Pesticide repackaging: What veterinarians need to know to avoid steep fines

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Veterinarians who open spot-on flea-and-tick product packages to dispense single applications to clients, for example, must label those re-packaged products in accordance with Environmental Protection Agency requirements.

The AVMA knows of at least one veterinarian who has received a complaint from the EPA about repackaging violations, and a steep fine hangs in the balance.

According to the EPA, the agency recognizes the benefits of allowing veterinarians the discretion to repackage pesticide products to meet their clients' individual needs, but also wants to ensure that consumers receive adequate product information. To reconcile those competing demands, the EPA has established, as a matter of policy, rules veterinarians must follow when repackaging pesticides.

Veterinarians prescribing, dispensing, repackaging, applying, or otherwise using pesticide products are subject to the regulations of the Federal Insecticide, Fungicide, and Rodenticide Act, which is administered by the EPA. The agency published a notice in the Nov. 1, 1979, issue of the Federal Register outlining how FIFRA applies to veterinarians.

To remind veterinarians of their responsibilities under FIFRA regarding repackaging and other pesticide use situations, the AVMA Council on Biologic and Therapeutic Agents and its staff worked cooperatively with the EPA to create a four-part series to educate veterinarians on this subject. Veterinarians are urged to read these articles and integrate the information into their practices to ensure safe use by clients and avoid steep EPA fines.

The first article outlined the rules veterinarians must follow when repackaging any pesticide. The articles were published in JAVMA and can be found on the AVMA Web site at the following addresses: