CLA and Agricultural Organizations Submit Opposition Letter to U.S. House of Representatives and United States Senate on S. 269

Read the letter submitted by more than 400 groups, including CropLife America.

March 13, 2023 The Honorable U.S. House of Representatives/United States Senate Washington, D.C. 20 Dear MC/USS: We write to share our opposition to S. 269, which upends the science-based safety standards that are used to protect farmers, workers, and the public. We represent a wide range of groups who rely on the availability of safe and effective pesticides in diverse settings to produce America’s food and specialty crops, fiber, and biofuel and to protect our public health and infrastructure and we support the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA).

FIFRA provides for federal regulation of pesticide distribution, sale, and use and establishes stringent safety standards and oversight. All pesticides distributed or sold in the United States must be registered by the U.S. Environmental Protection Agency (EPA), and then reregistered every fifteen years. EPA is required to review the most current scientific data on health and environmental impacts for all pesticide products and impose requirements to minimize any risks before they are made available for sale and use. The data must show that products work as intended and can be used safely. Product label restrictions and instructions are designed to ensure a product is used effectively and safely in a manner that mitigates any identified risks. FIFRA already requires EPA to consider economic, social, and environmental benefits and risks, and the most recent amendments to FIFRA included in the Food Quality Protection Act (FQPA) added specific considerations for risks to infants and children when determining if a product can be registered. While reregistration is required to occur at least every fifteen years, it can and often does occur more frequently. EPA can initiate a review if scientific data becomes available that questions the safety of a product. For example, some of the organophosphate products specifically mentioned in S. 269 have undergone multiple EPA risk assessments since 1996.

S. 269 would repeal decades of federal regulation and scientific progress, undermining the work of EPA’s career scientists in the evaluation of pesticide safety and oversight of pesticide registration and use. S. 269 would jeopardize the continued availability and innovation of pesticide products by imposing an unscientific and unbalanced process that could unnecessarily remove pest control options from those who need them to safely grow crops, to adopt conservation practices such as conservation tillage and resource-saving crop rotations, to protect homes and infrastructure, to control pathogens and disease vectors, and to maintain green spaces, such as parks and golf courses.

Pesticide manufacturers, pesticide users, and the public all have an interest in ensuring that the pesticide regulatory process imposes stringent regulatory controls on pesticide use based on the principles of sound science, transparency, and broad stakeholder engagement. We remain committed to protecting human health and the environment while maintaining America’s important food, fiber, and biofuel production and protecting its public health and infrastructure. If we can provide additional information or answer questions useful towards meeting these goals, please know our member organizations would be happy to provide more detail.

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