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


EPA Scientist Receives Award for Pesticide Risk Model

The U.S. Environmental Protection Agency (EPA) TODAY honored Dr. Steven Thomas Purucker as a recipient of the Presidential Early Career Award for Scientists and Engineers (PECASE), the highest honor bestowed by the U.S. government to science and engineering professionals in the early stages of their independent research careers.

“Congratulations to Dr. Purucker for receiving this prestigious award,” said Lek Kadeli, Acting Assistant Administrator for EPA’s Office of Research and Development. “EPA is honored to have dedicated scientists, like Dr. Purucker, who devote their careers to protecting human health and the environment. Dr. Purucker is not only conducting innovative research, but he is also providing the tools and information we need to turn the vision of a healthy environment into a reality for all Americans.”

Dr. Purucker is a research ecologist in EPA’s National Exposure Research Laboratory in Athens, Georgia. He received the PECASE award for his exceptional innovation and initiative in creating modeling applications that help decision-makers and scientists conduct chemical risk assessments that are important for protecting human health and the environment. His research involves updating mathematical models that are used to predict environmental exposures and effects.

These models are relied on as part of EPA’s pesticide registration process, which must be completed before a pesticide can be sold or distributed in the U.S. Dr. Purucker and his colleagues have been modernizing these models, including some that were initially developed in the 1980s. Dr. Purucker’s lab has updated many of these models, which are stored in the “cloud” and can be easily accessed and executed from a web browser.

This decision support “dashboard” accepts chemical properties, pesticide use information, ecosystem exposure data, relevant geographic information, and effects levels as input to estimate risks to water and land environments.

Dr. Purucker is also collaborating with other scientists at EPA’s lab in Athens to conduct applied research on amphibian exposures, working in the lab and field to characterize pesticide transfer rates across the dermis layer of skin and the subsequent impacts on amphibian metabolism.

Dr. Purucker has a Ph.D. in Ecology and Evolutionary Biology, and a B.A. in Zoology from the University of Tennessee. He joins 101 researchers across the federal government who are also receiving PECASE awards this year. The awards, established by President Clinton in 1996, are coordinated by the Office of Science and Technology Policy within the Executive Office of the President.

Awardees are selected for their pursuit of innovative research at the frontiers of science and technology and their commitment to community service as demonstrated through scientific leadership, public education, or community outreach.

More information can be found at EPA’s Office of Research and Development and White House’s Office of Science and Technology Policy.