James cited a couple of sections of statutes:

Your first citation is simply a blanket site registration requirement that has nothing to do with any particular product.  Rather it just tells EPA you exist and may some day do something with pesticides at the listed site.  And if you do something with a pesticide you must put your site number on the label.  This is a one time registration.  It is some of the routine boiler plate stuff any chemical manufacturer has to deal with. You fill out some form and submit it and the government gives you a site number for each facility registered.  Then once a year you may have to fill out a form on what chemicals or pesticides or animals you handled every year or whatever else is of concern to that particular agency.  If you are in the chemical business you will have to fill out and file such reports for one or more government agencies every year.  Each department even had to fill out forms like this that had nothing to do with pesticides every year when I was in R&D.  I would assume even Universities have to fill out such forms.  I know that any University that has any kind of animals has to register and get a site number and have an animal care over sight committee regardless of what they are doing with the animals.  Also all commercial Tox labs that handle animals need this same type of registration and more and more professional journals require you to have such a site registration if you publish animal studies of any type.  Yet, the government refuses to give people like me that are doing genetic studies with animals a site license as they say it would be too burden some for the government as the law requires them to do a yearly inspection of all registered sites!  All the government wants the registration for is so they know where to send the forms they want filled out.  So, getting a site registered is no big deal at all.  And, you likely will have multiple agencies that require such boiler plate registrations.  Site registration is neither burdensome nor linked to any particular product.  It is not even a commitment that you intend to make a product.  Just boiler plate in case sometime you do make or formulate or repackage a pesticide in this case.  Technically speaking if you poured some herbicide into a bottle for your neighbor to use you probably just repackaged the pesticide and should be an EPA registered site so you could put your site number on the label.  Or if you poured some terra into a bottle for a friend to use on his EFB hive you should have a site registration with FDA so you could put your FDA site number on the bottle.

Your second citation simply says that the EPA has the right to inspect you at any time during normal business hours if you handle pesticides in any way.  That includes the local lawn and garden center near you if they happen to have a shelf of bug or weed killers for sale.  So, I suppose there is also some kind of registration process for your lawn and garden store so the government knows where they are located.

If you are in business there are legal services you hire who understand what site registrations you need for different kinds of operations and will fill the boiler plate out for you. Any significant business will need several of these types of site registrations.  These are simply boiler plate things required to be in business and not a big deal and commit you to nothing other than following reporting laws and in some cases site inspection laws. It is not like you are registering a particular process or operation you intend to perform at that site and there is usually no requirement to disclose such details.  Such details might be required if your site was inspected and will surely be required if FDA is the inspector of if OSHA was the inspector and was investigating an incident.  EPA might want some details on any streams leaving the site due to environmental concerns.  I know of a case where EPA was having a Kitten because there was a water waste stream that had trace levels of cadmium.  The solution was to change from using oyster shells to crushed limestone to adjust pH.  Turned out the oyster shells had too much cadmium in them.

These types of registrations are entirely different from the implication that they were either a big deal or product specific.  If EPA wanted a registration for every Ag Formulator out there and what specifically they were doing it would be a huge problem.  Those guys often do not know what they are going to be running next month let alone next year.  That is why products and formulations are registered, not the particular equipment used to produce them and all that is required is the final production site listing on the label.  That final site may do nothing but mix two products and package the mix.  Or even just repackage out of a bulk container.  But, if needed, their records will show traceability to sources. 

In the case of oxalic acid this simply means anyone selling oxalic acid to be used as a miticide would need to have the last packaging site registered.  That is where he fills the bottles and puts his site number on the pesticide use label on the product. Or do what Mann Lake is doing and only label it as bleach to clean your wooden ware and you do not need a pesticide site number.  But, in that case the bee keeper is using a chemical as a pesticide illegally if he uses it to kill mites unless he does what Randy has done and gets an Experimental Use Permit which is another kind of registration.

Dick

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