Work cut out for us

[GeneralStark]

Looks like the rise in lumber costs in CA are due to producers passing on additional costs from tariffs to the consumer.

"Recent increases in lumber prices support the notion that Canadian producers will be able to pass along a portion of the cost to consumers."

from: http://madisonsreport.com/lumber-prices/

[wmick]

Isopropyl alcohol is legal to use in maple syrup production (for cleaning tubing) throughout Canada.

http://www.uvm.edu/~pmrc/Do%20Not%20...0in%20U.S..pdf

Dr. Tim - I've been doing a little research, trying to learn why IPA is permitted in Canada, but not in the USA.. I'm not coming up with any clear answers, other than the fact that the EPA hasn't approved it. (but not sure if it's been "disapproved" or just not approved "yet") I'd like to know.. Are you able to point me towards any information, comparing IPA to other commonly used or approved sanitizers... in terms of detrimental effects to health, environment, safety, etc?

[DrTimPerkins]

There is no simple resource I can point you to that will say that IPA cannot be used because of any specific reason. That isn't the way the system works. Similarly, there is little validity in trying to compare the U.S. and Canadian systems.....they are extremely different.

Instead, you have to first accept that, for this particular type of use, the product (IPA) is being used to "protect" the tubing system, which can mean that it lengthens the lifespan of use for the material. Because of that, IPA is considered a "pesticide" and would be regulated by the EPA and would NOT be regulated by the USDA (which many might assume and would seem logical since it is used in concert with a food product and food manufacturing materials -- but no...in the U.S. if it isn't used in food or directly in the manufacture of food it isn't part of USDA). For many pesticides that have been used for ages, they were grandfathered in. However most must undergo a review by the EPA for safety before being "permitted" for use. These permits are very specific for certain uses and doses and ways of use and materials used in (just read the caution and use labels on any pesticide). Companies manufacturing and selling such products must register their products with the EPA via an application process involving showing such use is effective and safe. It is not a requirement that the government show it is unsafe. The onus is on the company wishing to sell the product. Obviously, going through the application and permitting process is time consuming and expensive, with no guarantee of success. To date, no company wishing to sell IPA as a maple tubing sanitizer has gone through the process of permitting IPA in the U.S.

So, with all that, and weeks spent researching all the ins and outs of this, it was still somewhat confusing to us, so we wrote to the EPA asking for a definitive statement. Their response was (in part): "An IPA product would need to be registered with the EPA and include directions for use on maple tubing systems (or a similar type of use site) in order for it to be a legal use of the pesticide." At that point I stopped beating my head against this particular wall and accepted that. The ball is now in the hands of any company wishing to pursue an application for IPA use in maple tubing.

[amaranth farm]

Radio Silence.

[wmick]

Interesting... Thanks for the response... Much clearer to me now. You've got the USDA, EPA and I presume, the FDA all kind of crossing paths... makes it somewhat confusing, knowing that it is widely used in the sanitizing of food equipment.

Instead, you have to first accept that, for this particular type of use, the product (IPA) is being used to "protect" the tubing system, which can mean that it lengthens the lifespan of use for the material. Because of that, IPA is considered a "pesticide" and would be regulated by the EPA and would NOT be regulated by the USDA (which many might assume and would seem logical since it is used in concert with a food product and food manufacturing materials -- but no...in the U.S. if it isn't used in food or directly in the manufacture of food it isn't part of USDA).

This part I found the hardest to wrap my head around because of a couple areas of my misinterpretation... I would would be tempted to debate the following... - Is the tubing used "in concert with" or "directly in" food production? and.... Are we "protecting" or "sanitizing" the tubing?

[DrTimPerkins]

Interesting... Thanks for the response... Much clearer to me now. You've got the USDA, EPA and I presume, the FDA all kind of crossing paths... makes it somewhat confusing, knowing that it is widely used in the sanitizing of food equipment.

Actually, I don't believe IPA is used a lot in food equipment sanitization except in certain food manufacturing processes involving packaging. It is used a bit in medical sanitization.

This part I found the hardest to wrap my head around because of a couple areas of my misinterpretation... I would would be tempted to debate the following... - Is the tubing used "in concert with" or "directly in" food production? and.... Are we "protecting" or "sanitizing" the tubing?

Good luck debating with the EPA, FDA, and USDA. Things in those realms don't always make intuitive sense, but usually have some basis in fact buried deep in layers of regulation and historical decision-making.