May 14, 2008
TimberSIL was awarded the first (as of now only) EPA Approved barrier product exemption. Qualifying TimberSIL for the non-toxic barrier exemption of the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) part 152.10 Code of Federal Regulations (40 C.F.R.) because TimberSIL is not intended to “prevent, destroy, repel, or mitigate a pest” and that it is “intended to exclude pests only by providing a physical barrier against pest access”
This EPA determination represents almost four years of negotiations with the Agency, is an especially impressive achievement for several reasons.
First, according to EPA personnel, in its history, the Agency has never issued a letter expressly stating that a product qualifies as a barrier product. The barrier exemption has been on the books for over 20 years, and yet this is the first instance in which EPA has put in writing that a product qualifies.
Second, traditional wood treatment chemical companies and producers of traditionally treated wood products aggressively lobbied the agency not only to not issue this letter, but to take action to force TTT to go through the pesticide registration process.
Because of the pressure from traditional wood treatment companies and producers of traditionally treated wood products, EPA conducted an unusually thorough investigation of the TimberSIL process, the relevant literature, and the TimberSIL production facility. EPA chemists and toxicologists conducted a detailed site visit, and also spent many hours in interviews with TTT personnel and in document reviews.
Third, as EPA had not previously made a formal determination with regards to a barrier product, the Agency had to create a process and requirements specifically aimed at making such a determination for TimberSIL. This was one of the reasons that the final determination has held up for such a significant period.
After a process lasting almost 4 years, The EPA was convinced that, in fact, TimberSIL is not a pesticide but instead is a non-toxic barrier against rot, decay and common wood problems.
EPA Has Determined TimberSIL®: