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U.S. ENVIRONMENTAL PROTECTION AGENCY

PESTICIDE PROGRAM DIALOGUE COMMITTEE MEETING

Thursday, October 28, 2021
11:00 a.m.

DAY TWO


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PARTICIPANTS

PESTICIDE PROGRAM DIALOGUE COMMITTEE ROSTER

October 2021

Walter Alarcon
Ruben Arroyo
Amy Asmus
Manojit Basu
Steven Bennett
Jasmine Brown
Lori Ann Burd
Douglas Burkett
Douglass Cameron
Iris Figueroa
Joseph Gryzwacz
Gary Halvorson
Gina Hilton
Komal Jain
Mark Johnson
Patrick Johnson
Dominic LaJoie
Charlotte Liang
Amy Liebman
Aaron Lloyd
Lauren Lurkins

Daniel Markowski
Gary Prescher
Caleb Ragland
Damon Reabe
Karen Reardon
Charlotte Sanson
David Shaw

Christina Stucker-Gassi
Cathy Tortorici
Mily Trevino-Sauceda
Lisa Fleeson Trossbach
Tim Tucker
Edward Wakem
Nina Wilson
John Wise

Tim Lust


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3

PROCEEDINGS
DAY TWO - OCTOBER 28, 2 021

MR. MESSINA: Paul?

FACILITATOR: Yes.

MR. MESSINA: Can you hear me?

MS. BUHL: Ed? Yes, I can.

MR. MESSINA: Great.

FACILITATOR: I think we're good. We're
about a minute away. Perfect timing. We're up to
about 43, I think, participants. We might want to
give it a minute or two to give everybody a chance to
log in.

MR. MESSINA: Sounds good. I'll wait for
you're your cue.

FACILITATOR: Okay, sounds good. Thanks, Ed.

(Pause.)

FACILITATOR: Good morning, folks. This is
Paul Aninos. I just wanted to thank everybody that
signed on so far for signing in early. We're going to
give this another minute or so, a minute or two,
because I notice that our participant list is growing
rapidly right now. So let's give folks a chance to
log in and then we will kick off day two.

(Pause.)

FACILITATOR: Ed, I'm not sure if you see on


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your screen, but we're climbing quickly to about the

90	participant mark. If you'd like, we can give it
one more minute or we can get started.

MR. MESSINA: Yeah, I'll say another 30

seconds.

FACILITATOR: Okay.

MR. MESSINA: And do you want to kick it off?
Do you want me to start rolling into my welcome.

FACILITATOR: I think you just start the day,

Ed.

MR. MESSINA: Sounds good.

FACILITATOR: We definitely have a quorum at

91	people.

MR. MESSINA: Yeah, let's get rolling.
Welcome, everyone, to day two of our PPDC
virtual meeting. We had an amazing day yesterday from
my perspective, had some great presentations yesterday
from the farmworker and clinician training workgroup,
their recommendations. We heard from Walter Alarcon
from NIOSH on the SENSOR surveillance program, and
then, of course, our Kaci Buhl did a really great job
on risk communications, and then we had some great
comments from the public at the end of the day, which
we will also do today.

We have the three -- in terms of the agenda


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for today, we have the three remaining workgroups that
are going to present their recommendations, the
emerging pathogens workgroup, the emerging
agricultural technologies workgroup, and then the
pesticide resistance management workgroup report-out.

Also, as part of the agenda, we're going to hear from
the folks in OECA about the Good Laboratory Practices
Inspection Program, and we'll have time for some
breaks.

And at the end of the day, we'll do some wrap
up to things out of that session really in terms of
moving forward. We've got a half an hour discussion,
so it can be the beginning of the discussion. It
doesn't have to -- we don't have to finish everything,
but probably want to have some discussion around, you
know, which workgroups do we think should go forward,
which ones do we think are done, and then any topics
that folks feel like should be presented in the future
for the spring meeting, and then how -- you know, any
feedback on how this session -- two-day session went
virtually.

Maybe we'11 be able to start thinking about
an in-person meeting for the spring. So plenty of fun
wrap-up topics. We can open the floor up for the PPDC
members to talk about how to best make this meeting


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useful for everyone.

So with that, I will kick it over to our next
presenters. We're going to talk about their workgroup
report-out and we'll kick it Komal Jain, who's going
to be the co-chair of the recent session that talk
about emerging pathogens and the emerging pathogens
workgroup. So we've got Komal Jain and Taj ah
Blackburn from EPA as co-chairs of that.

So with that, take it away, folks.

Actually, before we go, any questions on
logistics or things we need to talk about that folks
want to point out for the rest of the day? Anything
that folks think we need to cover before we get
started? Any questions for me or Paul?

(No response.)

MR. MESSINA: Okay, hearing none, let's get
rolling. Thanks, everyone.

MS. JAIN: Paul, did you want to say
anything or should we just go ahead and --

FACILITATOR: I think Ed just introduced the
two co-chairs. So it's Komal Jain with the American
Chemistry Council's Center for Biocide Chemistries,
and Tajah Blackburn with EPA's Antimicrobials
Division.

Komal, I think you're on the hook to get us


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started this morning.

MS. JAIN: I am.

FACILITATOR: Thank you.

MS. JAIN: Okay. Well, good morning,
everyone. Great to see that we have such a large
number of listeners today.

I hope you're ready to switch gears. We're
going to discuss the antimicrobial pesticides as
opposed to conventionals. This morning, we are going
to discuss the work of the emerging pathogens
workgroup and our recommendations on how EPA can be
better prepared to respond to a pandemic or other
emergency situation. Our charter was to pull together
lessons learned from the COVID-19 response.

Primarily, we focused on the disinfectant market, what
went right and what did not.

My name is Komal Jain. I served as the co-
chair of this workgroup alongside Dr. Tajah Blackburn,
senior scientist of the Antimicrobials Division of
EPA. For those that do not know me, I am a long-
serving member of the PPDC. In fact, I am saddened to
say that I have come to the end of my tenure. So I
look forward to watching from the sidelines next year.

I also am the executive director of the
Center for Biocide Chemistries, which is a trade


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association of more than 50 manufacturers and
formulators of antimicrobials, including
disinfectants, and we sit under the umbrella of the
American Chemistry Council.

Members of the emerging pathogens workgroup
had a tremendous amount of experience to draw from,
and I, along with my co-presenters Rhonda Jones of
SRC, Alex Cook of the First Group USA, and Seth
Goldberg of the Law Firm Steptoe & Johnson are so
pleased to discuss our recommendations with you and
hope you will support our recommendations to the EPA.

Next slide, please.

So here's an overview of what will transpire
over the next 90 minutes or so. I will preview our
overarching recommendations to the EPA, provide
background on the emerging pathogens workgroup, and
discuss our objectives.

Rhonda will then review charge questions 1
and 2, as well as our recommendations, respectively,
followed by Alex, who will discuss charge question 3
and our recommendations. And I believe this topic,
which is all about education, will really resonate
with you. And I hope you'll have questions and
feedback for us during the Q&A session. And then Seth
will discuss charge question 4, which is all about


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enforcement. I will return and close the presentation
out. And then, of course, we will open it up to
questions.

We do have several workgroup members on the
line with us, so they stand ready to help answer any
questions you may have.

Slide 3, please.

Okay. So before we dive into the details,
let me provide our overarching recommendations.

And what do I mean by that, overarching? These are
the recommendations that will serve the foundation for
executing the more detailed recommendations that we've
provided in our report. But before I even go there, I
think it's really important to state the obvious.

COVID-19 is ongoing. It is singularly the most unique
and devastating pandemic that any of us have ever
experienced in our lifetimes and there was no previous
experience to draw from. So it is without reserve
that I say that the members of the EPWG commend the
Antimicrobials Division for their tremendous work
during COVID-19. And you heard some of the stats from
Ed yesterday.

I can say, based on my own personal
experience and my interactions with Tajah Blackburn,
we spoke and we emailed on Sunday afternoons. She


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worked 24/7, as did many of our colleagues, and that's
been ongoing since March of 2020. So, AD, you have
our sincere thanks and we do hope that these
recommendations, if affirmed by the PPDC, are seen as
positive and constructive ideas that once in place
will put you in a better position should there be a
pandemic, another pandemic. And let's be real, it's
just a question of when. And there are going to be
other critical emergency situations that we hope will,
again, provide a strong foundation.

So on this slide here is a brief review of
our overarching recommendations. First of all, the
workgroup believes that EPA can be better prepared for
future pandemics, as well as the occurrence of other
emergencies. And the recommendations provided in our
report often cite to other emergency situations, and
Rhonda will provide detail on our proposed definition.

Second, and one issue that has been debated a
lot over the course of the last two days is followup.

And that is -- you know, this workgroup put together
20 pages worth of recommendations. So there's a lot
there. And I'll be the first to admit that we really
didn't have the time or really the appropriate
resources, at this point, to try to prioritize those
recommendations. So we are asking that another


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workgroup be formed, whether that is under the PPDC or
whether OPP forms another workgroup, but the idea is
that there be an implementation workgroup and that's
where there's a collaborative process between
stakeholders and EPA to implement several of these
recommendations.

Third, as the workgroup assessed EPA's
guidance, communications, and other tools, there was
just a general sense that for the purpose of
responding to the pandemic, or any other emergencies,
many of these materials are vague and ambiguous. The
audience was not kept in mind with an eye towards how
the information would be received, interpreted, or
implemented. Thus, the group recommends EPA develop
better communication strategies, advance
communications on product performance or suitability
for an outbreak, consider a new acceptable label
graphics and symbols and socialize them now, and
establish and maintain a webpage on EPA's website that
addresses pandemics and that is kept to up-to-date in
real-time fashion.

Fourth, we'd recommend that EPA draw
knowledge from direct trade and other user groups and
learn from those experiences. And Alex is going to
talk about that in greater detail.


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And along with talking to trade and user
groups, there needs to be an acknowledgment that there
was some ineffective messaging across several sectors
due to information education gaps, and in response,

EPA should develop general, but also specialized
education resources.

Next slide, please.

Okay. So here on this slide you're going to
see a list of our members and I just want to take a
moment to talk about this workgroup and our
composition. So we were a large and diverse
membership. We had antimicrobial registrants. We had
trade associations that consisted of both registrants
but also downstream users, such as the airlines,
ground transportation, health care associations. We
had representatives from EPA and the CDC, and we had
consultants and academia that operate in the
antimicrobials space. This was a cross-functional
group and, therefore, we were able to assess the
response to COVID from various points of views.

I want to commend this workgroup for the
amount of hours and time that was put in towards this
effort. As we mentioned, when we met in mid-year, we
met on a biweekly basis for a couple hours of a time.

And that didn't take away from all the work that was


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done sort of offline. So it was clear that everybody
that served on the workgroup was willing to put in the
time and commitment, but, most importantly, really
open to hearing the perspectives of each other because
we all came from a unique space.

Next slide, please.

So what did we set out to accomplish? We had
three objectives. One, assess COVID-19 response and
the stakeholders experienced with the emerging viral
pathogens guidance; two, assess the user experience
with antimicrobial disinfection products registered by
EPA for infection control; and three, provide
recommendations to EPA for policy improvements and
identify education gaps.

As you will soon learn, these objectives led
to the self-identification of several charge questions
that Rhonda, Alex, and Seth will cover.

So with that, let me turn it over to Rhonda.

MS. JONES: Good morning. Thanks so much,

Komal. And I thank everyone for the honor to be here
to speak with you today.

As Komal said, my name is Rhonda Jones. I'm
the CEO and founder of Scientific and Regulatory
Consultants. It's a consultancy that's headquartered
in Indiana, but we focus on antimicrobial


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registrations. Probably the bulk of what we do is
disinfectants. And we do that here in the United
States at the federal and state level. We also do it
in Canada and a smattering of other countries
throughout the world.

So we were sort of uniquely in on the ground
floor of dealing with the VP guidance, and we work
very closely every day with the folks at AD who just,

I have to echo everything Komal said and could add
many more stories of the just Herculean efforts that
the efficacy team, Anita's team, went through to get
us through this very unique challenge and to continue
to get us through this very unique challenge.

So on a day-to-day basis, I'm a
microbiologist. So I sit in the seat of developing
protocols and study designs. I'm working with the
agency to get those approved for treating surfaces and
water and air and worked very closely with the agency
through this process and continue to today, as well.

So it was quite an honor to be invited to be
on the workgroup and to sit alongside all of these
experts and see their experiences and hear their
experiences and bring it into this realm of even
though so much went so well, in an unscripted
situation, we do see room for improvement. And I


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think from my point of view, a lot of the improvements
that I really want to see are about preserving the
precious resources that we have at AD.

I mean, we heard Ed yesterday talk about
we're at our, you know, FTE max in the program right
now. And I know they pulled a lot of volunteers from
other areas, but some of our suggestions will
hopefully automate aspects of the process and have it
so that there is less burden on those precious
resources at AD and on the efficacy team.

So just a little stage setting, a little
reminder. Here's a little clip of the cover of the
EVP policy. The first one was actually published in
2009. I was very happy to be on the group that pulled
that together; again. CDC, EPA, other stakeholders as
well that published the first one, and then again, in
2016, when this one was revised.

So what does this policy really do? It
allows us to preregister on our master labels for
emerging pathogen claims. Now, viruses by their
structure fit into three buckets and they're sort of
like a stair step. There's the easy bucket and then
there's a middle difficulty bucket and then there's
the top difficulty bucket. So the science is set up
that you have to test a harder-to-kill bucket to get


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the easier-to-kill bucket below you and so on. So
this document sets that stairway up and creates a
system and a set of communication tools by which we
can go forward into the marketplace very quickly once
EPA triggers this particular policy.

So that was the focus -- if you want to go
ahead to the next slide -- of really a lot of the
initial efforts of this workgroup, and then it sort of
feathered out from there.

So you'11 all remember sort of the basics of
how this unfolded, January 2020, EPA activates, for
the first time, this policy for prior emerging
pathogens. Slightly different programs were selected
at the time for various reasons, but this was really
the first. In March, we see that EPA is really
starting List N, so we have a list of products that
are effective that have the EVP claim on it. And that
for those that don't have that claim, EPA is going to
expedite getting that claim onto labels.

And then in May, we see now we have products
that have been tested with the virus and EPA offers a
special, very, very shortened program of reviewing
that data and getting testing onto the product labels
and out into the hands of the users.

And as I looked at this slide to really


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thinking about it, I feel like this slide doesn't make
what was really going on -- what is really still going
on today -- and I completely agree with Ed that your
2022 is going to look like just as many submissions as
you've had in the last two years -- but this slide
doesn't bring alive to me what really kind of
happened.

And I want to share with you that on January
22nd, 2020, I was on the phone with the efficacy
branch -- who will now become the efficacy branch
chief -- and doing normal day-to-day business. At the
end of the call, I'm like, hey, you know, there's this
SARS thing going on, are you guys going to trigger
this policy? I mean, what's really happening there?

To my surprise, she said, yeah, we are, and I no
sooner hung up the phone and the announcement came
over the OPP newsletter, it's triggered.

I don't think any of us on the regulatory
side or on the EPA side probably slept for the next,
at least, seven or eight days of what began to unfold
very quickly. The first thing for the people who had
the EVP claim is how do I get it written, how do I get
it out there, how do I get my name on it, can I
combine it with these 87 other things that were
actually very valuable communication tools. Like they


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wanted to tell people, yes, this will work and use the
language that's in the document, but they wanted to
say, oh, and you need to leave the surfaces wet for
five minutes and you need to dilute it this way. So,
you know, very valid additions to the communication
pieces that we probably just didn't really think about
in 2016, not having a really good emergency to learn
from.

And then really quickly the first -- I would
say look at this timeline between January and May and
run it out and make it be waves, and there's a crest
of each wave of different things that happens. The
first thing was the realization that we have 850-ish
disinfectants registered at the federal level.

Probably only at least 90, probably somewhere in the
15 0 range have taken the time to proactively, even
though it's been a policy for four years, but these
claims on the label. So the first deluge of work that
happened for us and then for AD is all these people
racing to add the EVP claim so that they could get
products in the hands of users and then eventually to
get on List N.

And then pretty quickly after that, the next
wave was, how do we get the virus from CDC through the
BEI resource group into the labs that had BSL-3s, how


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do we run the studies to get the claims on the labels,
is it the normal study, is it more than normal, is it
more replication, et cetera? Then how do we get it
going, to have a front row seat to the first testing
and the first submissions and to work through with AD
the process of the first submissions. We precleared
labeling claims so it could go faster. We tried to do
everything we could think of as industry to make the
process go as smoothly and as quickly as we absolutely
could.

No sooner did we fall into a groove with
that, then somebody started asking the question about,
well, that's about hard nonporous services. What
about the pizza I just got from UberEats or Door Dash,
or the Styrofoam carton, where does that fall all of
this? And, okay, we need more methods for soft
surfaces and semisoft surfaces and those types of
things, and then the question of error. And then
pretty quickly came the question of we have very large
spaces that we have to reopen and get people back
into. What about electrostatic sprayers and
developing the methods for those and getting them out
there?

And then about that time, the supply chain
issues start to hit, we can't get caps, we can't get


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actives, we can't get inerts. And the flexibilities
that EPA came rushing to our rescue with to allow us
to keep putting the product out and keeping the lines
functioning and really it's just continued since that
moment and I really don't think the very first
triggering event has abated yet. And, yet, now we're
faced with variants. In the middle of all this,
rabbit hemorrhagic fever happened, which nobody talks
too much about, but it's also an EVP.

So we're now sitting here today with at least
five strains under this EVP active, and then trying to
look at how this all congeals and comes together. And
I'm sure I left out another dozen threats that came,
and so this idea of the other emergencies is kind of
where this is born. And not all emergencies might be
triggered by a pandemic, but these are all pretty
closely associated with that.

And that's all while the agency is learning
to work fully remotely for the first time. They've
also moved during this period of time. They've taken
paper processes and advanced the IT significantly and
automated things, and all of those things are
wonderful and I'm so excited to hear Ed tell us
they're continuing and will continue because they've
just been great advancements in all of this.


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So we're also at home trying to teach our
kids that are there sitting next to us. I'll never
forget the introduction of Dr Anna Lowit, who's senior
science advisor to Ed and his team. Sitting through,
it was a global meeting of some sort, she was being
introduced and she's had a fabulous career. So she's
got a long bio. Got this funny smile on her face just
as she was ready to talk and she sort of stumbled the
beginning and she apologized. And she said, my kids
are sitting on either side of me doing their online
school with their homework and they just listened to
all that and leaned over and said, mom, did you really
do all of that. And so just so many different
variations in trying to keep life going and keep
things going.

So keep in mind this little three boxes just
doesn't kind of cut what we were all living through
and are really continuing to live through.

So go ahead to the next slide if you would,

please.

So List N, we got it up and going in March,
started out with 90 products. Those were the ones
that already had the EVP claims on them. This list
got created overnight, literally in 24 hours, because
there really wasn't a good IT way to develop this list


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quickly. And then we've continued to add onto it ever
since and, hopefully, there's IT solutions to being
able to quickly allow EPA and industry to sort the
products that are out there by surface or active or
bug, whatever you're trying to achieve. We definitely
need that ability for more dynamic access to that pot
of registered products. But it's very, very
successful.

I think if you'11 hit the forward key one
more time, the analytics will come up -- oh, no, maybe
not. Take me back one there.

