Apr 28, 2010
WASHINGTON, DC – On April 23, 2010 CropLife America (CLA) submitted comments to EPA, responding to the Agency’s Advance Notice of Proposed Rulemaking (ANPR) for disclosure of inert ingredients on pesticide labels. In its remarks, CLA questioned the need for placement of inert ingredient identities on pesticide product labels, particularly for nonhazardous inerts, but indicated it may support some alternate form of disclosure of “hazardous” ingredients after these are further defined by the Agency.
For the crop protection industry, inert ingredients play an important role in the effectiveness and manufacturing of pesticides used by growers for the production of safe, healthful and economical food. An inert ingredient is any substance other than an active ingredient in pesticides that is intentionally included in a pesticide product. Pesticide products typically contain multiple inert ingredients. Inert ingredients play key roles in the effectiveness of pesticides, including prevention of caking or foaming, extension of the product’s shelf-life, and as solvents that allow herbicides to more effectively penetrate plants. The EPA performs a rigorous evaluation of inert ingredients before they are approved for use in pesticide products.
“EPA has not demonstrated it has the authority under current statutory establishment to impose a ‘hazard-based’ labeling regime on top of the current ‘risk-based’ statutory regime and require disclosure of inert ingredients on the label of a registered pesticide product,” stated CLA President and CEO, Jay Vroom, encouraging the Agency reevaluate its interpretation of statutory support in implementing a new inerts policy.
The crop protection industry believes that FIFRA (Federal Insecticide, Fungicide, and Rodenticide Act, the core pesticide law) expressly and clearly protects inert information from disclosure. “The current registration and labeling procedures adequately inform users of the risk of using the pesticide products, including the inert ingredients they contain,” emphasized Vroom.
CLA, Responsible Industry for a Sound Environment (RISE) and the Chemical Producers & Distributers Association (CPDA) collaborated closely on this effort. CLA’s comments are posted at www.croplifeamerica.org/news/public-comments.
