September 28, 2006
I am Jay Vroom, President of CropLife America (CLA). CLA is a national trade association representing the manufacturers, distributors and formulators of virtually all crop protection chemicals used in the United States. I appreciate the opportunity to testify before you today.
I want to begin by thanking Chairman Lucas and the entire subcommittee for holding this important hearing and for your ongoing leadership and oversight on all pesticide and crop technology issues. I was pleased to testify before the full House Agriculture Committee just two weeks ago regarding how the Farm Bill impacts the agricultural chemical industry. I specifically highlighted the tremendous contributions our industry makes toward conservation efforts, including soil, water, wildlife, energy and labor conservation.
However, pesticide benefits represent only part of the story. There are a number of policy challenges facing our industry that also merit our attention, including U.S./Canada regulatory harmonization, Endangered Species Act (ESA) compliance, user fees under the Pesticide Registration Improvement Act (PRIA), and National Pollutant Discharge Elimination System (NPDES) permitting under the Clean Water Act.
Over the past decade, there has been a significant increase in the amount and complexity of data needed to support registration of pesticides which has placed additional burdens on regulators as well as pesticide manufacturers. As a result, there is a strong interest among regulators and industry alike to achieve international harmonization of the registration processes for pesticide approval, with particular attention being given to harmonizing the regulatory systems between the United States and Canada.
Before granting registration for pesticides, both U.S. and Canadian regulatory authorities perform thorough assessments to ensure that unreasonable adverse effects to human health and the environment will not result from approved uses. However, these authorities regularly differ in the type of data required, the regulatory review process itself and the time required for regulatory review and approval.
For example, the U.S. Environmental Protection Agency (EPA) may require submission of data on endangered species to support a particular use, while the Pest Management Regulatory Agency (PMRA) in Canada would not. Conversely, Canada reviews studies of the efficacy of agricultural pesticide products, while the U.S. does not. These differences can contribute to the disparate costs of doing business in the United States and Canada and affect the availability of certain crop protection products for use by farmers in both nations.
Equally challenging is the sheer number of pesticide products registered for use in both countries. In 2004, there were 16,115 registered pesticide products containing 1,015 active ingredients in the U.S. and 5,274 registered pesticide products containing 525 registered active ingredients in Canada. Since 1997, more than 149 new active pesticide ingredients and 2,489 new uses have been registered by the U.S. EPA alone.
