By Lisa M. Campbell and Lisa R. Burchi
The U.S. Environmental Protection Agency (EPA) recently launched a new Pesticide Worker Protection Dashboard (Dashboard). EPA states this Dashboard is “focused on the universe of agricultural operations regulated and farm workers and pesticide handlers covered by the Worker Protection Standard.” EPA states that the Dashboard provides charts and graphs presenting certain key enforcement and compliance information related to the Worker Protection Standard (WPS) program under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA). Specifically, the Dashboard has screens which show the number of WPS inspections conducted, the number of violations found during inspections, the types of violations found, and the types and numbers of enforcement actions taken. Since the Dashboard is interactive, users can find answers to questions such as:
- How many facilities in the United States employ workers or handlers covered by the WPS;
- How many inspections are reported; and
- How many violations have been found, and what enforcement actions have been taken by states, tribes and/or EPA.
EPA states that Dashboard information from states and tribes is compiled from data on state and tribal inspections and regulatory actions submitted annually (Form: 5700-33H) to EPA. This form provides information regarding the number of WPS inspections conducted, the types and numbers of violations found, and the number and types of regulatory actions taken during the year. EPA inspection data is obtained from EPA’s Integrated Compliance Information System (ICIS) database. Other information is compiled from data from the U.S. Department of Agriculture’s National Agricultural Statistics Service’s Agricultural Statistics, 2007 and 2012 Census of Agriculture database.
EPA makes several caveats to the data presented, including: (1) EPA does not require regional offices to enter all regulatory actions into ICIS, so many “informal” actions are not recorded; (2) the data included in the Dashboard do not reflect all compliance monitoring/inspections or enforcement activities, nor the full extent of enforcement activity within a state or tribe; and (3) tribal inspections and enforcement actions conducted under sovereign tribal authority and regulations are not EPA reviewed or reported, and are not included in the Dashboard.
The Dashboard shows data from 2010 to 2014 to provide context at the national level, or within a state or tribe. EPA plans to update the information annually when new data are available (e.g., after annual state and tribal reporting forms are submitted to EPA).
The Dashboard provides interesting information and should be monitored, as many groups will likely use it in support of their unique interests.
More information on the WPS is available in our blog item EPA Publishes Worker Protection Standard Final Rule.
By Lisa M. Campbell and Timothy D. Backstrom
On December 17, 2015, in the U.S. Court of Appeals for the Ninth Circuit Case Nos. 14-73353, et al. (consolidated), the U.S. Environmental Protection Agency (EPA) filed a reply in support of its motion for voluntary vacatur and remand of its decision granting a registration to intervenor DowAgroSciences LLC (DowAgro) for Enlist Duo herbicide under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA). DowAgro responded to the motion by agreeing that remand is appropriate but opposing vacatur as an effort to circumvent the normal cancellation process, while the petitioners Center for Food Safety, et al. (CFS) filed a response supporting the motion for vacatur. More information on the DowAgro and CFS responses is available in our blog entry DowAgro and Center for Food Safety File Responses to EPA’s Motion for Voluntary Vacatur and Remand.
In its reply, EPA rejects the argument by DowAgro that it is trying to “short-circuit” the normal cancellation procedures under FIFRA. Citing recent Ninth Circuit precedent on vacatur, EPA argues that “vacatur would be more protective of the environment during the time in which EPA evaluates the new information, and Dow has failed to demonstrate any disruptive consequences of vacatur.”
EPA also takes issue with certain statements by CFS that it characterizes as “erroneous or irrelevant.” EPA contradicts assertions by CFS that EPA overlooked important evidence concerning the synergistic effects of Enlist Duo’s principal ingredients, that EPA determined that Enlist Duo will not protect endangered non-target plants, that EPA has violated the ESA, and that EPA is approaching synergistic effects as a new issue. EPA also objects to the efforts of CFS to introduce an extra-record newspaper article.
This case will continue to be watched closely, as there is widespread industry concern about EPA’s effort to use a judicial process in lieu of normal adjudicatory procedures and about EPA’s substantive approach to evaluating synergistic efficacy data. In this regard, it is noteworthy that the issue of potential synergistic effects is relatively narrow and does not appear to be among the purported deficiencies in the EPA decision originally cited by the petitioners.