So the analytics, basically, there were -- I
think, as of this point, there's been almost 24
million hits to this site. So it's been very
important to users to be able to find it. There are
now about 550 products on that site. It's been split
into different uses. About 30 percent of the products
now actually have the SARS claim on it. So it's very
pivotal in the emergency to have this list and, you
know, to have it become an app on our phones and
things like that. It's just amazing work by the whole
team at EPA to make this happen. But we really think
there are some other ways to look at how to do this,
and I'll speak on those in just a minute.

If you can move forward, please, another


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side.

So that really gets us into our first charge
question and where do we go with this workgroup. So
really, truly an amazing group of people that has been
pulled together to look at this question. And we
first started fairly simply and that was taking the
document itself and taking a look at it and figuring
out what are the strengths and the weaknesses of the
document, where did the words in the document become
incomplete for us as we went through this real
emergency.

So go ahead to the next question -- sorry,

slide.

So yeah, this is a this is sort of an eye
chart for real. It looks like a little bit of a
bullseye, but you can see in the center there those
are the four sections of the document. So we very
literally went section by section looking at the
content of that section and how we would expand it or
improve it. And then you can see, as each triangle
builds out, where the focal points were in that
section of the document for changes and suggestions.

Now, we did try in our report as we went along to
compliment the agency wherever we could in their
outstanding work and processes that they created, but


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you asked us to focus on constructive changes and
advances. So that's what the report mainly details
are these type of changes that we want to go forward
with.

So again, as Komal said, some of these are
short-term changes, some of them are longer-term
changes, some of them are a little harder to effect,
some of them probably could be done tomorrow. So
there's a real mix of things here, but everyone on
this group is so committed to their ideas and what we
have come up with here that they would like to
continue on in some sort of role, if possible, in the
implementation workgroup, which I think is a real
testament to this dynamic group of people that came
together for the purposes of trying to help you work
your way through this.

So you can see basically here, in a quick
nutshell, all of our different recommendations on
looking at the question itself.

So to boil this down a little bit, on the
next slide, I'll just kind of share with you it's a
little bit of a repeat from Komal's statement. We
just really found that in a lot of areas the EVP
document was too ambiguous, which, not surprising, in
2016, we really hadn't been through this. We didn't


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know a lot of the details. Now, we can see where
there were sort of cracks in what we wrote and where
it was really hard to interpret. I wrote some of
those sentences myself. So I see now, you know, a
missing comma, how it can be interpreted incorrectly.

So we really think there's a need for clarity
in the document in a lot of places, and the area of
what triggers and how the trigger is announced is one
of those areas, and who does that that trigger, and to
what extent the registrants have to tag up with EPA
before they go forward. A lot of people felt like
they needed to do that, even though the intent was the
document that once EPA CPA blasts out the trigger, you
go. You can go with the communication documentation
that's there. But people just weren't clear. They
didn't want to make a misstep and they wanted to make
it factual, which just made it hard because that meant
AD had to field, I don't know, hundreds of calls from
people just so they could say, yeah, go ahead. So
again, I think we can do a lot to tighten that up in
that particular case.

There was -- once you started to write that
communication language -- and in this document, there
are two prewritten paragraphs. And all you have to do
is drop the name of your product in and drop the name


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of the viruses in and you should be ready to go, but
nobody really thought farther than that. So I know
with my clients, they wanted to pair it with a press
release and some of them wanted to pair it with use
directions. Other people wanted to pair it with some
of their other claims that they already had and so
just immediately people wanted to do different things
with the communications, but part of that was because
they're being asked those questions. So they want to
get this information out.

Where this paragraph and these paragraphs can
go wasn't really getting to the user. So that was
another problem is where can we communicate legally
with you and what can we communicate and can we
combine some of these other seemingly benign -- and
I'll admit it, a lot of pushing things out there, too,
and really trying to do too much marketing in that.

We did our best to hold that back from happening, but
I think there's merit in looking at that further and,
you know, to the extent that you'11 see that we want
to push it even farther away from those paragraphs to
something even more simpler.

And we have questions on the end about the
off ramp. There's a two-year off ramp. Well, we're
coming up to the two-year off ramp for SARS right now.


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So we're three months away from it. How is that going
to work? Are we going to extend it or are there
enough products already tested that it really is going
to off ramp and people have to pull those
recommendations and communications down. So again, in
the different phases of communication, we need really
to expand the policy and in some places not only
clarify it, but I think go a little deeper into these
areas.

So you can see from this list, too, that we
come down to, again, List N. And there were some
challenge -- as fabulous as a tool that it was and how
quickly it became like the focus of the United States
to go click on List N and find your product, you know,
we ran into problems. One of the first ones is that
when we register things at EPA, you may not be aware,
we're usually using a faux name, a project name, a
file name, it's not the commercial brand name. And
while we may only have 850 registered disinfection
disinfectants approximately, at the state level, by
the time those have all of their different brand names
on them and they've been subregistered to people, it
becomes 14-, 15-, 16,000 products with 16,000,
different brand names that your different users are
trying to pick off the grocery store shelf.


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At one point early on in the -- once List N
kind of got going around the sort of May timeline, I
remember being the grocery store and I wish I had
taken this picture, and there literally was a clog of
carts of everybody standing there with their bottle
reading it, trying to figure out if it was the right
one. So again, that led us to really think about is
there a more flexible way to do this and a better way
to communicate with people and a way to maybe even
make List N obsolete.

I mean, I realize whatever it was 24 million
hits at this point, maybe we still want to keep it,
but we know we have three buckets of viruses. We know
their structure. We already have a policy that tells
us what science we need on file to get to those
buckets. All of the educational material and all of
these lists can be created today and then just
updated, so that no one has to do it overnight in 24
hours ever again.

So we do think -- and I was struck by the
educational words from the farmworkers and the
clinician speakers yesterday and as well about some of
their materials and conduits by which we can educate
people, too. And I think there's a networking
opportunity between those workgroups and ours to steal


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some of those conduits for education. So very good.

But that's -- you know, sort of in a nutshell, those
were sort of the really big issues that we came about
with looking at the policy.

So if you'll go to the next slide.

Here's an overarching list of our
recommendations and you will see much tinier steps and
pieces of accomplishing these five things in the
report and different ideas, again short- and long-
term, that you could that you could go. But, I mean,
obviously, from this conversation, we want to revise
the document. We want to add clarity to so many of
the sections to bear out some of the experiences we've
had, and the gaps that have been identified, and now
to layer on what happens if you have five EVPs going
on at the same time. Does that change what we're
doing and how we're doing it?

So we really kept coming back to the fact
that we felt like, you know, CDC had a landing page
for what they were doing, some of the other user
groups had landing pages. But we really didn't feel
like we had a landing page. We kind of ended up with
List N as a de facto landing page, but we really think
there needs to be a hub that's the EPA angle on
communicating in an emerging pathogen crisis.


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And a user could go there or a registrant
stakeholder could go there to find out information and
then it could list all the things that currently have
an EVP, when it started, when it expires, when it off
ramps, where there's expedited processing in EPA, all
of those things that kind of came out one at a time
that could be all housed in one place, including
information the viruses and an understanding of their
structure and where they sit in this hierarchy of
difficulty of kill, and it would be very transparent,
could be readily updated as things change, as we add
different application tools, like ESS, et cetera. It
might provide good links to CDC and other
organizations as well.

One of the other areas we just kept coming
around with is that we think the time is here to
really look at having some sort of EVP communication
label, and I know from dealing with this since pre-
2009, that's been a very hard, hard thing to do, but
we think a lot of the challenges to the users would be
overcome by some sort of icon the actual label at the
point of purchase. We think this would just cut down
on so much of the traffic that the EPA staff had to
deal with during this time as well.

And there's -- here on the screen there, the


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team sort of developed a couple of ideas, you know.

These are not the final thing, but it's just something
for you to think about it. Is it a three-color thing
where it's blue green yellow and the emerging pathogen
is a blue virus and EPA says on this hub, okay, we
have a new emerging pathogen, its name is XYZ and it's
a blue, so look for the blue dot on the products or
the blue triangle or whatever it turns out to be.

I mean, we got a little marketing clever with
this and called it the outbreak ready stamp, which
might be a little too heightened efficacy for
everybody here, but whatever the icon or the logo
ended up being with this we thought it would be just
an easier way to preregister this and to go ahead and
have products carrying this logo and that the logo
with communicate the three tiers and the data would
already have been filed, it would already be there, it
would be there if we needed it, and if we didn't, it
just would sit there on the labels and add, you know,
to them. But it would be there other than that, when
we needed it.

We also think -- and you'11 see some
preventative things that we'd like you to do to expand
the policy to consider things that may not actually be
in -- on United States' soil yet. We continue to


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watch very closely the African swine fever virus and
have great concerns for what it might do to our swine
production in the United States, as it has done in
other countries. So there's a preparedness thing
there that farms want to do. I mean, they want to
know the disinfectant they already have is going to
deal with this virus. Now, it's in a different tier
than SARS is. SARS is in the easiest-to-kill tier,
but we think that can be done in a way that
communicates without causing hysteria or exaggeration
to the situation, but allows those -- that effective
use group to be able to get in the right product and
know that they're ready before it hits home. So we're
pushing on that as well.

We think, too, there might be an ability to
consolidate. EPA runs a number of lists like List N.

They've all been recently updated, but sometimes they
languish considerably. So we'd love to see maybe a
revisiting of those lists and do we really need a
special list for each one of these pathogens that
comes up, or at least for the viruses, do we just
need, you know, a number one list and number two list,
and a number three list, and whatever faces us in the
future, the agency communicates out to everyone, okay,
this is a green virus, pick out a green product, and


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look for your green logo, type of a thing.

So there was a lot of -- you know, we're all
kind of enamored with that idea because we felt it
solved so many different communication problems to
have it out there. And in many ways, we thought
really it already is a matter of public record. You
can go look up any product on the PPLS database and
see the 3 tier buckets of the EVP required label
language on the labels already. So we're just really
converting that into this icon thing and allowing it
to go on to the products. So we think we're really
close to that already and really urge you to look at
that as a way forward here.

Next slide.

So that brings me to sort of the next
question that we really we're looking at and it's
pretty broad as you can see it there on screen. And,
honestly, I think the workgroup took maybe half of a
meeting to debate what the question meant. And at
some point we started -- I even remember going well,
if they asked for this, is this what they mean, what's
the real question here? Luckily, we had two just
wonderful workgroup leaders, Taj ah and Komal, that
could poke us along when we got -- as Komal just did
to me -- when we got a little too deep in the trenches


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to move us along with this.

So next slide.

Here's what we came up with. So again, this
concept of other emergencies, where very rarely in
this industry, now, all of a sudden, based with only
one emergency at a time, and they come from lots of
different ways. And try as we might to define
emergency, we looked at a whole bunch of different
government emergencies and EPA definitions of
emergency and there just really wasn't one that we
could pick out to serve to you, but we think it
probably needs to be done. It was actually easier for
us to give you a list of examples of emergencies than
it was to come up with the definition.

So I mentioned many of them earlier, supply
chain disruptions, you know, maybe that's because
we're all at home working and there's not enough
people to make stuff. Maybe it's because our supply
is stuck in a container off the coast of the United
States; maybe it's because the main plant that creates
an ingredient froze in Texas and now we're not going
to have -- and all the pipes broke and now we're not
going to have that ingredient for some time; maybe
it's because of Ransomware, cybersecurity attacks. I
mean, just all manners of types of emergencies that


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could arise.

But what we really thought is that we could
push ourselves to come up with a framework of how we
would handle these emergencies no matter really what
they are and have templates and things pre-prepared
for expedited submission, and so maybe even example
templates so that your team's looking at the exact
same thing over and over again, not a bunch of things
that are sort of pulled together in that way.

So next slide, please.

So this is the list of documents that you
will see inside of our recommendations. We think
there is, inside of every one of these documents,
things that should be modified or edited to make this
process go better and faster next time. Some of them
are as simple as in the 810, we're very excited about
the interim ESS policy and residual policies, and
while we might want some changes inside of those
documents, we also want them pulled into the 810.

So some of these are very possible. You
know, with the 158w, which is a hard thing to ask to
change, but we really want to see virucidal claims be
disconnected from bacterial claims and be able to be
on other kinds of products as well. So again, there's
just a series of documents we've outlined for you and


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outlined a series of changes related to making this go
faster next time.

Next slide.

So the issues over here that we identified
under this charge question, again, it's somewhat of an
overlap. The EVP needs more flexibilities for
layered-on emergency, maybe layered-on other organisms
as well that are facing us. Some of the temporary
things that were done were just outstanding and worked
really, really well, and now some of those temporary
things are being off ramped and we really think we can
learn from how those temporary things worked and maybe
make them permanent. And so we'd really like to see
that and like to look at our limited resources, too,
and can we move things to more self-certification.

Did we just generate two days' worth of data that
supports that some of these things that have to wait
on an EPA review could be self-certified and go faster
and use less resources?

So again, other guidances, probably more
educational tools than guidances, and Alex is going to
talk about that a little more, that we think need to
be prepared. And Kaci's presentation just really
resonated with me yesterday about not only preparing
those documents because we already know what the three


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buckets of viruses are, let's get those documents
prepared. Let's get them honed to the point that they
do resonate with people.

And then whatever we can do to deal with the
resource strain on AD and make this go more smoothly
and sort of we'll game this up with our documents.

So the recommendation slide, and then I'll
turn it over to Alex.

So a whole series of recommendations coming
out of here to try and expand the EVP policy to allow
for different methods of application, like ESS, to
expand the EVP for these other types of consequences
of supply chain difficulty in that type and how that
might hamper our ability to respond to these public
health situations. We need to update the EVP for
variants and how are we going to handle variants. And
like I mentioned before, how are we going to handle
layers of EVPs going on at the same time with
different viruses.

We really would like to push ourselves to
look at the hierarchy of the viruses. Is it possible
that the bottom envelope virus hierarchy is so
tremendously easy to kill that we really don't need to
have a separate category for it? We can just say any
product with the word "disinfectant" on it achieves


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what is needed for an envelope virus, which tend to be
-- most often are emerging viruses.

And then we are also challenging you to look
at the opportunities to have bacteria, yeast, mold,
other type of microbes be included in this hierarchy.

Lack of diversity of products might seem odd
after I just said there's 14- or 16,000 products
registered, but it was very interesting to work with
the transport industry members of our workgroup and
find out that while we might be to a point today of
550 registered disinfectants that are on List N, there
still are only a couple that actually meet the
airlines special certifications for corrosivity and
other testing to be used in their airplanes. So while
we have, you know, a relative ton of products now,
there's only a couple that airplanes can use because
it damages the plane. So again, a finding through
this where we still have unmet needs in some of these
areas that, again, that's really maybe a charge to
industry. It reminds me of when EPA and USDA came to
us and asked us to have sprout treatments and create
them.

So let's see, some of these I've already
mentioned. Again, expanding some of the minor things
that were needed, CSF changes to add additional


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sources so that we could get product from more places,
or similar active ingredients and those type of
things, to move those into a non-notification or self-
certification space so we're not using precious agency
resources at a time where we need them elsewhere.

Special dispensation was given to testing so
that we could use non-GLP labs during this period of
time so that we get more labs doing the testing at one
time. We loved that. We believe it's worked very
well. We'd like to see that be maybe a part of the
document as well.

And then we think there at the end that EPA
should establish a crisis management office or team
that would roll into and maybe do modeling and
simulation games to make sure that they are ready to
be the one point of contact when these things are
going on and to be able to have the authority to
create tiger teams to look at -- you know, hopefully,
in the future, we're not in any paper processes
anymore -- but to look at those processes that need a
tiger team to look at really quick when we're finding
that they're bogging us down in the emergency.

So again, many more details on every one of
these in the report as to ideas on how to carry them
out.


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With that, I would be happy to turn it over
to Alex to take us through the last charge questions.

MR. COOK: Great. Thank you, Rhonda.

FACILITATOR: Alex, before you get started, I
hate to put additional -- this is Paul. I hate to put
additional pressure on you and Seth and Komal, but
we've got to bring this to a close in the next seven
to eight minutes in order to leave time for the Q&A
for PPDC and for the voting. So I --

MR. COOK: Understood.

FACILITATOR: -- am just going to encourage
your (inaudible).

MR. COOK: Very good. I'll pick up the pace.

So again, thank you to everyone for joining
us here. We've got a lot of exciting information.

My name is Alex Cook. I'm the chief engineer
for First Group America. First Group America is
comprised of a multitude of corporations in the
transportation business. We operate almost 50,000
school buses, own and operate. We also operate almost
16,000 transit buses. We do, for example, the City of
Houston, Texas. And then we maintain another 100,000
vehicles for different cities, be it ambulances,
emergency vehicles, police cars, across the nation.

I was very honored to be asked to be part of


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the workgroup. The amount of intellectual capital and
expertise and experience is just quite remarkable.

And I can't say enough to Komal and to Taj ah for help
leading us through all of this very intricate
information. So welcome and thank you.

Charge question 3, as you've heard that's
resonated from Rhonda moving forward, education,
understanding and communication, which walk hand in
hand, is a huge area for opportunity for us all the
way from what I term to be well to wheel to get all of
the information disseminated out to everyone that is
focusing on the problem. And so what can we do from
an educational standpoint during a pandemic or an
emergency now that we're talking about, what is termed
"an emergency" to the public and the end users and/or
regulatory authorities.

Next page, please.

There's a lot of information this slide. We
basically took a look, as a group, in our subpart B,
specialized challenges inherent to some industries,
and there's a lot of examples of this, but I'll give
you one just kind of near and dear, close to my
experience level.

We've looked at it in three buckets, pre,
during and post pandemic. And if you look at, for


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example, looking at transportation in general, we've
lumped that into ground transportation, into airline
and to cruise. If we look at one of the huge things,
as we heard Rhonda talk about, you know, with over
500-plus various products on List N right now, only a
very few small part of those are actually applicable
to the transportation industry, be it on the ground
side, even in the cruise, and specifically on the
airline side.

Behind the scenes, ourselves have had a lot
of communications with our other peers and industry
beyond the airlines and cruise and compared notes
behind the scenes. But one of the nuances that came
out of all those products that are on List N, as we
started to do testing, we found that very quickly
there was an incompatibility with those products on
List N from a standpoint of corrosive and
reactiveness.

So if you look at, just as one example in the
ground transportation, we're guided and governed by
the Department of Transportation for the United
States. There, for example, all of those are --
specifications are basically outlined in FMVSS
specifications. They're called federal motor vehicle
safety standards.


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And if we just take a look at two of those,
which is FMVSS 210 and 222, that calls out seat
anchorage and seatbelt strength. So what that means
is is that there's a standard that has to be met by
industry that basically for a seat anchorage and/or a
seatbelt that that assembly has to take a 20G
deceleration and still hold the occupant in the seat
and the seat has to stay attached to the floor.

As we started to do various testing on a lot
of these List N products -- and we did it in a
multitude of ways. We did coupon testing. We did
real-life application, all the way from wiping it on
to electrostatic spring of which there's a whole
multitude of applications in there. And then we
looked at those parent materials as to what was the
reactiveness and the corrosiveness. Much to our
chagrin, we found that a lot of those products were
very, very corrosive. And in the case of the example
that I'm talking about in seatbelt and seat anchorage
is we found a lot of very rapid degradation to those
subsystems, which effectively long term will have a
very negative impact on those materials and those
safety subsystems to be able to deliver for the life
of the vehicle.

That's in parallel with the Federal Air


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Administration who handles the airlines, obviously.

They have a whole other set of standards for aircraft
that have to have those same kind of safety standards.

And when we're dealing with materials that we' re
trying to analyze and deploy into the field to curb
and slow down COVID, one of the big nuances is the
incompatibility with what you're applying it to.

