JOHN THE OBSCURE ™

By John Ruch

© 2006

The Pen Is Mightier Than the Bacteria, And Other Ways to Write Dubious Ads

“With Anti-Bacterial Pen Protection*,” reads the package for Paper Mate’s FlexGrip Elite pens.

And what does that asterisk—the universal symbol for “what we really mean is…”—lead to? Why, to this fascinating explanation: “Anti-bacterial technology is designed to protect the pen’s surface and does not extend protection to skin.”

The US Environmental Protection Agency (EPA) had its own reading of this bizarre packaging when I asked about it: The claim violates government labeling regulations. “They cannot say antibacterial,” EPA spokesperson Enesta Jones said. The EPA can ban products for things like that.¹

Pens are being sold as having all sorts of super-powers these days. Bacteria-fighting is only one of them. Somehow, all of this had eluded me.

I’m a writer. I buy a lot of pens. I like them cheap, sturdy and reliable. So the Bic Ultra Round Stic Grip, black, medium, is my pen of choice. I’ve taken them to the Amazon, I’ve used them in all kinds of weather, I shove them in my back pocket and sit on them. They make no pretenses to James Bond-ian powers; they work.

But eventually I run out of them, and sometimes, so does my local CVS. So a few weeks ago, cursing the Bic-less shelves and feeling the pangs of ink withdrawal, I allowed my gaze to wander over the other pen offerings.

It was then I saw the “anti-bacterial” Paper Mate. And the uni-ball 207 Gel that “Helps Prevent Check Fraud.” And the uni-ball Vision Elite that “Won’t Leak in Flight,” with a little image of a passenger plane.

My Bic frown was rewritten as Paper Mate/uni-ball giggles. “They can’t be serious,” I thought. “But what do I know? Maybe they are, and there’s a world of super-pens about to open up to me.” I bought all three types of pens so I could take them home and find out either way.

It turns out that both Paper Mate and uni-ball are now owned by Illinois-based Sanford, LP. I spoke to a Sanford spokesperson who promised to get back to me with information on how these three pens work and were designed, but did not. She also did not return a call for comment about the EPA’s statement that the Paper Mate pen packaging violates labeling regulations.

“They Cannot Say Antibacterial”: Paper Mate and Clene Pens

If it’s not protecting human writers from disease, what’s the point of an “anti-bacterial” pen? Pens don’t get sick. I’ve never seen one consumed by plastic-eating bacteria. What’s the pen need protection for? Such were my basic questions about the Paper Mate.

The answer I got has nothing to do with protecting the pen. It has everything to do with EPA labeling regulations.

The Paper Mate pen is made with the technology of AgION, a Wakefield, Massachusetts company, which also makes its own line of “antimicrobial” Clene Pens. Both the Paper Mate and Clene pens are made by blending ionic silver, a known microbe-destroyer, into the plastic, according to AgION spokesperson Barry Green.

AgION makes many other “antimicrobial” products and markets them for food-industry and medical use. They include such items as stethoscope diaphragms and X-ray folders, and coatings for metal surfaces like air ducts and doorknobs. AgION is also on a brand of cutting board and a line of Stanley Bostitch office staplers.

The EPA regulates products that kill bacteria, viruses and/or fungus as pesticides, with some exemptions. These include “treated surfaces” intended to protect the products themselves, not human health, such as anti-mildew paints and shower curtains. AgION’s surface-treated products, including the Paper Mate and Clene pens, fall under this exemption, according to Green and the EPA.

As explained to me by Jones and on EPA Web site factsheets Jones directed me to, such products cannot advertise themselves as having any impact on human health. If they did, they would need to be registered pesticides and/or medical devices.

“AgION is registered as a materials preservative for plastics but companies using it cannot make public health claims,” Jones said.

That also means they can advertise themselves only as “antimicrobial,” not as “antibacterial” or as fighting “germs.” I find this distinction so subtle as to be meaningless for consumer-protection purposes, but it is a very clear point in the regulations.

That’s why, as Jones said, the Paper Mate’s “anti-bacterial” claim is a “violation of the treated articles exemption.”

“They cannot say antibacterial,” Jones said. “This would be correct advertising if it said antimicrobial.” The word “antibacterial” is a public health claim, and the asterisk doesn’t get them off the hook.²

It certainly confuses people; the promotional product Web site www.GarrettSpecialties.com lists “Prevent germ sharing” as a selling point for the Paper Mate. (It also lists “Stop spreading germs” as a selling point for AgION’s Clene Pens.)³

AgION itself is acutely aware of this. When I told Green about descriptions of “antibacterial” pens, he said, “I hope that’s not copy we wrote, because it’s not legal to say that.” (It was indeed not copy they wrote.)

