Comment submitted by Madison Gouin

I appreciate the Environmental Protection Agency’s initiative to provide guidance on evaluating pesticide products that make claims against viruses. Clear, science-driven evaluation standards are critical to protecting public health, guaranteeing consumer safety, and upholding trust in the regulatory process. I urge the EPA to be more specific on how efficacy data should be generated and interpreted for a range of viral pathogens, such as emerging or highly transmissible viruses. Providing clear guidance on appropriate study design, testing methods, and statistical analysis will help ensure that product claims are accurate, trustworthy, and not misleading to the public or commercial users. Another important clarification is labeling requirements, particularly regarding the scope and limitations of antiviral claims. When consumers are provided with accurate and transparent labeling, they make more informed decisions, and the risk of misuse or overreliance on products that may not provide adequate protection is heavily reduced. I encourage the agency to take environmental stewardship in the evaluation process into consideration. Antiviral pesticides may have unintended effects on non-target organisms, aquatic life, and soil health. Through guidance on minimizing ecological impacts, safe disposal behaviors, and monitoring for possible environmental consequences, confidence in the product's effectiveness is built while remaining environmentally responsible. Finally, I encourage the EPA to increase transparency in the evaluation process by publicly sharing summary findings, decision rationales, and supporting data publicly accessible. Meaningful engagement with stakeholders and the public fosters trust in regulatory decisions and reinforces accountability. By addressing these considerations, the EPA can ensure that antiviral pesticide products are not only safe, but effective while also protecting the public and the environment. Thank you for considering these comments.