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brad-haire-farm-press-soybean-spray-ga-2017-a.jpg Brad Haire

Do your comments really sway EPA's decisions?

Along EPA's regulatory path to the registration of chemical products, there are respites to give the public time to give opinion on the agency's choices.

The EPA received more than 1 million public comments regarding its neonicotinoids reregistration process and 500,000 comments so far for the glyphosate reregistration. Does it matter?

Along EPA's regulatory path to the reregistration of chemical products, there are respites to give the public time to give opinion on the agency's decision-making journey on where, when, how or even if a product remains available.

The agency by October 2020 must complete a Congressionally mandated first round of reregistration for about 1,100 active ingredients and over 20,000 products. Every 15 years after that, the agency is required to go through another reregistration process. EPA's Office of Pesticides is charged to do all of this. Rick Kiewgin directs the office. He spoke about the process during the Southeast Fruit and Vegetable Growers Conference in Savannah Jan. 10.

The process for each active ingredient takes about six to seven years, he said, along that way there are four separate times for public comment on the ingredient and process in which the agency is evaluating it.

It all starts with the agency 'scoping out' what the reevaluation will look like. After that comes the first pause for public comment, and then it moves on.

For example, after the agency conducts the risk assessment part of the process, growers can add comments correcting or claryfing how they use the chemistry, the rates and how often. "Hearing that is important to show us what and how you have been using (the product)," he said.

Along with public comment, the agency works with the registrar (or the entity seeking new approval), solicits new data as needed from industry or land-grant researchers to support or alter the decision process, which ultimately leads to the final decision on registering or not the ingredient.

What is called the Proposed Interim Decision happens in the middle of the process. "This is where hearing things like, 'In the absence of having this, the effect on my yield would be X or the cost of my inputs to control that pest will be something else.' That's what we really want to hear from you at that stage,'" he said.

So, do comments matter? Some of them do.

Effective comments, or those that can sway the agency's decision on a product, are those based on reliable data or real-world experiences. Comments the agency hears but that do not sway the process include personal views not based on reliable data.

The EPA this year will deliver important decisions to U.S. agriculture, including on chlorpyrifos, glyphosate, the neonicotinoids, pyrethroids, atrazine and over-the-top dicamba.

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