The ad for the Clene Pen on AgION’s own Web site is much more ambiguous and circumspect. The ad, presented in the context of items sold for hospital use, says the pen is “antimicrobial protected” and “provides an effective line of defense in the control of bacteria as it inhibits the growth of the damaging microorganisms on the grip.”

The safe-word “antimicrobial” is in there, but the EPA was not thrilled when I sent it the copy for comment. “This may [be] considered a public health claim and would require review of the product labeling by the Agency,” Jones said.

When I e-mailed the EPA’s statement to Green for comment, he acknowledged receipt of the message but made no other comment. In a previous interview, when I read the Clene Pen ad copy aloud to Green, he said it is in compliance with regulations.

At first blush, the EPA regulations seem like a bunch of semantics, and Green presented them to me as such. “It’s legalese a bit,” he said.

In fact, Green told me that AgION believes its core product to be an antibacterial agent and in Europe, under different labeling laws, sells it as such. There, he said, “We know we can use the word ‘antibacterial,’ and we do.” They even cite specific bacteria being killed, he added.

“The science is that it’s true, but in the US you can’t say that,” he said, later elaborating in an e-mail, “In the US the standard is not only ‘truth in advertising’ but what the government (EPA) allows. So according to US regulations, it doesn’t matter whether you think you can prove it or not, you cannot advertise public health claims for treated articles.”

Scientific studies don’t matter in the EPA labeling regulations, he said, but added that AgION indeed has many studies and operates an on-site lab in which they test the killing of specific bacteria. Customers often require such studies and, outside the US, advertise their results, he said.

An EPA factsheet on treated articles, however, says that it isn’t just semantics. “EPA’s policy is predicated on the fact that no scientific evidence exists that these products prevent the spread of germs and harmful microorganisms in humans,” it reads.⁴ That involves a distinction between being antibacterial in a lab and actually reducing disease in household and medical use, which we’ll get into a bit later. For now, it’s worth noting that AgION’s silver technology is not a fundamentally new idea; indeed, Green noted silver’s long history as an antibacterial.

It’s true that the EPA requires the strange disclaimer that the products are treated only for their protection, not that of humans; but that’s because that’s supposed to be the actual intent and effect of the products.

In two e-mails, I asked Green why AgION doesn’t just register its products as pesticides and/or medical devices, so it can openly advertise their benefits in the US. I’m not sure if the EPA would even allow such a submission (though EPA regulations indicate it would if presented with sufficient evidence), and mentioned that to Green, too. Green did not respond to the first e-mail. The second e-mail was the aforementioned message to which he only acknowledged receipt and made no other comment.

The EPA factsheet also expresses suspicion of “treated articles,” noting that they “often make implied or explicit public health pesticidal claims to protect the public against harmful microorganisms.”

Green emphasized the regulations against that as well, saying AgION “can’t imply an effect that either implies or claims impact on human health.” Instead, AgION products are largely marketed as keeping surfaces clean.

But, he acknowledged, “Some reasonable people would make that connection” between a clean surface and human health.

Indeed, as previously described, Green explicitly claimed public health benefits for AgION’s technology, saying that it just can’t be advertised as such in the US. But he seemed to imply public health benefits for US consumer products, too.

“So what this [AgION technology] does is, it’s a way of preventing large-scale—preventing all kinds of growth…on touch surfaces,” Green said. “That, some people would say, that’s a way where lots of microbes get transmitted one way or another.”

He noted as one example that doorknobs can get dirty, and repeatedly referred to protecting surfaces “that many people may touch.”

When I asked specifically about what “antimicrobial protection” does for the Clene Pen if it doesn’t benefit human health, Green said, “I can tell you what we can say.” He then described the scenario of purchasing an item with a credit card and having the clerk hand you a pen with which to sign the form. “If something’s actually going on on that pen to inhibit the growth of microbes…that has to help,” he said.

