CLA, ASTA, and BPIA Comments to the U.S. Environmental Protection Agency on the Treated Seed Petition
CropLife America, American Seed Trade Association, and Biological Products Industry Alliance write to the U.S. Environmental Protection Agency on the Treated Seed Petition, stating that “the Petition the Agency will address in connection with the Consent Decree seeks to impose a regulatory process on agriculture that would entirely duplicate the EPA’s existing exercise of its authority under the Federal Insecticide, Fungicide, and Rodenticide Act (“FIFRA”), 7 U.S.C. § 136 et seq., while having no impact on human health or environmental safety.”
Re: CropLife America, American Seed Trade Association, and Biological Products Industry Alliance Comments to the U.S. Environmental Protection Agency on the Treated Seed Petition, Docket ID No. EPA-HQ-OGC-2022-0511, 87 Fed. Reg. 40233 (July 6, 2022)
Dear Mr. Hill:
CropLife America (“CLA”), the American Seed Trade Association (“ASTA”), and the Biological Products Industry Alliance (“BPIA”) appreciate the opportunity to provide these comments to the U.S. Environmental Protection Agency (“EPA” or the “Agency”) on EPA’s Proposed Consent Decree: Unreasonable Delay Claim Regarding Petition Concerning Treated Seeds and Treated Article Exemption, published by EPA on July 6, 2022.
Established in 1933, CLA is a national, private, not-for-profit trade association representing companies that develop and sell crop protection products for agriculture and pest management in the United States. Founded in 1883, ASTA is one of the oldest trade organizations in the United States. Its membership consists of over 650 companies involved in seed production and distribution, plant breeding, and related industries in North America. Incorporated in 2003, BPIA is the leading not-for-profit trade association dedicated to fostering the use of biological technology, including biopesticides, biofertilizers, and biostimulants, and represents over 150 member companies around the world, ranging from small, innovative sole proprietors to large, international corporations.
As EPA is aware, the Petition the Agency will address in connection with the Consent Decree seeks to impose a regulatory process on agriculture that would entirely duplicate EPA’s existing exercise of its authority under the Federal Insecticide, Fungicide, and Rodenticide Act (“FIFRA”), 7 U.S.C. § 136 et seq., while having no impact on human health or environmental safety. All pesticides approved for use as seed treatments in the United States are subject to rigorous, scientifically robust review under FIFRA and the federal Food, Drug and Cosmetic Act (“FFDCA”). Moreover, EPA, in partnership with CLA, ASTA, BPIA, their members, and other stakeholders, has taken and continues to take affirmative measures to address the pollinator health and other environmental impacts alleged in the Petition. Accordingly, CLA, ASTA, and BPIA respectfully request that EPA deny the Petition for the reasons identified in comments submitted to the Agency by our organizations on March 26, 2019. Those comments are attached and incorporated herein.
Again, CLA, ASTA, and BPIA appreciate the opportunity to provide these comments on the Consent Decree and in support of EPA’s current interpretation of the Treated Article Exemption with respect to pesticide-treated seed. Should EPA have any questions or wish to discuss these issues further, please do not hesitate to contact us.
Thank you for your consideration of these comments.
Sincerely,
Chris Novak President/CEO CropLife America
Read the comments submitted by CropLife America, the American Seed Trade Association, and Biological Products Industry Alliance.