CropLife America Public Comments – 2018

July 23, 2018. Comments to the U.S. Environmental Protection Agency on the Biological Opinions for Pesticides Issued Under the Endangered Species Act
Read the cover letter and the comments

July 5, 2018. CropLife America, RISE, the Household & Commercial Products Association, and the Council of Producers & Distributors of Agrotechnology submit comments to the Office of Environmental Health Hazard Assessment on Proposition 65 “Safe Harbor” Warning Regulations
Read the comments.

June 12, 2018. CLA and Responsible Industry for a Sound Environment (RISE) comments on the EPA's, “Interim Science Policy: Use of Alternative Approaches for Skin Sensitization as a Replacement for Laboratory Animal Testing"
Read the comments.

June 12, 2018. Comments to European Food Safety Authority on its scientific report, “Establishment of cumulative assessment groups of pesticides for their effects on the nervous system.”
Read the comments and addendum.

April 30, 2018. Comments to the U.S. EPA on registration review of glyphosate, including human health and preliminary ecological risk assessment
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April 21, 2018. Comments to the U.S. EPA on registration review on neonicotinoid risk assessments, work plans, and updated schedules
Read the comments.

February 23, 2018. Comments to the U.S. EPA on nominations for the FIFRA Scientific Advisory Panel
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February 13, 2018. Comments to the U.S. EPA on the draft risk assessments of 2,4-D
Read the comments.

February 8, 2018. Comments to the Office of the United States Trade Representative on 2018 Special 301 Review: Identification of Countries Under Section 182 of the Trade Act of 1974
Read the comments.


CropLife America Public Comments – 2017

December 13, 2017. Comments to the U.S. EPA on the Registration Reviews: Draft Human Health and/or Ecological Risk Assessments for on lambda-cyhalothrin and gamma-cyhalothrin.
Read the comments.
 

December 11, 2017. Comments to European Commission WTO TBT notification G/TBT/N/EU/521 proposal to reclassify propiconazole
Read the comments.
 

November 2, 2017. Comments to the U.S. EPA on the Registration Review; Draft Human Health and/or Ecological Risk Assessments for Benfluralin, Bromuconazole, Carbaryl, Clodinafop-propargyl, Deltamethrin, Diflufenzopyr, Esfenvalerate, Lufenuron, and Mepiquat Chloride/Mepiquat Pentaborate
Read the comments.

August 2, 2017. Comments to the U.S. EPA on the Preliminary Ecological Risk Assessment for Registration Review of 2,4 D
Read the comments.


July 24, 2017. Comments on the draft pollinator risk assessments for the neonicotinoid insecticides, clothianidin, thiamethoxam, and dinotefuran
Read the comments.


July 24, 2017. Comments to the U.S. EPA on the Proposed Interim Decisions for Aldicarb, Azoxystrobin, Bifenazate, Chlorpyrifos-methyl, Ethalfluralin, and Pirimiphos-methyl
Read the comments.


July 7, 2017. Comments on Pyrethroids Ecological Risk Assessment
Read the comments.


May 19, 2017. Comments on Certification of Pesticide Applicators Rule; Extension of Effective Date
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May 11, 2017. Oral Testimony Before the Senate Committee on Agriculture, Nutrition & Forestry on Providing Stakeholders with Certainty through the Pesticide Registration Improvement Act
Read the testimony.


April 17, 2017. Comments on Rule Proposing Organic Research, Promotion, and Information Order; 82 Fed. Reg. 5746
Read the comments.


March 27, 2017. Comments on Health Canada Proposed Re-evaluation of Imidacloprid
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March 20, 2017. Notification to WTO – Draft Commission Implementing Regulation amending Implementing Regulation (EU) No 540/2011 as regards the conditions of approval of the active substance diflubenzuron
Read the comments.


March 15, 2017. Comments on the U.S. Environmental Protection Agency’s Initial 10 Chemicals for Risk Evaluation
Read the comments.


March 1, 2017. Emergency Petition to Extend Effective Date of Final Rule Designating Rusty Patched Bumble Bee as Endangered
Read the petition.


February 14, 2017. Oral Testimony Before the House Agriculture Committee on PRIA Re-authorization Review
Read the testimony.

 

 

CropLife America Public Comments – 2016

December 21, 2016. CLA submits comments to the U.S. Environmental Protection Agency (EPA) Office of Pesticide Programs on Registration Review: Draft Malathion Human Health Risk Assessment
Read the comments.
 

November 29, 2016. CLA Petition to the U.S. Environmental Protection Agency (EPA) to suspend any regulatory decision making on human health risk assessment(s) for organophosphate and other pesticidesRead the petition.
 

November 21, 2016. CLA submits comments to the U.S. Fish & Wildlife Service on the Proposal to List the Rusty-Patched Bumble Bee as an Endangered Species
Read the comments.

