Pond Boss Forums AQUATIC VEGETATION Controlling unwanted plants LAKE DYE Comparisons

Sorry, but I find your comments misleading - if not also inaccurate.
Under FIFRA (1972), ANY product that claims pesticide activity (by EPA's definition below), including lake-dyes, must obtain an EPA registration.
Pesticide claims are partially sanctioned by the definitive disclosure of the product's contents and efficacy-data; both of which are required for said registration. Other critical factors, such as environmental and toxicological assessments, are also evaluated during the EPA registration purposes.
If not for the requirements set forth in FIFRA, ANYONE could make a bathtub mix of ANYTHING and say it'll kill/control/inhibit SOMETHING, presumably in a SAFE manner, and never need to prove anything. Granted, if the product doesn't work, Joe-consumer probably won't buy it a second time. But, a few million gullible Joe-consumers could produce a sizable volume of single-purchase sales - not to mention a potentially huge impact on the environment.
True, there are many unregistered lake-dyes on the market - some good, some decent, some ???. But, to say that the EPA "no longer requires registration of lake dyes for ponds" is misleading at best, and is absolutely false IF the lake-dye makes any claim of impeding weed & algae growth.
Also, I would like to know what "simple testing" may be used to determine the pure-dye-content (PDC) of ANY lake-dye; registered or otherwise. Surely you're not suggesting that such tests be conducted visually - with the limited capabilities of the human's eye - ??
All dyes will appear extremely dark in their concentrated formulations. But, by no means does that appearance indicate their PDC - nor the ratio of individual pigments (with Yellow 23 being a relatively expensive component of the registered lake-dyes; and as a consequence, is usually low in content or completely absent from MOST non-registered lake-dyes).
When placed in a pond, all lake-dyes will generally turn the water blue - to some extent or another. But, unless you have two ponds (or sample vessels of water), to which equal amounts of two different dyes are added, then observed, compared and evaluated OVER TIME and under identical environmental influences, there is little means (to my knowledge) for Joe-consumer to verify that he received what he thinks he purchased. So please, let me know some details about the simple testing process - which presumably doesn't require lab equipment (i.e. a spectrophotometer, centrifuge, etc).
IMO, the "clever marketing technique" is often played by manufacturers of non-registered lake-dyes; who almost always mimic or benchmark against the 1-qt/acre-foot dosage that is recommended on the registered lake-dye labels - implying that they all contain the same amount of PDC (which the consumer simply can't verify).
I'll stop there, and await your response.....

Oh, one more thing: After April 11, 2011 - under the new NPDES guidelines, I believe dyes MUST be registered for (legal) use in lakes & ponds - period. Please correct me if I'm wrong.

EPA's DEFINITION OF A PESTICIDE
"A pesticide is any substance or mixture of substances intended for: preventing, destroying, repelling, or mitigating any pest."
WHAT IS PESTICIDE REGISTRATION
The process of registering a pesticide is a scientific, legal, and administrative procedure through which EPA examines the ingredients of the pesticide; the particular site or crop on which it is to be used; the amount, frequency, and timing of its use; and storage and disposal practices. In evaluating a pesticide registration application, EPA assesses a wide variety of potential human health and environmental effects associated with use of the product. The producer of the pesticide must provide data from tests done according to EPA guidelines.

This is a fascinating thread, thank you Kelly for creating it and monitoring it!

