键组件,以及清洁能源生成和存储技术,包括风轮机和太阳能电池Continue Reading… p对齐=scenterEnvironmental Protection Agency ("EPA") announced its plan to streamline the typical review process for Mixed Metal Oxides ("MMOs"), including certain cathode active materials, which are key components in electric vehicles' lithium-ion batteries, as well as clean energy generation and storage technology, including wind turbines and solar cells.  MMOs can also be used in semiconductors. 

    As we have written about previously, increasing the domestic supply of EVs and semiconductors, and expanding the country's clean energy capacity are among the core policy objectives of the Biden Administration.

    Each of these supply chains could utilize these new MMOs, which are not currently listed on the Toxic Substances Control Act ("TSCA") Inventory.  Because they are not listed, MMOs are subject to Section 5 of TSCA — a point that EPA confirmed in a separate compliance advisory.

    Given this backdrop, manufacturers and importers of new MMOs must submit a Premanufacture Notice ("PMN") to EPA before manufacturing or importing these substances.  Upon receipt of a PMN, EPA considers the potential hazards and exposures associated with the substance, and determines whether steps must be taken to reduce the risk to human health or the environment before the substance can enter the U.S.市场 关键是制造商和进口商按要求提交通知,包括因为TSCA禁止为商业目的使用个人知道或理应知道不符合TSCA方面要求的任何化学品,包括提交PMN或有资格免上这一要求的要求§ 2614.  Manufacturers and importers do not need to submit PMN for MMOs already on the inventory (or that become added to the inventory).

    EPA's announced plan to streamline this review process is good news for the EV, clean energy, and semiconductor industries.  Under recent similar streamlining initiatives for biofuels, EPA has been able to complete its review for nearly all of the dozens of PMNs it has received since January 2022.  This streamlining appears to be, in part, a response to concerns that EPA has acknowledged with respect to the speed of its new chemical reviews. 

    More details are forthcoming, and the EPA has announced that it will provide outreach and training sessions for interested stakeholders to describe the new streamlined review process.

    EPA问题三请求信息循环专题与程序输入 //www.ludikid.com/2022/06/epa-issues-three-requests-for-information-seeking-input-on-recycling-topics-and-programs/ John Mizerak、Laura Martin和Thomas Brugato Thu, 16Jun202215:57:47+00 电池回收 电池组 电池回收 双党基础设施法 消费者垃圾处理 环境保护局 EPA公司 基础设施 回收利用 //www.ludikid.com/?p=7771 p对齐表示scenter###p>环保局发布三份信息请求 关于回收问题,第一步分配资金并完成去年基础设施投资与工作法(通称双党基础建设法)所载任务EPA请求信息程序主要面向改善回收使用Continue Reading… p对齐表示scenterquaEPA请求信息程序主要面向改善消费者垃圾回收:

    环境保护局发布三份信息请求 关于回收问题,这是分配资金和执行去年《基础设施投资与就业法》(通称双党基础建设法)所载任务的第一步EPA请求信息程序主要面向改善消费者垃圾回收:

    图类高度:自动机abjectivity-left数据对齐>IIJAsec70401bbrbrbrbrbrbr>(2) 建立程序促进电池回收,为电池生产者和消费者开发电池和其他形式的通信材料自愿标签指南,说明电池关键材料的复用和回收IIJAsec70401cabr+++br+++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++br信息电池回用和回收通信素材面向电池生产者和消费者EPA在每个类别中列出了一系列关于当前回收实践的具体问题,例如:见 IIJA分会J. 2.75亿澳元赠款,从2022-2026财年开始每年递增5 500万澳元 (2)EPA还必须开发模范回收程序工具箱,供州政府、地方政府和部落政府用于实施回收程序IIJAsec70402(b)(7). 每年1500万美元5年 EPA请求对具体专题发表评论,包括:标准术语住宅回收消费者教育素材测量有效通信and Current Stakeholder Education and Outreach Programs.

    The current recycling rate in the United States—about 32 percent—is well below what it could be.  EPA has set a target of 50% by the end of the decade, and last year published the agency's first ever national recycling strategy.  These requests for information focus on some of the most commonly cited reasons for the low rate, including consumer attitudes toward recycling and poor infrastructure in many parts of the country.

