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How to Submit Comments to EPA

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EPA is required to seek public input at several stages of pesticide registration review, from draft risk assessments (that use models and science-based data to outline potential human health and environmental risks of pesticides under review) to draft rule changes that could impact the pesticides that are available to end-users. EPA reviews comments submitted by scientists, growers and other end-users of pesticides, advocacy groups, and the general public before making final decisions about continued product registrations. Your input could make a difference!

Comments may be submitted directly to EPA online, or you may anonymously contribute to comments developed and submitted by the Arizona Pest Management Center.  

1. Submit Comments Directly to EPA:
For any chemistries under review, there is a webpage on the regulations.gov website where comments can be submitted until 11:59 PM Eastern Time on the due date.

Visit https://www.regulations.gov , search for the active ingredient or EPA docket number you are interested in, then click the "Comment Now" button for further instructions.

  

2. Contribute to Arizona Pest Management Center (APMC) Comments:
The Arizona Pest Management Center submits comments to EPA on behalf of agricultural stakeholders in Arizona and other Southwest states. If you would like to provide input on how you use a particular pesticide under review, why it may be important, or perhaps no longer used in your production system, please contact Al Fournier prior to the comment due date. He will ask you questions and your input will be included in our comment anonymously. We rely on good information from growers, pest control advisors, County Agents, Extension Specialists and others to help inform our comments and make them as accurate and descriptive as possible.

Please email or call Al Fournier, fournier@cals.arizona.edu, 520-374-6240 or 520-705-9903.

  

How to Prepare Effective Comments:
* Identify yourself and describe your expertise in the subject, e.g., "grower of carrots in Arizona for 35 years." Name and contact information may be used by EPA to contact you if they have questions about your input. However, be aware that all comments, including identifiable information, are available to the public.

* Be specific. Identify specify crops, target pests, formulation, application methods used, and whatever conditions determine your use of the pesticide in question. Here is a list of questions to consider as you think through your response:

# For this pesticide, Which Crops have routine or important uses?

# For each crop:

  • What are the main target pests?
  • What rates are used?
  • Number and timing of applications
  • Application method (e.g., soil applied, foliar, by air, ground or chemigation)
  • Is there a particular "niche"for this pesticide? A need it addresses that would be hard to replace?
  • Are there alternative pesticides or non-chemical practices available? To what extent are they used? If they are not used, why not?
  • What risk mitigation practices (buffers, etc.) are used?
  • Are there MRL restrictions? Or any other economic considerations that affect the use of this pesticide?
  • Is this pesticide used to manage an invasive pest species?
  • Are there resistance management issues that impact the choice or use of this pesticide?
  • What would be the economic impact to growers if this management option were lost?

* Submit your comments on or before the specified deadline.

  

For More Information:

More information on the EPA registration review process

EPA's Registration Review schedule shows which chemistries are scheduled for review on a quarterly basis.

Archive of Arizona Pest Management Center Comments

  

For more information, contact Al Fournier at fournier@cals.arizona.edu.

 

 

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