unsubstantiated claims

By Philip L. Comella and Craig B. Simonsen

The U.S. Environmental Protection Agency recently ordered an orthotic shoe insert manufacturer to pay over $210,000 in civil penalties for making “unsubstantiated antimicrobial claims” about their orthotic shoe inserts – resulting in the sale and distribution of an unregistered pesticide, a violation of the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA).

This
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