My speculation: Vibrant has some fluconazole in it...

[taricha]

Again, correct me if I'm wrong. There are different QACs with different alkyl or aryl groups. Hypothetically, if the type of QAC is different, they may have different COD while having similar quat reactions.

Yes, it is mathematically possible that all the stars could align in such a way. Vibrant could contain 2/3 of the amount of quat as algaefix that is precisely 3/2 times as reactive to the quat indicators, and leaves room for vibrant to also have the label amount of organic carbon and still register precisely the same COD as algaefix. That would be a remarkable 3 variable coincidence.
(Or they could just be the same)
A bacterial digestion will address that possibility.

 

[J1a]

Yes, it is mathematically possible that all the stars could align in such a way. Vibrant could contain 2/3 of the amount of quat as algaefix that is precisely 3/2 times as reactive to the quat indicators, and leaves room for vibrant to also have the label amount of organic carbon and still register precisely the same COD as algaefix. That would be a remarkable 3 variable coincidence.
(Or they could just be the same)
A bacterial digestion will address that possibility.

Yeah. I'm just trying to cover all bases with the data available.

Really enjoy following the whole experience. Thank you for the great work.

 

[taricha]

So I read the AlgaeFix EPA registration and it does contains the bacteria, Bacillus licheniformis S83086. "Contains a minimum of 2.25 x 108 Colony Forming Units."

Not sure if that info helps you at all. You're on a different level then I lol. Awesome work regardless, its been fun following this thread.

https://www3.epa.gov/pesticides/chem_search/ppls/008709-00010-20080205.pdf

I was wondering how I missed that. It's actually a different API product though.
https://apifishcare.com/product/microbial-algae-clean
(I kinda love that they say literally the strain of bacteria)

If you want that bacteria marketed as a reef product, you can get a bottle of spores here....
https://www.bulkreefsupply.com/live-rock-enhance-bacterial-live-rock-conditioner-reef-brite.html

 

[mojo8427]

Not sure if new knowledge or not but the quat in AF is bactericidal. Used industrially to remove bacterial slime from pipes and to kill mollusks in FW systems.

May explain the apparent success some have had fighting chrysophytes that seem to have a durable/protective slime coat?

The LC50 test API ran was only for 96 hours... seems pretty short to have recorded the entirety of its effects. Or is that standard for the industry?

https://www3.epa.gov/pesticides/chem_search/ppls/001448-00042-20000918.pdf

 

[Dan_P]

Look, if any test ever actually convinced you of anything, I think I'd disappear from from the forum due to heart attack.
It is unnecessary to update us like 5x on every page that you wish to discount all the testing done and you remain unconvinced. We know that already.

LOL!

I somehow thought this post ended, but nearly pooped my pants when I saw the number of pages it now has. So, I got to reading this evening. Thanks for sharing your work.

Would it be any use to compare the effect of Algaefix and Vibrant have on chlorophyll A production in algal biofilms? It seems like an interesting thing to do but maybe it would not resolve anything. I may just add to my list of things to do.

As for Vibrant containing bacteria that harm algae, wouldn’t heat inactivation be a test of what type of thing, living or non-living, is the active ingredient?

 

[MnFish1]

LOL!

I somehow thought this post ended, but nearly pooped my pants when I saw the number of pages it now has. So, I got to reading this evening. Thanks for sharing your work.

Would it be any use to compare the effect of Algaefix and Vibrant have on chlorophyll A production in algal biofilms? It seems like an interesting thing to do but maybe it would not resolve anything. I may just add to my list of things to do.

As for Vibrant containing bacteria that harm algae, wouldn’t heat inactivation be a test of what type of thing, living or non-living, is the active ingredient?

No - many bacterial spores are designed to survive 'heat'. (Depending on the level). Many bacteria form spores in response to heat.

 

[MnFish1]

Per the FDA:

"There are limitations to FDA oversight of claims in dietary supplement labeling. For example, FDA reviews substantiation for claims as resources permit."

"Federal law does not require dietary supplements to be proven safe to FDA's satisfaction before they are marketed."

"Some supplements have had to be recalled because of proven or potential harmful effects. Reasons for these recalls include

• microbiological, pesticide, and heavy metal contamination
• absence of a dietary ingredient claimed to be in the product
• the presence of more or less than the amount of the dietary ingredient claimed on the label

In addition, unscrupulous manufacturers have tried to sell bogus products that should not be on the market at all."