Green also e-mailed me: a product testimonial from a health care facility saying bacterial growth had been inhibited there by an AgION surface coating; a university survey of germs found on household items; and a reference to the Web site of the Helford Clinical Research Hospital at City of Hope in Duarte, California, a cancer facility that installed AgION-coated ductwork. Regarding the hospital’s Web site, Green directed me to “read the paragraph entitled ‘Highest Level of Patient Safety,’” which describes the ducts, among other hospital features. “For me, this is a strong endorsement of the technology and the product,” Green said. “Note, though, that AgION could not make the statements that the hospital did. In fact, our attorney had to work to distance us from the statements which, though true, cannot be attributed to AgION technologies. We were not a party to the creation of this statement.”

Green also pointed out that AgION is now selling a liquid disinfectant and virucide that, under EPA regulations, can (indeed, must) claim antibacterial abilities, and noted it contains the same basic silver technology as the surface products.

After looking at the EPA material and getting Jones’ comments, I told Green in an e-mail that many of his comments appear to imply public health claims, but do so without using keywords like “antibacterial.” (Excepting, of course, his descriptions of the company’s European marketing.) I asked him to clarify what appears to be his understanding that a claim is not a public health claim unless it contains one of those keywords, and noted that my reading of the EPA regulations and the comments of Jones indicated that public health implications of any kind are not allowed. This was part of the same e-mail mentioned above, which Green responded to only by acknowledging receipt and making no other comment.

Besides the pen ad on the AgION Web site that the EPA said “may [be] considered a public health claim,” other AgION hospital-use products are advertised with the following statements on a Web page topped with a photo of what appears to be a doctor with a stethoscope around her neck: “can be an element of a hygiene program that inhibits surface contamination and improves sanitation”; “guarding against unclean surfaces that contribute to problems in hospitals”; “delivering effectiveness against bacteria on surfaces”; “helping hospital leadership meet regulatory requirements to reduce contaminants and improve cleanliness.”

If we pretend we’re in Europe and could openly say AgION products are antibacterials, which Green said would be the case, then any controversy here looks silly indeed.

However, as the EPA factsheet indicates, antibacterial products in general are controversial for possibly not working at all, and/or for having unintended negative consequences. The now-familiar antibacterial soap is under suspicion; treated items are viewed even more skeptically by the EPA.

A US Food and Drug Administration advisory committee last year found there is no evidence that antibacterial soaps are any more beneficial than regular soaps, and the Centers for Disease Control and Prevention (CDC) earlier found no effect from household use of antibacterial soap (no less disease and no more antibacterial-resistant strains being bred).⁵

Critics of the antibacterial product trend have two fears: that if such products work, they can help breed those resistant strains, resulting in unkillable super-bugs; and that they will kill the normal bacteria that surround us at all times, possibly allowing pathogenic bacteria to thrive in their place, or weakening the immune system of young children.

But the biggest argument of all is that antibacterial products are largely unnecessary, even in many medical settings. Alcohol-based hand-cleaners do an excellent job; and the biggest hygiene problem is simply getting people to wash their hands regularly and thoroughly, as the CDC notes and recommends.⁶

This is part of the EPA’s worry, too. The treated articles factsheet says, “EPA is concerned about these [public health impact] claims because, in addition to being unlawful, they are also potentially harmful to the public (e.g., if people believe that a product has a self-sanitizing quality, they may become lax in their hygiene practices).”⁷

Indeed, the EPA’s suggested labeling for treated articles includes a line saying the product itself should be cleaned and washed after use. That doesn’t show up on the Paper Mate packaging or Clene Pen ad.

Green acknowledged the importance of hand-washing as an active disease-preventing measure. He contrasted AgION’s products as a “passive” antimicrobial effort that’s always working.

I asked Dr. Harrison Weed of the Ohio State University Medical Center, whose work includes infectious disease research, about the idea of Paper Mate’s “anti-bacterial” pen.

He reiterated the fear that if it did work, it could help reduce the normal bacteria on the hands, leaving room for unusual infections. Green didn’t respond to that particular concern, but AgION’s Web site says the product is less likely to create resistant strains because it is inorganic.

Weed also expressed concern that the coating could wear off and could be toxic or produce allergic reactions. Green said in the case of the pens, the product is blended into the plastic and can’t wear off. He said the silver compound is “less toxic than table salt and less irritating than talcum powder,” registered for use in contact with food and drinking water, and works on contact rather than by leaching out into substances.

But Weed’s ultimate concern was that “there is no evidence that I am aware of, or that I could find, that an ‘antibacterial’ pen or other [antibacterial] stuff is of any benefit to anyone.”

Catch Me If You Can: The uni-ball 207 Gel

While the Paper Mate battles bacteria, the uni-ball 207 is fighting crime.