We came to the realization that a lot of
these products, which have been used elsewhere, be it
in the health care environment or food industry, have
been very successful, but where there's a lot of
differences in materials, be it a lot of stainless
steels, a lot of ceramics, so forth and so on. So
that was a huge watch-out for us if you will. And
then started to -- how do we start to communicate
that, how do we -- these various, because there's a
lot of variables in this equation, not only the
compatibility of the material at which you're applying
the said product to, but as well as the whole inherent
of how do you balance the product that you're putting
on that's going to be in contact with a lot of people
in a short time period.

You know, for the case -- an example of a
school bus, we have to disinfect up to potentially
five times a day. So what's the long term exposure of


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that product to the children that are riding those
school buses, looking at it from a standpoint of the
application of the product off of List N, all the way
from wiping it on with a microfiber towel to using a
garden sprayer, to using a fogger, to using an
electrostatic sprayer, and what are the inherent
nuances of applying a said product with those
different types of application and then what's the
potential consequences of those from a standpoint of
how PPE is utilized, what's the exposure, what's the
dwell time, how does the dwell time change from wiping
it on versus electrostatic flogging it, what's the
particle size, you know, the dynamics of the wetted
surface, and how long should you hold said application
methodology at the surface.

So there's a lot of variables in that
equation to reach success, and success is combating
the virus and curbing, obviously, the infection rate.

And so if you look at it from a pre, during and post,
there's a lot of crossover between those on things
that -- in one bucket of the pre versus the during
that still plagued us. And the key is here, again, as
Rhonda had alluded to education of this detail. The
devil is in the detail and how do we disseminate that
education and experience to all of those entities that


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are using these products for the greatest success as
possible.

Next slide, please.

So identified issue, we felt that there was
an ineffective messaging across several sectors, not
just transportation, health care, the food industry,
due to information and educational gaps. So if we
look at, again, well to wheel from the manufacturer to
the entity that's applying it and that all of the
constraints are met definitively for the highest level
of success and that there are no unintended
consequences to what you're applying it to, that
education and education -- or communication is
absolutely key and critical.

Next slide, please.

So we come into the recommendations and, you
know, this is bucketed into the three different
buckets here. If we look at information gathering,
because there are so many nuances out there from so
many different end users, the group felt that maybe
one way to get at this on a large scale would be to
conduct some surveys, be it on the airline side, the
health care side, the ground transportation side, and
conduct those surveys pre, during and post to gather
that information to start to build that great


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knowledge as to what needs to be disseminated to the
balance of everyone.

I do think that there's a collaboration
effort with the trade user groups, you know,
in our case it's the American Bus Association. There
are a whole host of other trade user groups by
industry that I think we can tap into to help glean
this information. So it's a two-way flow,
bidirectional. Not only do we glean the information
out of it through potential surveys, we're asking
questions or meeting, but we can also use those same
groups to collaborate with to disseminate the
information back out.

And when we look at communication
recommendations, a key thing is provide bilingual
messaging. So I think we heard that at our mid-year
meeting, that we make sure that we are able to access
that entire broad spectrum of users on making sure
that we talk on their level at all times, from a
standpoint of making sure that we drop all those
barriers so that it's crystal clear, again
bidirectionally, on what are the lessons learned and
how do we disseminate that and communicate that.

Provide specific messaging when required. As
we've seen with what we're living through today,


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which originally started out as, you know, heavy
emphasis on fomite transmission now starting to
migrate to airborne and a lot of focus being put on
airborne. As things change dynamically we need the
ability real-time to understand that, be able to clock
that, and then recommunicate that out to as many
people as possible.

Establish a dissemination process, a lot of
conversation around what's the best methodology and
mode of getting the message out there, be it through
webinar -- now that we're everybody's focused on
working from home and the technological advances that
we've seen here in the last year, year and a half to
be able to bring massive groups together virtually as
if we were in person to disseminate this. The
utilization of EPA website and specific easy ways to
navigate to get to this information that's been
gathered just as some examples.

And then continue to educate through every
phase of this. Again, because it's such a dynamic
situation and things are changing real-time, we all
need the ability to keep up with that pace and
continue to get that word out there real-time to the
best of our ability, because, again, that just means a
much higher level of success for us all in the fight.


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And then we looked at specialized messaging
for certain sectors. Again, engaging those trades and
those various groups, as you see there to the right,
be it air, cruise and/or ground or rail. And I think
they can help immensely bear some of the burden that
the agencies had to bear and we start to divest a
little bit of that to bring everyone, to the best of
our ability, into the fight.

Next slide, please.

So our response is to develop targeted
resources and references for general and specialized
messaging, back to my earlier comments on utilizing
those trade and industry groups, utilizing those
existing communication chains for that bidirectional
education and communication, utilizing that in a more
formalized way, and especially focusing on those key
sectors. And we need to do it at different stages of
the pandemic, or the emergency, as we're, you know,
potentially redefining it. And then, you know, gather
that all together in a very easily communicable
standpoint, and then use those outreach tools to get
those messages out there.

So I know that was a lot in a very short time
period. I'm trying to pick the pace up. Again, thank
you for all attending and we greatly appreciate this.


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It's been a true honor.

And with that, I will turn it over to Seth

Goldberg.

MR. GOLDBERG: Thanks, Alex.

Going ahead then to charge question 4, which
really addresses enforcement. And, you know, EPA did
a great job in OECA in enforcing against disreputable
kind of practices and products. A few numbers, 447,
you know, civil enforcement actions were brought in
Fiscal 2020; 60 criminal cases were brought in Fiscal
2020. A lot of product was stopped from entering the
United States at the ports. So impressive job. This
workgroup looked at areas for potential improvement.

Going to the next slide, the principal things
that we identified had to do with promptness and
comprehensiveness of enforcement. There was a sense
that, you know, enforcement lagged the practices that
were -- could lead to misrepresentations in the
marketplace by a significant period of time, and that
was really the principal topic or area that we felt
improvement might be made.

Going to the final slide in this set, the
recommendations really have to do with allowing more
prompt action the enforcement front. The suggestions
roughly -- and they are set forth on the slide -- are,


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first of all, to surge monitoring and enforcement
resources early in the process and perhaps have a
trigger at the same time an emerging pathogen event is
triggered to get the agency to be able to devote more
resources to enforcement. That includes resources
with EPA, as well as resources from other agencies,
perhaps including FTC, perhaps including the state
partners in the FIFRA enforcement process so that
there can be real-time monitoring of what's going on
in the workplace and prompt responses to violations or
perceived violations.

In addition, there should be a clear
communications plan that will allow both consumers
with questions and more responsible players in the
marketplace to be able to contact EPA in a way that
will directly refer questionable practices to
appropriate enforcement officials.

In addition, the communications plan really
should include the idea that EPA communicates to
players in the marketplace, that it will be taking an
aggressive enforcement approach, and if you cut
corners, you may be subject to even higher penalties
than you would be ordinarily because of the nature of
the public health emergency and the fact that
misleading people could have very serious


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consequences.

So that, very quickly, is the fourth charge
question which was focused on enforcement. And I
commend you to look at the slides for additional
detail. Thanks very much.

FACILITATOR: Maybe I'm missing it, but I
think you're still on mute.

MS. JAIN: Oh, sorry.

FACILITATOR: Okay.

MS. JAIN: Yep, all right. Thanks,
everybody. Thanks, Rhonda, Seth, and Alex. For those
that listened in, obviously, there was a lot of
passion and commitment associated with the work of
this workgroup. PPDC members, I do ask that you take
a look at the report, but I think, Paul, we have a few
minutes for questions.

FACILITATOR: Yes, we have to leave a couple
of minutes for the vote on passing the recommendations
on from PPDC to EPA. But it looks like Liza has made
a comment just before the end of the presentation, and
I would assume that's a comment as opposed to a
question. And then Lori Ann has a question. It's in
the chat. You can see it. It has to do with surface
transmission, surface-based transmission of COVID-19.

So maybe, Komal, you can read that question


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and direct it -- either answer it or direct it to the
right person.

MS. JAIN: Okay. So this is from Lori Ann
Burd. Back in the Fall of 2020, CDC announced that
COVID-19 transmission is primarily airborne and
clarified that statement in April to state that COVID-
19 transmission is extremely rare transmitted via
surfaces, but the vast majority of products for this
pandemic seemed to still be focused on surface.

Can the workgroup or EPA share ideas on how
to ensure that pathogen eradication efforts are based
on the current science to allow for efforts to be
appropriately focused on the correct transmission
routes? How do you think OPP should now address the
rarity of surface transmission and its approval
process and cost benefit analysis? We've heard from
many municipal water managers that they're seeing
concerning amounts of surface cleaning products show
up. So this is not a hypothetical problem, but rather
a real consequence of the continued focus on surface
cleaning.

Complicated, complicated answer. I'm going to
turn it over to other workgroup members that are
really in the area.

Seth, I see your hand come up. So maybe you


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can start us off.

MR. GOLDBERG: I could take a stab. Thanks.

You know, I think that EPA has followed the
CDC's approach here and has said that we are not going
to expedite approvals of surface products any longer,
and has shifted focus to air, to products that can
sanitize and kill the virus in the air. Having said
that, that's a significant, you know, R&D effort that
is being undertaken.

I think the workgroup's view is that we need
to be prepared to address whatever the next outbreak
is. The idea is to be able to be prepared and to
assist or facilitate having products available that
are appropriate to the threat. And so I did think
that there was some lag in shifting emphasis from
surface transmission to airborne, but that has
happened and is happening, and that in the future, we
can be more agile by adopting the recommendations from
this workgroup.

MS. JAIN: Thanks, Seth.

Any other workgroup members that want to

chime in?

MR. ARDUINO: Yeah, this is Matt Arduino from

CDC.

Fomites do still play a small role. So


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there's still some role that cleaning and disinfection
does play. You just don't have to go crazy, and not
like we've seen early in the outbreak where we've seen
people fumigating buildings and houses. You know, so
still where I do see cleaning, disinfection play a
role is frequently touched surfaces, especially like
in the home where you have an ill individual or in
health care settings where you're actually treating
actively infected patients. But for the general for
the general population, your routine cleaning and
procedures that you normally do is probably more than
sufficient.

But, you know, to -- with all the emphasis
that -- I don't think we need the current emphasis on,
you know -- that we've seen in the past on
disinfection because it's not as big a role as the
airborne route.

Does that help?

MS. JAIN: Matthew, thank you.

And, Lori Ann, I will note that both the EPA,
the CDC, and several trade associations have put out
education material on the difference between
disinfecting and cleaning, and when it was
appropriate, we followed the science. The key is
making sure that message gets out and that's something


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that's an ongoing effort.

Paul, are there any other questions or hands

raised?

FACILITATOR: I don't see hands raised, but
maybe I'll just ask Shannon and Sarah if they see any.

But I also see the comment there, I think it was a
follow up from Jasmine, Jasmine brown, stating a
concern, the exposure concerns associated with
airborne or aerial disinfectants.

MS. BROWN: Thank you, Paul. Jasmine Brown.

I do agree that the disease, you know, since that
survives in the air for six hours, it's highly air-
transmissible, so we do need to look at air products.

But I just hope that the EPA isn't over-gracious in
their reviews because pesticides in the air are
already a concern, and if we're going to be giving
that a huge push into the environment and into to
human health, I just hope that we're prepared for that
safety-wise. You know, that's my only comment.

FACILITATOR: Great. Thanks. I'm glad you
had a chance to make that point, Jasmine.

I think what I'm going to do now is take over
the mic, so to speak. I want to thank this workgroup
for the amazing work that was done and such a thorough
presentation. We've run out of time and we are -- so


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two things, PPDC members that have additional
comments, questions, concerns, feedback for this
group, the chat is still open. It's open all day. So
feel free -- it will be captured here. Feel free to
be entering your thoughts even over lunch, right, that
we're getting ready to break for.

In the meantime, much in the spirit of
yesterday, we are going to take a quick poll of the
PPDC members on what the -- in terms of hearing a
motion to accept the spirit of these recommendations
and pass those on to EPA, to OPP and EPA. So if we
hear a motion and a second that would be -- that would
get us started on the voting.

LIZA FLEESON TROSSBACH: This is Liza
Trossbach. I make a motion to accept the
recommendations.

FACILITATOR: Thank you, Liza. Is there a
second to that motion?

DR. GRYZWACZ: This is Joe. I'll second

that.

FACILITATOR: Thank you, Joe. I'll open it
to discussion the administrative process of voting
only. And we covered this pretty thoroughly
yesterday. I'm hoping we don't have to rehash that
again today. But if there's a burning issue


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associated with this vote, we did ask -- I'm sorry, we
did add a third option call abstain and the only
people who are voting that we'11 actually count the
votes will be PPDC members. Even though you'11 notice
that there'll be many, many abstentions probably or
non-votes, those will be the non-votes from everybody
other than the PPDC members.

So any questions about what we're getting
ready to vote on?

(No response.)

FACILITATOR: Hearing none, the vote is open.

DR. BASU: Hey —

FACILITATOR: Oh, go ahead. Who is that?

DR. BASU: Hey, Paul, Mano here. Sorry, I
was just trying to unmute myself.

So again, we discussed this yesterday a bit.

You know, it's okay in spirit, but all these working
groups have worked extensively hard over the period of
last year to come up with these recommendation. But,
you know, what happens with these recommendations, I
mean, all the work that we all have put together in
making these recommendation? I think it would really
help from a clarity perspective how the agency plans
to approach these recommendations, what happens to
these recommendations.


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What about the resources? I mean, we heard
about, you know, the strategic priorities 2022 to
2026, certainly, climate change, environmental
justice, and a lot of other priorities for the agency
overall. But then, you know, some of it will
certainly flow down to OPP. We also heard about
staffing and the number of registration requests,

PRIA, and everything where it is going up; the
challenges we heard with the AD staff working 24/7 for
the past several months over a year now. I mean, so
the question is, what will happen with these
recommendations?

I mean, is voting just an exercise? You
know, what does this voting get us? If it's just
recommendations given to EPA, then do we really need
to vote whether we agree or not? So I was just hoping
to get some clarification of what the plan is with
these recommendations.

FACILITATOR: That's a very reasonable
question, Mano. And I -- can I make a recommendation?

My guess is Ed may be chomping at the bit to jump in,
but I might even cut Ed off by just suggesting that
maybe in the 30-minute segment that Ed is chairing at
the end of the day, he can address that question to
the extent possible or -- for all the workgroups. So


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we don't take time away from this workgroup, or if we
have slack time at the -- at some other point in the
in the meeting. I'm sure EPA is actually thinking
about the same thing you're asking about, how are we
going to prioritize and allocate resources to
implementation of some or all of these recommendations
over what period of time, right? That would be what
would be going through the agency's -- any agency
receiving advice from a FACA would be thinking about
those things.

So I'm going to suggest that -- you've raised
the question and I'm going to kind of push it down the
field to a little later in the day, if that's okay.

DR. BASU: Okay.

FACILITATOR: Okay. So with that, thank you,

Mano.

And the vote is open and -- is that correct,

Sarah, the vote is open? You can select one of those
three options and you have to hit the button called
submit in the lower right-hand corner of that dialogue
box. So yes or no or abstain and then hit submit and
your vote will be recorded. And we'll give it a
minute or two.

I don't know how to count -- to see our vote
counts. I think Sarah probably does.


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FACILITATOR 2: Yes, we have about 32 people
who have voted so far.

FACILITATOR: Okay. And we have a 40-member
PPDC, so we're going to give it another 30 seconds in
case -- and if anybody feels like they're having
trouble voting, they can throw that in the chat, we
can resolve that later.

(Pause.)

FACILITATOR: Okay, so the poll has ended it
looks like, at least according to my screen. And what
did we end up with in terms of numbers of votes for
those three choices?

FACILITATOR 2: We ended up with 38 votes and
I can display those results in just a second.

FACILITATOR: Okay. Okay, very good. So
total of 39. We'll audit these later to make sure
that we didn't have non-PPDC members voting, but
that's the overall. So the recommendations are
advanced on the EPA as the result of this vote.

And then, at some point, EPA will describe to the PPDC
the process for addressing these recommendations.

Okay. With that, we're going to break for
lunch. Just like yesterday, we're going to suggest
that you do not leave the meeting, that you just go
ahead and go on mute. You click the mute button, you


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click the stop video button, you go about your
business for the next 30 minutes or so. We're going
to reconvene -- the meeting will start promptly at --
I hope I have this right -- 1:00 p.m. Eastern.

And if you want to log in a minute or two
early, that allows us to get started right on time
with the next workgroup presentation, which is
emerging agricultural technology. Okay?

Have a good break. See you in about a half-
hour. Thank you.

(Lunch break.)

FACILITATOR: Good afternoon, everyone. It's
1:00 sharp here on the East Coast of the U.S. And
let's give it another minute. Actually, I'm looking
at the participant list and we have a lot of people
obviously still logged in. So we're going to start
here in just about one minute.

MR. MESSINA: I'm here, Paul.

FACILITATOR: Oh, perfect. Okay.

And, Mano, I see -- your panel is there,

Mano.

DR. BASU: I'm here, Paul.

FACILITATOR: Perfect, okay. Just make sure
that that's the case. And also let me just check real
quick, just a quick roll call on your team. I see


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also that Nick Tindall is presenting. Nick, are
you --

MR. TINDALL: I'm here.

FACILITATOR: Excellent. And how about Dan

Martin?

MR. MARTIN: I'm here.

FACILITATOR: Great. And how about Greg

Watson?

MR. WATSON: Present and accounted for.
FACILITATOR: Wow, this team is ready to

roll.

And with that, I think -- you know, given
that, I think we're going to go ahead and jump right
into the kick-off of the afternoon session. And as
your slide in front of everybody sees, this is the
emerging agricultural technologies workgroup report-
out. The co-chairs of this workgroup are Mano Basu,
the Managing Director of Regulatory Policy at CropLife
America and, of course, Ed Messina, the Director of
the Office of Pesticide Programs at EPA.

So, Mano, I think I am showing you as kicking
off the presentation.

DR. BASU: That is correct. Thank you, Paul.
And I'll say next for the next slide, and I don't know
if you or Sarah is running the slide, if either of you


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can move, that would be great. I think all the
speakers that have agreed to present today will do the
same.

So again, good afternoon, everyone, and thank
you very much for the opportunity to present here on
the emerging technology. I just would like to thank
the agency, first, for putting this workgroup together
and all of the members of the workgroup who
contributed extensively over the past one year on the
charge questions and the deliberations that went on
about the emerging technologies, the opportunities
that we have, challenges, and what the path forward
is. It's just a full team effort that we present here
today in the extensive report. I hope you had a
chance to go through it, providing documents of what's
going on and what the future looks like with emerging
technology.

Again, thanks to Ed as a co-chair and helping
us guide through some of the charge questions. And,
you know, all the work that we have done.

We had represented --

MR. MESSINA: Hey, Mano?

DR. BASU: Sure, Ed.

MR. MESSINA: Yeah. And thanks -- also, you
know, honorable mention is Brian Satorius. I just


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wanted to say I'd like to spend a minute on that. He
was an Illinois farmer that's served on the workgroup.

Unfortunately, as are the hazards of agriculture, he
was killed in a grain bin accident on his farm, and he
left behind his lovely wife and two young kids. So I
just wanted to just state our sadness for this tragedy
and our hearts go out to the entire Illinois Farm
Bureau and that shared community, and we really thank
Brian for his service as well. So I just wanted to
acknowledge that we lost someone along the way and
take a moment to recognize Brian Satorius. Thanks,

Mano.

