Care lnc.

ogies
Jan.24,20LL

To whom it may concern: I am the Research Director Eco-Care of Technologies a Canadian Inc., R&Dcompany.Our President and CEO, GeorgePuritch, Dr. founded Eco-Care 1991and previously in co-founded SaferInc.(the first companyto commercialize insecticidal soap). Eco-Care develops low toxicity,environmentally-friendly pesticides we are world leaders this area. Our products not marketed us but instead and in are by are marketed various by companies aroundthe world. lnitially, demandfor our products was highest in public's Europe, wherethe general yearsaheadof North concern the environment for was several America. Our R&Dwork focusingon safealternatives conventional pesticides to beganlong beforeit was trendy,there was a demandfor productsin North Americaor any cosmeticpesticide bansexisted. We haveinvented manyof the low toxicityproducts the marketplace in today. Our products include: (withoutthe synthetic insecticidal soap,herbicidal soap,pyrethrins insecticides synergist PBO) and vegetable insecticides. alsoinventediron phosphate oil We slugand snailbaits,the first effective alternative metaldehyde baitsto be developed morethan 50 years. Manyof our products to slug in also haveorganic certifications. inventions Our haveallowed the replacement manytoxicconventional of pesticides suchas metaldehyde, syntheticpyrethroids, chlorpyrifos and 2,4-Din both consumerand ComAg markets various in countries. After manyyearsof research, developed low toxicity,selective we a lawn herbicidebasedon FeHEDTA (now marketedin Canada Scottsas Weed-B-Gon by and by Neudorffas Fiesta).FeHEDTA, chelated or iron,is a commoniron fertilizer similar FeEDTA hasbeenusedworldwide manydecades to and for (BPPD) without any adverse effects. FeHEDTA accepted reviewby the Biopesticide was for Division of t h e U . S . E P A a n d t h r o u g h t h e l o w - r i s k s t r e a m o f t h e P M R A i n CF in a da w a s r e q u i r e d t o m e e t s t r i c t a est a. for criteriato be considered reviewthroughthese regulatory divisions, including long historyof safe a usewithout toxicological concern,low toxicityto non-target organisms and non-persistence the in part of regulatoryrequirements, environment.As independent studieswere conductedon a rangeof non-target including organisms, fish,aquaticinvertebrates, honeybees, birdsand mammals.All results further demonstrated low toxicityof the product. Based toxicological the on evaluations, product the was classified ToxicityCategory by the EPA(their leasttoxic category) acuteoral, acutedermal, as lV for acuteinhalation, irritation eye and dermalirritation.Fiesta was alsoreviewed and allowed usein for pesticide and is alsoallowed usein Quebec Ontariounderthe cosmetic ban for and NovaScotia. from lobbygroupsto the contrary,there are no municipalities Canada Despiteassertions in where FeHEDTA beenbanned. has

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implythat a Inert ingredients addedto pesticide formulationsare proprietary. Lobbygroupssometimes productis toxic basedon its unknowninert ingredients.As the inventorsof Fiesta, can confirmthat we in List in all of the inert ingredients the productare EPA 4 inerts. List4 inertsare compounds the lowest (including NOPand OMRIcertified for formulations category and are allowed usein organic toxicityEPA products).ln addition,all of the toxicology tests (discussed above),which confirmedthe low toxicityof product(whichincludes inert ingredients). the with the end-use were conducted the product, weedswithout killing controls evenwithinthe PlantKingdom.FeHEDTA FeHEDTA highlyselective, is in grass.Thisselectivity based fundamental differences how iron is takenup and assimilated in is on (e.g. grasses). weeds)versus monocots dicots(e.g. to for containrecommendations wait untilthe productdriesbeforepeople Our productlabels Fiesta of shouldnot be interpreted an indication anyconcern as and petsentera treatedarea. Thislanguage as relatingto toxicology, was presentedby a lobbygroup. lt is importantto note that when the product recommended the authorities, Eco-Care the researchers as was initiallysubmittedto regulatory has placement this warningon the labelto avoidstaining clothes.FeHEDTA a darkcolourand it is on of grassbeforeit dries. Thiswarning possible staining occurif a consumer/pet were to sit on treated for to (waiting productto dry)is alsoa commonminimalrequirement labels.The label on for language improvement a for to recommendation consumers wait untilthe productdriesis actually significant whereconsumers are 2,4-D, the lawn herbicide including selective compared manyother pesticides, to Thereis alsono REI on concerns). requiredto keepoff treated areasfor severaldays(based toxicology (Restricted for EntryInterval) the product. to are lron chelates, suchas FeHEDTA, susceptible in is FeHEDTA not persistent the environment. (UV The presence of beingthe primarymodeof degradation. with photolysis degradation) degradation, than to moresusceptible breakdown makingiron chelates metal(e.g.iron)is importantin this process, papers lron of the breakdown iron chelates. document Numerous scientific chelators. standard (microbial UV underaerobic conditions. degradation) to are chelates alsosusceptible biodegradation is In terms,FeHEDTA degraded environments. simple degradation alsooccurin aqueous and microbial sunlight and soilmicrobes. by natural and lawn careoperatorsto haveeffective,low toxicity,environmentallyIt is importantfor homeowners available them for combatingpests. In effortsto to including weed control products, friendlypesticides, peopleoften resortto home remedies control pest to pesticides in the absence pesticides, of or avoid to usedby homeowners combat problems.Forexample, and tablesaltare sometimes both vinegar of than a usedmeasurement toxicity) is toxic(i.e.higher1D50, commonly weeds;FeHEDTA even less coulduseevenmoretoxic that homeowners it's Withoutsafeoptions, alsopossible thesecompounds. suchas high outlinedon the internet) weeds(e.g. controlmeasures for compounds combating bleach and ammonia. of concentrations gasoline,

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FeHEDTAa low toxicity, is environmentally-friendly productthat offersan effec{ive 2,4-Dreplacement. Eco-Care Technologies is proudto bethe inventors behind Canadian this succesF story. Fiesta been has embraced regulatory by authorities jurisdictions NorthAmerica. arefropeful the cityof and in We that Halifax not beswayed well-meaning will by groups lobby who arelacking infurmation the needed to correctly evaluate product. the researchers inventors thisproducf, areknowledgeable this As and of we aboutallof the details relating thislowtoxicity to product confidently and standbehind As it. parents pet owners homeowners, and ourselves, arealsohappy havesuclh safe, we to a effective product usein our ownyards. for

Sincerely,

@*t'K____
Diana Parker Research Director Eco-Care Technologies Inc. (2s0)6s2-ss1.0 diana@ecocare.bc.ca