    The RFIs should be of interest to a broad set of stakeholders.  EPA's desire to better understand battery recycling practices is of particular note, given the prevalence of batteries in modern consumer products, and the importance of energy storage solutions to the Biden Administration's climate goals.  The guidelines developed by EPA could ultimately become the basis for either federal or state mandatory requirements.  Manufacturer take-back programs are also specifically mentioned, suggesting that EPA may eventually consider extended producer responsibility for these products, a trend that is prevalent in a number of states.响应这些请求的书面评论和信息必须在2022年7月25日或之前收到。 EPA资源保护恢复局今年将在全国各地主办虚拟会议。 国家科学院报告室内空气质量问题和调控考量 //www.ludikid.com/2022/05/national-academies-of-sciences-report-highlights-indoor-air-quality-issues-and-regulatory-considerations/ 托马斯布鲁加托 2022年5月24日20:30:13+00 CoVID-19 空气质量 净空技术 CDC EPA公司 室内空气质量 国家科学院 //www.ludikid.com/?p=7742 2022年5月24日 国家科学院发布一份报告 由EPACDC等赞助Continue Reading…

                On May 24, 2022, the National Academies of Sciences released a report, sponsored by EPA, CDC, and others, on indoor chemistry and air quality issues.  The report stresses the importance of these issues given that "people spend, on average, more than 80 percent of their time" in indoor environments, "often in close proximity to sources and processes that emit chemicals" and biological pollutants.  A main theme of the report is that there remain many outstanding questions in this area, and that "the management of indoor chemistry is at a nascent stage," but rapidly evolving.

                Several aspects of the report are likely to be of particular interest to companies that market products for indoor use, particularly air cleaning and air sensor products.

                First, the report underscores the importance of indoor air quality, an issue that has gained increased prominence as a result of the COVID-19 pandemic, and discusses various air-cleaning technologies.  The report noted the importance of "air-cleaning technologies," while stating that for some technologies, "[t]he lack of testing and regulation has led to rampant unsubstantiated claims about efficacy and health benefits of devices.  The potential health risks and benefits resulting from their use warrant further investigation and potential certification or regulatory oversight."  The report suggested that one way to address these concerns would be the development of "[s]tandardized consensus test methods."

                The report's focus on this issue highlights that companies that market air-cleaning devices should ensure that they are in compliance with all applicable regulatory requirements, such as EPA's requirements for pesticide devices, and maintain adequate substantiation for the claims made for their air-cleaning devices.  Other regulatory requirements, including those imposed by FDA, the FTC, states, and others may also apply, depending on the device's intended use and the claims made for the device.  This has been an area of heightened focus since the start of the COVID-19 pandemic, and companies that are not compliant run the risk of agency enforcement actions, consumer lawsuits, and other adverse actions.

                Second, the report notes a trend of the "increased use of consumer-grade indoor air quality monitors," which "may help improve indoor air quality and present opportunities for citizen science" by providing actionable information regarding indoor air quality issues in real time.However, the report also observed that some devices may suffer from "potential accuracy and precision performance issues," and that effective use of these devices would require users to be "equipped with enough knowledge to interpret the information they provide."  Similar to air-cleaning devices, the report suggested "[c]ertification processes for consumer-grade sensors" and the development of "consensus test methods" may be appropriate, noting that test methods for PM2.5 and CO2 are being developed.

                Companies developing these sorts of sensors should carefully consider both the accuracy of the information those sensors generate, as well as the information and recommendations that are provided to users of those sensors.  Again, regulatory and litigation risks may exist if inaccurate information or recommendations are provided.

                Third¸ echoing recent Biden Administration themes, the report noted that indoor air quality can have particular environmental justice considerations due to the "potentially unique indoor environments documented in low-income, rural, and cold-climate areas as well as in communities of color."  The report also noted that indoor air quality issues also have cross-cutting linkages with climate change, outdoor air quality, and energy efficiency considerations, which the report indicated warrant further study.

             Finally, the report observed that management of indoor air quality poses significant regulatory challenges, including because of the "inherent challenges in regulating non-occupational indoor air quality, such as privacy, personal liberty, and property rights."  The report suggested that, moving forward, a combination of "[b]uilding codes, standards, and guidelines," as well as regulation of "emission factors of new and recycled products introduced indoors," and of indoor-air cleaning technologies and sensors, may all be part of a set of "crosscutting, multipronged … solutions."