DR. BASU: No, thank you very much, Ed, for
reminding that he was an active member of the
workgroup, and it's just sad to get that news.

Thanks, Ed, for the reminder again.

So as I was saying, our workgroup
representation from various sections, we have
academics, we have members of companies that represent
some of these emerging technologies and are constantly
working on it. We had registrant members. We had
USDA participation. Again, Dan will talk about some
of the work on, you know, these emerging technologies,
and a lot of representation from trade associations as
well as we started looking into technology, what the


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role of these technologies should be, how can we look
into these technologies being accessible, affordable
to all communities and helping farming in general
as we deal with some of the challenges associated,
whether it's climate change or other future challenges
that we are looking at, and what these opportunities
are.

So it is my pleasure here to come in and work
with this group and present what this working group
has worked on for the past year.

Next slide, please.

So as we started working on the emerging
technology workgroup, we were given two charge
questions. First one for EPA to obtain a greater
understanding of these technologies and how does it
impact risk. One of the things as we started looking
into from a risk perspective, yes, there will be
certain technologies, which will certainly help in
reducing the risk of exposure or reducing the risk
from an overall load perspective. But could there be
newer risk, unknown risk, or an increased risk? So we
were taking a look from the charge question
perspective, how does these emerging technology impact
risk, things that we know, things that we don't know.

And then the second question around labels,


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this has come up in several working groups and, you
know, here we are in the emerging technology talking
about label, what the opportunities are on improving
the labels, on, you know, making sure that these
technologies are able to talk with the labels,
understand the labels, what needs to be accommodated.

So those are few areas that we looked into to
address the charge questions and it's been covered in
our report.

Next slide, please.

We met on a monthly basis, the working group.

We had agendas set and, again, my thanks to Shannon
Jewell for organizing all the meetings, getting the
agenda, getting the minutes out, making sure we had
all our external presenters available, and giving them
the opportunity to present on all the work that has
been done.

Just a week back, we finalized our report and
met for the last time to go over the presentation and
our plan of action presenting to the full PPDC.

Next slide, please.

We had some extremely interesting
presentations giving us an overview of what's going on
in the emerging technology work. You may recall Nick
Tindall did present earlier to the PPDC on what was


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happening from a technology and manufacturing
perspective. He shared the same presentation,
provided some more update to the emerging technology
workgroup. Then we had a presentation the CERSA work.

This is the Center for Excellence and Regulatory
Science for Agriculture based out of University of
North Carolina. We had registrants present on
technologies that were being developed on subsurface,
pest, soil, and microbiome detection, emerging
technologies, and then we also had presentation from
some of the emerging technology companies providing an
overview of what's going on.

Next slide, please.

So as we look into the charge question and
thinking about the deliverables, how can we best
address these charge questions, we said, okay, let's
take a look at overall emerging technologies that are
out there that we don't know today and maybe we can
come up with a list of such emerging technologies for
the agency. I mean, some of them may be in a pilot
phase, some of them may already been in use, and some
of them may be completely a concept.

So we thought of, as a deliverable for this
workgroup, coming up with that list of emerging
technologies, and as we developed the list, then


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thinking about the charge question what happens to
risk, increased risk, reduced risk, what kind of label
adjustments would be needed for some of these
technologies that we have captured. Again, as you
would all know, you know, this is certainly not the
exhaustive list of emerging technologies. You know,
more and more of these technologies are being
developed as we speak even today and more will come
later.

Then our second goal was to take a deep dive
on autonomous application platforms. These are
technologies that are coming in using data information
to say when to spray a pesticide, where to spray a
pesticide, how much to spray. And these technologies
could be applied whether it's a tractor-based sprayer
or a manned aircraft or a drone. Irrespective of the
platform, there's a lot of these autonomous
application platforms that are coming -- autonomous
application technologies that are coming up. And, you
know, there's a lot of data and number crunching that
is going on. So we wanted to take a deep dive on
those and look at some of those technologies and
specifically look at remotely operated application
platforms, like the drone.

Again, the same set of questions, what


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happens to the risk and what are the label changes
that are required.

So with that, I'll pass it on to my workgroup
colleague, Nick Tindall, to take us through our
deliverables on the list of technologies. Nick, over
to you.

MR. TINDALL: Great. Thank you, Mano.

If we could advance to the slide that starts
with hardware and data and analytics.

Again, I am with the Association of Equipment
Manufacturers, representing the off-road equipment
industry. So most of the things you see on a farm is
probably manufactured by one of our 1,000-plus member
companies. And when you think of emerging
technologies, of where we're going, you know, you
could broadly divide them up in between two
categories. We have, first, being hardware, and those
are the items that are easiest for people to wrap
their heads around because, you know, they're
physical, you could see them, and in many cases, you
know, such as nozzles, they've been around for a long
time and the technology continually gets better.

The other one, data and analytics, if you
want to sum it up even more into just one word, you
could say digital agriculture, and it mostly deals


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with the use of manipulation and utilization of data.

And this is a really exciting time in agriculture when
it comes to data. We estimate that in the next 100
years, we will see greater productivity gains from the
use of smart data than we saw in the last 100 years
because of mechanization. You know, just imagine, you
know, kind of wrap your head around that, the sort of
tremendous improvements we've seen with tractors and
combines and self-propelled sprayers, you know,
doing better than that just because of ones and
zeroes. And it really comes down to, you know,
prescription agriculture enabled through artificial
intelligence.

Today, the technology exists and it
increasingly gets closer to full scale commercial
implementation of treating every single plant in every
single field differently. You know, the average
Midwestern cornfield probably has somewhere around
33-, 34,000 seeds planted per acre, and, you know,
with this technology, we can tailor all those inputs,
fertilizer, you know, water, when it's an irrigated
system, and pesticides to ensure that individual plant
is treated uniquely to maximize its productivity.

It's truly incredible.

You know, as I've been saying for a while,


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the tractors are getting a lot smarter faster than
they're getting bigger. And, actually, outside of the
defense industry, there isn't a sector more
technologically intensive than American production
agriculture.

If we go to the next slide, you know,
focusing a minute here on the hardware side of things,

I first want to emphasize that most of the
technologies, you know, where we discussed in emerging
working group and that you're going to see out there
and that we hope EPA regulations are written in such a
way that fosters innovation, you're going to see them
retrofitted onto existing platforms. That's how, you
know, this technology will first be used in production
agriculture. And then the next stage will be, you
know, farmers purchasing a whole unit that encompasses
these technologies from the design floor all the way
to the end.

You know, autonomous systems, you know,
essentially if you've been inside a modern tractor
today, they're essentially already autonomous. They
just have the human in the cab as a fail safe and to
turn it around on the row ends, and then he just puts
the wheel back up into its sort of a way position and
can lean back and look at the monitors to make sure,


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you know, all the technology is working properly.

Spot farming, precision agriculture, you
know, that's an encompassing word for all sorts of
things that can be retrofitted onto existing systems
or software updates onto existing technology
platforms. Same thing with that's how you get to your
boom height control improvements, rate control and,
you know, mounting weather stations on your equipment
and having that feed into your digital platforms.

Ground-based robots, there's a lot of really
cool paradigm shifts that are going to happen when you
start seeing autonomous equipment from the ground up
being deployed. You know, the reason why tractors and
combines and sprayers have gotten so big is because
the most important piece of farm equipment, today and
tomorrow, is the farmer. And so if they're going to
spend 16 hours a day doing something, sitting in a
cab, you have to make that machine the most productive
piece of equipment as possible. And that has largely
meant getting bigger.

But when you go to robots and autonomous
vehicles, that paradigm shift is totally different.

You take away the cab. You start redesigning it
where, you know, human comfort for those 16 hours is
no longer a factor. And then also when a piece of


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equipment doesn't need an individual operator, it
doesn't need to be huge. And so instead of dealing
with a 50,000 pound tractor and soil compaction being
a big issue and limiting the amount of time, you know,
when can you get into a field after it rains because
the soil's got to be fairly dry, that's no longer a
factor. You could have a dozen 3,000-pound robots
doing that work continuously, and it just opens up a
whole new universe of the art of what is possible.

And, of course, you know, such really neat
technologies, such as manually weeding. You know, why
use a pesticide if a robot can just handpick it for
you. Same thing with bug vacuum robots. And, also,
you know, there are people out there working on
putting lasers on drone's heads to just zap -- I mean,
very -- you know, zap the insects instead of even
bothering to vacuum them up.

You know, these last two lines here of
autonomous tractors and autonomous ground sprayers
kind of encompasses sort of the unknown. You know,
what will be the economic model of autonomy? It is
undetermined. Will it be a bunch of autonomous
tractors that pull up to different various modular
systems, you know, pull-behind sprayers, planters, et
cetera, and und utilize those tools, you know,


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separately, at separate times, or will you have a
separate autonomous ground sprayer, you know, a
separate autonomous, you know, planter, all those
kinds of things. I mean, the future is unknown.

Some of my member manufacturers, they
envision autonomous tractors being larger and then
others envision the more swarm model where it's just a
whole bunch of little ones. You know, still to be
determined. So we need to make sure that the
regulatory framework allows the market and technology
determine where that goes.

You know, nozzles and spray nozzles of
course, have been around forever and they continually
get better and better. You know, same thing with
injection systems, stack systems, and targeted spray
technology. And what I want to emphasize here is
when, you know, developing label language, what's most
helpful is to -- you know, what are the performance
criteria you want the applicating system, the
applicator, to meet and the industry will design a
suite of tools to meet that and probably even do
better.

You know, the opposite direction, which we
try to avoid is when the label specifies a specific
spray nozzle. You know, it says the brand name and


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the model number. And the problem with that is then
it discourages innovation in that industry because
even if your nozzle meets or beats that standard that
that, you know, specific product from that specific
manufacturer achieves, you're frozen out of it.
because you're not that brand name and you're not that
part number.

Go on to the next slide, you know, where we
talk about what I consider to be the enabling
technologies. You know, precision agriculture, the
actual hardware you see means nothing without all of
these tools. If you don't have hyper-accurate GPS
systems that track exactly where you are in the field
to within the inch, and the sub-inch in many cases,
all those inputs and precision and artificial
intelligence and prescriptions don't mean anything.

Boundary mapping, you know, make sure that
we've cleared all buffer zones and producers that are
doing organic next field over aren't impacted by
conventional systems.

Smart guidance continually gets smarter.

Maintain constant speeds. When turning in a head row,
adjust the spray amount, because the outside sprayer
is moving a lot faster than the inside of the sprayer,
things of that nature.


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And, you know, one of my favorite things that
I'm really excited to see that it would be one of the
first things that's retrofitted on existing spring
platforms is targeted spraying or, you know, see-and-
treat applications, where artificially driven cameras
are going through the field and when they see a weed,
they spray the weed. When they don't see a weed, they
don't spray. Essentially the end of, you know, broad
cast application for many systems and in many
instances. I'm sure broad cast spraying will be
required in a lot of situations, but this will mean
when it's not, then it's not.

And so we expect see-and-treat applicating
technology to reduce pesticide use 80 to 90 percent,
and that's huge. And it also eliminates a lot of
concerns around weed resistance, because now when we
see a weed, we can make sure we kill it and hopefully
the label language will allow us to ensure we kill
that weed and we can avoid the need to develop new
chemistries for additional crop years because of weed
resistance, because when we saw a weed, we killed a
weed, and we're able to spray more on that week
because when we go to another 20 feet down where there
are no weeds, we're not spraying anything. The
application is zero.


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And, lastly, on board weather stations, it's
going to just be even better when you're dealing with
micro-climates. We all know that temperature, wind
play dramatic into drift when spraying and, you know,
it's hard to take a constant count of what is the
temperature between an hour as the sun continues to
rise, between when you started and where you are at
the moment, did the wind speed change, and the wind
can be different one end of the field than the other
based on trees and hills and all kinds of varieties
when you're dealing with a 40-acre plot.

Now with on board weather stations, the
equipment can make those real-time adjustments on a
foot-by-foot basis practically. You know, so that --
we can go to the next slide.

I'll hand it back to you, Mano, to tee up the
next speaker.

DR. BASU: Dan, go ahead.

MR. MARTIN: All right, thank you. My name
is Dan Martin. I'm a research engineer with USDA.

And I'm going to be talking about some of these
technologies, primarily some of the autonomous drone
technologies. And so one of the first platforms we
have here is these unmanned aerial vehicles or
unpiloted aerial vehicles. I don't really like the


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term "unpiloted" because they have a pilot, the pilot
is just typically on the ground. But what they allow
-- then there's really two uses for these types of
platforms. One is to collect remote sensing data for
a certain field. So typically, those types of drones
will have a camera mounted on board or special sensors
and then they're collecting data -- specific data
about a particular field or site.

And then in addition to that, some of the
pictures that you see here on this slide are spray
drones. And in the one upper left-hand corner, that
actually has a spreader on it and that is applying
actually a granular insecticide with that one, but it
could just as well apply fertilizer or seed for cover
crops. So these systems apply some type of material,
either dry or liquid, and they have nozzles,
they have booms, they have pumps, they have a hopper,

GPS, as Nick was talking about. Almost all the units
that are used for now in agriculture have GPS because
it's so essential. So these are used for applying
different types of materials.

Next slide, please.

So some of the emerging technology that we
have with drones, we're looking at increased digital
solutions and some of these are satellite-driven


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technology, big data analytics, autonomous vehicles,

AI, artificial intelligence, and these are all helping
farmers to make better, more informed and more
efficient crop-growing decisions.

Drones are a really important component of
this precision agriculture and have the potential to
assist with achieving these sustainable agricultural
goals. So these drones have been used in Asia for
many, many years, but just recently in the U.S. have
they been allowed to be a part of our system here,
especially for agriculture.

The precision ag sector has responded to this
increased demand now there's a lot of manufacturers
that are producing drones that are available to users
here in the U.S.

The need to produce significantly more food
and feed while using fewer pesticides, coupled with
harvest losses and shrinking agricultural land, has
accelerated this agricultural innovation in the drone
realm. So it's both -- for both uses, both for remote
sensing and then for pesticide application or granular
application.

And drones are garnering worldwide interest
as an application technique for pesticides. We just
held what we call an RPAAS workshop, remotely piloted


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aerial application system workshop, a couple of weeks
ago, and we had over 175 from all over the world that
were in attendance at the workshop. So there's a huge
amount of interest in this technology, and it will
just grow from here forward.

Next slide, please.

So some of the methodology for the remote
sensing use of drones, there's a lot of technical
detail in here, but basically there's a sensor on
board for a lot of this remote sensing and it's --
typically high resolution is what you want, but it's
not always required depending on what the application
is. So you have it in the red, the green, the blue,
or you'll hear RGB, or VIS, which is the visible
spectrum.

Then you have in the upper regions, the near-
infrared regions also give you additional data that
can help with vegetative indices. You might have
heard of NDVI. Well, that's one very popular
vegetation index, but there's many more. And so the
visible spectrum is in that 400 to 7 00 nanometer range
and then the infrared is up in the 750 to 1,400 range.

So a lot of these sensors have multispectral
or hyperspectral sensors. A lot of NDVI just requires
three or four band. So that's more of your


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multispectral. Hyperspectral is 1,000 or more bands
that can be used with some of these sensors. And
sometimes you need those extra bands, but a lot of
what's done can actually be done with just the three
or four bands that are very common with the
multispectral sensors.

In addition, there's thermal sensors, which
detect infrared radiation in the long wavelength
region from 7,700 to 13,000 nanometers, way up there.

May be used to measure temperature and plant canopies
and other objects. What this really is used for is
detecting stress. Okay. So plant temperature -- as
the temperature of a plant increases, it just means
it's stressed. And there's many reasons for that.

Drought may be one of those, but it could be insect
pressure or weed pressure, other things that are
causing stress on that plant, even nematodes probably.

But those are what thermal sensors are used for.

And then LIDAR sensors, those emit their own
light in the form of a laser beam and they can measure
the time that the light is reflected at the surface
and the return to the center. It's just a -- it's
another way of getting measurements for canopy. And
so if you're looking at plant height over a field, you
can map that out with LIDAR. Typographical data is


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what it measures. And so if you're looking at
specifically -- like, for instance, if you have cotton
and you're looking at putting on a plant growth
regulator and the cotton is of different heights, the
really short cotton would not need any plant growth
regulator, right? But the very lush cotton that's
very tall, that would probably need your higher rate
plant regulator. But see, that's how we can vary the
application rate during the -- in the field and limit
the amount of environmental loading that we have for
some of these agricultural production products. So
using technologies like this to map out what the needs
are of the field and then using that for site specific
variable rate applications is very important.

Next slide, please.

So some of the other use cases for using
drones and some of the sensors that are attached to
them, one is estimating soil and field conditions. So
detecting soil erosion, drainage, salinity, acidity,
nutrient deficiencies, wide nutrient loss after
floods, monitoring drainage and fertility. These are
all things that we can use these platforms for.

Seedling emergency, so if you have really
high resolution mapping, you can identify where the
planting has occurred and where some of the seedlings


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have not emerged, and then you can use that data to
determine whether or not you need to replant in
certain areas of the field, whether that would be
economically viable or not.

Crop monitoring, so you can use it for real-
time assessment of vegetative stage, biomass and then,
ultimately, how much yield could be predicted from
that crop in the field. You can optimize
fertilization. You can use it for assessment of
damage resulting from storms, farm equipment, or
malicious intrusion. And also you can use it for
evaluation of different hybrids -- this would be on
the research side -- and cultivars for experimental
plantings.

Next slide.

Some additional use cases, for crop health
assessment. So you can monitor insect infestations,
whether they be bacterial, viral, or fungal diseases.

You can use them for designing precise pesticide
applications. This would be site-specific
applications, which can reduce -- well, the
application rate is whatever is on the label, but you
can cover just the area that's needed based on some of
these maps that are created. And you can help
minimize the amount of pesticides used. So one of


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these cases would be for spot spraying. And this is
where it could be complementary to some of the
existing conventional manned aerial applications.

So an aerial application could be made with the a
manned aircraft for broadcast application. A couple
of weeks later, you go in and you map that area for
where these existing weeds, maybe they're herbicide-
resistant weeds, or maybe they were just skipped, and
then that map can be used to load into a spray drone
and then go spray just those areas that need it.

And a lot of times, as Nick was talking
about, this could be just 5 or 10 percent of the
field. Instead of spreading the whole 100 acres,
maybe you're only treating 5 to 10 acres of that,
along with the associated chemicals that are needed
for that and the costs associated with those chemicals
as well.

It can be used for water management.

Efficiently monitoring water stress in crops on a
timely basis and then over large areas. The data
generated from this can be used to fine-tune
irrigation systems to optimize water delivery.

Remember we were talking about stress. So if you're
dealing in thermal area, you can tell where the plants
are still drought-stressed. You can increase the


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supply to areas that are under stress while avoiding
unnecessary oversupply in other areas. And it can
also tell you where nozzles may be leaking on your
irrigation system, and then you can go in and fix
those areas so that it doesn't use any more water than
it has to.

And then for weed detection, as we talked a
little bit earlier, its multispectral and
hyperspectral sensors can be used for detecting where
weeds are not only just in a fallow field, but, now,
with artificial intelligence and machine vision, we
can identify where weeds are within an existing crop,
whether it may be rice, cotton, even turf, say, for
golf courses and such. So this is very important to
be able to detect and look at the unique signatures of
specific weeds within existing crops.

And then for livestock monitoring, you can
use these trends for real-time surveillance for
location, the number, the behavior of the livestock,
and confirming the adequacy of the pasture and
fencing, gates, water supply, feed troughs, et cetera.

