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EPANonrulemakingEPA-HQ-OPP-2018-0262

Petition Seeking Revised Testing Requirements of Pesticides Prior to Registration; Notice of Availability.

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Agricultural Retailers Association filings
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Agricultural Retailers Association filed 1 comment on this docket between Apr 2, 2019 and Apr 2, 2019. 5 other organizations filed here. The comment window closed 2686d ago.

What Agricultural Retailers Association filed (1)

Apr 2, 2019· Comment submitted by Richard Gupton, Senior Vice President, Public Policy & Counsel, Agricultural Retailers Association· EPA-HQ-OPP-2018-0262-0153

On behalf of the Agricultural Retailers Association, a non-profit trade association representing the nation's agricultural retailers and distributors, I am writing in opposition to this petition and in strong support of the comments submitted by the Pesticide Policy Coalition (PPC) as well as CropLife America (CLA). The Center for Food Safety's grounds for testing revisions are not based on sound science and utilizes flawed, inaccurate data., and not based on sound science. EPA already has very well-established testing regimes in place that follow FIFRAs safety standards and statutory requirements under FQPA and ESA. In addition, the additional testing requirements soughts by CFS are contrary to Congressional intent in its enactment of FIFRA. Sincerely, Richard Gupton Senior Vice President, Public Policy & Counsel Agricultural Retailers Association

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Abstract

The petitioner, CFS, requests the Agency require testing of whole pesticide formulations to account for the toxicological effects of inert and adjuvant ingredients and the testing of tank mixes to assess the interaction between pesticide ingredients. CSF believes this change is needed to meet the applicable safety standards of the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA).

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Co-filers (5)

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