By Sheryl L. Dolan and Margaret R. Graham
The U.S. Environmental Protection Agency (EPA) recently updated the electronic reporting option for pesticide establishments using the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) Section Seven Tracking System (SSTS), now referred to as the Enhanced Section Seven Tracking System (eSSTS). On December 17, 21, 22 and 28, EPA will hold four public webinars to explain the Central Data Exchange (CDX) registration process for the eSSTS and demonstrate report submission using eSSTS. EPA state that any establishments/authorized agents that used electronic reporting last year should automatically be registered to use the new eSSTS system. CDX registration for eSSTS will be open after December 18, 2015; submitters will need to register to use the new system. Pesticide establishments can use the CDX to submit EPA Form 3540-16 “Pesticide Report for Pesticide-Producing and Device-Producing Establishments,” the annual pesticide establishment report required under FIFRA Sections 7 and 17 to be submitted by all active domestic and foreign pesticide producing establishments, regardless of whether or not the establishment produced or distributed a pesticide, active ingredient, or device, by March 1 of each calendar year.
The first webinar on December 17, 2015, from 1:00 p.m. to 2:00 p.m. (EST) will explain the CDX registration process for the eSSTS. Webinars 2, 3, and 4 will cover eSSTS training, but will all have the same information -- participants only need to attend one of these sessions. Additional announcements and reporting instructions are posted on EPA’s Pesticide Establishment webpage. More information on the specific trainings is listed below. The links will not be active until the time of the webinar:
- CDX Registration Training for EPA's eSSTS, Thursday, December 17, 2015, 1:00 p.m. - 2:00 p.m. (EST) (Recorded): An Overview of how to set up an EPA CDX account and set up a user role under EPA's eSSTS, will be available at http://epawebconferencing.acms.com/eSSTSCDX.
- EPA's eSSTS Industry User Training 1, Monday, December 21, 2015, 11:00 a.m. - 12:00 p.m. (EST) (Recorded): Industry overview of EPA's eSSTS, will be available at http://epawebconferencing.acms.com/eSSTS_Industry_Testing.
- EPA's eSSTS Industry User Training 2, Tuesday, December 22, 2015, 2:30 p.m. - 3:30 p.m. (EST): Industry overview of EPA's (eSSTS), will be available at http://epawebconferencing.acms.com/eSSTS_Industry_Testing2.
- EPA's eSSTS Industry User Training 3, Monday, December 28, 2015, 11:00 a.m. - 12:00 p.m. (EST): Industry overview of EPA's eSSTS, will be available at http://epawebconferencing.acms.com/eSSTS_Industry_Testing3.
By James V. Aidala and Margaret R. Graham
On December 11, 2015, the U.S. Environmental Protection Agency’s (EPA) Office of Pesticide Programs (OPP) made publicly available several documents associated with the Biological Evaluations (BE) for the first three “pilot” chemicals that are being evaluated: chlorpyrifos, diazinon, and malathion. For each chemical, the following supporting documents are now available: problem formulation; fate and effects characterizations; and related appendices. The provisional models are available here.
EPA states on its website that these documents contain the analysis plan and underlying data that will be used to make effects determinations as part of the pesticide consultation process. The entire draft biological evaluations for the three chemicals, including the effects determinations, will be released for public comment in the spring of 2016.
These BEs are a product of the collaboration among the National Marine Fisheries Service (NMFS), the U.S. Fish & Wildlife Service (FWS) (together, the Services), EPA, and the U.S. Department of Agriculture (USDA) in response to the National Academy of Sciences’ April 2013 report, Assessing Risks to Endangered and Threatened Species from Pesticides, which examined topics pertaining to tools and approaches for assessing the effects of proposed Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) actions on endangered and threatened species and their critical habitats, and provided recommendations.
USDA provided expertise on crop production and pesticide uses and assistance with the use of the National Agricultural Statistics Service Cropland Data Layer to help define the footprint of agricultural use patterns. The FWS and the NMFS will use the analyses and data from the biological evaluations and integrate it into their final Biological Opinions for the three chemicals due in December 2017.
This is the opening blow for developing the next round of the EPA-Services’ Endangered Species Act (ESA) assessment process. This bolus of information, in the range of 30,000 pages, is the EPA part of the assessment process -- now to be examined by the Services to become the complete ESA assessment of the pesticide products and their possible impact.
It is less clear what these extensive efforts will achieve; in essence, it is likely to indicate little more than “everything affects everything.” On the other hand, it will provide information useful to indicate where the greatest risks to certain species in specific habitats may lie. Separately, the mere volume of the information and the amount of effort needed to produce it presents a daunting prospect for the ability of the government agencies (EPA and the Services) to further refine the process into anything resembling a timely and efficient process (not to mention the implications for any public review of the information or associated regulatory conclusions).