Next slide, please.

And then specifically for pesticide
applications, there may be areas that for manned
applications it's either dangerous or just really hard


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to get to, and then for ground application as well, if
a field is muddy after a rain, it would be either
impossible or just not wise to send ground vehicles in
to treat those areas. So if you have these types of
areas that have physical impediments, such as power
lines, uneven typography, drones offer a very
complementary approach to existing conventional
technologies for plant protection, such as your manned
aerial and your ground applications.

As we talked about a little earlier, this
technology has been used in Asia for many, many years,
and just recently approved in Europe for specific
applications in vineyards and orchards.

But there is a data gap between the drone
technology, specifically on the spray drone
technology, and then the existing conventional
application technology. Although they're very similar
in many aspects -- matter of fact, we use in drones --
with drones, we use ground nozzles because of the
speed. We're always under 20 miles an hour right now
and so we can just use ground novels for that. So
those are well established. And there's many
similarities, so that droplet spectrum is going to be
the same, too.

Now, the interaction between the rotor wash


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from the props and the spray is something that still
needs to be investigated there. There's a lot that we
don't know. So there's many variables that need
further understanding for these drone-based pesticide
applications.

And then many of the above technologies are
not limited to unmanned systems. They're used for the
ground and the manned aerial application as well. So
there's a lot of increased interest in the spray drone
-- not only spray drone technology, but drone
technology for remote sensing as well. And these need
to be explored further, looking at the differences
between these and some of the existing application
technologies that have been working very well for
many, many years.

So there's several different groups that are
working on better understanding these technologies.

And that's the OECD, the Drone Sub-workgroup, RPAAS,
as we mentioned a little earlier that workshop held
every year, and then the UAV Task Force, CropLife
American has a drones working group, and then we
continue working and presenting this at CERSA.

So there's many different groups that are
working to better understand these technologies and
how they fit into the current plant protection


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structure within American agriculture.

Next slide, please.

And then, finally, we're looking at some of
the benefits and challenges with these technologies.

Clearly, you know, especially if -- for replacing
backpack sprayers, people that are actually in the
field next to where the application is taking place,
drones can come in and reduce work exposure to these
pesticides and save a lot of time and labor in these
areas where hand application is normally used.

There's an opportunity to use this technology in
tough, difficult, and even dangerous situations where
traditional application methods may not be feasible or
present additional hazards.

I know there are certain areas in Hawaii
where they have guys repelling off of cliffs to spray
invasive species, and this would be perfect for going
in there and making that a lot safer.

And then there's potential to reduce
environmental loading of pesticides, specifically as
we're talking about doing spot spraying or site-
specific spray applications, and then depending on the
equipment type, there may be a resulting reduced fuel
use or emissions. Most all the drones right now are
battery-powered and the cost to entry is also lower


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with drones. Typically, it's in the $20- to $40- to
$50,000 range. And so it may be a little bit more
affordable for somebody to come in with that type of
system compared to some of the conventional systems.

So then some of the challenges, it needs to
be noted that, you know, we don't know a lot about
these systems. It's at a very early stage in the
United States. And so, you know, we need to be
careful not to overstate the benefits in the
development and rollout, but that also means we need
to be able to quantify those benefits as these
technologies evolve. And they're evolving very
quickly. Every year, there's new technology
incorporated that are making these systems better.

And then, of course, the safety,
implementation and regulatory compliance aspects of
this, there's a lot of data gaps that are out there
because it's such a new technology for us. You know,
what is the offsite movement that may impact the
applicators, bystanders, wildlife? That may be
different than the conditional application techniques
that are used. And are these differences in the
applications that may impact pesticide efficacy or
tolerances or perhaps even result in crop injury? And
what application training will be required and who


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will who certify? And then, additionally, at the very
end is, you know, what label language needs to be
changed or does the label need to be changed at all?

It is a different technology and it's a
different platform with its own unique benefits and
challenges, and so we need to better understand those
in order to make these important decisions.

And with that, I'll turn it over Greg Watson,
who will do the wrap-up. Greg?

MR. WATSON: Thanks, Dan. And I guess since
the World Series has started, I get the closer role.

But I appreciate the opportunity to try to bring this
home. While I won't repeat a lot of what has been
said today, I certainly would ask PPDC to, again,
reference the report that was written. I actually
think that's a very good job of capturing the detail
of what we talked about. I do want to highlight some
overarching things, particularly in the conclusions,
the next steps, and some of the recommendations.

So the first overarching conclusion I think
we would come to is that, as you've heard in the
presentation today, emerging tech is moving into the
agricultural space and its adoption will continue to
grow. It's not different than our own lives. We all
carry around these large computers. We have devices


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in our homes that allow us to do things that, you
know, five years were not possible. So the internet
of things and the digitalization of our economy is
going to be a driver in agriculture. So I think
that that's a clear take-home.

I think we also can't ignore the impact on
the non-ag sector, particularly in vector and mosquito
control, and not only enabling access to dangerous
terrain or difficult application conditions, you can
also see the advantages of being able to have precise
applications because -- near population centers.

I think the challenge of, again, going back
to, as Dan just talked about, the potential benefits,
is the challenge for industry growers and users is to
ensure that these emerging technologies are actually
making improvements in the sustainability of our
culture and helping to really drive what, you know, ag
and non-ag uses of pesticides are really about, again
feeding the population and providing abundant and safe
food supply, and then protecting human health.

I think another broad theme to emphasize --
and EPA is actually to be commended here, I believe,
not just for the formation of our emerging tech
workgroup, but they -- OPP has been involved with
stakeholders already, particularly outside of their


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normal space, and I think that's going to be, you
know, incredibly important because that's the only way
that you're able to get some sense of what is actually
coming into the regulatory framework within the
agency.

And as you've heard Dan talk about and
others, there is an absolute need for the agency to
continually review and update its approach on how it
looks at pesticide risk and the risk assessment
process. And I think that, again, is a space where we
would believe that continued work needs to be done.

Next slide, please.

So again, going with a broad themed aspect of
this, one of the things we've tried to say in the
report is that there's incredible opportunity here.

And the agency instead of trying to look at the
mindset, oh, this is just another thing I have to do,
another problem I have to solve, coming at it with an
attitude that this is an opportunity for change that
could be reinvigorating to the program. And the
adoption of a digital mindset, given all the
digitalization that's happening not just in the
practice of agriculture, but in the systems we use to
talk, manage date, and inform ourselves as we try to
make right decisions.


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So I think there's a clear opportunity here.

We encourage the agency to embrace that and, again,
look at look at it through the eyes that it is an
opportunity.

Again, as Mano said earlier, labels are
always a question, but I think one of the things that
we see a benefit for is looking at can standard
language, and not just for the current application
methods, but their emerging technology ones, get
better. And is there a process by which you could
more efficiently update those as you learn more and to
try to not think about this being a paper world
anymore. I'm firmly convinced that we're not far away
from the label not being a piece of paper on a
container. It's going to be a QR code, and you're
going to pick it and read it by using your phone. I
don't know about you, but any time I go to restaurant
now, that's how I get a menu. So I think we have to
think about what those changes bring.

And, similarly, the risk assessment approach,
particularly operator and applicator exposure, dietary
exposure, how environmental assessments and -- how the
models and the standard practices that EPA utilizes in
risk assessment, including offsite movement, need to
be adopted and changed to account for these


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technologies as we've talked about. And there is also
really a need for the agency to help prioritize how
they signal that additional information and data is
needed and, again, particularly in the risk assessment
areas.

Again, the winners in the emerging tech space
really haven't been declared, so that's -- we, in
industry, we try to have a foresight to be able to
get there in terms of these -- you know, what, again,
information data might be there, but EPA certainly, I
think, has a role in there as a regulator and it's not
just frankly in the U. S., but their voice in the
international forums, like OECD, is important and it
will be increasingly important.

And finally, again, we just can't emphasize
enough the continuing engagement with the external
stakeholder community. And, again, we feel that the
agency has done a very good job here and would need to
continue in that stead.

Next and final slide, please.

So hopefully, we presented you a picture that
we've worked hard as a workgroup to put together the
picture and answer some of the first charge questions
we were given. We think there's more work that this
emerging tech workgroup could and should do. So we're


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recommending to the PPDC that the workgroup stay
together for one additional year. But we'd like to
provide some suggested changes to the charge questions
that would be in front of us.

We think our current membership is
satisfactory. We've got players from, again, across
the stakeholder spectrum. And certainly we're open
and have been open, as we began work, to expand
membership to address specific questions or gain
expertise where it actually was not resonant within
our membership. So I think we certainly would -- we'd
continue that.

And in terms of potential revised charge
questions, one of the first ones that we still have to
answer, we believe, is in the environmental justice
area and certainly that is this current

administration, and as Ed spoke in his overview of the
OPP, a clear priority for the agency, and that is, is
there information availability and affordability of
emerging technologies for all communities. And Dan
talked about that a little bit, but I believe that
there's information there that we could leverage and
highlight to sort of indicate where emerging tech is
going in that regard.

There's clearly still a need to think about


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process. While we, as a workgroup, recognized that
adapting the risk assessment practice and the standard
operating procedures underlying that, they, in some
ways, have -- or sometimes have not kept up with even
existing technology and certainly manned aerial
aircraft offsite movement has been one of the places
that has been mentioned and not just in our workshop,
but in other forums.

So I think the -- again, how do we get for
prioritization and feedback from EPA? What's that
process for additional information and data when that
is needed? And again, establishing a process that is
efficient for updating the label language to, again,
allow, again, spot application or how would you link
that to a recommendation that would be based on
machine learning, for example. So I think there's
some opportunity for thinking about what the process
like that should look like.

And finally, to return back something that,
again, I think is very important and it's about the
digital mindset towards the program and its staff.

Again, and embracing this as an opportunity. And I
think to be able to start thinking about that, as it
fits in some of the other programs that the agency's
starting in this space, is there something in the


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label process that we could use to kick off that
hopefully would be an option or that kind of mindset.

So with that, again, I thank you for the
opportunity to be a closer. I will never say that I
Mariano Rivera, but hopefully I served the workgroup's
goal on that.

Ed, since you were such an important member
of the group, I'd ask if you have anything to add.

MR. MESSINA: No, I'm just really, really
impressed with the having seen firsthand the level of
effort that this group undertook under Mano's
leadership. If you've had a chance to look at the
report itself., it is pretty in-depth and expands on
even the slides that are here. So I'm hopeful and I'm
glad the group wants to continue.

And I'm pausing because I feel like I want
the agency to be able to answer some of these
questions, right? I'm sort of in that mode now where
I'm like, okay, let's get rolling, let's encourage
this, let's get the science in, let's start making
some decisions on labels, you know, and that -- I'm
still maintaining my patience from EPA's standpoint,
and so all of the outside advice is really, really
helpful and I think it's really starting to become
obvious that, you know, EPA needs to take a laboring


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oar on encouraging these technologies, and I'm also
really, really pleased with the continued
collaboration that's been happening, as you mentioned
and as the other folks mentioned.

There are many conversations happening across
the entire world around this, in this really exciting
space that could have just incredible impacts for
farmers and growers and everyone. So it's just an
exciting topic to be part of. So thanks for your
efforts.

DR. BASU: Thank you very much for your
support, Ed. You know, hopefully, if the workgroup is
there next year, we look forward to answering some of
the other questions going forward.

I'm happy to answer any questions from the
full PPDC.

FACILITATOR: Thank you, Mano. Thanks, team.

And the floor is open. I did notice -- I'm trying to
keep track of the chat here, and I think that Cathy
Tortorici from NOAA has put a question in the chat.

Maybe you all can see that. It says, what are the
technologies that reduce pesticide loadings that are
close to coming online?

MS. JEWELL: Paul, let me interject really
quick. This is Shannon. And maybe others can nod if


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this is true. Your audio is a little bit low for me.
It's not terrible, but I really have to listen hard to
hear you right now. Are others experiencing that as
well?

MR. MESSINA: That last comment was a little
low for me, Shannon, as well, from Paul.

MS. JEWELL: Okay, thanks.

FACILITATOR: Okay. I am sorry about that.
I'm not sure what happened. Has that been consistent
all the way through the last day or so?

MR. MESSINA: No, it was just that last
comment, Paul.

FACILITATOR: Okay.

MR. MESSINA: For me.

FACILITATOR: I would direct your attention
to Cathy's comment and maybe someone on the team wants
to take that on.

DR. BASU: Damon, go ahead.

MR. WATSON: I can't see the comment. Was it
which one the technologies is closest to the market?

MR. MESSINA: Yeah, that one —

MR. REABE: I actually wanted to take
a crack at this. I think it really falls into the
scope of what the workgroup is working on and it's the
difficult question that is -- you know, as Ed


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mentioned is testing his patience, and I can
understand that. And I think it has a lot to do with
just the framework of -- specifically of risk
assessment. And so Cathy's question talking about
technologies that reduce loadings that are coming
online, these technologies that reduce environmental
loading, affect drinking water, these adverse effects
from these pesticide applications, those technologies,
many of them are 30, 40-plus years old that are still
not quite being accounted for in the risk assessment
process. Simple nozzle selections for making
different droplet sizes.

And these are -- EPA's not doing this in a
vacuum of information. The EPA, as I understand it,
is doing this based on the premise of worst case
scenario. And I think what's happened, in my opinion,
in agriculture, in particular, the industry has
matured to a place where these technologies have been
brought forth due to the industry's interest in being
stewards.

And so I think it's really critical while
-- and it's happening -- but while this work is being
done, to overhaul risk assessment processes to enable
technologies that have improved effects on our
environment and society as a whole that we quickly,


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meaning industry and EPA, work together to make sure
that risk assessments are done accurately, accounting
for all of the existing technologies and kind of get
past this risk assessing based on the worst players
and simply enforce the label language so that those
players aren't allowed to operate.

And my hat's off to the EPA, they're working
closely with the NAAA, but much of what we're working
on is literally decades old conversations. Wind
directional buffers, you know, specific droplet size,
effective boom length, all of these things -- and,
again, it's not to disparage the EPA. There's
processes in place that have to be transparent and
science-based and it's not just take our word for it,
but it has -- I think the EPA has to become far more
nimble in accounting for those existing factors.

UNIDENTIFIED MALE: And to kind of play off
that and to looking forward, you know, we can see
tremendous additional gain from the increased adoption
of existing technologies, such as variable rate,
section control of sprayer nozzles. You know, current
adoption rates of those technologies have resulted in
30 million fewer pounds of pesticides used, but still
the adoption rate of a lot of those technologies for a
lot of crops is 20 percent-ish. But then looking


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forward to technologies that aren't widely available
on the market today, I would say the see-and-treat
where the machine is only spraying where it sees the
weed is something you'11 see in a couple of model
years.

UNIDENTIFIED MALE: Yeah, and I would just
come over the top as to Damon's -- you know, to
(inaudible) Damon's comment and what (inaudible) said
see and treat has certainly been in a research phase,
but it's right at the edge of implementation in a full
way. And again, in many cases, it's agnostic of the
equipment, whether it be ground, manned aerial or
unpersoned or unmanned aerial. So I think that
certainly is in play.

And there are multiple offers in the
agricultural space to couple those with digital ag
offers. So for example, advice that would provide
prescriptions or treatments that might be (inaudible)
or broadcast, depending on the situation. Again,
linking all that information together from scouting
platforms and being able to allow the grower to follow
that all the way down to a yield monitor. Those kinds
of systems and support are out there.

And again, in the non-ag space, that's also
important because being able to know where you


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sprayed and documenting that digitally from connection
to GPS coordinates, that is there. So I think, you
know, we are -- again, why winners in lot of space
haven't been declared, we are at the space where there
is adoption rates starting.

DR. BASU: Yeah, Greg, just to add do a Damon
said and what you said, you know, certainly,
yes, there are quite a few technologies which have
been in the marketplace, reducing environmental load
and whatnot. Going forward see-and-treat is a great
example, but from a risk assessment point of view,
if the approach is taking the worst case scenario,
then presume, I mean, under these circumstances, a
scenario where you are having see-and-treat a 40-acre
farm, your worst case scenario is the entire 40-acre
field is full of weed. So are you now doing risk
assessment for the entire 40-acre, a full load, or is
it see-and-treat.

So how does these technology gap -- bridge
the gap between the advancement in technology, the
reduction in environment load to the risk assessment?

I think that's where the agency has to be nimble and
figure out mechanisms to incorporate the benefits of
these see-and-treat kind of technology and other
technology which reduce pesticide load overall into


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the risk assessment process.

So again, I don't know what it looks like,
what the new worst case scenario would be for these
technologies and how we can incorporate technologies
that are coming out or technologies that are already
in the marketplace.

MS. TORTORICI: This is Cathy. I hope you
all can hear me. I just want to make a quick comment
on what you all are saying. The reason I asked this
question is because as we're working with EPA on
consultations under Section 7 of the ESA, we're
looking for a couple of things, you know, two big
things.

How can what you all are describing, to the
extent that it's appropriate and practicable, be
incorporated into the biological evaluations that EPA
is working on to bring these kind of technologies to
the forefront in talking about effects that they're
that they're analyzing to listed species? So that's
one piece of it.

The second piece is how industry is bringing
these technologies and the use of them to EPA at the
beginning of the FIFRA process, as well as to us when
we're talking about mitigation options. You see where
I'm at? So the more information that we have on the


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benefits of these technologies, and I -- you know, I
understand what Damon is saying. For a number of
these, you know, these have been around for a while.

So we've known about some of them for sure. Others
are newer. To the extent that we can understand their
application, the applicability of them and the
effectiveness of them, then it's easier for us to
incorporate that into the process that we're using
with EPA from a consultation standpoint.

I'm very excited about this presentation.

There's a lot going on. I mean, it's -- I want to
give complete credit to the people that worked so hard
on this because it's a massive list of stuff that has
potential. It's just I want to be able to figure out
or work with you all to figure out how we bring it to
the forefront a bit more in terms of the processes
that we're using from the consultation standpoint.

And I know that wasn't one of your charge
questions. I'm just thinking about your information
through that lens. Thanks.

DR. BASU: Thank you, Cathy.

MR. MESSINA: Yeah, this is Ed. I'll respond
to that. I mean, so both things are true and one is
what Damon mentioned, which is we have existing
methodologies and risk assessments that we can use and


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drift modeling that we need to update to address some
of those -- that risk analysis. The other thing
that's true is these are somewhat entirely new
technologies with different weights and different fan
rotors and so they are this sort of entirely new
thing. And so the key for me is -- and that's -- I
think a lot of what the workgroup is focused on is,
how do you bridge this new technology and fit it into
our existing frameworks, right?

And that's one of the many questions, but I
think it's kind of a salient question that the group
was sort of struggling with, and which is why I'm
acknowledging my impatience, but I get it, right? I
mean, it's not like we can flip a switch and tomorrow
all of our risk assessments and all of our protocols
and all the test methodologies are sort of updated by
Friday and we're good to go on Monday. It's a longer
term process.

FACILITATOR: Thank you, Ed.

Damon, did you want to jump in with a

followup?

MR. REABE: Yeah, and this would be just to
respond to your comment, Cathy, and your question.

I'll just provide an example. We're working on -- the
National Ag Aviation Association is working with EPA


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on inputs used during risk assessment, on
approximately six of those inputs. We've come to the
EPA with that worst case scenario mindset as part of
the process, and simply by updating these inputs to
modern best management practices and equipment, we are
reducing drift by 43 percent versus the existing tier
one modeling that's using -- now, not to get off in
the weeds on aerial application, we can get far more
prescriptive on pesticide labels beyond the 43
percent, where we can start to see numbers that exceed
80 percent reductions in drift by more prescriptive
labeling with existing technologies.

