Standards for Pesticide Containers and Containment; Extension of Comment Period

Filed on regulations.gov — full text not in the inline record.

Filed on regulations.gov — full text not in the inline record.

Filed on regulations.gov — full text not in the inline record.

Document Processing Desk (PM Team) Office of Pesticide Programs (7504C) U. S. Environmental Protection Agency 401 M Street, S.W. Washington, D.C. 20460-0001 RE: Docket No. OPP- 20040049 Docket ID OPP-2004-0049-0002 On behalf of the 6,000 dealer members of the Agricultural Retailers Association (ARA), we respectively request EPA extend the public comment period for the proposed rule on ?Standards for Pesticide Containers and Containment? an additional 45 days beyond the current proposed deadline, in order to provide EPA with up-to-date and accurate information. A number of state agricultural groups as well as ARA need additional time to gather data from the industry on this important issue. For example we have only recently initiated inquiries and surveys concerning the storage of bulk and non-bulk chemicals at non-regulated locations. In past issues of this magnitude EPA has held open the comment period for longer time frames. End user chemical storage has only been a factor for the last few years. Thus creating the challenge of obtaining and analyzing data, and responding to the EPA in the short time frame allowed. We plan to present information concerning commercial application equipment sales to end users, not chemical retailers, in order to set an appropriate base for our position. End user storage will become even more prevalent in future years, due to the dramatic increase in the sales of generic crop protection chemicals. Our comments will show that in today?s crop protection market place, over 50% of all crop protection chemicals active ingredients are off patent and by 2006 70% or more, will be without patent protection. ARA needs more time to gather information, as the emerging marketplace will allow less stewardship-minded brokers to resell products in a new opportunity marketplace. ARA believes that a forty-five day extension serves as a legitimate request in order for an industry to fully summarize and respond wi