FDA 101: Dietary Supplements

Dietary supplements can help improve health but can also have risks. Get the facts on supplements and how the FDA regulates them to help keep you safe.

www.fda.gov

BTW - this was my point - even though this is discussing the FDA as compared to the FDA - there is a key difference. The key sentence is that products have been recalled because they contain harmful chemicals. There is a difference for example if 'product x' was merely plain water (i.e. not harmful) claiming to do something, as compared to product x containing 4.5% QAC. Known hazards are required to be reported (above a certain level). QAC (at least the one used in Algaefix( - is considered a 'pesticide' per the FDA. It is interesting to me that Algaefix reports QAC to the EPA. Vibrant reports 'bacteria' - which falls under 'microbiological' above.

 

[mojo8427]

BTW - this was my point - even though this is discussing the FDA as compared to the FDA - there is a key difference. The key sentence is that products have been recalled because they contain harmful chemicals. There is a difference for example if 'product x' was merely plain water (i.e. not harmful) claiming to do something, as compared to product x containing 4.5% QAC. Known hazards are required to be reported (above a certain level). QAC (at least the one used in Algaefix( - is considered a 'pesticide' per the FDA. It is interesting to me that Algaefix reports QAC to the EPA. Vibrant reports 'bacteria' - which falls under 'microbiological' above.

My understanding is that AlgaeFix had to report it to the EPA to be compliant with the law. Busan 77 has but one use and it is to kill life. Making it a pesticide according to their definition. Even if AlgaeFix said that the active ingredient was bacteria, because they add a quat, whose only purpose is as a pesticide. They would have to report it for compliance as well as add the EPA's warnings to the label.

The same applies to Vibrant. It doesn't matter what they say is the active ingredient is. If they add a quat, whose only purpose is "pesticidal" they would have to register it.

The FDA regulates foods and Busan 77 is "not for human consumption." I think I read last night that it is illegal to harvest fish that have been in water treated with Busan 77. Because AlgaeFix isn't for consumption, its reported to the EPA....

Sorry, I know this wasn't the clearest of comments. I think we agree on these points but I've not had coffee yet and have quite a fog going on.

 

[taricha]

Not sure if new knowledge or not but the quat in AF is bactericidal. Used industrially to remove bacterial slime from pipes and to kill mollusks in FW systems.

for those interested in the bacterial-suppressing qualities, I looked at the amount of bacterial suppression in Saltwater in post 179 (it was an identically tiny amount for AlgaeFix and Vibrant)
And I also looked at the bacterial growth suppression in freshwater in post 192 (it was an identically large amount - compared to saltwater - for algaeFix and vibrant.)

Would it be any use to compare the effect of Algaefix and Vibrant have on chlorophyll A production in algal biofilms? It seems like an interesting thing to do but maybe it would not resolve anything. I may just add to my list of things to do.

As for Vibrant containing bacteria that harm algae, wouldn’t heat inactivation be a test of what type of thing, living or non-living, is the active ingredient?

Running Vibrant through a 0.22um filter prevented any subsequent bacterial growth in a rich medium (post 445). So maybe that's easier, unless you feel like the polyquat might be at risk due to filtration moreso than heat.

If you put those two ideas together and I'd be very much interested in the results.
That is, check the subsequent Chlorophyll in your films vs Nothing, AlgaeFix, Vibrant, and 0.22um filtered Vibrant.
(I attempted to run that test on ulva, but my peices of ulva were too big for the recommended doses of algaefix, vibrant or filtered vibrant to do anything)

 

[MnFish1]

My understanding is that AlgaeFix had to report it to the EPA to be compliant with the law. Busan 77 has but one use and it is to kill life. Making it a pesticide according to their definition. Even if AlgaeFix said that the active ingredient was bacteria, because they add a quat, whose only purpose is as a pesticide. They would have to report it for compliance as well as add the EPA's warnings to the label.

The same applies to Vibrant. It doesn't matter what they say is the active ingredient is. If they add a quat, whose only purpose is "pesticidal" they would have to register it.

The FDA regulates foods and Busan 77 is "not for human consumption." I think I read last night that it is illegal to harvest fish that have been in water treated with Busan 77. Because AlgaeFix isn't for consumption, its reported to the EPA....

