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May 19, 2020

EPA Announces Third Temporary Modification to Pesticide Registration Notice 98-10 to Address Supply Chain Issues for Food-Contact Surface Sanitizer Products in Response to COVID-19

Lisa M. Campbell Heather F. Collins, M.S. Barbara Christianson

On May 15, 2020, the U.S. Environmental Protection Agency (EPA) announced that it is issuing its third temporary modification to Pesticide Registration (PR) Notice 98-10 to include food-contact surface sanitizer products containing the active ingredient (AI) isopropyl alcohol.  This new temporary amendment permits all the registration modifications outlined in the March and April modifications, while also expanding the criteria for the types of products that qualify for the provisions of this amendment.

EPA states that this temporary, time-limited amendment to PR Notice 98-10, dated May 11, 2020, will extend some of the supply chain flexibilities to products used in the food manufacture and preparation industries.  Specifically, this temporary amendment expands these flexibilities to manufacturers of food-contact surface sanitizer products containing isopropyl alcohol and adds isopropyl alcohol to the list of AIs commodity chemicals allowed to be changed by notification in order to use any similar source to produce List N registered disinfectant products.

According to EPA, these isopropyl alcohol sanitizer products are not to be applied directly to food.  Instead, they are used to sanitize equipment and surfaces used in food manufacturing and food preparation.

EPA intends for these flexibilities to increase the availability of products for use against the SARS-CoV-2.  This third temporary modification to PR Notice 98-10, according to EPA, is in response to feedback from the food manufacture and preparation industries that are experiencing challenges acquiring sanitizers for use in production facilities processing low-moisture products like cereal, flour, and industrial baked goods.

Additional information on submission information for registrants is available at Temporary Amendment to PR Notice 98-10 and on our blog.