I'm bring this as an example not to be self-
serving for the current manned aerial application
equipment. I think there are stories like this on
ground sprayers as well. I think shielded ground
sprayers have that technology. It is not necessarily
accounted for on current agricultural pesticide
labels. But with all these new technologies being
presented to us, many of which can get mounted on the
aircraft that is piloted by an individual, it's an
overarching requirement for extreme amounts of nimble
work on the EPA's behalf to very quickly adopt the
benefits of these technologies accurately in the risk
assessment process. That encourages the adoption.


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The reason why the adoption rate for a lot of this
technology is so low is because you're left with the
limitations on the label, that is the law, which is
all based on the worst case scenario.

So it's kind of a chicken and an egg story in
my mind. The sooner the EPA goes to industry with
draft label language or works together with them, the
sooner we can see adoption of that type of technology
whether it be unmanned aircraft systems, autonomous
spray systems on existing platforms. Whatever those
things are that are being worked on, we can really
move the needle here, I think, in a pretty dramatic
way.

MR. MESSINA: Yeah, thanks, Damon. My
reaction to that is -- and I'll put this request out
there again -- OPP is very good at dealing with the
issues it has in front of it in kind of real case
examples. We're very good at the PRIA analysis, we're
very good at registration review and incorporating
ESA. We're very good when we have something in front
of us to kind of chew on and run through the paces.

So similarly, if there's a registrant or, you
know, a grower or academics that are interested in a
submission to EPA that has a label, that we want to
put through the paces, it'll put it in our pipeline


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and it will force us to kind of address those
scientific issues and label language at the end of the
day. So we haven't had those submissions yet, but I
think that is one way to kind of move this ball
forward where we do get requests to add drone
technologies.

And as mentioned there are really some really
great applications, you know, vineyards. The Hawaii
one is the new one for me. I always mention the high
hazard areas, mosquito abatement, those are some areas
where, you know, it makes sense. We're not at the
stage where we're going to be flying, you know, giant
fixed-wing autonomous vehicles over cornfields.

There's just other cheaper technologies that exist.

But currently is a niche technology that can satisfy a
hazard area in particular applications I think we're
good. We'd be willing to chew on those things and
kind of then think about a pre-submission meeting on
what protocols and what data development we would like
as part of that submission.

So just a point to your -- interested in
seeing any registrants you want to come forward for
application of this technology so we could work
through those label questions.

And thank you, Liza, for (inaudible) also


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willing to assist.

FACILITATOR: Thank you. Thank you, Ed.

Listen, I think Greg Watson would like to add
a comment about the UAV task force. Greg?

MR. WATSON: Really it's kind of in response
to Ed's comment about proposals. So there has been a
task force of industry members, including the
registrant UAV manufacturers and UAV application
companies. We've come together to start putting
together proposals for data development to inform the
risk assessment and, therefore, the labeling process.

And because of the divergence in spray systems and the
types of machines, that proposal will include a
proposal for a benchmark or a reference, a drone or
UAV machine, as well as the space system would be on
it.

So I think that's, again, the kind of effort
we're trying to get to so that we can align on what
the study protocol, for example, of an offsite
movement study might look like. And there's certainly
efforts also within the CropLife America community in
terms of looking at the existing data. There's a
project there to do we already have some information
that can inform an offsite movement curve using
aggression-based analysis.


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So I think there's some things that are again
on the cusp of doing exactly what it is suggested.

So thank you.

FACILITATOR: Thank you. Thanks, Greg.

Charlotte, I think you had a question.

MS. SANSON: Yeah, thanks, Paul. Thank you.

I'm good. It just took a second.

Yeah. I know it's been said that the work
that the group has done, like all the workgroups, has
been very impressive, and so I applaud the workgroup
for all the time and energy they've put into this.

This is an area that's only going to keep on growing
and becoming more relevant in our industry.

And so I guess my question is more to Ed in
terms of the resources in OPP. I mean, I know -- I
heard your -- I heard what you said about working
directly with, you know, doing pre-submission
meetings, working directly with the RD contacts, but I
guess I could see this becoming a bigger opportunity
within OPP, you know, having some dedicated resources
to this area. I think it's just only going to become
more and more important and relevant in the industry
for the reasons that have been already mentioned.

So maybe it is more of a comment than a
question, but you're -- so far you've been the main


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contact and last I checked you're a pretty busy guy.

MR. MESSINA: Yeah. Well, we had Amy added
to the workgroup as well. But that's exactly my
comment. In terms of having bandwidth to deal with a
theoretical, it's sort of been me, and if folks
recall, you know, three years ago as the deputy, I was
the one who kind of put this on the agenda as
something we should all think about it. And I'm just
so amazed at how much progress we've made since then.

But in terms of, you know, an OPP response, we're
going to need to pilot some things. Sorry for the
pun. But, you know, really work small to kind of see
what we can get through the door and what will work,
and then I think expand from there.

We don't have the resources to work through
this theoretical and that's exactly why having it be a
PPDC workgroup was my way of applying additional
leadership and smart minds and industry to think
about, you know, how we try to solve this problem
collectively. So we don't -- we did have more
resources, and it's the faces that are presenting
today and they did an amazing job.

So thanks for that, Charlotte.

FACILITATOR: Thank you. Thank you, Ed.

We're going to wind up. We have time for one


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more comment or question. And, Iris, you're up.

MS. FIGUEROA: Thanks, and I'll try to be
brief. I just wanted to make a couple of comments,
sort of on the worker perspective of some of these
emerging technologies and some of this we've raised
before. There's some opportunities here, I think, and
some exciting ideas, especially when it comes to
things like reducing drift, which we know is a huge
issue. But as we've mentioned before, just making
sure that there's a process and clear guidelines for,
for example, if there's an unmanned application
instrument, you know, that there's a way to see if
there's bystanders and communicate with those
bystanders, et cetera, and some of those other
elements that are needed beyond the details of the
application itself.

And also when it comes to assumptions for
risk assessment, and this is again a broader issue
we've brought up, we also caution against assuming
best case scenarios. For example, many times there
will be the assumption that PPE is worn and that it's
worn correctly or that folks are reading the label to
begin with, which, as we've talked about, is not
always the case. And so just a reminder that
technology is not -- is a great tool, but it's not


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perfect and there's still a human error to account for
in that.

MR. TINDALL: Nick here. I'd just like, you
know, to make a couple of comments based on that. You
know, one, as far as worker safety, there actually is
an autonomous spray unit being used in a vineyard
setting. And when that is being deployed, the area of
operation is completely roped off and segregated from,
you know, any worker to be in that area and, you know,
proper notice was made and whatnot. So it really
limit the ability for human-machine interaction.

And when you see moving forward and you're
going to see that autonomous 5,000, 3,000-pound
tractor, it's going to have a much higher safety
threshold than a human operator because the LIDAR
system that will be to detecting obstacles will be
working on a 360-degree angle viewpoint and also never
blinks and never gets tired. So you're definitely
going to see an increase in safety over a human
operator.

DR. BASU: And just to add to Nick's comment,
all these technologies coming up -- I mean, you know,

Bill Jordan raised -- made his comment yesterday
around PPEs and global temperatures, going up. These
technologies help in reducing human exposure and


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worker exposure. So again, lots of opportunities.

Thank you very much for everyone for your
time to listen to our workgroup's presentation today.

FACILITATOR: Mano, you got the last word.

Thank you. Great way to wind it up. And I think we
are going to move to the poll. This is becoming
pretty routine already for us.

So Sarah is going to post the poll, which is
basically where we're asking for a motion to pass
these recommendations on to OPP from the PPDC. So
we're asking PPDC members only to vote. But, first,
we need a motion from a PPDC member.

MR. REABE: I'll make the motion. This is

Damon.

MR. SHAW: I'll second that. David Shaw.

FACILITATOR: I didn't hear. Who was the
person that made the motion?

MR. REABE: Damon Reabe.

FACILITATOR: Okay, Damon, thank you. And
who seconded?

MR. SHAW: David Shaw.

FACILITATOR: David Shaw, fantastic. So we
have a motion and a second. Any discussion what
you're voting on right now?

(No response.)


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FACILITATOR: Okay. You have the three
choices, yes, no, or abstain. Once you select one of
those, you click the submit button and you'll have
voted. So let's open the polls.

I think they are open. Go ahead. PPDC
members only.

And, Sarah, I'm guessing that you're watching
the tally as it mounts up. So when we get close to
that, you know, I don't know 35 to 40 mark, let us
know.

FACILITATOR 2: Will do.

(Pause.)

FACILITATOR 2: Just a reminder to folks to
make sure you hit submit once you make your selection
so that we register your answer.

FACILITATOR: So you pick one of the three
and then hit submit. The vote doesn't go in until you
hit that button.

(Pause.)

FACILITATOR: It looks like we have 38 people
who voted, so I will display those results in just a
moment.

FACILITATOR: Okay. I think that is
consistent with the last vote. So it seems like we
might have 38 members present. There you go.


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All right. Thank you very much, Sarah.

And we'll move forward. We're at the next
item in our agenda. We have a team of folks from OECA
that have joined us. Francisca Liem, Dan Myers, and
Elizabeth Vizard are here today. And I'm going to, I
believe, pass this to Elizabeth to get it kicked off.

And so thank you all for joining us and we're looking
forward to the presentation.

And, Elizabeth, if you were there, you might
be on mute.

MS. VIZARD: Can you hear me now?

FACILITATOR: You bet.

MS. VIZARD: Oh, good. I was just trying to
put on my camera. Sorry, I'm clicking on the video
button, but I'm not sure that it is working.

Well, I don't want to waste any time. Sorry,
my camera doesn't seem to be coming on Webex.

Thank you for the introduction. This is
Elizabeth Vizard. I'm the Acting Deputy Director of
the Monitoring, Assistance & Media Programs Division
in Office of Compliance in OECA. We're happy to be
here.

In our division, we have the Good Laboratory
Practice Program for anyone who is not familiar. And
we wanted to introduce ourselves, or reintroduce


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ourselves, to those who might know us and we would
like to more formally engage with this group. We
think that it would be very valuable for us to be able
to bring up topics of interest to provide updates on
our program and to -- from time to time, there are
opportunities for us to ask questions or provide
updates so that we can hear your feedback directly.

So for today, we wanted to provide a brief
overview of the program because if you're not
familiar, we do work hand in hand with Office of
Pesticides and the Office of Toxics. There are GLP
regulations under FIFRA and TSCA. And our team of
inspectors are responsible for the compliance
monitoring program, whether they're going out in the
field, or during these times of COVID, we have been
doing a lot to implement offsite compliance monitoring
approaches so that we can keep the work moving forward
and progressing, completing the study audits and
providing confirmation of GLP compliance, which we
know is so important to registrants and others in the
community.

So with that, I'm going to turn over the
presentation to Francis, who is the section chief of
the GLP group, and Dan Myers, one of our seasoned
senior inspectors, who also is our new representative


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on the OECD GLP working party group. So we wanted to
also touch on that as well. So I'll turn it over to
Francis and Dan.

MS. LIEM: Good afternoon. My name is
Francisca Liem. I'm the Director of the EPA GLP
Program. As Liz just mentioned, you know, we'd like
to introduce the GLP Program to the PPDC.

First of all, for you who are not familiar
with good laboratory practices, or GLP, a very brief
overview of what is actually GLP or good laboratory
practice. GLP is an international quality management
system. It is used by many countries in the world,
and most of them are OECD member countries. So GLP is
in international management system that focuses on the
process and conditions. So these are how to conduct
the nonchemical or the environmental studies. There
are recommendations for planning, how to conduct the
studies, the performance of the study, monitoring and
reporting, and archiving the data and the records of
the studies.

So the purpose of the GLP Compliance
Monitoring Program of EPA is to assure the quality,
validity, and integrity of facilities and their
scientific studies that support a regulatory decision
by government agencies, for instance, at EPA is under


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FIFRA and TSCA.

So the question is now why should PPDC know
about GLP.

Next slide, please. No, I think it's the
slide before.

Okay. So PPDC membership include
stakeholders that are important to the Office of
Compliance. GLP compliance monitoring activities are
inspections and data audits. We assure the quality
and integrity, as I mentioned before, to assist OPP's
management and scientists in their regulatory
decision-making for pesticides.

During the COVID pandemic, EPA moved or
transferred temporarily from the onsite inspections to
offsite compliance evaluations. One example of the
offsite compliance monitoring is the desktop audit.

This is a data audit of the studies that have been
submitted to OPP. We didn't have to do -- we normally
do the data audit onsite, but during the pandemic, we
did the data audit offsite, so at the inspectors'
desks.

I'd like to explain the benefits of these
desktop audits. First, the OPP approvals of
pesticides registrations, reregistrations and so on,
so the regulatory decision-making indirectly benefits


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to registrants and sponsors because EPA assures the
validity and integrity of the data submitted to OPP.

The second benefit is when testing facilities
are having a desktop audit and also a remote virtual
compliance evaluation, this is done by video, it shows
that there is a process of the EPA GLP Compliance
Program. So (inaudible) authorities feel that they
are assured of the EPA GLP compliance status of the
testing facility.

Benefit number three, EPA has done a number
of requested desktop audits from OPP and several
foreign countries. They were requested during this
pandemic. The request was to support at OPP and a
foreign country decision-making. So let me
(inaudible) about the registration of pesticides.

The fourth benefit is these offsite
compliance monitoring activities support also PRIA-4.

As part of the continuous -- I'm sorry -- part of a
continuous comprehensive compliance monitoring
program.

So these are the four benefits that we can
think of I'm sure there are more, but these are the
four most important benefits of these offsite
compliance monitoring activities.

Occasionally, EPA will have topics or


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documents shared with stakeholders, including matters
that may arise from OECD's GLP working party and we
would like to use the PPDC as a way to exchange
information and obtain feedback as necessary.

Next slide, please.

This is a brief summary of the most important
GLP recommendations. I call them the ten pillars of
GLP. They comprise of a statement of compliance,
inspection, know when a lab refuse inspections, for
instance, and the effects of noncompliance. So
(inaudible) there are several (inaudible) on those.

The second pillar is about organization and
personnel. That includes the personnel for the
management, quality director, or assurance and other
personnel involved in the conduct of a study.

The third pillar we call it facilities.

These other recommendations on, you know, what type of
facility is appropriate for a certain type of study.

There are a lot of (inaudible) on that (inaudible).

Number four is archives. Archives is a
place, you know, where we keep all the records that
are supporting studies and complete the studies. So
these archives are for completed studies. Again, they
are recommendations. They are also a rule or
recommendation regarding how long they have to keep


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the archives and how to keep their archives to be
compliant.

The fifth pillar is regarding equipment.

This is the current calibration, you know, what type
of equipment is appropriate for studies and so on.

Number six is about testing facility
operations. This includes standard operating
procedures. I think it's the most important part that
facilities should know.

The seventh pillar is the current test system
care. The test system care is normally sought of
biological species, but it can also be a chemical that
would be also a test system. They are recommendations
on that, how to keep them, how to handle them and so
on.

Number eight is the current test, control,
and reference substances. The test substance is the
chemical or the (inaudible) of the product that the
sponsors or registrants, you know, has to provide data
on.

Number nine is the protocol and conduct of a
study. Protocol is, as you know, is the study design.

So this recommendation, you know, recommends how to
conduct a study and the study design itself
and how to conduct the study. Like, for instance, you


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have to sign with indelible ink, for instance, but
nowadays it's all computerized. So those are all the
recommendations regarding the conduct of a study.

Finally, number ten, the tenth pillar is the records and
reports. On the records, I've just mentioned about
archives, of how to maintain the studies or how to
maintain the raw data, how long to retain and so on.

And reporting, what are required to be in the final
report before you submit it to OPP.

Next slide, please.

MS. VIZARD: Francis, I just want to do a
time check. We're about halfway through our time and
I know I just want you to be able to get through all
the material that we wanted to share.

MS. LIEM: Okay. The basics about the GLP
Program. This is a headquarters of programs. The
(inaudible) are not involved with the GLP. The
studies that we select for data audit comes from the
OPP database, or OPPIN.

Next slide, please.

There are two types of GLP inspections that
we conduct. First, is called the neutral scheme.

These are random selected facilities that are being
inspected. We get these facilities, again, from the
OPP database, OPPIN. We have, as I said, you know, a


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neutral scheme and randomly select the facilities.

These facilities are based on the criteria and applied
weights. The criteria are, of course, the compliance
history, the last inspection date, the number and type
of studies that have been submitted to OPP, and also
the geographical location.

The second part of GLP inspection is called
the requested or for course. These inspections would
normally be requested by OPP, you know, because there
is a pending registration evaluation and PRIA action.

The question or request could also come from a foreign
government and, of course, tips and complaints.

Next, please.

We talked about the responsibility of GLP is
to assure the quality, validity, and integrity of the
data submitted to OPP. We also conduct inspections
and assure that the facility's current studies are in
compliance with the GLP. We provide compliance
assistance to the regulated community, and we
participate in the OECD Mutual Acceptance of Data
program.

Next slide, please.

What happens when an inspector find an issues
or deviations at the facility during the inspections?

There can be three actions that OPP -- I'm sorry, that


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EPA can take. First, is the regulatory -- we call it
regulatory action. This is OPP regulatory action or
kind of enforcement action. OPP could reject the
study when there are GLP violations, OPP could also
suspend or cancel a registered pesticide or deny an
application for pesticide approval. So that's the
regulatory action done by OPP.

We also have civil action and it is enforced
by the Office of Civil Enforcement of OECA. They can
issue a notice of noncompliance, a notice of warning,
or they can also issue penalties to the registrants.

And finally, there's the criminal actions.

If we suspect of a criminal activity at the
laboratory, the GLP inspector, the GLP program, would
refer that to the Office of Civil -- sorry, of
Criminal Enforcement. The criminal enforcement
actions could be imprisonment and/or penalties.

I think this is my last slide, and the next
slice would be done by Dan Myers. Thank you very much
for your attention.

MR. MYERS: Hello, everybody. I'm Dan Myers,
and I will be talking about how our GLP program fits
within the international community. So as Francis was
talking about our domestic inspection program and the
reason we have that is so that we have a level of


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quality that we can rely on when reviewing safety data
here in the United States. Well, as you can imagine,
globally, there are other countries and the citizens
of those countries and governments have those same
questions and concerns.

So there's an entity set up to harmonize GLP
issues globally, and that's done through a large
global entity called the Organization for Economic
Cooperation and Development, which harmonizes a lot of
issues from social issues to economic issues to
environmental issues, which is where our working party
resides within that section of OECD.

So what we do with the OECD is meet routinely
and talk with other countries and coordinate efforts
so that we are all on the same page when it comes to
good laboratory practice or regulations is what we
call them in the United States or the GLP principles
for the rest of the world. And what we want to do is
we want to kind of mid of minimize our necessity to
continue to do evaluations of laboratories from other
countries. So it's kind of -- what I'm trying to say
is it's kind of the next tier.

Rather than of evaluating laboratories in
other countries, what we're doing now is we're working
with the governments of other countries to establish a


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valid evaluated and accepted GLP programs and
monitoring authorities. And we do that through this
mutual acceptance of data program within the GLP
working party.

So let's go ahead and change slides, please.

So as you can imagine, the EPA is heavily
involved in OECD's MAD program, and how we're involved
is by conducting training, evaluating, attending
meetings. In fact, I was up at 5:00 am this morning
attending a meeting on IT issues and how they pertain
to GLP studies. And so we're constantly talking with
other countries about GLP issues.