By Lisa M. Campbell, Lisa R. Burchi, James V. Aidala, and Timothy D. Backstrom
On December 7, 2015, in the U.S. Court of Appeals for the Ninth Circuit Case Nos. 14-73353, et al. (consolidated) Intervenor Dow AgroSciences, LLC (DowAgro) filed a response, and Petitioner the Center for Food Safety, et al. (CFS, et al.) filed joinder in and response to the U.S. Environmental Protection Agency’s (EPA) motion for voluntary vacatur and remand of EPA’s registration of DowAgro’s Enlist Duo herbicide under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), as well as a response to DowAgro’s Fact Sheet, a public statement made by DowAgro after EPA’s motion was filed.
DowAgro’s response calls EPA’s motion a “Dr. Jekyll & Mr. Hyde” motion. The request for remand, DowAgro states, is “uncontroversial” and will allow the agency to review the new information that may bear on the pesticide registration. DowAgro thus does not object to the remand and believes ultimately that “the new information cited by respondents has no impact on the validity of the existing registration.”
On the other hand, DowAgro argues that EPA’s request to vacate the registration is “novel and unlawful.” DowAgro states that EPA is trying to “short-circuit [the FIFRA] regulatory scheme and abdicate the responsibilities Congress assigned to the agency.” Specifically, DowAgro argues this case is “closely analogous” to the Reckitt Benckiser case (762 F. Supp. 2d 34 (D.D.C. 2011), where the court did not allow EPA to circumvent the statutory cancellation regime, finding that FIFRA Section 6 “establishes a detailed, multistep process that EPA must follow when it wants to cancel or suspend a registration.” Id. at 42 (emphasis in original). DowAgro states that the court must “limit its relief to a remand for the agency to exercise primary jurisdiction to review the new information and decide what additional steps, if any, are warranted.” While EPA reviews the additional information, DowAgro has agreed to “stop sales of Enlist Duo, and to work out an appropriate agreement to that effect with the agency.”
CFS, et al.’s filing asserts that vacatur is the appropriate remedy. CFS, et al. states that EPA now “has an opportunity -- a mandate -- to meet its duties under FIFRA and the ESA, and ensure Enlist Duo’s safety.” CFS, et al. “not only agree, but believe EPA greatly downplays the potential for harm by focusing only on the buffers and terrestrial plants,” and states that the “potential for harm far outweighs any likely economic disruption to Intervenor Dow.”
The outcome of the issue raised by EPA’s motion, and DowAgro’s position that EPA should not be permitted to “bypass” regulatory cancellation procedures is of significant interest to all pesticide registrants. This case will be closely watched not only because Enlist Duo is a major new product for Dow and a new tool in the herbicide-tolerant crop world, but also because of the potentially precedential process that EPA’s motion seeks with regard to pesticide registrations.
More information on EPA’s motion is available in our blog entry EPA Files Motion for Voluntary Vacatur and Remand of Enlist Duo Registration.
By Lisa M. Campbell and Timothy D. Backstrom
On December 7, 2015, in Case Nos. 14-1036 and 15-5168, the U.S. Court of Appeals for the D.C. Circuit issued an order denying the U.S. Environmental Protection Agency’s (EPA) motion for summary affirmance of an order issued by the D.C. District Court dismissing a complaint filed by Plaintiffs-Appellants Center for Biological Diversity, et al. (the Center) for lack of jurisdiction. The Center’s complaint alleged that EPA violated the Endangered Species Act (ESA) and the Administrative Procedure Act (APA) by registering pesticides containing the new active ingredient cyantraniliprole without first consulting the U.S. Fish and Wildlife Service or the National Marine Fisheries Service.
EPA’s motion, filed on August 27, 2015, moved for summary affirmance of the district court’s order dismissing the complaint for lack of jurisdiction, stating that “the district court’s determination that exclusive jurisdiction over the Center’s claims lies in the courts of appeals under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA or the Act), Section 16(b), 7 U.S.C. § 136n(b), is so plainly correct that summary affirmance is warranted,” and “FIFRA’s special judicial review procedure applies to this case because the Center challenges EPA’s registration of cyantraniliprole, which is regulated by FIFRA.” The Center argues that the district court has separate jurisdiction under the citizen suit provision of the ESA and/or that jurisdiction lies in the district court because there has been no public hearing under FIFRA Section 16(b).
The order denying the motion states that the “merits of the parties’ positions are not so clear as to warrant summary action.” Opening briefs are due beginning January 19, 2016, and final briefs are due April 8, 2015.
Although the general division of jurisdiction between U.S. district courts under FIFRA Section 16(a) and U.S. courts of appeal under FIFRA Section 16(b) has been construed differently, in general, since the 1986 D.C. Circuit decision Humane Society v. EPA, whether there has been a “public hearing” within the meaning of FIFRA Section 16(b) is determined based on the adequacy of the record for appellate review. Since cyantraniliprole is a new active ingredient, EPA provided notice and an opportunity for comment under FIFRA Section 3(c)(4) before granting the registrations in question, so the record compiled by EPA appears to satisfy this test. The decision of the D.C. Circuit to deny EPA’s motion for summary affirmance may reflect the stringent standard that must be met for such an action, rather than an indication of how the D.C. Circuit will ultimately rule on the merits.
By Lisa M. Campbell, Lisa R. Burchi and Timothy D. Backstrom
On November 24, 2015, in the U.S. Court of Appeals for the Ninth Circuit, Case No. 14-73353, the U.S. Environmental Protection Agency (Respondent; EPA) filed a motion for voluntary vacatur and remand of EPA’s registration, as amended, of Dow AgroSciences LLC’s (Dow) Enlist Duo herbicide under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA). The motion for vacatur is unusual and noteworthy to all pesticide registrants.
This case commenced in October 2014 when the Natural Resources Defense Council (NRDC) and other environmental groups including the Center for Food Safety (CFS, et al.) (together, Petitioners) filed petitions for review challenging EPA’s decision to register Enlist Duo, a new product designed for use with crops genetically modified to be resistant to glyphosate and 2,4,-D. Petitioners argued, in part, that EPA failed to consider the impacts of increased glyphosate use on monarch butterflies, and did not fully assess the potential human health effects from 2,4-D.
EPA’s motion reverses EPA previous position that Dow’s application for Enlist Duo satisfied the requirements for issuance of an unconditional registration under FIFRA Section 3(c)(5). EPA states that it is seeking a voluntary remand to reconsider the Enlist Duo registration in light of new information regarding potential synergistic effects referred to as “synergistic herbicidal weed control” between the two active ingredients 2,4-D and glyphosate contained in Enlist Duo on non-target plants. Specifically, EPA is in the process of evaluating information submitted to it by DAS on November 9, 2015, in response to EPA’s request for all available information related to synergistic effects. EPA asserts that none of this information was submitted to EPA prior to EPA’s issuance of the Enlist Duo registration.
EPA states that the claimed synergism could affect EPA’s “assessment of drift reduction measures for avoiding impacts to non-target organisms, including those listed as endangered.” EPA also states that it “cannot be sure, without a full analysis of the new information, that the current registration does not cause unreasonable effects to the environment, which is a requirement of the registration standard under FIFRA” and that its initial review “indicates that the 30-foot buffer included in the registration may not be adequate.”
DAS has until December 7, 2015, to file its response before the court will consider EPA’s motion to remand the registration. Although it has not completed its assessment, EPA states that if the court vacates the Enlist Duo registration, EPA will issue a cancellation order to regulate the sale, distribution, and use of existing stocks of Enlist Duo pursuant to FIFRA. This case is being considered for the March 2016 oral argument calendar but the exact date of oral argument has not been determined at this time. More information regarding this case is available in our blog items Environmental Groups File Opening Briefs Challenging EPA’s Decision to Register Enlist Duo and Ninth Circuit Denies Requests to Stay Use of Enlist Duo Herbicide During Judicial Review.
EPA’s request for remand with vacatur rather than a remand without vacatur is a severe action. EPA could have chosen to seek remand without requesting that the registration be vacated, and then demanded prompt revision of the buffer zone that EPA now believes may be inadequate to protect non-target plants from synergistic effects. EPA may have decided to send a message that there will be serious consequences when an applicant fails to submit all of the data in its possession that may be pertinent to EPA’s assessment of the statutory criteria for registration. In any case, Dow reportedly has stated that it does “not expect these issues to result in the long-term cancellation of the Enlist Duo product registration” and that Dow will “continue to prepare for commercial sales of Enlist Duo for the 2016 growing season with enthusiastic grower adoption."
By Lisa M. Campbell, Lisa R. Burchi, and James V. Aidala
In a press release issued on November 22, 2015, the Canadian province of Québec (Quebec) announced its release of Québec Pesticide Strategy 2015-2018. Although the Strategy itself is available only in French, Québec has provided a summary of the Strategy in English, which is available here.
