CH2O has a distributor agreement with Buckman which allows them to produce and distribute the product MECT-5-CT (EPA Reg. No. 1448-171) under their brand name PACT-5 (EPA Reg. No. 1448-171-43553). CH2O produced, sold, and distributed PACT-5 with a misbranded label. According to CFR40 both the registrant and the distributor can be held liable for this violation.
Throughout 2006, CH2O produced PACT-5 with a misbranded/outdated label. This label was missing critical updates to the first aid, directions for use, and the directions for disposal statements. This product had a signal word of Âwarning and these are critical updates that need to be current on the product label. This product was placed under a SSURO until corrected. CH2O took immediate action to correct the label and to ensue that all product labels were current and up to date.