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The USEPA is seeking public comment regarding proposed changes in language on pesticide labels to address pesticide drift. In the opinion of our industry, this proposal is more onerous than the attempt the EPA made years ago when they sought to put in a wind restriction of 10 mph for pesticide application. This new proposal will apply a subjective standard for pesticide application that will increase the likelihood of penalties and frivolous lawsuits against our industry.
In this proposal, USEPA is seeking to abandon existing guidance on the pesticide labels that currently allows the legal application of pesticides so long as the application does not cause “unreasonable adverse effects.” USEPA is proposing to abandon this legal standard and replace it with a hazard-based standard which would make it a violation of the pesticide label to apply the product in a manner that “could cause adverse effects.” This is commonly referred to as the “precautionary principle" and is the governing principle in many European countries. USEPA gives an example of an “adverse effect” for human exposure as “any negative physical impact, health symptom, or illness, regardless of whether it requires medical treatment or is temporary in nature.”
IFCA has prepared a sample letter for you to use as a guide as you draft your own personal letter to USEPA. Please include information about your business, the number of acres you serve and your commitment to pesticide stewardship and belief in reasonable regulation that does not adversely impact food production.
The sample letter is attached or go to www.ifca.com to download it and for instructions on sending it to USEPA via mail or electronically. You should also mail or email it to your US Congressman and US Senators Durbin and Burris. LETTERS ARE DUE BY MARCH 5, 2010.
Crop Life
http://www.gopetition.com/online/33776.html
Thank you!