10.3 Pesticides, Herbicides, and Disinfectants

The EPA registers pesticides according to 40 CFR Part 150–189:

152.3 (Definitions) Pesticide means any substance or mixture of substances intended for preventing, destroying, repelling, or mitigating any pest, or intended for use as a plant regulator, defoliant, or desiccant, other than any article that: (1) Is a new animal drug under FFDCA sec. 201(w), or (2) Is an animal drug that has been determined by regulation of the Secretary of Health and Human Services not to be a new animal drug, or (3) Is an animal feed under FFDCA sec. 201(x) that bears or contains any substances described by paragraph (s) (1) or (2) of this section.

The EPA makes no provision for off-label use or any situation outside those listed on the registered product’s label. Virkon and comparable products are provided as disinfectants but are not registered for water treatment! Foreign governments may have different regulatory statuses on drug use in their country. Be very clear in understanding the U.S. regulatory status when dealing with food fish in the United States.

Be knowledgeable about the disinfectants being applied. Understand the need to alternate disinfectants to avoid resistant microbes becoming established. Current thinking suggests indiscriminate or unchanging use of disinfectants such as quaternary disinfectants may also support antimicrobial resistance in bacteria surviving the disinfection process.^[2]