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Request for assistance (Wisconsin residents)
- To: Aquatic-Plants at actwin_com
- Subject: Request for assistance (Wisconsin residents)
- From: Greg Morin <greg at seachem_com>
- Date: Thu, 24 Apr 2003 13:48:06 -0400
- In-reply-to: <200304241114.h3OBEZmp007774@otter.actwin.com>
- References: <200304241114.h3OBEZmp007774@otter.actwin.com>
If you are (a) a resident of the state of Wisconsin (b) use our
Flourish Iron and (c) are satisfied with the result of its usage,
then please contact me off list if you are interested in helping us
to ensure that you can continue to purchase this product in the state
of Wisconsin.
Flourish, Flourish Iron and Flourish Tabs are available at Petsmart
in all 50 states. Because these products are considered fertilizers
by state agricultural departments they must be "registered" in nearly
every state (and of course we get to pay each state per product for
the "privilege" of selling it in their state every year). We have
completed this process for every state requiring registration,
however the state of Wisconsin has an efficacy substantiation
requirement that no other states have. If you have a product that is
not substantially identical to a product already known to them then
they require that a company must submit independent, peer reviewed,
publishable research that said product provides a benefit. That
sounds like a great thing, the only problem is that the manufacturer
is not allowed to do the research themselves, only a third part can,
and Wisconsin can't recommend any one to do it and we can't find
anyone to do it and even if we did the amount it would cost would
take more than 50 years for us to recoup the investment (based on
sales only to Wisconsin). It simply makes no economic sense for us to
do this for a product we (Seachem) already know works.
Anyway, the general issue is this: the Wisconsin department of
Agriculture does not believe that an iron supplement product (not
just ours, any type of iron supplementation) is beneficial in any way
to a planted aquarium in the state of Wisconsin. The opinion of one
individual there is that basically local tap water has plenty and
you'd get enough from the gravel and fish food. That is certainly
going to be true in _some_ cases but as I'm sure most on this list
can attest to, iron supplementation does provide a benefit in certain
situations, whether it be ours or someone else's product. But
apparently because some do not need it, that is sufficient cause to
exclude a product pending an overwhelming preponderance of scientific
data when simple logic would tell you that if iron becomes deficient,
then adding it will make it not be deficient and will thus be of
benefit.
So even though this would not constitute scientific research, I
thought it might possibly be persuasive if residents of the state of
Wisconsin were to write a letter (US Mail) expressing how in their
experience Flourish Iron has provided a noticeable benefit (others
may write as well if you feel so inclined, I'm sure it would not
hurt). We would then collect all such letters and forward them on to
the Wisconsin Department of Ag. and see if it helps at all. If it is
not persuasive then we will have no choice but to withdraw that
product from the Wisconsin market. All similar products from other
manufactures will likely disappear in the near future as the person I
spoke with said they are getting ready to do "go out in the field"
and pull unregistered products off the shelf. So this is not just a
"Seachem" issue but an industry wide one. I know the intent of their
law was good but it has had the unfortunate unintended consequence of
limiting competition and reducing consumer choice: i.e. only huge
corporations can afford to get into the Wisconsin market as only they
can afford to provide the very expensive efficacy data.
Letters can be sent to:
Seachem Laboratories, Inc.
attn: Greg Morin
15151-A Prater Drive
Covington, GA 30014
--
Gregory Morin, Ph.D. ~~~~~~~President/CEO~~~~~~~~~~~~~~
Seachem Laboratories, Inc. www.seachem.com 888-SEACHEM
~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~