I would think that one could argue that substituting veterinary products with brand names and a variety of carriers - e.g. Maverick is OFF LABEL.


With respect to Oxalic, its a defined acid, not a formulation, and if it's purity is at or above that of the 'registered' oxalic, it's the same product, oxalic is oxalic is oxalic. I would suggest that USDA needs to change wording to Reagent Grade Oxalic, and that should be clearly the label.


Reagent grade is generally equal to ACS grade (≥95%) and is acceptable for food, drug, or medicinal use and is suitable for use in many laboratory and analytical applications. USP grade meets or exceeds requirements of the United States Pharmacopeia (USP). This grade is acceptable for food, drug, or medicinal use.  I can see no reason why that's not On Label.



Seems to me like USDA needs a chemistry lesson or they need to tweak the Label Language.  



Certainly, this is an issue that AHPA and ABF should push for clarification.





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