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aandt

05/05/20 9:25 PM

#100323 RE: Smokenjoe1 #100321

Yeah that's something that has been discussed a few times recently. It certainly appears they are connected more than originally thought. Danolyte has been a sub-registrant with the same EPA number for a while, but they do also have their own number. There are also some other common roots and connections, but no real clear answers.

beer$$money

05/05/20 9:29 PM

#100326 RE: Smokenjoe1 #100321

Never a dumb ? It can get complicated when dealing with EPA Regulations.

Supplemental Distribution of a Registered Pesticide

According to 40 CFR 152.132, registrants may distribute or sell their registered product under another company’s name and address instead of (or in addition to) their own. Such distribution and sale is termed “supplemental distribution” and the product is referred to as a “supplemental registration” or “distributor product.” The distributor, also known as a “subregistrant,” is considered an agent of the registrant, and both the registrant and the distributor may be held liable for violations pertaining to the distributor product.

Detailed information on the supplemental distribution or supplemental registration of another federally registered product can be found in 40 CFR 152.132.

Important Note: Supplemental registrations are only an extension of a currently federally registered pesticide product. They are a duplication of the basic registered product and must reflect any changes in formulation or labeling made to the basic registered product within the same timeframe imposed on that product.

If the basic registered product is canceled, the supplemental registration is automatically canceled effective on the same date as the basic registered product, and existing stocks must be sold in the same time period (40 CFR 152.132(e)).
If the basic registered product is transferred to another company, supplemental distributorships do not transfer with the section 3 registration. Registrants must notify all supplemental distributors of the transferred product of the transfer agreement.
If the new basic registrant wishes to continue any supplemental distributorship or add new ones, the basic registrant must fill out a new "Notice of Supplemental Distribution of a Registered Product” Form 8570-5.

https://www.epa.gov/pesticide-registration/pesticide-registration-manual-chapter-9-supplemental-distribution-registered



ABC Medical of San Juan, Puerto Rico (www.abcmedicalpr.com) has signed on to be a
distributor and sub-registrant for PCT Corp. in Puerto Rico. Through a sub-registration licensing
agreement, which includes royalty revenues to PCT Corp., ABC Medical will initially receive one
large volume Hydrolyte® System for the purpose of producing, bottling, and distributing
Hydrolyte® solution to their existing hospital and healthcare clients.
The move signals the
company’s first distribution agreement in an area outside the continental United States.
"We’re excited to be able to expand into Puerto Rico," says Gary Grieco, CEO of PCT LTD.
"Expanding into this market is good business for us and for ABC Medical, especially during this
critical time when health and hygiene are at the forefront of people’s minds," Grieco further
commented.
According to the Puerto Rico Hospital Association, Puerto Rico has a total of 63 hospitals
managed by private and public sectors. The largest concentration of hospitals is in the San Juan
metropolitan region (where ABC Medical is located) with a total of 26 hospitals (10 public
hospitals and 16 private).
As a result of increased demand, an existing customer, BioBlasting LLC of Egg Harbor
Township, New Jersey (www.bioblasting.com) has also purchased two of PCT Corp.’s largevolume Hydrolyte® generators.


https://www.para-con.com/images/docs/PCTL03-13-20.pdf

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