Québec’s press release states that the Strategy “sets out the major directions and goals that will guide government action to protect public health, pollinators, and the environment in the coming years.” One of the ways the Strategy seeks to do this is to impose additional restrictions on the use of the "highest-risk pesticides" which the Strategy states includes atrazine, chlorpyrifos, and neonicotinoid insecticides. To reduce use of high risk pesticides, the Strategy’s “Objectives” to be implemented through legislative and regulatory changes include:
- Requiring agricultural application of such highest-risk pesticides to be "justified by an agronomist in advance of 100% of cases";
- Tripling of the number of pesticides that are banned in urban environments for use on lawns and green spaces;
- Obliging owners of golf courses that use the greatest amount of pesticides to reduce their use of the highest-risk products by 25 percent; and
- Authorizing the "unrestricted sale of all biopesticides by all retailers" and encouraging “the application of the lowest-risk pesticides through economic incentives (levies, permits and compensation fees).”
To lower exposures, the Strategy calls for ensuring adequate qualification levels for employees that apply pesticides and increasing mandatory minimum distance when pesticides are applied near inhabited areas.
With specific regard to neonicotinoid insecticides, Québec seeks to reduce such use with the following “Objectives,” some of which overlap with the Objectives noted above for high risk pesticides:
- Banning the use of all neonicotinoids for lawn and flower bed maintenance;
- Requiring agricultural application of such neonicotinoids to be "justified by an agronomist in advance of 100% of cases"; and
- Encouraging the use of seeds uncoated with neonicotinoids through economic incentives such as levies, permits, and compensation fees.
Québec also intends to obtain additional information about use of treated seeds in Quebec by requiring companies to submit reports on Québec sales of neonicotinoid-treated seeds.
Québec in its Strategy summary also describes the following specific activities it plans to undertake in 2016:
- Amend the Pesticides Management Code to “tighten the conditions under which pesticides may be used”;
- Modernize the Pesticides Act to incorporate coated seeds and strengthen compliance through a system of administrative penalties; and
- Hold pesticide users accountable by “having users of highest-risk pesticides assume a greater share of associated environmental and public health costs.”
Québec’s Strategy to impose additional restrictions on the use of the "highest-risk pesticides," including neonicotinoid insecticides, is part of its efforts following a 2011 strategy aimed at reducing the risks related to pesticide use by 25 percent by 2021. The Canadian province of Ontario also issued final regulations in June 2015 aimed at reducing the area planted with maize and soybean seed treated with neonicotinoid insecticides as discussed in our blog item Canadian Province Finalizes Neonic Reduction Rule, although Quebec’s Strategy goes arguably farther by broadening the scope of the pesticides at issue to include atrazine and chlorpyrifos. It remains to be seen whether different rules in different provinces will create any confusion or other regulatory issues for companies seeking to comply with these restrictions.
In the U.S., the issue of forbidding “prophylactic” use of pesticides has been raised to date primarily at the local level in a relatively few number municipalities. Regarding pollinator issues more generally in the U.S., the U.S. Environmental Protection Agency (EPA) is in the process of reviewing comments it received on its “Proposal to Mitigate the Exposure to Bees from Acutely Toxic Pesticide Products” released earlier this year. The next milestone in EPA activity related to neonicotinoid pesticides is the expected release of a registration review risk assessment document for imadicloprid, a widely used neonicotinoid insecticide, before the end of the calendar year.
More information on pesticides and pollinators is available on our blog under topics "pesticides" and "pollinators."
By Lisa M. Campbell and Lisa R. Burchi
On November 6, 2015, the U.S. Environmental Protection Agency (EPA) announced that it has a new webpage that compiles information about secondary containers and service containers for pesticides. Secondary and service containers are containers that are used by the pesticide industry as part of the process of applying pesticides, not for further sale or distribution. EPA states that the website combines and replaces information previously found on the Labeling Questions and Answers page and in the Label Review Manual, and addresses frequently asked questions. The announcement states “this is not new guidance, but the EPA hopes this new resource will make information on secondary and service containers easier to find and will lead to improved handling of these containers.” According to EPA, the webpage is designed to help pesticide registrants and applicators:
- Understand EPA’s definition of secondary and service containers;
- Learn about EPA’s recommendations for good management practices when labeling secondary and service containers; and
- Learn how to properly identify the contents of a secondary or service container, including when the pesticide is diluted.