I attended the July 2010 meeting of the Aquatic Plant Management Society in Bonita Springs, FL. I met one of the presenters from the U.S. EPA
Ms. Allison Weideman
Branch Chief of the Rural Branch of Water Permits Division
Environmental Protection Agency
401 M St. Sw
Washington Dc, District of Columbia 20460
United States
(214) 665-2200
(202) 252-0500 Fax
www.epa.gov
I asked her about regulations concerning dyes. She told me that dyes are not a pesticide and are not regulated. I also spoke with the Michigan Department of Natural Resources this summer and they reiterated the same statement. "We do not regulate dyes". While you may be true that back in the FIFRA in 1972, 38 years ago which you referenced, dyes were regulated, but I could find not such statement in the current FIFRA(FEDERAL INSECTICIDE, FUNGICIDE, AND
RODENTICIDE ACT)
[As Amended Through P.L. 110–246, Effective May 22, 2008]
http://agriculture.senate.gov/Legislation/Compilations/Fifra/FIFRA.pdf As far as the NPDES guidelines it not applicaple since the dyes are not a pesticide.
Contrary to what you are saying one can purchase lake dyes with Acid Yellow 23. The Yellow 23 is not a significant contributor to the cost of the product, at 1-2% dye content it does not really alter the cost. In Fact because the Yellow 23 is not stable(it falls out of solution) at high concentrations, AQUASHADE is a weaker product than many dyes available on the market. If you try and make a concentrated product containing Acid Yellow 23 the Yellow 23 falls out and you are left with an off standard product. I have also heard of many complaints that the people do not like the Aquashade color, it looks too un-natural. The yellow makes it too green. You might try adding some black dye to the blue to make it more appealing and light absorbant over a wider light spectrum(Some black dyes contain yellow 23).
Now to a couple simple tests.
1. Take an eye dropper
2. Put a couple of drops of blue dye of the products in question in separate quart containers of the exact same amount of water (try and be as accurate as you can with the drops, the more drops the better as this will reduce the error. but not too many as the product will be too hard to evaluate) Try and get exactly the same amount of dye in exactly the same amount of water. As long as the dye solution is not too concentrated you should be able to see through the solution. The darker the solution the stronger the dye products. Repeat with as many products and compare side by side. You can determine the relative strength by diluting the product. For example the Aquashade is 50% when compared to Pure Blue Liquid dye. The solutions will look the same(minus the green tint for the Yellow 23) if the same amount of Pure Blue Liquid is in 1 gallon as compared to the same amount of Aquashade dye in 1/2 gallon of water. By the way the blue and yellow dyes used are the same dyes used to color easter eggs! Spectrophotometers are great as a tool but all they try to do is simulate the human eye.
As far as your other comments in a free market society competition is encouraged because it makes the system work its most efficiently.

Readers - no legal advice is given on this forum. Dye Chemist do not give legal advice here. If you are an attorney you would know better if you are not then don't give legal advice. It is only fair to the readers that you disclose your financial interest , if any , in this discussion.

Readers never ever count on getting legal advice you can count on from a regulator because its your rear end that is at risk. I have had federal and state regulators assure me that something was ok only to have them take the opposite position later. Good thing for my clients that I knew better and confirmed the statements in writing. They were dead wrong when they gave the advice and also wrong in thinking the judge would agree with them. Problem is it is very expensive to fight a government

I'm back into this old and renewed topic. The newer information is interesting. First to answer an earlier question by ewest:
"What effect does the proper use of registered pond dye {that containing the correct acid blue and acid yellow content} in a pond have on the plankton base in the pond? Does the pond dye block out those light wavelengths that are necessary for plankton growth?"
ANSWER: Lack of light to the plankton generally inhibits it. The more the light is reduced the less the plankton grows. It is hard to put a number on the amount of plankton reduction due to several factors such as: concentration of dye, species composition of the plankton, natural stains in the water, water fertility variations, amount of suspended detritus (natural), and water chemistry. IT ALL DEPENDS.

Advanced reading.
Two kinds of plankton: phytoplankton - tiny, suspended 'free floating' plants in the water column, and zooplankton - the animal part, comprised of microscopic ones and those up to sizes visible with the eye. This includes one celled animals (Protoza), rotifers, and the larger more 'free swimming' crustaceans. simplistically, the zooplankton mostly generally feeds on the phytoplankton group. Bacteria and tiny organic particles are also commonly eaten by many of the zooplankton.

Lack of proper light reaching the phytoplankon generally inhibits its growth and development. The less light it receives the less it grows; similar to terrestrial green plants. As with terrestrial plants some phytoplankters are adapted to grow well in shade or low light. Some of these may not be good or edible food for zooplankton.

