CPDA President Sue Ferenc Addresses Farm Chemicals International's "Trade Summit of the Americas"
In her presentation, CPDA President Ferenc discussed the challenges faced by inert ingredient and adjuvant suppliers at both the state and federal levels as related to the regulation and labeling of these products. CPDA President Ferenc told the Summit audience that while EPA does not mandate the registration of these products, a handful of states do, including the Washington State Department of Agriculture and the California Department of Pesticide Regulation. She also noted that there are some states, such as for example California, that have very specific data requirements for the registration of spray adjuvants as well as accompanying label formatting requirements. In addressing the issue of pesticide spray drift, CPDA President Ferenc provided a brief overview of the efforts of several CPDA member companies in developing a protocol for measuring the relative drift reduction capabilities of spray adjuvants. She noted that CPDA is concerned that EPA’s drift reduction technology program, focused largely on the use of nozzles as the preferred technology choice for spray drift reduction, may be discounting the use of adjuvants as an effective tool in minimizing drift. CPDA President Ferenc reported that the Council’s Drift Reduction Technology Working Group has been working with ASTM International in securing approval of a standard protocol for measuring the relative drift reduction capabilities of adjuvants under high and low-speed ground application conditions. In her other comments related to drift, Dr. Ferenc cited CPDA’s strong objections to EPA’s proposed PR Notice on pesticide drift labeling in which the Agency proposed an enforcement standard of “could cause adverse effects.” The Agency’s proposal stood in sharp contrast to the current risk-based standard in FIFRA under which EPA must ensure that the use of a pesticide does not pose an “unreasonable adverse effect” on human health or the environment. CPDA President Ferenc explained that EPA’s proposed policy would have constituted a de facto “no-drift” policy that presumed all off-site drift “could cause” adverse effects. She told Summit attendees that CPDA intends to continue its strong and active involvement in the regulatory and technical aspects of managing pesticide spray drift. CPDA President Ferenc then discussed the current efforts aimed at securing the reauthorization of PRIA. She highlighted the addition of new fee categories in PRIA 3 for inert ingredients used in pesticide products. Currently, approval of an inert ingredient used in a pesticide product is not subject to a fee under PRIA unless it is linked to a new product application, but those fee-exempt inert approvals are not guaranteed an approval decision time-line. Dr. Ferenc told Summit attendees that the negotiations over PRIA 3 ultimately produced compromise language that ensures these new fees will be fair and reasonable and that the associated statutory time-line for approval review will not exceed one year. She pointed out that these changes in PRIA will result in a process that gives inert ingredient suppliers the assurance that an Agency decision on a product application will be made in a timely manner. In her other comments, CPDA President Ferenc described how the current federal and state regulatory climate is bringing increasing pressure on the industry to disclose inert ingredient information on the pesticide label. She emphasized that traditionally this information has received protected status as Confidential Business Information. CPDA President Ferenc warned that the push for increased public disclosure of proprietary information on the label will likely continue unabated in the foreseeable future. Concluding her remarks, CPDA President Ferenc discussed the CPDA initiative surrounding an effort to establish standard terminology and definitions intended to bring greater clarity and consistency in the use of the term “biorational” when applied to a particular product. Dr. Ferenc explained that although certain sectors of the conventional pesticide industry believe that many of these products are not yet ready for mainstream production, small “mom and pop” establishments are selling them directly to producers or retailers with label claims that may not be valid. She emphasized that there is a real need for consensus definitions and product standards for those naturally derived materials commonly referred to as “biorationals.” |
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Council
of Producers & Distributors of Agrotechnology President Sue Ferenc was a
featured speaker at the Farm Chemicals International’s “Trade Summit of the
Americas” held in Miami, Florida on August 6-8, 2012. The Summit drew an audience of more than 500
attendees representing crop protection interests from around the globe. Speaking as part of a roundtable panel
discussion that focused on emerging legislative and regulatory issues impacting
the agricultural chemicals industry, Dr. Ferenc emphasized the important role
that spray adjuvants, inert ingredients, and other agrotechnology products play
in the development of innovative farming methods that help to optimize crop
yields, improve plant nutrient uptake, provide for more efficient agricultural
usage of water, and facilitate greater environmental stewardship. 