“Helps Prevent Check Fraud,” says a blurb on the package. The back of the package explains further: “Endorsed By: Frank W. Abagnale, SECURE DOCUMENT EXPERT…CHECK WASHING IS A FORM OF CHECK FRAUD…Check washing is a process where a thief erases the ink from a stolen check using common household products. Many uni-ball pens, such as the uni-ball 207, use specially formulated inks that contain color pigments that are absorbed into the check’s paper fibers, ‘trapping’ it [sic] from check washing efforts.”

There’s also a great big seal of approval from Abagnale, depicting an approximately 10,000-mile-tall microscope observing an equally giant check against the backdrop of the globe.

I’d never heard of check-washing, but it seemed like the whole problem could be avoided by locking up or destroying old checks, immediately depositing newly received ones and/or using electronic payments instead. But then, I’m not a secure document expert, let alone a SECURE DOCUMENT EXPERT.

Frank Abagnale is. He’s the scam artist made famous by the book and movie “Catch Me If You Can.” Among his crimes were various check frauds.

Having reformed and mended his ways long ago, Abagnale is now a security consultant, with his old confidence-man charisma obviously helping. He sells books, does lectures, issues a newsletter—all the required cult-of-personality stuff of today’s celebrity economy.

One thing he doesn’t do is talk about his unusual endorsements. A spokesperson in his Abagnale & Associates’ Washington, DC office told me Abagnale doesn’t talk to the press in general, and won’t talk to me about the uni-ball specifically.

Abagnale’s Web site claims the uni-ball 207 was created to his specifications after his previous endorsements of other uni-ball pens. In a Sanford press release, he claims to use the 207 to sign all his personal documents.⁸

Abagnale’s relationship with Sanford appears to be a regular cross-marketing effort. Sanford issued a pre-Tax Day press release this year giving his advice about how to file taxes while preventing identity theft.⁹

Part of it was dubious, where Abagnale recommended writing out “Internal Revenue Service” on tax-payment checks because thieves can easily alter the abbreviation “IRS” to “MRS.” and add a fake last name as the payee. In fact, as income tax forms make clear, you’re supposed to make the payment out to “United States Treasury.”

Every little bit helps in the world of check security, of course. (“Helps” is the cautious, vague word here; the most Sanford North America president Rory Leyden claims for the pen in company press releases is that “we can help individuals feel safer about the checks they’re writing.”¹⁰) But I wondered if a special pen is really necessary, or even popular among banks or security experts.

Outside of Abagnale’s own comments, I couldn’t find any citation for check-washing being a significant national problem. The Web sites of the American Bankers Association (ABA) and the US Secret Service say nothing about it.

But check security is obviously important. What do authorities recommend? Again, outside of Abagnale, I couldn’t find any recommendations of special pens or inks.

The Secret Service says to keep checks locked up, use direct deposit and keep personal information secure.

The ABA only talks about legislation that allowed banks to destroy original checks and keep digital copies instead, in part as a security measure.

Many experts also recommend using electronic payment methods as much as possible, instead of checks.

In his own report on check fraud for Union Bank of California, Abagnale says nothing about special pens/inks, though he briefly mentions the dangers of check-washing.¹¹ (It was written about three years before the debut of the uni-ball 207, but Abagnale reportedly has endorsed uni-ball pens for years before the 207, and gel inks have long been known industry-wide.) The “Best Practices” he recommends include keeping checks locked up, putting asterisks in blank spaces on the payee name line and writing in big letters.

When I asked about check-washing and special pens, Bank of America directed me to its Web site information about checks with built-in security features that make alterations obvious.

Abagnale strongly recommends secure checks, too—in fact, he designed one, the Supercheck. Its features include areas that make it obvious if check-washing occurs. In other words, his own check obviates the need for the pen he endorses.

The pen’s claim appears to be technically true; the more security features to “help,” the merrier. And ink that soaks into the fibers is a feature of some secure-document papers.

But I could find no evidence that you’re at significantly higher risk for check fraud if you don’t use the uni-ball 207, or are significantly safer if you do. As Abagnale and other sources point out, keeping the checks themselves out of criminals’ hands in the first place is the major security step. And as Abagnale also notes, there’s a whole other concern with stolen checks: identity theft, which any brand of ink won’t combat.

Incidentally, the Federal Trade Commission Web site notes that most states have laws protecting bank customers from losses associated with forged checks, as long as they took reasonable measures to keep the checks secure.