I generally think that when dyes are used at label dosages it reduces the plankton growth (overall natural productivity) by about 50%. The reduction may in reality may be somewhere in the 30%-60% range. I am currently conducting a few tests on this topic. More information will follow. If I'm successful, watch for it; probably in a Pond Boss article.

It was stated that the Yellow 23 is not very stable in aqueous solution and it readily percipitates. I am pretty sure this is why Aquashade brand utilizes Monoethanolamine (<1%)in their product. Monoethanolamine is a emulisifier and dispersing agent to keep both of the dyes dissolved and in proper suspension. I was told long ago by Aquashade representatives that the yellow dye is an important component to properly filter out red and orange wavelengths to achieve effective suppression of plant growth i.e. photosynthesis. Just becasue the water appears blue does not mean You are getting good or effective reduction of both red and orange wavelengths that are necessary for photosynthesis of green plants (weeds, FA, and I assume most of the phytoplankton species). The presence of yellow 23 and monoethanolamine in pond dye may be worth a little extra expense if you are using dye / colorant to achieve plant control.

Commentary. I would expect that you could contact the pond dye manufacturer for the PDC (pure dye content) and total contents / ingredients. If they will not provide that information I would be very suspect of the product and maybe the knowledge and/or integrity of the manufacturer.

Eric: I've already emailed Ms. Weideman with an excerpt from DC's post. I'll await her reply to post that response. However, knowing the load she currently has on her plate, it might be awhile
Quite honestly, a technical loop hole has always existed regarding pesticide registration requirements. The looming issue in this thread, and in the marketplace in general, is whether or not a product's manufacturer MAKES a pesticide claim (i.e. does the manufacturer say it will impact a pest organism?). If so, it is the industry's long-held understanding that the product conforms to the definition of a pesticide - and thereby must be registered as such. If not, and if in this instance a lake colorant is simply marketed for "aesthetic enhancement", then a pesticide registration is not required. But, this scenario may also infer that the product's aesthetic benefits may not replicate the effects of a registered colorant for curbing weed & algae growth. Maybe it does, maybe it doesn't. Either way, there's no regulatory oversight to validate the product's contents, safety and environmental impact - all of which, as in this case, are left to the discretion of the manufacturer's voluntary and non-verified disclosures.
This latent debate may become a mute point next April. When I last reviewed the proposed NPDES regulations, even microbial agents (commercial "pond bugs") would constitute a "pollutant" and thereby fall under the new NPDES statues. I'll double-check the latest version to verify that understanding in relation to lake colorants. For better or worse, the proposed regs have seemingly been written in pencil thus far, with a lot of erasure-marks.
From a slightly different perspective, would anyone want to apply a substance to their pond that has not passed through regulatory filters that are intended to protect the buyer and the environment?
I generally agree with Bill regarding the use of colorants (of any type) in ponds that are managed for fishing. There are other means for reducing sunlight penetration - besides colorants, which are more likely to benefit the natural food-chain rather than impede it. Urban ponds & lakes (where fish are not a primary concern) are another story.

Huh? Where did I insinuate otherwise?
Regarding the "relative cost" of Yellow 23 vs Blue 9, what would you estimate the cost per kg of each?
As for the use of black lake-dyes (which appear to contain red & yellow pigments), they're often applied 50:50 in relation to half the typical dose of certain blue lake-dyes to yield a much more natural appearance. But, in my experiences with this practice, I have yet to notice any notable suppression of submerged macrophytes.
And what is the PURE BLUE LIQUID to which you referred? And who, pray tell, produces it???

Thanks Bill.

Kelly - no matter what Ms. Weideman says I don't want anyone here to think they are in the clear. Enforcement is at best arbitrary and sometimes totally off-base. No matter if one is correct they may be dragged through the wringer by regulators just to make a point.

