|
CPDA President Sue Ferenc Speaks at SCPA Annual Meeting: CPDA President Sue Ferenc was a featured speaker at the Southern Crop Production Association (SCPA) Annual Meeting held on October 24, 2011 in South Carolina. Speaking before an audience of more than 125 individuals representing the pesticide registrant community, CPDA President Ferenc provided an update on EPA’s implementation of the Endocrine Disruptor Screening Program (EDSP), the status of negotiations over the reauthorization of PRIA, the development of EPA’s Pesticide General Permit for discharges of certain pesticide applications on, over, or near U.S. waters, and the Endangered Species Act consultation process in evaluating the effects of pesticides. EDSP Update CPDA President Ferenc began her remarks with an overview of EPA’s proposal to expand the EDSP to include screening of priority water chemical contaminants as authorized by the Safe Drinking Water Act and called for in the House Appropriations Committee report for EPA’s FY 2010 appropriations. She told the audience that thus far EPA has failed to develop and make public clear, transparent and scientifically supported guidance for the submission of existing data or other scientifically relevant information (OSRI) that would be deemed sufficient to satisfy List 1 chemical testing orders. Dr. Ferenc pointed out that in its Terms of Clearance that qualified approval of the 2009 EDSP Information Collection Request, OMB directed EPA to promote and encourage test order recipients to submit OSRI in lieu of performing all or some of the Tier 1 assays and to accept OSRI as sufficient to satisfy test orders to the greatest extent possible. Dr. Ferenc explained that despite the restrictions imposed by the Terms of Clearance, EPA is seeking to prematurely expand the Tier 1 screening program to include more pesticide chemicals and potential drinking water contaminants. Dr. Ferenc noted that EPA has rejected a majority of OSRI submissions for Tier 1 screening of List 1 chemicals without clear and transparent justification and emphasized that EPA needs to provide greater clarity on how it will evaluate future OSRI submissions before it issues new EDSP test orders for List 2 chemicals. CPDA President Ferenc emphasized that EPA should allow for completion of the first phase of EDSP screening and then make necessary modifications to the Tier 1 battery before ordering additional EDSP screening so as to maximize the efficiency and minimize the burden of its testing program. PRIA 3 Dr. Ferenc next addressed ongoing efforts to reauthorize the Pesticide Registration Improvement Renewal Act (PRIA). She told SCPA meeting attendees that CPDA and other members of the PRIA Coalition are actively engaged in negotiating several EPA proposals including extended due date product review timelines, fees for inert ingredient approval, changes in maintenance fees, and footnote language. She reported that a number of work groups have been formed to address issues specific to EPA’s Registration Division, Antimicrobial Division, and Biopesticide and Pollution Prevention Division. Dr. Ferenc reported that the work groups and teams are hoping to reach a consensus by November with the ultimate goal of having a reauthorizing bill drafted by next January. NPDES In her other remarks, CPDA President Ferenc addressed EPA’s efforts to finalize its Pesticide General Permit (PGP) for discharges of certain pesticide applications on, over, or near U.S. waters. As had been announced during the October PPDC meeting, EPA issued the PGP by the court-ordered deadline of October 31, 2011 with an effective date of November 1, 2011. It is now available on the Agency’s website, but is not subject to further public comment. The PGP is identical to the pre-publication version of the draft final PGP released on April 1, 2011 with the exception that the final permit includes a set of conditions in response to the recommendations made by the National Marine Fisheries Service in its June 17, 2011 draft Biological Opinion (BiOp) pursuant to Section 7 of the Endangered Species Act (ESA). EPA has signaled that once the U.S. Fish and Wildlife Service has completed its consultations with the Agency and developed its BiOp recommendations, the PGP may be subject to further revision. Meanwhile, CPDA has been working collaboratively with its industry partners in support of H.R. 872, legislation that would exempt FIFRA registered pesticide products from the requirement for an NPDES permit. This measure was included in the base text of the Interior & Environment Appropriations bill. However, Congress has not been able to pass individual spending bills due to a larger fight on overall government spending. ESA Consultation Dr. Ferenc told SCPA meeting attendees that the broken ESA consultation process between the Services and EPA remains a major concern for the pesticide industry. She noted that the failure of the U.S. Fish and Wildlife Service and the U.S. National Marine Fisheries Service (the “Services”) to complete consultations with EPA in a timely manner has led to the successful filing of a series of lawsuits by environmental groups and the imposition of “interim measures” arbitrarily set by the courts. Meanwhile, this past October, the National Academy of Sciences’ National Research Council (NRC) initiated a study to examine scientific and technical issues related to the methods and assumptions used by EPA, FWS, and the NMFS in determining the risks to endangered and threatened species and critical habitats associated with the use of pesticides. To access a copy of the presentation made by CPDA President Sue Ferenc click here. |