So if a country, including ours, has any
issues that might arise or concerns, this can be
brought up through this avenue and talked about with
other countries, see what other countries are doing,
if they run into the same issues, and how can we be
consistent globally on GLP issues. And that's a two-
way street. If there's another OECD MAD country, such
as New Zealand when they have an issue, they may come
up with questions for us as well.

So you can see from my slide here there are
currently 38 countries that have evaluated and
accepted mutual acceptance of data monitoring
authorities, 38 countries. Thirty-one of those


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countries are actual OECD member countries. And then
there are other developed nations that aren't actually
members of OECD, but wanted to become a part of this
MAD program and their governments have been evaluated
and deemed acceptable to meet the standards of what's
required for OECD for this type of inspection process.

So again, one of the main areas that we are
involved in is harmonizing efforts, protocols,
procedures globally. We do that through giving
presentations, providing training. We can provide
training to -- just general training to already MAD
countries, or if there's up and coming countries that
want to get into the MAD system, one of the things
that all of us MAD countries do is provide training to
help that country meet the standards set by OECD.

And in addition to that, we also participate
in audit teams. And what I mean by that is is I'm not
auditing scientific data from a study that's generated
in Italy, let's say. What happens is all of these MAD
countries are up for reevaluation a 10-year rotating
basis. So every ten years a country or many countries
will be chosen and a group from other OECD MAD member
countries will fly in and evaluate that country's
monitoring authority for compliance with OECD's set of
standards for monitoring authorities for GLP.


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Some advantages of being part of a MAD
country is that we reduce the duplication of efforts,
meaning we're not inspecting -- many inspectors from
all around the world aren't inspecting the same
laboratory over and over. We rely -- once a
monitoring authority's government is set up, we rely
on that government to do their own inspections. It
also minimizes efforts within their regulated
community to redo studies. If a study is done once in
one of these MAD countries, such as Japan, for
instance, then it can be accepted by all of these
other countries.

And I think the last point I'11 bring up is
that once you are a member of MAD and have gone
through these evaluations -- oh, I also wanted to say
that the United States, even though we invented the
GLPs and came up with this whole idea, we are not
exempt from this 10-year evaluation process. So we
get monitored just as all of these other countries do.

But once countries are in the MAD system, one of the
stipulations is that these countries are required to
accept studies for review purposes from other MAD
countries, if they're compliant with the GLP
regulations.

So there's two points there. One, we're


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sharing information; two, we are accepting these
studies for review purposes. It doesn't mean we have
to accept their chemicals or accept the conclusions in
the studies, but our receiving authorities accept
studies from other MAD countries.

Okay, I think we can go to the next slide. I
believe that's the last one.

Does anybody have any questions for either
Francis or I or Liz?

MS. VIZARD: Do you want to read the
questions or I was going to go ahead and help
facilitate?

FACILITATOR: Go right ahead. Go right
ahead, Elizabeth.

MS. VIZARD: Okay. So maybe I'll help kind
of tee it up to Francis and Dan.

So a few questions. PRIA-4 provided set-
aside funding for the GLP program. How is it being
used?

So I can also respond to that. So with the
PRIA set-aside funding, we were able to hire three
more inspectors to the program, which we were very
happy to do. We've been training those new inspectors
and building their capacity. Obviously with COVID,
it's had a bit of an impact on us. But as we


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mentioned, we have pivoted to offsite compliance
monitoring. So that hasn't stopped us. We've been
training and working with those inspectors and have
integrated them into our team, and they have been
learning the process and learning the study audits.

Number two, how are GLP inspections being
conducted during the pandemic and how is EPA handling
the backlog of inspection given the pandemic?

So I might tee that over to Dan or Francis,
if you want to talk a little bit more in details about
offsite compliance monitoring, how we're doing the
desktop audits.

MS. LIEM: Yeah, sure. All the (inaudible)
they have discussed about the offsite compliance
monitoring. The offsite compliance monitoring
activity consists of two parts. One is the facility
-- (inaudible) the facility inspection. Now we do it
by (inaudible) by video, do a partial compliance. We
don't call it an inspection; we don't call it a
compliance monitoring activity. So we go to the
facility and with a facility person holding the camera
and we tell the person, you know, what we want to see
and then they go slowly through each side or each part
of the laboratory that we would like to see.

So that's the facility or the compliance monitoring


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activity of the facility by video.

The second part is a desktop audit. So
we always write to let you know, you know, we pre-notify the
facility that we are going to do this. We tell the
laboratory what studies we want to see and what to
audit and their laboratory then has to provide the
data electronically to the inspector. So the
inspector would do a data audit like it does at the
facility, but now he does it at his desk. He has
questions, of course. You know, he would then send it
to the laboratory by email. And we then also receive
the answer or the response, you know, of the
questions, you know, by email.

We do an opening conference as usual as in
like the onsite inspection. At the end, we do the
closing conference. And the facility would be
provided the same type of form that we use for an
onsite inspections. (Inaudible) observations that is
required by the PRIA-4. So we are still following,
you know, and try to meet all the PRIA requirements.

So that's the current offsite compliance
monitoring.

FACILITATOR: Did That tackle the three
questions that Charlotte had?

MS. LIEM: I don't see the questions.


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FACILITATOR: Okay. Well, I'm asking
Elizabeth actually.

MS. VIZARD: Yes, I think so. Let me scroll
back up. I was trying to catch up on some of the easy
ones .

FACILITATOR: That's okay.

MS. VIZARD: They're asking us about the
number of labs. There's approximately 1,200 or so
potential labs domestically in the United States. And
there was a question about inspecting -- how many
inspections, and I did want to make sure that people
understand the way our regulations are and how we plan
for our inspections annually, it's based on the
studies that are submitted to EPA for review. So we
must have studies submitted in order for us to
consider inspecting that facility. We do not have a
certification program. So we aren't just going out
and have, you know, for instance, like a list of the
labs and just go out and inspect them and, you know,
kind of renew a certification, like some programs
might act. That's not how ours operates. And the
FDA's GLP program operates in the same way.

Charlotte had mentioned about a backlog of
inspections. I don't know that I would refer to it so
much as a backlog because really one of the things


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that I explained is how it's so important to have the
studies. I would say that, you know, really one of
the most critical components is our ability to review
the studies and so we have continued doing that
remotely.

Yeah, Francis reminds me we had 67 or 60-some
data audits that we were able to complete those past
year.

FACILITATOR: Yeah, Elizabeth, I'm going to
have to cut it here. Shannon can capture these
questions that are emerging in the chat box.

MS. VIZARD: Okay.

FACILITATOR: She can get those off to you
and your team and perhaps you could provide some quick
responses to the things that you haven't responded to
yet because there are quite a few. And a lot of this
is, you know, how many of these and how many of those.

So Id rather divert those questions to you offline and
maybe you can provide some responses to the team, to
the PPDC, or to Shannon and --

MS. VIZARD: Sure.

FACILITATOR: -- she'll transfer it to the
PPDC. So we want to thank all --

MS. JEWELL: I'll send those over now. Thank

you.


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FACILITATOR: Yeah, okay. Thank you very
much to the OECA team for coming today and we really
appreciate the information you've shared with us.

MS. VIZARD: Thank you for having us. And
we're happy to answer the questions. We're really
happy to see so much engagement in the chat. So we
look forward to talking with you more in the future.

FACILITATOR: Fantastic. Thank you very

much.

MS. LIEM: Thank you.

FACILITATOR: So I think we're going to
transition now to the final workgroup report-out.

This is the pesticide resistance management workgroup
report-out. So the co-chairs on this team are David
Shaw from Mississippi State, Bill Chism, and Alan
Reynolds, both from EPA. And so I'm going to pass the
baton to David who will speak first and introduce the
team and get the presentation started. David?

MR. SHAW: Thank you very much, Paul. And
the format that we're going to use on this is I'm
going to give a few introductory remarks as as the co-
chair of this, and then we have five recommendations
that I hope all of you has seen, and we'11 have one of
the workgroup members speak -- a different one speak
to each of the five. And then we'll wrap things up


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and obviously answered or respond to any questions or
comments that we have.

And I'd like to say right off the bat a huge
thank you to the EPA team that worked with us on this.

Bill Chism and Alan Reynolds were mentioned here, but
also especially Shannon Jewell, who was invaluable in
helping us stay organized and on task. And so thanks
to to everyone that assisted on that.

Next slide, please.

So the overarching goal that we were charged
with in the working group was to develop
recommendations to EPA on how the agency can assist
stakeholders in addressing all of the challenges of
conventional pesticide resistance. After we began our
work, we immediately moved into identifying several
charge questions, and I'll talk about that in just a
moment.

Next slide, please.

I guess by way of introduction, I think all
of us recognize that resistance to classical
pesticides or conventional pesticides has been a
growing problem that has really taken on a huge
magnitude in recent years. In our work within the
weed science community, we've been doing a great deal
of work with sociologists and they term this a


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"wicked" problem, a problem that has just a whole host
of causes with no easy solutions and oftentimes
solutions from one perspective actually can create
additional problems from another perspective.

So as our working group began to deliberate
on this, we really wanted to focus in on, number one,
the great work the EPA, as an agency, has already been
doing in this arena and we certainly do want to
applaud the agency for that, but we also wanted to
call out the fact that there were a number of
opportunities to have a much larger impact than the
agency is currently having, and we see several
opportunities for that and are really excited about
the opportunities that we do see before us.

Next slide.

I mentioned the charge questions. When we
initially began the deliberations as our working
group, we really circled around four subgroups that we
wanted to be able to create. The first charge
question or the first subgroup that we created focused
on the idea that there are a number of EPA policies
out there now that have both positive, and in some
cases, negative effects on pest resistance management.

And so the question that we posed to this group was,
what policies are there and then what policies could


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be reworked to be able to more positively address
resistance management.

The second one is taking a look at current
industry programs that are having an impact, and so
everything from incentive programs all the way to
programs that might lock a grower into a certain
pesticide regime and what what role could EPA then
have in being able to assess those programs and be
able to work with industry to have a positive impact
on resistance management.

The third charge question that we developed
was looking at incentives, incentives to both the
registrants and to the pesticide users that could be
considered when we think about resistance management
and pesticide regulation in a much more positive way.

And then, also, are there some ways that the agency
could be working with stakeholders, and I define
stakeholders in a very broad sense to be able to, in a
much more cooperative way, address resistance
management.

And then finally, the last charge question
that we developed was, are there elements of EPA's
really successful Bt PIP resistance management program
that could be used for conventional pesticide
resistance management.


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Next slide, please.

So to be able to populate the breakout
groups, we recruited a number of additional
individuals. And you can see -- I'm not going to name
off names, but as much as anything, I would call out
the opportunity that we had to really reflect a very
diverse audience in the breakout groups that we did
assemble, everything from NGOs and commodity
organizations to regulatory folks at the state level,
independent growers, academics, as well as industry.

Next Slide.

From that -- and I can tell you that we had a
number of meetings, biweekly meetings since the
workgroup was established, and we initially developed
over 20 different recommendations. After a great deal
of additional deliberations, we really honed in on the
five that will be presented to you today. And I'm not
going to read these off verbatim, but basically we're
looking at the first one that really is focusing in on
labels from a uniformity and a simplicity
standpoint, from a resistance management standpoint.

The second one is looking at reviewing EPA's
policies holistically to be able to determine where
there are contradictions and where there are
opportunities to be able to much more effectively


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manage resistance.

The third one is looking at how EPA can
better collaborate with other federal agencies, as
well as other stakeholders, to be able to address this
in a much more holistic way.

Next slide.

Fourth, we really wanted to see how EPA could
work cooperatively with industry and with academia to
be able to address this problem through cooperative
agreements, training materials, and potential grant
programs that might could be developed.

And then, finally, the fifth one is really
looking at incentive programs, incentives especially
to be able to look at how we can have more accurate
early detection and timely adoption of regionally
specific resistance management actions. And this is
so closely tied to the need to be able to really
identify potential or prospective resistance as early
as possible in order to get out in front of it.

And with that, I'm going to begin going
through the individual recommendations. We'll have 5
five people that will be presenting.

Amy Asmus will be presenting on
Recommendation 1. Amy is the principal for Asmus Farm
Supply. Our second one will be from George Frisvold,


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who is an economist from the University of Arizona.

Our third one will be presented by Cameron Douglass
with USDA's Office of Pest Management Policy. And
then fourth will be Kenny Seebold from Valent USA
Corporation. And finally, the fifth one will be from
Patti Prasifka from Corteva Ag Sciences.

And so with that, Amy, I'11 turn the
microphone over to you.

MS. ASMUS: Well, thank you, David, and thank
you to everybody who allowed this great group of
people I got the opportunity to work with to present
these recommendations to you today.

So Recommendation Number 1, uniform, clear
and concise label formats. Okay, we're going to
recognize up-front that this is a huge list for EPA
and registrants. I doubt it can be done without
rulemaking and consulting with many, many stakeholder
groups. Each workgroup, as well as Kaci during your
risk communication presentation, mentioned label
concerns. Yes, sometimes it takes a lot of work and
resources up-front to make it easier for end users to
understand products and use them correctly,
effectively, and safely.

Not everyone listening today may have
experience with pesticide labels, so I want to compare


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them to general directions that come with many of the
products that we use.

Let's fast forward a month or two in the
future when boxes with smiles on the outside show up
on your doorsteps. Many of those boxes will come with
contents unassembled. At my house during the
holidays, people gather round and start the adventure,
following directions to assemble gifts. We all take
out directions. I get my trusty highlighter to
highlight each step after I complete it. My son grabs
his electronics because he wants to find a YouTube
video that shows him how to complete the assembly. My
husband, bless his soul, looks at the directions,
determines there is too much to read or understand,
sets them aside and thinks he can do it without them.

We may or may not all get to an effective end

Yes, personality studies would say that you
will always have different people take different
approaches to directions. Also, different individuals
read directions from different levels of
understanding. There will always be those differences
and those differences must be considered when drafting
a clear and concise set of directions. Federal labels
are a set of directions. You will always find the
must be included information that deals with safety


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and environmental concerns and you will find use
directions.

Sometimes it's an exercise in frustration not
quickly finding what you are looking for or
understanding it once you find it. But a few times,
it's a wonderful process, but it's not consistent.

The information may be different depending on what
you're using, but wouldn't it be nice if the formats
were the same, the information you need in an easy-to-
find and understandable layout? All users would then
know at least where to look in the directions document
and understand what they need to effectively use that
product.

Kaci alluded to it yesterday, and I'll bring
it up again today, in 2016, the FDA went to a similar
process to this ask when they standardized nutrition
facts labels. How many calories are in a serving of
figs? How much sodium is in a serving of this soup?

Given the nutrition facts labels, you could all answer
those questions relatively quickly. Granted, nutrient
facts do not contain near as much information as
needed in a pesticide label, but we are all educated
in the format of those nutrition facts and where to
look to quickly find the information that's needs.

Next slide, please.


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As this applies to resistance management, we
do have a couple of PR notices suggesting, not
requiring, that resistance best management practices,
be included on labels. This is great, but those best
management practices users need to know what the
correct rate is for a target pest in a specific
cropping system. Well, that's found somewhere on the
label.

They need to know what pests are suppressed
or controlled by a specific treatment. Again, that
information is found somewhere on the label, not
necessarily always in the same place on different
labels.

They need to know the mode or mechanism of
action the pesticide employs to suppress or control
that pest. Somewhere on the label. But wait, maybe
that information is on the label because it's required
information, just suggested, but it is needed
information that may not be found on all labels,
depending on the registrant.

Along with uniform, clear and concise labels,
they need to be in the way, as Kaci's words yesterday,
for everyone and how they seek information. OPP's
electronic label project is addressing some of that by
making them searchable, and we are very excited about


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that initiative. But what about those users who do
not have access to or don't use electronic means to
seek information? They need consistent format, so
they can find it quickly within any label.

For resistance management, and I daresay for
a lot of other issues and applications as we have
heard from workgroups over the last two days, uniform,
clear, and concise labels available electronically and
traditionally is wanted and needed by users.

Yes, it's a very heavy lift on the part of
those who create, regulate, and review labels. It
will take time and resources by many stakeholders to
do it effectively, but please, please help end users
find important information, interpret and understand
that information, and implement pesticides when needed
in a safe and effective manner. This is needed to
manage pest resistance development and growth, which
is our specific ask. But it's also a recommendation.

This recommendation has far reaching benefits across
all label users.

Thank you.

On to George.

MR. SHAW: Thanks so much, Amy.

George, and let's go to the next slide.

MR. FRISVOLD: Okay, can you hear me okay?


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MR. SHAW: Yes.

MR. FRISVOLD: Great. So our second
recommendation is that EPA should conduct a thorough
review of their policies and regulations affecting
resistance management, and to the greatest extent
possible remove those contradictions that can hinder
resistance management.

We recognize that EPA is charged with
implementing many different kinds of regulatory
recommendations and requirements and these often are
drafted with other regulatory objectives in mind, such
as protecting health or environmental safety, not
necessarily considering resistance management.

So we recommend that EPA should preserve the
efficacy of current pesticides and develop or revise
their policies that delay development so that we can
delay the development of resistance and to preserve or
extend the durability of the pesticide efficacies we
have in the market.

Next slide, please.

MR. FRISVOLD: We also recommend that EPA
proactively review and adjust rules to account for
various opportunities that new technologies provide
and present and to also not have a one size fits all
approach, but to account for the diversity of U.S.


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cropping systems and pesticide uses.

Another recommendation is that EPA elevates
resistance management to a major benefit when they're
balancing benefits and risks. Programs and policies
don't necessarily consider resistance management as a
major benefit, but we think they should.

MR. FRISVOLD: George, I'm sorry to
interrupt. This is Paul. I think we're having
trouble hearing you. I'm not sure if you can move
closer to your laptop mic or whatever mic you're
using.

MR. FRISVOLD: Is this working? Can you hear
me better now?

FACILITATOR: That's not a complete change.
That is perfect.

MS. FRISVOLD: Okay. My laptop is now a
shoulder top anyway.

FACILITATOR: Okay, very good.

MR. FRISVOLD: Okay, so let me go to the

next.

Okay. So we think resistance management
should be elevated to a major benefit and EPA should
develop and revised policies that achieve a balance in
various pesticide application requirements without
compromising best resistance management practices. So


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this will support the long-term availability of the
most possible pest control options.

And finally, to improve the efficiency in the
approval of pesticides to consider what is needed to
fight the selection of resistant pest populations, and
during the whole approval process, to consider how
that affects what kinds of modes of action are
available.

And on to Recommendation 3.

MR. SHAW: All right. Thank you, George.

Cameron?

MR. DOUGLASS: So our third recommendation --
next slide, please -- EPA should expand collaboration
and outreach efforts with other federal agencies and
convene panels of relevant stakeholders to address
specific priority issues and questions associated with
resistance and resistance management.

As my colleagues and I were thinking about
how we'd like to see EPA implement this broad-reaching
recommendation, we grounded our deliberations in the
understanding or thinking that pesticide resistance is
really a community problem, and as such, we need to
work towards discussing solutions as a community.

Pesticide resistance, though, is an especially tricky
problem. As David said, it is outside even -- said it


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was a wicked problem because different members of our
collective community have varying priorities, values,
and experiences with pesticide resistance.

