Making Comments with Data Carries Weight in Crop Protection

Make Comments When Needed

By Patrick Cavanaugh Farm News Director

Dave Brassard of Brassard Pesticide Regulatory Solutions, based in Washington D.C., regularly assists with getting new products registered with the EPA. California Ag Today spoke with him about making comments regarding the registration status of crop protection products.

“We’re pesticide consultants, and we basically assist registrants into getting everything registered, and getting through a lot of the data requirements, data waiver processes, that they need to go through,” he explained.

Brassard and his wife have a combined total of 73 years experience working in the EPA’s office of pesticide programs.

“The importance of data collection in pesticide regulatory reform, and the need for real data collection to be used in growers defense. Especially when growers reach out for support, the data is the most important, and the most reliable, form of evidence to present to the EPA,” he said.

“What typically happens is we will keep track and count the number of comments. But a lot of comments are very generic, and are not supported by data,” Brassard said

Simply having a large number of comments is not enough; it’s the quality content that really matters.

“So a lot of times it just becomes a little blurb that we had 10,000 comments from stakeholders worried about a concern, but what really, I think, makes a big difference, is if it’s somebody sends in data that can change EPA’s opinion on something,” Brassard explained.

“Let’s say that the EPA is going to regulate a chemical that is the only chemical to control, say, an obscure pest that we didn’t even consider in our original analysis. Somebody sends in that studies, and boy that stops the presses! It’s, ‘Let’s review this,’ ” Brassard said. “Does this change our opinion on anything? Can we make an exception for this particular use-pattern? Is there a different kind of risk-mitigation that we can impose?”

“Sending in real data are comments that make a real difference,” he said


MRL Discussion Continues to Expand

MRL Transparency is Needed to Avoid Hurting Exports

by Emily McKay Johnson, Associate Editor

Gary Van Sickle, executive director of the California Specialty Crops Council (CSCC), and host of the annual Maximum Residue Level (MRL) Harmonization Workshop in San Francisco earlier this month, spoke about the increased MRL discussion that has taken place in the last decade. “We had the vision about 11 years ago to see there was a need to start talking about MRLs in a public forum,” he said.

With nearly 125 attendees at their workshops, CSCC “has anywhere from eight to ten international countries participating,” said Van Sickle. And as the organization has grown, Van Sickle and his team have found that MRL awareness is increasing. “One of the major focuses here is to bring into the sector an awareness of what is going on with MRLs. Through this workshop, that comes to light.” he said.

Gary Van Sickle,
Gary Van Sickle, Executive Director of California Specialty Crops Council.

“Also very important,” Van Sickle said, “is the linkage between the different sectors represented here—the registrants, the agricultural industry, the government agencies and even the universities and academia.”

Van Sickle discussed how MRLS are convoluted in other countries. “There are disconnects between crop protection measures in one country versus another,” he began, “which can hurt exports for American farmers. When a crop protection company develops products for crops, the crops are tested for what could be a maximum residue level, say it is 0.5 parts per billion,” Van Sickle explained. “The trouble comes when an importing country puts the MRL at a different level, say .1 parts per billion. Suddenly, that limits the crop’s importing potential into that country.”

Van Sickle added, “Some [countries] have tolerances that are on the low side and under our usage levels here in the states, so they can apply the [standard] properly.” Problems occur when MRLs for an American crop export “does not make the residue level for the country that it is going into,” according to Van Sickle.

Another important discussion was implementing consistency in regulation over the years. “We are also in a situation where there’s a lag-time for getting MRLs registered,” he said. “As new products come out, they get registered here for growers to use. Sometimes there’s a lag-time of three to five years or more for another country to get [the same product] registered so that the American grower can use that new chemical, which could slow the export to a particular country, keep it diverted to another country that has MRLs, or keep it off an export situation altogether,” he concluded.

IR-4 Update

IR-4 To Focus on New Strategic Plan

By Courtney Steward, Associate Editor

At a recent meeting, California Ag Today met up with Dan Kunkel, associate director of the IR-4 Project for The Food and International Program at Rutgers University in New Jersey.

IR-4 Project LogoSince 1963, the IR-4 Project has been a major resource for supplying pest management tools for specialty crop growers by developing research data to support EPA tolerances and labeled crop protection product uses. The main goal of the IR-4 program, according to Kunkel, is to help specialty crop growers in California, but with a new emphasis on crop exportation.

Commenting on this new strategic plan for the IR-4 program, Kunkel said, “We are going to be doing a lot of the same things, like residue work, efficacy testing and our biopesticide and ornamental programs. But we are taking a larger focus on international harmonization of the pesticide residue limits for our grower exporters so they can feel more confident that their commodities won’t have issues in foreign trade.

“Of course we submit crop protection registration to the EPA for our growers. But when the commodities go abroad, we also submit the data to CODEX, an international database with maximum residue limits (MRLs), a type of tolerance standard, for pesticides,” said Kunkel.

“We also share data with some of the U.S. commodity groups to submit to the Asian and European markets so our growers’ exports can meet these residue limits as well,” he said.