It is ok to say "user you will probably be alright but there may be a problem so be careful". It is not ok to say "user you are in the clear" only later to find out the hard way that user was at risk all along just because of a remark by a regulator.

Surely, you're not implying that different government regulatory agencies try to referee from different rule books.

They often fight with each other over power and control so why would you think they would not use them on little old you.

I do not claim be a expert legal or otherwise about environmental regulations or the laws governing such regulations. I have done my research and stated my opinion to the best of my ability. I do know about the dyes used by consumers and applicators for lakes and ponds. I have done extensive testing on the various products available on the market. They all use or are based on Color Index Name Acid Blue 9, Color Index number 42090, CAS # 3844-45-9. The color index is a catalog published by the Society of Dyers and Colorists in conjunction with the American Association of Textile Colorists and Chemists. It catalogs the various dyes and pigments. http://www.colour-index.org/ Acid Blue 9, which by the way is not an acid, but referred to this way because of the method by which it is applied to textiles, is the generic name of FD&C Blue #1. FD&C Blue # 1 is the same chemical as Acid Blue 9, but FD&C Blue # 1 has gone through a certification process by the manufacturer to allow to be used in Foods, Drugs and Cosmetics. Acid Yellow 23 is the Colour Index name of FD&C Yellow #5. I do not know what this process entails, nor do I know what the regulations are governing the use levels in foods, drugs or cosmetics. I assume that the reason that the dyes were chosen for use in lakes and ponds in the first place because of their approved status for use in foods, drugs and cosmetics. I believe that the EPA no longer offers registration of these dyes for lakes and ponds. The products mentioned in previous posts were registered when it was offered, but I could be wrong and have written the EPA a letter requesting clarification on this issue. It is my opinion that the various dyes on the market are the "generic" form of these products. They vary in strength, but they are the same chemical. There is nothing special about the dyes used in the registered products. As opposed to the generic brands, the registered products are the "Brand" names of lake and pond dyes. I use the analogy of generic versus brand name pharmaceuticals. The generics are usually cheaper. When I subscribed to the Pond Boss magazine this week I was told that it was discouraged to promote ones products on this forum, yet I saw that happening on various posts, so I felt it my responsibility to "as a public service" to state my views on the subject as one who has been in the dye business my entire professional career of 29 years. I could go on about the difference between dyes and pigments, why a formula cost is not significantly effected by a ingredient that is only 1 to 2% of the formula: For instance if a ingredient costs $10 and you double the content from 1 to 2% the cost of the product goes up $0.10. I’ve tested products where the fancy packaging is worth more than the contents. The dye industry has always been a little secretive to protect ones own interests. It seems to me that nothing has changed in that respect.

Thanks for the clarification and info. We try to discourage direct selling of products by the people with an economic interest in them , especially if the relationship is undisclosed. That should be done through advertising with PB HQ. We also are interested in all the facts being available to the readers here so they can make informed choices. Direct attacks against people or products by name or inference is strongly discouraged except in the rare circumstance where (mgt/mods)suspect the possibility of misleading claims which may harm the unknowing readership. Opinions are just that and are not facts. All of this can be confusing to new posters. As with all new things it is often a good idea to ask questions and get a feel for things before diving in head first.

At the risk of beating this horse any more, I'll simply paste the somewhat predictable response below. Interestingly, the two specific questions that I posed were written in such a manner that either a "yes" or "no" would suffice.
It is almost comical how many/most/all gov't agencies seemingly prefer to offer verbal responses to specific questions during off-the-record conversations.

Dear Kelly,
Thank you for your questions. The EPA is in the process of finalizing the pesticide general permit within the next few months. Any questions and comments that are submitted to the Agency after the public comment closed on July 19th, 2010, are being collected and will be included in our question and answer document that will be made available on our website shortly after the permit is published. Please look for our responses to your questions then.
Sincerely,
Allison Wiedeman
-----------------
Sent by EPA Wireless E-Mail Services


My previous comment was posed quite facetiously Your assessment is very accurate!

Kelly I knew you posed that quite facetiously.