    EPA应用后农药政策改进机会 //www.ludikid.com/2021/07/epa-opportunities-for-post-pandemic-pesticide-policy-improvements/ 托马斯布鲁加托 Tue, 13JL202114:05:17+00 化学类、农药类和塑料类 CoVID-19 FIFRA Pesticide设备 杀虫药 //www.ludikid.com/?p=7609 sessiona病毒大流行在美国,67.7%的成人至少注射一针疫苗,为Biden政府EPa提供独特的契机,评估其大流行响应并考虑可能做出的任何政策改进。该文章侧重于两个特殊问题:(1)EPAContinue Reading…

    The easing of the coronavirus pandemic in the United States, with 67.7% of adults having at least one vaccine shot, provides the Biden Administration's EPA with a unique opportunity to take stock of its pandemic response and consider any potential policy improvements that could be made.  This post focuses on two particular issues: (1) EPA's regulation of pesticide devices, including in particular indoor air quality-related devices, and (2) treated articles.

    Pesticide Devices

    The Federal Insecticide, Fungicide, and Rodenticide Act ("FIFRA") regulates both pesticide devices and pesticides.  Pesticide devices operate by physical or mechanical means, and EPA has concluded that ultraviolet ("UV") lights and various types of air cleaning machines are pesticide devices, if claims to kill microbes or other pests within FIFRA's jurisdiction are made.  Under FIFRA, devices are subject to fewer requirements than pesticides—for example, unlike pesticides, devices are not subject to pre-sale review and approval by EPA.  Instead, EPA's principal substantive regulation of devices is premised on its authority to take action regarding "misbranded" devices.  7 U.S.C.万博体育app手机登录§ 136j.  EPA interprets the misbranding requirement as mandating that a device be safe and effective for its claimed use and that devices not bear any false or misleading labeling—including efficacy claims that are not adequately substantiated.

    While EPA requires sellers of devices to not make false or misleading efficacy claims, EPA has provided little guidance to industry regarding what efficacy data or other substantiation is adequate to support such efficacy claims.  Indeed, in an April 12, 2021 letter addressing UV lights, EPA declined to provide detail regarding the type of substantiation it believes is appropriate for UV lights, other than to note that "[i]f claims are made against specific pathogens, EPA maintains that testing of the device against those pathogens on the specific substrate (e.g., E.coli on cloth) is necessary to substantiate those claims."  Likewise, EPA has cautioned consumers about devices claiming to be effective against SARS-CoV-2, but has not provided guidance on what efficacy substantiation is required for such products.

    This lack of guidance is in tension with recommendations by public health authorities that such devices may be important tools to combat the pandemic.  For example, the CDC has indicated that upper-room UV light systems "can be used to control SARS-CoV-2 as a useful ventilation tool to consider in reducing the spread of infectious pathogens."  Yet an entity marketing such a system would have little guidance as to what type of efficacy data might satisfy EPA, or what data EPA considers necessary to substantiate any given claim.

    With the easing of the pandemic, EPA now has an opportunity to consider, in a non-emergency context, whether and how it can provide guidance to both regulated parties and consumers regarding appropriate efficacy claims and substantiation.  There may well be significant challenges associated with such guidance, given the different types of devices and the fact that their effectiveness could potentially change depending on the environment in which they are used.  Nevertheless, EPA plainly could develop some guidance (e.g., safe harbor specifications, generalized guidance regarding certain efficacy claims and data requirements, efficacy claims it views as impermissible or data it views as unreliable), and nothing prohibits the Agency from doing so after soliciting input from stakeholders via a public notice and comment process.

    Treated Articles

    Treated articles are products that are treated with an EPA-approved antimicrobial pesticide to kill microbes (e.g., a shower curtain treated to resist mildew).  Under longstanding EPA regulations and guidance, claims for such treated articles are limited to claims to protect the article itself.  40 C.F.R.万博体育app手机登录§ 152.25(a), PR Notice 2000-1.  Thus, claims to kill disease-causing bacteria or viruses may not be made in connection with treated articles.  Instead, to make such claims, an entity must "register the article as a pesticide product," which is a lengthy, complex, and costly process.  PR Notice 2000-1.  Unlike pesticide devices, this class of products is subject to full-blown regulation under FIFRA.

