WHAT DETERMINES IF A PRODUCT IS A PESTICIDE OR AN ANIMAL DRUG?
Products used by veterinarians in prevention and treatment of conditions in livestock may be regulated as animal drugs, pesticides or both. In the early 1970’s, responsibility for regulation of pesticides on the federal level was transferred from the United States Department of Agriculture to the EPA. An Environmental Protection Agency and Food & Drug Administration (FDA) Memorandum of Understanding from 1971 outlines when a particular product or product use is regulated as a pesticide or an animal drug. This Memorandum of Understanding remains in effect today is found as part of FDA Compliance Policy Guide 7155b.03. Because this document is lengthy and complicated, contact the Department of Agriculture to determine if a product you are distributing or using is regulated as an animal drug, pesticide or both. REPACKAGING PESTICIDES Pesticides may only be sold or distributed in the manufacturer’s original, unbroken container. In order to repackage pesticides, the business must be registe