Jan 5, 2018· Comment submitted by Komal K. Jain, Executive Director, Biocides Panel, Senior. Director, American Chemistry Council (ACC)· EPA-HQ-OPP-2016-0671-0026
The American Chemistry Council's Biocides Panel appreciates the opportunity to provide the attached comment to the U.S. Environmental Protection Agency's (EPA or Agency) draft Pesticide Regulation (PR) Notice 2017-XX, Notifications, Non-Notifications and Minor Formulation Amendments. As detailed in the attached, the Panel asks the Agency to reconsider several provisions of PRN 17-X and revise the notice accordingly. Given the substantial number of amendments we believe are needed, the EPA should issue a revised PRN 17-X for public comment. Separately, we recommend that EPA establish a docket specific to the topic of ingredient disclosure and separately address this complex issue.