October 20, 2016. CLA submits comments to EPA on the Registration Review: Draft Malathion Human Health Risk Assessment
Read the comments.
 

October 12, 2016. CLA submits comments to EPA on the FIFRA Scientific Advisory Panel (FIFRA SAP) to review EPA’s evaluation of the carcinogenic potential of glyphosate
Read the comments.
 

October 4, 2016. CLA submits comments to EPA on Atrazine, Simazine, and Propazine Registration Review.
Read the comments.
 

October 4, 2016. CLA submits comments to EPA on FIFRA SAP: Glyphosate.
Read the comments.
 

September 14, 2016. CLA submits comments to EPA on Draft Guidance for Pesticide Registrants on the Determination of Minor Use.
Read the comments.
 

September 1, 2016. CLA submits comments to EPA on Draft Guidance for Pesticide Registrants on Pesticide Resistance Management Labeling
Read the comments.
 

August 24, 2016. CLA submits comments on EPA’s evaluation of the carcinogenic potential of Glyphosate
Read the comments.
 

July 12, 2016. CLA and other agricultural organizations and associations’ letter to U.S. Trade Representative regarding impending legislation in the EU governing crop protection products.
Read the letter.
 

June 17, 2016. CLA submits comments on proposed registration of Sulfoxaflor for use on agricultural crops, ornamentals and turf.
Read the comments.
 

June 10, 2016. CLA submits comments on EPA Office of Pesticide Program’s draft biological evaluations of Chlorpyrifos, Diazinon, and Malathion.
Read the comments.


May 31, 2016. CLA submits comments on EPA’s Proposed Registration of Dicamba for Use on Dicamba-Tolerant Cotton and Soybeans.
Read the comments.


May 25, 2016. Written Testimony of Jay Vroom, President and CEO of CropLife America Submitted to the U.S. House Committee on Agriculture Re: May 25, 2016 Hearing Titled, “Food Waste from Field to Table”
Read the testimony.


May 13, 2016. CLA submits memorandum to open docket for meeting minutes, documents, and proposals related to integrated approaches to testing and assessment
Read the comments.


May 12, 2016. CLA submits comments to the FDA on the draft environmental assessment and preliminary finding of no significant impact concerning investigational use of Oxitec OX513A mosquitoes
Read the comments.


May 10, 2016. CLA submits comments to the FDA on the use of the term “natural” in the labeling of human food products;
Read the comments.


April 14, 2016. CLA submits comments on the Preliminary Pollinator Risk Assessment to Support the Registration Review of Imidacloprid
Read the comments.


April 11, 2016. CLA submits letter in support of the Trans-Pacific Partnership
Read the letter.


April 8, 2016. CLA submits comments on the FIFRA Scientific Advisory Panel (FIFRA SAP) to consider and review Chlorpyrifos: Analysis of Biomonitoring Data
Read the comments.


March 22, 2016. CLA submits comments on EPA’s peer review draft guidelines for human exposure assessment
Read the comments and attachment.


February 22, 2016. CLA submits comments on EPA’s pesticide registration: draft human health and ecological risk assessments for sulfonylureas and certain other pesticides
Read the comments.


January 5, 2016. CLA submits comments on EPA’s proposed rule to revoke all tolerances for chlorpyrifos, a pesticide active ingredient of crucial importance to American agriculture and insect pest management
Read the comments.

 

 

CropLife America Public Comments – 2015

November 6, 2015. CLA submits comments on Nominations to the Report on Carcinogens and Office of Health Assessment and Translation; Request for Information (80 FR 60692; October 7, 2015)
Read the comments.


September 22, 2015. CLA submits comments on Draft Guidance for Pesticide Cumulative Risk Assessment: Framework for Screening Analysis Purpose.(Docket ID: EPA-HQ-OPP-2015-0422)
Read the comments.


September 11, 2015. CLA submits comments on EPA’s Scientific Advisory Panel (FIFRA SAP) to consider and review Development of a Spatial Aquatic Model (SAM) for Pesticide Risk Assessment. (80 FR 43086. July 21, 2015. Docket No. EPA-HQ-OPP-2015-0424)

Read the comments.
 

August 31, 2015. CLA submits comments regarding Endangered and Threatened Wildlife and Plants (80 Fed. Reg. 37,568)
Read the comments.


August 28, 2015. CLA submits comments on EPA’s proposal to mitigate exposure to bees from acutely toxic pesticide products (Docket No.: EPA-HQ-OPP-2014-0818.)
Read the comments.


August 24, 2015. CLA submits comments regarding pesticides; Risk Management Approach To Identifying Options for Protecting the Monarch Butterfly; Notice of Availability and Public Comment Opportunity (Docket No.: EPA-HQ-OPP-2015-0389.)
Read the comments.