Also you got about the reply from EPA that I expected.

Truth be known I was heavy handed on the Aquashade last year. I calculate the volume of our pond, 60'x160' by 7 feet deep with 3.5 pitch sides at about 188508 gallons. The water was crystal clear most of the time. Chara grew in the shallows areas and I knocked that down with Curtain-Plus. The pond is already heavily shaded. It is airly aggressively aerated with micro bubble bottom diffusers. By my volume calculation according to the manufacture it comes out to only 20 oz about every month. We have little flow through and none during most of the summer.

From what I read, the type of platonic algae is different in an aerated pond, What's that about?


So, how much platonic algae should there be? If I use a Secci disk, what would I be looking for? I'm dropping in 250000 golden shiner fry, I don't want them to starve.

The amount of planktonic algae will vary from season to season. For the growing season, 18"-36" would be good. In some local lakes that now have visibility in the 60" or greater range, during the summer they only have about 18" of visibility.

Missed this thread back int he fall.

Kelly do you feel the dropper test is a valid one? If so I might volunteer to do this for PB if it gives us some useful info. I would like to get my clients the "best bang for their buck product" so Love to know the answers myself on which brands are stronger.

DC I appreciate your input and perspective.

Greg - I haven't personally attempted the dropper-method (quoted below from DC's previous post). But, any misteps in the process (i.e. inaccurate ratio-measurements or cross-contamination) could easily influence the results. You'd undoubtedly have a better go at it using your lab equipment. Also, exposure to sun + time might further delineate the levels and/or stamina of dye-content in each sample.
Let me know if you decide to pursue the matter. I have a couple of contestants to contribute.

1. Take an eye dropper
2. Put a couple of drops of blue dye of the products in question in separate quart containers of the exact same amount of water (try and be as accurate as you can with the drops, the more drops the better as this will reduce the error. but not too many as the product will be too hard to evaluate) Try and get exactly the same amount of dye in exactly the same amount of water. As long as the dye solution is not too concentrated you should be able to see through the solution. The darker the solution the stronger the dye products. Repeat with as many products and compare side by side.

I could get my hands on lots of bottles-and add 1,2,3 etc. drops and take pics of each "products bottle" as we go. This of course will not have anything to do with the light absorption, algae, etc. However it would tell me what looks more blue, vs another. We use it for asethetics to help the muddy look of ponds after a rain to clear "mask" turbidity.

This excerpt was taken from the web page http://www.epa.gov/npdes/pubs/proposed_pgp_fs.pdf

Cultural Method
Cultural techniques include the use of pond dyes and water-level drawdown. Use pond dyes to manage filamentous algae and submersed (underwater) vegetation. Several pond colorants and one or two dyes are EPA-registered for aquatic-weed control. Pond dyes and colorants can be effective if there is little water outflow from the pond. Dyes and colorants intercept sunlight needed by algae and other underwater plants for photosynthesis. Therefore, they are generally ineffective on floating plants like duckweed and water lilies and emergent (growing above the surface) plants like cattails and bulrushes. Dyes and colorants are nontoxic and do not kill the plants, and they are safe for use in ponds for irrigation, fishing and livestock. However, they are not intended for use in large lakes with a lot of water flow or lakes used for
59
U.S. Environmental Protection Agency 2010 NPDES Pesticides General Permit Fact Sheet
public water supplies.8

What am I missing here ?

Ok so I am reading this post and I am even more confused then I was. As ewest said here I am a reader that would like to know what the best dye to use is??? But don't want to do something stupid either because Mr. or Mrs Government Expert said this and this. Without getting into any type of issue here over a product in your non expert humble opinion what do you all think about Aquashade as a dye in general????

Thanks

I hope to talk to Bob and do a colorant test with several products and present the data at PB conference.. I will let you know what comes of the idea.

Thanks Greg that would be a cool test for sure. Hope you get time and the ok to do it.

Greg, when doing your tests see if you can come up with some data to see if the water with dye warms faster that unstained water.