    Based on publicly-available information, EPA has registered few, if any, articles with claims to kill disease-causing bacteria or viruses.  One of the few examples emerged earlier this year, when EPA announced that certain copper alloys used in hard surfaces (e.g., a doorknob) was the first such product registered to make antiviral claims.  EPA has also provided draft guidance for hard-surface antimicrobial coatings.  But for many other types of products, EPA has not developed test protocols or other guidance indicating what sort of data (efficacy, safety etc.) would be adequate.

    It is not difficult to imagine the potential utility of such products, both now and in any future pandemic—especially a pandemic where surface transmission is a significant disease vector.manbext网页版For example, treatment of high-contact surfaces (e.g., public transit seats, light switches) could potentially provide significant public-health benefits, assuming efficacy, safety, and durability can be ensured.

    To be sure, there may be significant challenges and questions associated with developing such products.  But that is all the more reason for EPA to implement a process to work through these issues sooner rather than later.

    Conclusion

    EPA has played a key role in regulating antimicrobial products throughout the SARS-CoV-2 pandemic, and in expediting a variety of approval processes to provide immediate assistance in combatting the pandemic.  Now that the pandemic appears to have abated, EPA could consider giving thought to lessons learned from this pandemic, including how to provide a broader suite of antimicrobial tools to combat the next pandemic, while ensuring that those products are in fact safe and effective for use.

    加利福尼亚雇主必须遵守新Cal/OSHACOVID-19工作场所安全标准 //www.ludikid.com/2020/12/california-employers-must-comply-with-new-cal-osha-covid-19-workplace-safety-standards/ Carolyn Rashby、Thomas Brugato和DanielAusten Wed, 09 2020 16:54:59+00 空气污染和温室气体控制 CoVID-19 加利福尼亚州 Corona病毒 工作场所安全 //www.ludikid.com/?p=7370 p对齐='Center'###p> 202011月30日,加利福尼亚职业安全卫生司发布紧急临时COVID-19职场标准(“ETS”)生效ETS要求严格工作场所协议以抑制COVID-19扩散,它适用于所有加利福尼亚雇主,但受Cal/OSHAA喷雾性疾病标准约束的雇主或那些.Continue Reading… p对齐='Center''##p>i11月30日COVID-19职场标准紧急发布manbext网页版The ETS, which requires stringent workplace protocols intended to curb the spread of COVID-19, applies to all California employers, other than those subject to the Cal/OSHA Aerosol Transmissible Disease standard or those with only one employee at the workplace who does not have contact with others.  Under the ETS, employers must adopt and implement a comprehensive COVID-19 prevention program that includes identification and correction of COVID-19 risks, employee screening, investigation of cases, use of face coverings and other protective equipment, exclusion of exposed employees, and provision of free COVID-19 testing in certain circumstances, among other requirements.  The ETS also mandates testing and other action when there are multiple infections or an "outbreak" in a workplace.

    Cal/OSHA promptly published a "Frequently Asked Questions" document ("FAQs"), a one-page summary of the ETS, and a Model Prevention Plan.  These documents shed additional light on the ETS and how it might be enforced.

    Below is an overview of the key takeaways from the new ETS and subsequent Cal/OSHA publications.

    Basic Elements of the COVID-19 Prevention Program

    The central feature of the ETS is the requirement that all employers implement a written COVID-19 prevention plan.  At a high level, the prevention plan must include the following:

    • Communication to employees about the employer's COVID-19 prevention procedures;
    • Screening of employees for COVID-19, although employees may be asked to evaluate their own symptoms before coming to work;
    • Identification, evaluation, and correction of COVID-19 hazards;
    • Physical distancing of at least six feet unless it is not possible;
    • Use of face coverings, with only limited exceptions;
    • Use of engineering controls, administrative controls, and personal protective equipment as required to reduce transmission risk;
    • Procedures to investigate and respond to COVID-19 cases in the workplace, including to verify cases and receive information on test results and symptom onset;
    • COVID-19 training to employees;
    • Testing of employees who are exposed to a COVID-19 case, and in the case of multiple infections or a major outbreak, implementation of regular workplace testing for employees in the exposed work areas;
    • Exclusion of COVID-19 cases and exposed employees from the workplace until they are no longer an infection risk!manbext网页版and
    • Maintenance of records of COVID-19 cases and reporting of serious illnesses and multiple cases to Cal-OSHA and local health departments.