Sorry, I know this wasn't the clearest of comments. I think we agree on these points but I've not had coffee yet and have quite a fog going on.

Yes - algaecides are 'pesticides' according to the EPA - and have to be labeled as such on the bottle. My guess is that there are certain percentages below which this is not required.

 

[mojo8427]

Yes - algaecides are 'pesticides' according to the EPA - and have to be labeled as such on the bottle. My guess is that there are certain percentages below which this is not required.

"EPA has determined that pest control organisms such as insect predators, nematodes, and macroscopic parasites are exempt from the requirements of FIFRA." A bacteria would not fall under these exemptions nor would a quat. I even checked the exempted database and tried finding the quat in question, it wasn't there.

7 U.S.C. §136 et seq. (1996)​

The Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) provides for federal regulation of pesticide distribution, sale, and use. All pesticides distributed or sold in the United States must be registered (licensed) by EPA.

A pesticide cannot legally be used, sold, or distributed if it has not been registered with EPA’s Office of Pesticide Programs.

Biopesticides (microbial pesticides, biochemical pesticides, and plant-incorporated protectants) are required to be evaluated by EPA.

Crucial to any evaluation of the hazards presented by a microbial pest control agent is correct identification.
Agency expects a registrant to provide the most accurate, current taxonomic information to verify the identity of their active microbial agent. For bacteria this information can include genetic DNA homology, morphology, biochemical tests and antibiotic sensitivity.

While biopesticides require less data and are registered in less time than conventional pesticides, EPA always conducts rigorous reviews to ensure that pesticides will not cause unreasonable adverse effects on human health or the environment. For EPA to be sure that a pesticide is safe, the Agency requires that registrants submit a variety of data about the composition, toxicity, degradation, and other characteristics of the pesticide.

 

[jda]

EPA approval is required for any use. So is accurate labeling. BTW - so is using the product in accordance with the label by the end consumer. Just the cost of doing this for a small business is staggering, if what I heard was correct. The cost of the EPA investigation will be more, unfortunately.

 

[mojo8427]

Just to kick the horse a final time. Even supposed inert ingredients are regulated by the EPA. I believe that was something the company mentioned earlier. That their quat was non-contributory or something to that effect. It seems the EPA has complete and total domain over any chemical or biologic in the states.

Under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), all pesticides sold or distributed in the United States must be registered with EPA. Because of concern that some inert ingredients might also cause adverse effects to humans and the environment, EPA outlined its strategy for regulating inert ingredients in 1987.

@jda I think that the EPA would firstly allow Vibrant to register their product to their standard before they launched an investigation. I imagine this is small potatoes to the EPA.

 

[jda]

I don't know what this means, but had an environmental lawyer PM me - perhaps they will post. This is probably well into larger fine category with the deception, misrepresentation and not just a simple mistake or not knowing. I am not on Facebook at all, but I guess that is a record of more intentional deceit. Said that some federal AGs might pick this up criminally, but that is less certain - consumer fraud for profit.

I am not a lawyer, EPA investigator or AG, so why knows, right? I am in real estate and I have personally seen cases where people are investigated by 5+ FBI agents and prosecuted by the Denver AG for $10-20k in mortgage fraud - the deterrent is worth the effort to some of these people.

 

[mojo8427]

I don't know what this means, but had an environmental lawyer PM me - perhaps they will post. This is probably well into larger fine category with the deception, misrepresentation and not just a simple mistake or not knowing. I am not on Facebook at all, but I guess that is a record of more intentional deceit. Said that some federal AGs might pick this up criminally, but that is less certain - consumer fraud for profit.

I am not a lawyer, EPA investigator or AG, so why knows, right? I am in real estate and I have personally seen cases where people are investigated by 5+ FBI agents and prosecuted by the Denver AG for $10-20k in mortgage fraud - the deterrent is worth the effort to some of these people.

Not a lawyer either but the EPA vs Aquarium is an interesting read. It parallels Vibrant pretty closely.

https://yosemite.epa.gov/oarm/alj/alj_web_docket.nsf/All%20Content%20-%20Web/982B32318A242AA285257FBC00701F3E/%24File/aquarium-products-ifr-063095.pdf

Some of the highlights:

Moreover, as Complainant correctly argues, under Section 152.15 of the FIFRA Pesticide Regulations, a product is intended for preventing and destroying pests if the seller claims, states or implies by labeling or otherwise that the product can or should be used as a pesticide.