Sanford did not respond to my questions about the uni-ball 207.¹²

uni-ball Is My Co-Pilot: The Vision Elite

Much like Superman, the uni-ball Vision Elite fights crime while flying. Not only does it have the anti-check-washing ink (minus Abagnale’s endorsement), it “Won’t Leak in Flight.”

Not surprising, since neither will most other pens. Indeed, spokespeople for US Airways and the Air Line Pilots Association (ALPA) told me that pens don’t leak in passenger plane cabins, which is also my experience.

However, a friend recently told me he used to regularly experience leaks in flight from a particular line of pens, the Pilot Rollerballs, a ballpoint pen that uses a free-flowing wet ink.

Presumably, uni-ball’s claim is based on some air-pressure effect. Indeed, the first ballpoint pens became popular among British air force crews in World War II, because the then-prevalent fountain pens leaked in the low pressure.

ALPA’s John Mazor noted that modern airplane cabins are pressurized to simulate the air pressure at a few thousand feet of altitude. Normal pens should not expand to the point of leakage at that pressurization.

“Undoubtedly, many pens might leak at 35,000 feet if the cabins weren’t pressurized—but if that were the case, a leaking pen would be the least of your problems,” Mazor noted.

Mazor and US Airways’ Phil Gee both told me they’ve never experienced leaking pens on planes, have never heard of such problems from pilots or flight attendants, and have noticed no pen preferences among the same. (Mazor has been at ALPA for 27 years.)

Mazor did say that some baggage holds might not be fully pressurized, and out of that concern, he sometimes puts pens in his luggage inside plastic bags. (He uses a variety of pens; the one he mentioned by name is the Pilot Razor Point.) But he still has never had a leak. Gee said US Airways’ holds are pressurized.

I’ve personally flown to Asia, Europe and South America, as well as various domestic destinations, with various types of pens (including ballpoints and felt-tips) in my pockets. None of them leaked.

However, as aforementioned, my friend had repeated problems with, ironically, a pen made by a company called Pilot. He said that if he flew regularly, he might be interested in a special anti-leak pen. His current practice is to not bring pens along for the ride at all, instead purchasing pencils at the airport. No leaking there.

The Vision Elite’s ink chamber appears to be pressurized, which presumably is the source of the no-leak claim. However, it appears that the majority of ballpoint pens offer the same benefit, especially considering that one of the first uses for the regular ballpoint pen was leak-resistant writing on poorly pressurized airplanes. Certainly, my cheap Bics do not leak in the air.

On the other hand, cheap Bics have that cheap ink. The Vision Elite contains a fancier gel ink, akin to the fountain-type or gel inks in the reportedly leaky Pilot pens. So a special benefit of the Vision Elite might be that you get that wet, fountain-y ink without leakage (presuming the pen does in fact not leak, an experiment that is beyond this column’s budget).

In the end, it seems you’re safe enough tossing a regular, cheap ballpoint into your carry-on. No special pen is necessary, unless you can’t live without fancy ink.

Sanford did not respond to my questions about the uni-ball Vision Elite.

Incidentally, the US Airways online gift shop sells company-logo pens. They are Bic Clic Stics.¹³

Sometimes a Pen Is Just a Pen

Call me a nostalgist, but I remember the days when pens had unquestionable features to advertise. Paper Mate was a god when I was kid for promoting erasable ink. Now that was cool. (But what would Frank Abagnale think?)

Still, whatever the merits of their advertising, all the pens mentioned above are first and foremost writing tools that could be worth buying simply as such.

I didn’t think to order a Clene Pen, but I possess the other three kinds. A brief review:

The Paper Mate FlexGrip is a click pen with a kind of semi-rubberized black surface. It’s refillable, but pretty cheap. It’s also pretty bad—the surface is sort of sticky, it’s too fat and its ink action is not smooth.

I’ll hand it to Abagnale—the uni-ball 207 is the best of the lot. It’s another click pen with faux metal accents. It’s got a good feel and nice, smooth ink. Who knows? Maybe I’ll even start writing checks with it. Its one problem is that the tip shakes slightly.

The uni-ball Vision Elite is a cool-looking Space Age cap pen with a silvery surface. It writes smoothly with nice ink, though it comes out a bit heavy and wet. The real problem is that the pen’s surface is so hard and smooth, the cap flies off the end when you write—perfect for getting lost under an airplane seat.