    Closer Look: Training Requirements

    The ETS requires employers to provide training and information on the following topics:

    • The employer's COVID-19 policies and procedures;
    • Information regarding COVID-19-related benefits;
    • The fact that COVID-19 is an infectious disease that can be spread through the air when an infectious person talks, vocalizes, sneezes, coughs, or exhales, that COVID-19 may be spread through surface contact, and that an infected person may have no symptoms;
    • Methods of physical distancing at least six feet apart and the importance of face coverings;
    • The fact that particles containing the virus can travel more than six feet, especially indoors, so other controls, including face covers and hand hygiene, must also be used;
    • The importance of frequent hand washing with soap and water for at least 20 seconds and the proper use of hand sanitizer;
    • Proper use of face coverings and the fact that face coverings are not respiratory protective equipment!and
    • COVID-19 symptoms, and the importance of obtaining a COVID-19 test and not coming to work if the employee has symptoms.

    Closer Look: Investigation of COVID-19 Cases and Notification of Exposure

    The ETS contains strict requirements for investigating COVID-19 cases in the workplace.  Employers must determine the day and time the COVID-19 positive individual was last present and, to the extent possible, the date of the positive diagnosis or appearance of symptoms.  Employers must determine which employees may have had a COVID-19 exposure by evaluating the activities of the COVID-19 case and all locations in the workplace the individual visited during the "high-risk exposure period."  The ETS defines the "high-risk exposure period" as either (1) from two days before they first develop symptoms until 10 days after the symptoms have first appeared, and 24 hours have passed with no fever, or (2) from two days before until ten days after the specimen for the individual's first positive test for COVID-19 was collected.

    Within one business day, the employer must notify all employees who may have had COVID-19 exposure (and any authorized representatives, such as their union), as well as any independent contractors or other employers present at the workplace during the high-risk exposure period.manbext网页版Importantly, the notice must not reveal the identity of the employee with COVID-19.  The FAQs clarify that notification is required only to employees who were potentially exposed by being within 6 feet of a COVID-19 case for at least 15 minutes over a 24-hour period during the high-risk exposure period.

    Employers also must offer the potentially exposed employees free testing during working hours, and the FAQs confirm that the time an employee spends being tested (including during outbreaks as described below) is compensable work time.  Employers must also provide these employees with information on benefits to which the employee may be entitled (such as workers' compensation, paid sick leave, leave under the federal Families First Coronavirus Response Act, company leave benefits, or benefits under a collective bargaining agreement).

    Closer Look: Exclusion of COVID-19 Cases and Return to Work

    The ETS requires employers to exclude employees with COVID-19 until they meet specified return to work criteria.  Furthermore, all exposed employees must be excluded for at least 14 days after the last known exposure to a COVID-19 case.  However, if permitted by a local health department, an employee may be temporarily reassigned to work where they do not have contact with other persons until they meet the return to work criteria.  A negative test result cannot be required as a condition of returning to work.

    The ETS also contains an exemption from the exclusion requirements for circumstances in which "removal of an employee would create undue risk to a community's health and safety," provided this does not violate a local or state health order for isolation or quarantine.The employer must request such an exemption from Cal/OSHA, and if granted, the employer must implement effective additional controls, including isolation of the employee or use of respiratory protection.

    The ETS specifies that COVID-19 cases with symptoms may not return to work until: (1) at least 24 hours have passed since a fever of 100.4 or higher has resolved without use of fever-reducing medications, (2) symptoms have improved, and (3) at least 10 days have passed since symptoms first appeared.  COVID-19 cases who tested positive but never developed symptoms may not return until a minimum of 10 days have passed since the specimen collection date of their first positive COVID-19 test.

    For employees excluded from work but who are otherwise able and available to work, the employer is required to continue and maintain the employee's earnings, seniority, and all other rights and benefits.This does not apply, however, to any period of time when the employee is unable to work for reasons other than protecting others at the workplace from possible COVID-19 transmission, or when the employer can demonstrate that the exposure was not work related.

    Multiple COVID-19 Infections and Outbreaks

    If a local health department identifies a place of employment as the location of a COVID-19 outbreak, or when there are three or more cases in an "exposed workplace" within a 14-day period, the ETS requires employers to provide free COVID-19 testing during working hours to all employees.  At a minimum, all employees must receive an initial test and a follow-up test one week later.  The employer must also provide continuous testing at least once per week until there are no new cases in a 14-day period.  The FAQs explain that the testing requirement for outbreaks triggered by three or more cases is not based on three or more cases in the "entire building," but rather in the "exposed workplace."  The FAQs further clarify that areas where masked workers momentarily pass through the same space without interacting or congregating are not part of the "exposed workplace," and that the "exposed workplace" only includes "the areas of the building where the COVID-19 cases were present during the ‘high-risk exposure period.'"