July 6, 2015. CLA submits extension request on Risk Management Approaches to Identifying Options for Protecting the Monarch Butterfly comments (Docket No.: EPA-HQ-OPP-2015-0389.)
Read the request.


June 8, 2015. CLA submits comments in response to the proposed rule on the endangered species status of the Big Sandy Crayfish (Docket No.: FWS-R5-ES-2015-0015)
Read the comments.


April 30, 2015. CLA submits comments in response to the revised human health risk assessment for the registration review of chlorpyrifos (Docket No.: EPA-HQ-OPP-2008-0850)
Read the comments.


April 24, 2015. CLA and RISE submit comments on the proposed rule on the operation and certification of small unmanned aircraft systems (Proposed Rule, 80 Fed. Reg. 9544)
Read the comments.


March 2, 2015. CLA submits comments on the petition to list the Monarch Butterfly as threatened under the Endangered Species Act
Read the comments.
 

January 23, 2015. CLA submits comments on the benefits of neonicotinoid seed treatments to soybean production (Docket No.: EPA-HQ-OPP-2014-0737)
Read the comments.
 

January 20, 2015. CLA submits comments on the European Union Roadmap for the Establishment of Criteria for Determination of Endocrine Disrupting Properties
Read the comments.

 

 

CropLife America Public Comments – 2014

November 24, 2014. CLA submits comments on EPA’s request for stakeholder input on the Pollinator Health Task Force’s development of a federal strategy
Read the comments.

 

November 14, 2014. CLA submits comments on the proposed rule to define “Waters of the United States” under the Clean Water Act
Read the comments.

 

October 10, 2014. CLA submits comments regarding the draft environmental impact statement, Monsanto petitions for determinations of nonregulated status for Dicamba-resistant soybean and cotton varieties
Read the comments.

 

August 18, 2014. CLA submits comments on EPA’s proposed revisions to Agricultural Worker Protection Standards
Read the comments here and here.

 

August 11, 2014. CLA submits comments on EPA’s labeling of pesticide products and devices for export
Read the comments.

 

July 25, 2014. CLA signs a letter with more than 45 organizations to thank member of the House Agriculture Committee for their willingness to examine the benefits of biotechnology
Read the letter.

 

July 25, 2014. CLA signs a letter with more than 45 organizations to thank Hillary Clinton and The Clinton Foundation for their support of agricultural innovation
Read the letter.

 

July 24, 2014. CLA, as part of the Endocrine Policy Forum, submits comments regarding the FIFRA SAP on high throughput exposure
Read the comments.

 

July 11, 2014. CLA’s Human Health Risk Assessment Committee (HARC) and Environmental Exposure Work Group (EEWG) team together respond to EPA’s draft guidance on the consideration of volatilization in pesticide risk assessment.
Read the letter.

 

July 8, 2014. CLA comments on draft white paper, issued by the U.S. Environmental Protection Agency, on percent crop area (PCA) adjustment factors used in the development of community water system – drinking water exposure assessments.
Read the letter.
 

June 30, 2014. CLA comments on the proposed registration of Dow AgroSciences Enlist Duo®  Herbicide
Read the letter.
 

April 25, 2014. CLA comments on EPA Draft Guidances: Pesticides; Consideration of Spray Drift in Pesticide Risk Assessment
Read the letter.
 

March 28, 2014. CLA joins 22 organizations to support USDA ARS.
Read the letter sent to United States Senate
Read the letter sent to United States House of Representatives.
 

March 11, 2014. CLA comments on the USDA, APHIS draft Environmental Impact Statement re: Dow AgroSciences petition of nonregulated status for certain corn and soybean varieties
Read the letter.
 

March 2014. CLA comments on Memorandum of Understanding between the U.S. EPA, OPP  and the U.S. Fish and Wildlife Service Regarding Implementation of Executive Order 13186
Read the letter.


February 14, 2014. CLA sends letter of thanks to those who supported FFAR and Sec. 7601 in what is now the Agricultural Act of 2014. FFAR awarded $200 million investment for Research, Extension and Related Matters
Read the letter.


January 22, 2014. CLA Comments on Renewable Fuel Standard
Read the letter.


January 10, 2014. CLA joins nearly 100 food and agricultural organizations and companies strongly supporting the confirmation of Deputy Under Secretary for Farm and Foreign Agricultural Services Darci Vetter as Chief Agricultural Negotiator in the Office of the United States Trade Representative (USTR).
Read the letter.


January 10, 2014. CLA provides comments to the EPA FIFRA Scientific Advisory Panel to consider and review, RNAi Technology as a Pesticide: Problem Formulation for Human Health and Ecological Risk Assessment
Read the letter.