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TOP THREE REGULATORY ISSUES FOR INDEPENDENT CROP CONSULTANTS
By Rick Kesler, Governmental Affairs Liaison for National Alliance of Independent Crop Consultants (NAICC)

These are the top regulatory actions affecting NAICC members.

EPA's Final Rule On Chlorpyrifos

The final rule to stop use of chlorpyrifos on all food crops was effective Oct. 29, 2021, and the tolerances for all commodities expire on Feb. 28, 2022. NAICC partnered with the Pesticide Policy Coalition to submit written objections stating the rule is inconsistent with federal statute; the agency's own record on chlorpyrifos; and sound, science-based and risk-based regulatory practices. It is hoped the agency will stay implementation of the rule until objections can be formally addressed.

By EPA's own admission, though all chlorpyrifos food tolerances would be revoked, a number of food uses would still meet all safety standards even after applying EPA's most stringent criteria. Nevertheless, EPA's action would revoke tolerances for food uses even where, in certain crop production areas, use could be allowed. Examples include alfalfa, apples, asparagus, cherries, citrus, cotton, peaches, soybeans, strawberries, sugar beets and wheat.

BumbleBees

The U.S. Fish and Wildlife Service published a 90-day finding on bumblebees and will conduct a status review on whether those bees should be on the threatened or endangered species list. A petition filed with the agency says the pollinator's population dropped by nearly 90% during the past 20 years and is no longer seen in eight states. The agency will assess the American bumblebee's status in the next year. It is asking for any data that might be out there. The petition was filed, in part, by the Center for Biological Diversity. It says habitat loss, pesticides, disease, climate change and competition from non-native honeybees are reasons for bumblebees' decline.

Pesticide Registration Improvement Act

The next PRIA isn't due until 2023, but work still continues under the current PRIA. A PRIA funding increase recently passed out of the House and is currently in the Senate. One key issue driving this could be that EPA continues to miss deadlines in the registration process.


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