    In the event of a COVID-19 outbreak, the employer is required to notify the local health department immediately, but no later than 48 hours after the employer knows, or should have known, of three or more COVID-19 cases within a 14-day period.  Additionally, the employer must immediately investigate and determine the possible workplace-related factors that contributed to the outbreak.

    Major COVID-19 Outbreaks

    The ETS defines a "major" COVID-19 outbreak as 20 or more COVID-19 cases in an exposed workplace over a 14-day period.  In the event of a major outbreak, employers must provide testing twice per week, exclude all COVID-19 cases, investigate workplace illnesses, and take steps to eliminate any COVID-19 hazards.  Employers are also required to report major outbreaks to the local health department within 48 hours.  Employers must comply with the major outbreak requirements under the ETS standards until no new COVID-19 cases are detected in the workplace for a 14-day period.

    COVID-19 Prevention in Employer-Provided Housing and Transportation

    The ETS requires that employer-provided housing allow for six feet of physical distancing, including appropriately spacing beds to allow for six foot spacing in all directions.  Employers also must ensure that housing units, kitchens, bathrooms, and common areas are disinfected and cleaned at least once per day, maximize outdoor airflow and increase air filtration efficiency, provide face coverings and COVID-19 testing, and isolate exposed residents.manbext网页版These standards apply to all housing, including hotels and motels, but do not apply to housing provided for emergency response purposes.

    The ETS also sets out requirements for employer-provided transportation.  Employers must screen employees prior to boarding, separate employees by at least three feet in all directions in the vehicle, provide face masks and hand sanitizer and enforce their usage, and clean the vehicle's high-contact surfaces before each trip.  Additionally, vehicle windows must be kept open, with limited exceptions for hot and cold weather, and the employer must ensure that the ventilation system maximizes outdoor air.  The employer-provided transportation standards do not apply to transportation necessary for emergency response, or when the driver and all passengers are from the same household outside of work.

    Looking Ahead

    Because the ETS standards are now in effect, employers will need to immediately review and update their COVID-19 protocols to ensure compliance!万博体育app手机登录Cal/OSHA可能向Cal/OSHA投诉和/或对雇主实施ETS规定措施的挑战时,Cal/OSHA可能在未来数周发布更多指导帮助雇主更好地了解并遵守其培训、通知、雇员排除、测试和其他义务 EPAWERNS光公司Corona病毒索赔 //www.ludikid.com/2020/10/epa-warns-uv-light-companies-about-coronavirus-claims/ 托马斯布鲁加托 Tue 2020年10月13日14:22:39+00 CoVID-19 Corona病毒 EPA公司 //www.ludikid.com/?p=7349 万博体育app手机登录p对齐='Center'###p>EPA最近发布守法建议解决紫外线病毒(或其它病毒或细菌)问题,该机构根据FIFRA管理新科洛纳病毒(或其它病毒或细菌)为杀虫装置Continue Reading… 万博体育app手机登录

    EPA recently released a compliance advisory addressing UV lights that make claims to mitigate the novel coronavirus (or other viruses or bacteria), which the agency regulates as pesticidal devices under the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA).  While the advisory largely reiterates past guidance relating to pesticidal devices, which this blog previously discussed, it does underscore that EPA is particularly focused on UV lights, and contains three important cautions for companies making claims that their UV light products kill the coronavirus or other microbes.

    First, EPA has emphasized that the efficacy of UV lights can vary based on "a variety of factors including, but not limited to, the device's duration of use, distance of the light from the surface intended to be treated, the UV wavelength, the specific pest being targeted, the strength or wattage of the UV light bulb, the age of the UV light bulb, shadow areas or other factors."  Accordingly, companies making pesticidal claims for their UV lights should ensure that they are providing appropriate directions for use, and that the efficacy data they generate in support of their claims is generated consistent with those directions for use as well as the other characteristics of the product.  Companies may also wish to generate efficacy data in a variety of contexts (e.g., with aged bulbs, on different types of surfaces) to ensure that there are efficacy data supporting the claims for the life of the product, and in the various contexts in which it may be used.