In the end, I went to Staples and bought a box of Bics.

¹ Since, and presumably because of, the publication of this column, the Paper Mate FlexGrip Elite’s packaging and advertising have been changed to say “Anti-Microbial.” As the rest of this column explains, that means the pen’s main advertised claim is now OK from a regulatory perspective, while remaining incredibly misleading from common-sense and consumer-protection perspectives.

Update: I noted this change on Paper Mate’s web site. However, my local CVS recently received a new stock that still advertises itself as “Anti-Bacterial.” At the very least, Paper Mate appears to believe it can continue to sell off its back stock marked by this claim.

² The original Paper Mate packaging appeared to violate regulations in another way. The 2003 EPA factsheet “Consumer Products Treated With Pesticides” on the EPA’s Web site says, “The preservative claim and qualifying statement on the product packaging (type, size, color) must be given no greater prominence than other described product features.” On the Paper Mate package, the “anti-bacterial” claim was made on a sizeable yellow-and-blue shield inserted into a special compartment in the clear plastic atop the pens. No other product feature was given such prominence. The new “Anti-Microbial” slogan appears on a similar shield on the Paper Mate Web site.

³ Or as it says in one case, “Stop spreading the gems,” which is certainly a gem of ad copy itself.

⁴ “Consumer Products Treated With Pesticides,” op. cit.

⁵ The CDC’s Web site, and “Antibacterial Soaps Cause Concern” by John J. Lumpkin, Associated Press, Oct. 19, 2005, via the CBS News Web site.

⁶ CDC Web site, op. cit.

⁷ “Consumer Products Treated With Pesticides,” op. cit.

⁸ Available on Sanford’s Web site.

⁹ Op. cit.

¹⁰ Available on uni-ball’s Web site.

¹¹ “Frank W. Abagnale’s Check Fraud, Identity Theft and Embezzlement Volume II,” 2002, available at the hoabankers dot com Web site.

¹² A new packaging for the uni-ball 207 that I saw after the publication of this column features a prominent red-and-white sticker on the package front reading, “Specially Formulated Ink Helps Prevent Check Fraud!” This highlighting of the “specially formulated ink” deserves more highlighted attention than the same claim buried deeper in the original packaging. As the pen’s own packaging says elsewhere, the ink is not specially formulated for this pen, and as uni-ball’s and Abagnale’s other publicity materials describe, it was apparently not specially formulated for preventing check fraud at all. Rather, gel inks, a general phenomenon throughout the pen industry, are known to soak into paper; Abagnale later reportedly recommended uni-ball gel ink pens for this feature; and the marketing phenomenon of the uni-ball 207 followed. The new packaging would likely lead customers to presume some sort of special anti-check-fraud formulation had occurred. Again, Sanford did not respond to my questions about the uni-ball 207, so I must leave open the possibility that there is some newer, different information than is described in their and Abagnale’s Web site materials. However, based on that information, I think it would be more accurate to say that the uni-ball 207 simply contains specially endorsed ink.

It should also be noted that uni-ball is not the first pen to make the anti-check-washing claim. Pilot’s PermaBall, introduced in 2004, made the same pitch (minus celebrity endorsements), as a Dec. 9, 2004 press release at the Pilotpen.us Web site advertises.

¹³ This section originally said, on the basis of airline authorities, that no pen leaks in passenger plane cabins. It has been revised in light of my friend’s information about his leaking-pen experiences and his knowledge of ballpoint pen history, which I confirmed elsewhere (including, in the easiest-to-read version, the “ballpoint pen” entry at Wikipedia.org). Again, Sanford did not respond to my questions about the Vision Elite.

Significant sources not cited in the text or footnotes include: the EPA’s “Regulating Antimicrobial Pesticides” information page and all related documents on the EPA Web site; the EPA’s “Pesticide Registration Notice 2000-1,” March 6, 2000, provided via e-mail by Mr. Green; tax forms on the Web site of the IRS; and the Web site of the company Winbrook, which produces secure documents paper. Thanks to Prof. Alan Feldstein at the Southwestern University School of Law for suggesting sources. Please note that all hyperlinks have been removed or not spelled out in this column because one or more of them caused severe code-corruption problems in the text and on this site. All sources have been identified sufficiently to be found via a Google search. Feel free to contact the author for any specific citations. Posted June 26, 2006. Updated June 27; July 5, 6 and 7; and Dec. 15, 2006; and April 13, 2007.

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