The uncontested facts show that the label on the oxygenator

box states that the product acts on fungus and that the handle on the box sets out that the oxygenator eliminates slime build up on filter impellers. Further, the literature in the oxygenator box states that the product: acts on fungus; inhibits the growth of hair algae and black algae; controls fungus; and eliminates slime build up on filter impellers. In light of this, the labeling and literature accompanying the oxygenator make pesticidal claims and a reasonable person would conclude that the product is intended to be used as a pesticide. Therefore, the oxygenator is determined to be a pesticide as defined in Section 2(u) of FIFRA and Section 152.3(s) of the Regulations.

3. The Misbranding Violations Involving the Oxygenator

As seen from the statement of material facts, supra, the oxygenator label ·and accompanying literature do. not contain an Agency establishment number as required by Section 2(q) (D) of FIFRA nor do they contain an ingredient statement showing the name and percentage of each active ingredient and the total percentage of all inert ingredients in the product, as required by Section 2(q) (2) (A} of FIFRA. Therefore, both the California and the Colorado sale of the oxygenator constitute the sale of a misbranded pesticide in violation of Section 12 (a) (1) (E) of FIFRA. As a result, Aquarium is liable for the violations charged in Counts IV and V of the Complaint.6

In light of the above analysis and since Aquarium has admitted that the oxygenator has not been registered as a pesticide, it must be and hereby is concluded that the Respondent is -liable as charged in Counts I and II of the Complaint, of selling an unregistered pesticide in violation of Section
12(a) (1) (A) of FIFRA.

 

[UWC]

This will more than likely be my last post in this thread as your guys have taken it to absolutely no man lands.

You guys are really talking in circles at this point. When we spoke with the EPA about registration and also third party registration companies, they seemed very uninterested in wanting to do anything with Vibrant. This market is too small and it seems like a sector they are not interested in getting involved in at this point. Maybe years ago when things were different before literally tens of thousands of products hit the market via the internet in every market sector of the world, it would have been different as there were so few companies involved.

Go to BRS's additives page or any wholesaler and scroll through all the pest products. whether that be for aiptasia, flatworms, algae's and so on. How many of these are registered with the EPA? Don't know if any of these companies tried to register or if they ran across the same thing, but none of them are registered. This would include Reeflux, chemiclean, dinox, products from Fritz, Dr. Tims, Brightwells and the list go's on and on and on. The EPA at this point is simply not interested in our market as it is such small fish, so to speak. They are after the broad market application products . Is the EPA being out of our hobby good or bad? I guess that's up to how you interpret what would happen if they were involved.

As for the fraud claims, yeah right. We created one of the most consumer happy products in the market that has stood on its own very well. Head back on over to the BRS additives page and scroll through the products and see how many companies actually list their ingredients (minus plain things like bicarbonate, et.). I'd say it's 50/50 and some actually list no ingredients at all. There is a reason for this and a reason for why some things are listed as proprietary. We are not the only ones. We are again talking about basically every company in this market that makes supplements. Run tests on these products and you will come back with wildly different test results from what is listed on the ingredients label.

Are all reef products 100% reef safe? Nope and neither are any products sold in this market and you see this daily with threads popping up about x product or y product. Why is this? Why does one thing work so well for others and can be a complete disaster for someone else? Nobody will ever know as there are far too many variables involved. One thing though, it's easy to come to a conclusion if something generally works for the masses and what does not.

 

[Dan_P]

No - many bacterial spores are designed to survive 'heat'. (Depending on the level). Many bacteria form spores in response to heat.

Autoclave!

 

[MnFish1]

Autoclave!

Lol. Not THAT hot. Edit. Of course spores can survive even boiling. The autoclave works because of high temp and pressure

 

[Miami Reef]

UWC summary:

We use polyquat, not bacteria. But no other additives on BRS’s site mention their ingredients either, so it’s cool!

 

[a.t.t.r]

UWC summary:

We use polyquat, not bacteria. But no other additives on BRS’s site mention their ingredients either, so it’s cool!

“And we claim the opposite of what it really is so it’s all good”uwc