    Second, EPA has noted that it "has been receiving complaints that UV light devices may be in violation of FIFRA.EPA继续关注这些装置并声明打算采取执法行动,因此制造或分发紫外线灯的公司应考虑审查它们的主张、营销材料和辅助数据,以确保其产品与FIFRA兼容性。

    归根结底,如同早先的咨询意见一样,EPA没有澄清哪种效果数据足以为UV灯或其他杀虫剂装置提供corona病毒索赔。
    EPA问题紧急批准 //www.ludikid.com/2020/08/epa-issues-emergency-approval-for-first-ever-residual-antiviral-product/ 托马斯布鲁加托 Tue,2020年8月25日17:31:03+00 化学类、农药类和塑料类 CoVID-19 Corona病毒 FIFRA //www.ludikid.com/?p=7338 p对齐='Center'###p>首次经EPA批准根据FIFRA(FIFA)对残留杀虫药、杀虫药和杀鼠药法(FIFRA)进行抗病毒处理。批准可能是COVID-19战斗中的重要恩惠,但也引出几个关键题 关于EPA对小说corona病毒采取更广泛方法的问题EPA历史方法Continue Reading…

    For the first time ever, EPA has approved a pesticide making residual antiviral claims under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA).  The approval may be a significant boon in the fight against COVID-19, but it also raises several key questions about EPA's broader approach to combatting the novel coronavirus.

    EPA's Historic Approach to Residual Antiviral Products

    Products that are sold with antiviral claims must typically be registered as pesticides under Section 3 of FIFRA, which can take 18-24 months.  EPA has historically declined to approve products making residual antiviral claims (i.e., claims that a product remains effective against viruses hours, days, or longer after its application), and during the current pandemic has informed applicants that they must develop their own testing protocol in support of such products.  Development of such testing protocols can be a lengthy and expensive process, with EPA taking a year to review the protocols alone.  Once such a protocol is approved, an applicant would then need to generate efficacy data and submit a registration application.While this process helps ensure that robust efficacy data underlies such registrations, it can also limit innovation and hinder EPA's ability to react rapidly to developments like the COVID-19 pandemic.

    The Granted Exemptions & Their Significance

    In a shift away from its historic approach, on August 24, EPA issued two public health emergency exemptions to the Texas Department of Agriculture.  The exemptions allow Texas to permit an airline and a orthopedics clinic to use a new surface coating that inactivates coronaviruses like SARS-CoV-2 for up to seven days.  The exemptions last one year.     The exemptions were issued pursuant to Section 18 of FIFRA, which authorizes EPA to grant state and federal agencies emergency exemptions for unregistered uses of pesticides to address emergency conditions.  Section 18 exemptions allow applicant agencies to oversee the limited use of an unregistered pesticide in defined geographic areas for a finite time.  Only federal and state agencies can apply for Section 18 emergency exemptions.

    Unanswered Questions

    This unprecedented use of emergency exemptions creates more questions than answers about EPA's long-term strategy to combat COVID-19 and its plan for residual disinfectant products, including:

    How will EPA evaluate data about a residual antiviral product's efficacy?  Texas submitted data demonstrating the coating's success against an EPA approved surrogate coronavirus and bacteria.  However, EPA has not released a summary of such data, a description of the protocol used to generate the data, or an explanation of the standard by which such data will be measured.  Accordingly, what EPA will require for future applicants remains unclear.

    How will this impact EPA's issuance of regular registrations for products making residual antiviral claims?  EPA has also not explained how the efficacy data requirements it applied to this Section 18 emergency exemption differed from those applicable to standard Section 3 registrations, other than to explain that the submitted data for this product do not "qualify for registration under section 3."  What additional research is necessary to qualify this surface coating (or similar products) for registration under Section 3 of FIFRA?  Will registration occur on an accelerated timeline, or will EPA continue granting emergency exemptions until the standard registration process is completed?  EPA has indicated that it will provide information on at least some of these issues "in the coming weeks."

    What about treated articles?  This emergency exemption addresses only a surface coating that is designed to be regularly re-applied.  To date, EPA has not addressed what efficacy data might be required for articles treated with antiviral products that are designed to last for months or even years.  Will EPA develop an approach for evaluating and registering such products?  EPA's Science Advisory Board found in June that such products could "have high potential in reducing or eliminating exposure to SARS-CoV-2," and thus should be a "high priority area to investigate."

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