Although registrants are not required to submit labels to secondary containers to EPA for review, EPA provides the following Q&A for when EPA will approve such labels if submitted to EPA for review:
Q: If a registrant wishes to submit and have EPA review the secondary container label, what does EPA require?
A: As it isn't required that a secondary container label be submitted, there are no requirements per se. EPA will review them on a case-by-case basis and would be likely to accept them if:
- The EPA-approved master label includes directions for diluting the product.
- The secondary container label is submitted as part of the master label.
- The master label bears a statement that the secondary container must be labeled as presented on the master label (e.g., “When this product is diluted in accordance with the directions on this label, the dilution container must bear the following statements:”)
- The secondary container contains a statement prohibiting further sale or distribution.
- The secondary container may have reduced precautionary language (if supported by dilution-specific acute toxicity data), but not a reduced signal word.
Requirements governing secondary containers are often a source of questions within the regulated community; many may find EPA’s new website a useful source of information on this topic.
NAFTA TWG on Pesticides Meeting
By Lisa M. Campbell and Margaret R. Graham
On November 3-5, 2015, the North American Free Trade Agreement (NAFTA) Technical Working Group (TWG) on Pesticides, established in 1997 to streamline certain pesticide shipments between Canada (CN), Mexico (MX), and the United States (U.S.), held a meeting hosted by the U.S. Environmental Protection Agency in Durham, North Carolina. NAFTA TWG states that its primary objective “is to develop relevant and cost-effective pesticide regulation and trade among the three countries and meet the environmental, ecological, and human health objectives of NAFTA.” Further, TWG partners address trade issues, national regulatory and scientific capacity, governmental review burden, and coordination of regulatory decision making and industry burden reduction.
The topics discussed at its November meeting, a government-stakeholder meeting with the Executive Board, regulatory officials, and interested stakeholders such as growers, industry, and public interest groups, were:
Five-Year Strategic Plan and NAFTA Industry Working Group (IWG) Updates. The presentation was as follows:
Science and Policy Initiatives:
- Updates on Pollinator Protection in the U.S., CN, and MX. The presentations were as follows:
“Update on Pollinator Protection Activities in the U.S.” (Lead: U.S. - Rick Keigwin);
“Pollinator Protection in Canada” (CN - Scott Kirby);
MX’s input regarding “US EPA Guidance for Assessing Pesticide Risks to Bees” (Lead: MX -
SEMARNAT or SENASICA);
“Update on Mexican Project: Preliminary Study on Some Factors That Influence on Bee Colony
Loss in Different Regions of Apicultural Importance in Mexico” (Lead: MX - Nelly Peña); and
“Pollinator Update: US, CN, and MX” - Presentation on Behalf of IWG on Pesticides (Lead: CN -
Maria Trainer, CropLife Canada).
- Re-evaluation of Neonicotinoid Pesticides Update in the U.S. and Canada. The presentation was as follows:
“Update on Re-evaluation of Neonicotinoid Pesticides in the U.S. and CN” (Leads: U.S. -
Don Brady and CN - Margherita Conti).
- Minor Use Program Developments. The presentations were as follows:
“Joint Minor Use Updates” (Leads: U.S. - Susan Lewis and CN - Margherita Conti); and
“IR-4: Update on Local Minor Uses” (Leads: U.S. IR-4 - Dan Kunkel and MX -
Alma Liliana Tovar Diaz).
- Maximum Residue Limits (MRL)/Codex. The presentations were as follows:
“MRL Alignment Activities Update” (Leads: U.S. - Susan Lewis and CN - Yadvinder Bhuller);
“Benefits of Harmonized MRLs” (Lead: CN - Gordon Kurbis, Pulse Canada); and
“Inadvertent Residues” (Lead: CN - Craig Hunter, Ontario Fruit and Vegetable Growers’
Stakeholder Presentations and Discussions:
- Stakeholders’ Lessons Learned on Joint Reviews including Industry’s Experiences and Prospectives of Joint Reviews. The presentations were as follows:
Lead: CN - Tanya Tocheva, Syngenta Crop Protection Canada;
Lead: CN - Gordon Kurbis, Pulse Canada; and
Lead: MX - Hector Guillén, Avocado Growers Association, APAMEX.
- Progress of the TWG’s joint action plan and receipt of input on the next phase of activities.
- Discussion on Future Collaboration Regarding Joint Review.
The presentations, many of which address issues of significant controversy and debate, are of interest to many in industry and to other stakeholders.