So my colleagues and I started thinking about
how we wanted to bring everyone together, how we could
bring everyone together, and what the appropriate role
was for EPA in this process. We got to thinking about
the ultimate goal of sustainable pesticide resistance
as being analogous to a two-legged chair, which is
available on the market currently. Sitting in a two-
legged chair, in our estimation, is conceptually a bit
like sustainably managing pesticide resistance. It
relies fundamentally on two legs, one being the best
available science, and also experiential knowledge
from those in the field, livestock production
facilities, homes and in clinics.

In order to have any hope of even just
comprehensively tracking cases of pesticide
resistance, we need innovation. We need better
technologies for monitoring for resistance, both real-
time tools for users in the field and extremely
precise tools for scientists in the lab. When we talk
about actual solutions for managing pesticide
resistance, we not only need these out-of-the-box
technologies, but we need to listen to and integrate


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the experience and knowledge of practitioners as we
talk about how to disseminate these new technologies.

Ultimately though, sitting in a two-legged
chair depends on using your legs and your core muscles
to keep yourself upright, just like sustainable
managing pesticide resistance will ultimately depend
on transparent, regular, inclusive communication,
coordination and collaboration.

So our recommendation to PPDC necessarily
focuses specifically on what EPA can do to help
further and facilitate the sustainable management of
pesticide resistance. But before moving forward, I
wanted to emphasize that this really involves all of
us, others in government at all levels, state, county,
federal who are involved with pest and pathogen
management, pesticide users, applicators, consultants,
academics, those in the registrant community,
nongovernmental organizations, and members of the
public.

So let me move into our specific
recommendations, the first of which you see here. Our
workgroup struggled a bit to reach consensus on where
and how to address the technological problems that we
face in trying to think about how we can sustainably
manage pesticide resistance. Because of this lack of


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consensus or disagreement, we propose, first, that EPA
establish one or more scientific advisory panels that
could focus on specific scientific and regulatory
questions that we believe are necessary to answer as
EPA and the rest of us seek to better manage pesticide
resistance.

These SAPs can focus on both natural and
social science questions importantly related to
barriers to detecting and monitoring for resistance in
different systems and disciplines, but also cross-
cutting issues, such as how to develop a system or
systems or databases to allow for the reporting of
resistance cases to EPA, but also other relevant
federal authorities, such as CDC, FDA, and USDA.

Next slide, please.

Our last two recommendations are really
centered on facilitating communication, collaboration,
and coordination. The first of these is that we
recommend the formation of a federal workgroup on
resistance management to be comprised of -- not only
of U.S. government employees representing agencies
with an interest in pesticide resistance, these
agencies could, of course, include EPA, USDA, CDC, but
also others, DoD, FDA, anyone in the Federal
Government who has interest in pesticide -- pest


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pathogen management and pesticide resistance. But we
would also recommend that there's explicit involvement
from representatives from state lead agencies,
including AAPCO, NASDA, and other state authorities.

We would also propose that PPDC maintain this
resistance management workgroup in some fashion,
perhaps with a skeleton group of members, to help
coordinate communications between the proposed federal
workgroup on resistance management and other public
stakeholders. As we understand FACA, the federal
workgroup, which would be comprised solely of federal
and state employees, would not be able to directly
hear advice from members of the public, which is
critical, as we said, to moving forward on pesticide
resistance.

So we propose maintaining this workgroup
under PPDC's FACA charter to serve in the role of
coordination between the federal efforts that we
propose ramping up on pesticide resistance management
and the parallel efforts by other stakeholder groups
working on resistance management and IPM, integrated
pest management, the coordination of which is really
vital.

And with that, I'll pass it on to Ken for the
next recommendation.


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MR. SEEBOLD: All right. Can you hear me

okay?

MR. SHAW: Yes.

FACILITATOR: We can hear you great.

MR. SEEBOLD: Excellent, excellent. Yeah, I
was thinking back when when David was introducing the
subject and talked about the wicked problem, well,
today is the Valent USA day for a wicked problem. Our
network is down. So I'm going to attempt to do this
on my iPhone broadcast to my TV here in the living
room. So let's see how this goes.

So where we're going to go next in this
Recommendation 4 really has to do with stopping a
problem before it gets started. It makes me think
back to -- before I came to Valent, I was an extension
specialist at the University of Kentucky. I'm a plant
pathologist and I deal with disease management. And
sort of a central theme that we always taught growers
and county agents and things like that was that when
it came to a disease problem preventing it was much
better than dealing with it once it got started.

And I think you can probably link this over
into the same way of thinking when it comes to
resistance management, you know, being proactive,
right? You know, being able to essentially come in


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and manage the appearance -- even prevent as much as
possible the appearance of resistance versus dealing
with the problem after the fact.

So what we're looking at here, you know, the
group, in terms of discussion, talked about
essentially thinking about ways that the EPA could
encourage proactive resistance management through
prevention programs that would cooperate with
industries. You know, we're the ones that develop
these chemicals, you know, through the RACs, the
resistance action committees. You know, we set down
the guidelines on how to best manage these
chemistries. And then, of course, you know, the
partner to that are the universities through crop --
you know, cooperative extension are the team that's
basically going out and providing education to the end
users or the growers.

But is there a way to to essentially, you
know, encourage proactive resistance management
through cooperation of industry and universities and
set -- by setting up agreements, by working through
and refreshing and revising training materials and
exploring the idea of incentivizing things with grant
programs ?

So, you know, like we say here, you can see


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that, you know, collectively planning for resistance
before it becomes a problem really helps keep the
tools in place. You know, it preserves them, protects
yield, helps consumers, and really at the end of the
day, you know, gives you the best financial end
result, better impact on the environment and
ultimately better societal outcomes.

So the recommendation coming forth is that we
think that we should basically take stock of what
we've got in place now. So by doing that, what we're
saying is the EPA should conduct an analysis of the
programs that are in place now, as well as the
training information that you see that's provided by
by companies and universities. But take a look at
those things. Also, take a look at the target
audience. You know, who are we aiming at when we when
we send these programs out and how are they receiving
them, what are they learning, you know, what impact as
does it have. But take an analysis of that so that
you can understand how successful we are, how the
outcomes were, or where we need work. So that's kind
of what we want to recommend there.

And it sort of dovetails into the second part
of this, which is on the next slide. And that is
essentially once you've gone through and you've taken


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stock of the tools that we have available, how those
tools are being used by the end users, think about
what we could do to make those better, you know, keep
what's working, you know, make changes and adopt a
path forward to improve what we've got. But through
that, we think that the EPA should explore this idea
of creating a grants program that would aid with
community-based resistance.

Having an integrated framework, as you can
see here on the slide, allows for better coordination
across our stakeholder communities for programs that
would just basically help us improve awareness amongst
our end user group, and then the implementation of the
programs that would help get ahead of resistance
problems before they start. And we recognize that
this is an awful lot of work and would require, you
know, would require a tremendous amount of effort, not
only on the part of the agency but also the
cooperators themselves, you know, the universities and
the industry. But we think that would be a very
positive step in trying to get a handle on things
before they blow up.

MR. SHAW: Thank you, Kenny.

MR. SEEBOLD: Yes, sir.

MR. SHAW: We'll shift it over to Patti


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Prasifka now for Recommendation 5.

Let's go to the next line.

MS. PRASIFKA: Thanks. Okay. So other
recommendations, the one we just heard, Recommendation
4, called for the EPA to review educational materials,
possibly build new materials and make sure that the
field has the technical tools they need to implement
IRM. Recommendation 1 called for more clear, concise
labels to help with implementation of IRM and
understanding. And all this being said, the fact
remains that the adoption of resistance management
practices remains uniformly low among growers.

In many cases, decision-makers know what to
do. They have the tools, so why don't they implement?

Perhaps growers and other decision-makers are waiting
for confirmation of resistance. It's hard to want to
change if you don't know for sure you have a problem.

The time it takes to confirm resistance can be long.

We talked about this extensively in our group and, you
know, best case scenario, maybe 18 months, maybe even
years to get that confirmation of resistance, and it
varies highly across portfolios and different types of
pests.

During this time, resistance can spread
rapidly, and if we could get confirmation faster of


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resistance, this might help spur action sooner.

Let's go to the second slide, some specific
recommendations we had. If we can shorten the time
between suspected and confirmed resistance, we can
reduce confusion and simplify decision-making. We
recommend that the EPA establish a nationwide research
grant program focused on encouraging support or
supporting the efforts to accelerate that rate between
suspected resistance and confirmed resistance.

And, secondly, we ask that the EPA take a
deeper look into why decision-makers, growers, crop
consultants, other folks that are making those
decisions are not taking action when they become aware
of a potential resistance in their field or in a
neighbor's field.

Can EPA better enable proactive management?

Is there a lack of information? Some of
Recommendation 4 may get to that. Or are the right
messengers not delivering the information? Is it not
from a trusted individual? And some of the community-
based, again, information may get to that as well. Or
is there a need for additional motivation or reward to
get that early action potential resistance. And,
again, previous recommendations mentioned the
community-based approaches and how those are perhaps


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more successful in getting immediate action.

It's important to identify those barriers so
solutions can be developed. And that's -- I didn't
read through the specifics there, but that's the gist
of recommendation 5 and really ties into some of those
other recommendations, bringing them together and
wanting to get action to be taken, just good
resistance management, good IPM across the board.

And that's all.

MR. SHAW: Thank you, Patti. I'll take a
couple of moments just to wrap up and then certainly
we want to open it up questions and comments.

As I began the presentation, we talked about
this idea of a of a wicked problem. And this is one
of those problems that many people see this as a
biology problem, an evolutionary biology problem.

Many others see it as a technology problem. I think I
view it much more as a human decision problem, because
it is the decisions that we are collectively making
that are driving the development, the evolution, and
the expansion of resistance. And if we do not take
the opportunities that we've discussed in these five
recommendations, certainly, the problem is going to
grow in magnitude.

Just as a recap, we've talked a lot about


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labeling and the need to address that in a much more
effective and efficient manner. We've talked about
convening, the agency convening scientific advisory
panels, as well as convening a federal working group
on this top. We've talked about incentives to be able
to not only increase reporting, but also incentives in
terms of ways that we can have coordination and
collaboration amongst all of the stakeholders
necessary.

We've talked about cooperation. I think the
idea of the development of a scientific advisory panel
or multiple panels is really important as a next step
to be thinking about from an agency perspective. And,
certainly, from our standpoint, there's a great deal
of enthusiasm about the idea of continuing to see this
working group live on past the report that we have
turned in.

We would also, I guess in wrapping this up,
like to request that a report be provided back to the
PPDC at our spring meeting, so that we can have a
response from EPA on the steps that are being taken
and the steps that are being considered in response to
the recommendations that we provided.

Again, as I wrap up, I want to thank all of
the participants of the working groups. This is a


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great group to work with. We had a lot of wonderful
conversations, a lot of difficult conversations, but
always in the spirit of trying to be sure that we were
providing the very best focused recommendations that
we possibly could. And so thanks to the working group
and thank you to EPA and to the PPDC for allowing us
to present this.

FACILITATOR: David, team, thank you very
much. And I think we've got ample time right now for
Q&A. So thanks for your kind of rapidly moving
through the slides and it gives plenty of time for
discussion and Q&A.

So the floor is open. You can blurt
something out and either you will be heard, or you can
identify your interest in speaking in the actual chat,
and I can call on you that way, however you want to do
it. You all know the drill.

Liza?

MS. FLEESON TROSSBACH: Hi, thank you. This
is Liza Trossbach. I'm representing AAPCO, which is
the Association of American Pesticide Control
Officials, and I just want to make a brief comment.

First of all, thank you for the presentation.

Yet another great workgroup presentation from the last
two days. I certainly agree with the points that are


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brought forward. I just wanted to mention from a
pesticide regulatory official's perspective, one of
our concerns, in addition just to the issues with
resistance management, is that when you have pesticide
resistance, you also set up a situation that increases
the potential for misuse of pesticides, whether
existing pesticides that were used, for example, using
more than the label rates or for a use of a pesticide
that's not approved for that. So I certainly support
the efforts of this group and the continuing work with
this group. So thank you.

FACILITATOR: Thank you, Liza.

Mano is up next followed by Charlotte.

DR. BASU: Thanks, Paul. And, David, thank
you very much for the overview and all the presenters
of the working group. I did notice that there were
several subgroups, if I may say so, within the working
group. And as these recommendation came out, are
these recommendations coming out from each of the
subgroups within the working group or are these
recommendations the overall working group
recommendations? That's my first question and then I
have one other followup question.

MR. SHAW: So thank you for the question,

Mano. Each individual group developed a draft of


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their recommendations based on the deliberations that
we had coming out of the charge question groups, but
the final recommendations were actually very
thoroughly vetted by the entire working group. And we
had a great deal of input and a great deal of
conversation about those questions. And so, no, they
are representative of the entire working group and not
just each individual charge question or working
subgroup.

DR. BASU: Yep, thank you very much, David.

And the followup question again for the full PPDC and
even for the agency, we hear label on almost all
working groups now, whether it's in resistance
management, emerging technologies, emerging pathogen.

So if label is coming up in all these working groups,
what's the best way to approach the around label? Can
we take a broad look and what the improvement
opportunities are on the label language, content, you
know, process, timeline of the label, review update,
rather than just specifically looking into one
recommendation from each working group?

So again, that would be a missed opportunity
here, given that each and every workgroup has a label
recommendation. Thank you.

MR. SHAW: And, Mano, if I can take license


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to chime in with you, I could not agree more. Even
though that is something that came through strongly as
the first recommendation that we provided, I
completely agree that it needs to be in the context of
a much broader discussion. And certainly, that would
be my recommendation as well, is to take a holistic
look at labeling.

DR. BASU: Thanks, David.

FACILITATOR: Thank you, David. Thank you,

Mano.

Charlotte, you're up.

MS. SANSON: Yeah, I don't need to be
redundant. I was actually-- it was going to be
similar to Mano, but first say thanks to the working
group. I read the full report and obviously a lot of
thought and a lot of smart people in this group, too.

So I really appreciate all the work they've done.

With regard to labels, I agree with Mano. I
see more of an overarching need to look at labels in
terms of, you know, the points that were brought up.

It's not just relevant for resistance management, it
applies to the other working groups and other things
that are relevant to us. So when I was looking at the
recommendations or I was thinking that I didn't really
even see that as, you know, part of -- you know,


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Recommendation 1, to me, would be totally into a
separate label workgroup. And I'm not saying it's --
I'm not dismissing it at all. It's important.

But the fact is that many of the -- much of
the label language that's on labels is prescribed as
-- you know, comes out of the reviewers, the
scientific reviewers. And so, you know, maybe we
could -- I mean, there could be a way to look at all
that in terms of how those labels are being reviewed
and asked of registrants to put statements on. And so
anyway, that's just my thoughts and I think it's great
to have a separate discussion labels and how labels
can be more readable for the user and still contain
the critical information that's needed from the
scientific assessments.

Thank you.

FACILITATOR: Thank you, Charlotte.

Other PPDC members or -- yeah, other PPDC
members that want to ask a question or provide some
feedback, or if there are workgroup members on this
workgroup that wanted to embellish or add a point to
any of the presentations that were just -- any of the
specific recommendations that were just described?

UNIDENTIFIED FEMALE: I put it in the chat,
but just a plug to say to check out the appendix


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material if you didn't already because there's a lot
of good information there about kind of the process
that went through our heads in some of this, some good
background information. It is extra at the end, but
it's some good material to understand more of our
conversations.

MS. ASMUS: Yeah, I just wanted to point

out --

FACILITATOR: (Inaudible).

MS. ASMUS: I wanted to point out, too,
there's a lot of stakeholders when it comes to
creating labels and the label is the law and there's
many considerations as to what language is enforceable
on the label, what language is supplemental on the
label and not enforceable, what language needs to be
provided outside of the label maybe in a link or an
educational format that users can use on the label.

It's an easy thing to say do the labels, and
I am a champion and I will carry that flag for the
growers. And for everybody who calls our retail thing
in the back of a spray rig, wanting to know
information from a label and we have to help them.

But it's a huge risk and there are many stakeholders
involved and many aspects to this. The label is a
regulation, and although it's easy to shoot out there,


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just make them easy, make them understandable, make
them uniform.

Our group went round and around because this
will be a huge lift, but it's a needed lift and,
hopefully, we have input from all concerned
stakeholders because to do it right, it has to be done
right the first time, and I don't think we piecemeal
it together and try to make it work bit by bit, just
my two cents as a user and as somebody who calls
frequently to interpret or to find information those
labels.

FACILITATOR: Thank you, Amy.

And Jasmine, Jasmine Brown, do you have a

question?

MS. BROWN: Yes. My question is if the group
could look at simplifying the acid equivalent on the
labels. As an inspector, one of the questions I get
asked a lot when people are mixing formulations is --
sometimes that has to do with a percentage or an
amount of the acid equivalent, and there are -- you
know, we go over the math with them, but I don't know
if there's somewhere in the label where that could be
really simplified for them to get their mixtures
correct. I would just ask this group to include that
in their future label discussions.


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Thank you. If they haven't already.

FACILITATOR: If anybody on the workgroup
wants to react or respond to Jasmine, feel free.

MS. SANSON: So, Paul, this is Charlotte. I
know this discussion is on resistance management and
we've sort of drifted into a label discussion, I mean,
which is still good. And maybe it's something we can
talk at the end that perhaps there could be another
workgroup formed that, you know, addresses -- that
looks at labels. And like Amy had said, there's a lot
of stakeholders involved. And so anyway, just a
recommendation to throw out there for discussion
later.

MR. SHAW: I very much appreciate the
comments from both of you and I guess I would --
Jasmine, as you were saying that, I was thinking about
what Amy did visually with her presentation with the
food labels, and I think that's actually a fairly
visual reminder of the way that simplicity needs to be
a theme for any considerations about changes and
labels and so your point is very well taken.

FACILITATOR: Thank you. Thank you, David.

Other questions, comments, and feedback for
this team?

(No response.)


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FACILITATOR: Well, if not, that's fine and
you also have the option of tossing a comment into
chat at any point during the public meeting, at any
point during this meeting today.

And what we want to do now, we're finishing
this segment a little bit earlier than scheduled,
which is fine, and but what we'll do just to close out
this session is to go through the polling process for
the last time today.

And so what I'll ask is for a motion to
accept and to forward these recommendations from the
pesticide management workgroup on to EPA. We would
like a motion and maybe a second to that.

MS. ASMUS: Amy Asmus, I so move.

FACILITATOR: Okay. Thank you, Amy. The
motion was by Amy Asmus. And do I hear a second?

MR. FREDERICKS: Jim Fredericks seconds.

FACILITATOR: Thank you, Jim. Seconded by
Jim Fredericks.

And any discussion what we're voting on?

(No response.)

FACILITATOR: Okay, thank you. Sarah has
published the poll on your navigation panel. You have
three choices, yes, no, and abstain. And remember
once you highlight one of your choices, you also have


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to click on the submit button in the lower right-hand
part of that dialogue box. So select your response
and hit submit, and we'll give it a minute or two to
make sure we gather all the votes. These are PPDC
members only that are voting. Thank you.

(Pause.)

FACILITATOR: And, Sarah, my guess is, you're
monitoring the tallies, so we've been targeting around
35 to 38 votes in today's voting. So let us know when
you start approaching that number.

FACILITATOR 2: Will do.

FACILITATOR: Thank you.

(Pause.)

FACILITATOR 2: It looks like the votes are
slowing down, so I'll give it just another few seconds
before I close the poll.

FACILITATOR: Last call to PPDC members to
cast your vote, yes, no, or abstain, and hit the
submit button.

(Pause.)

FACILITATOR 2: All right. I don't see any
more votes coming in, so I will close the poll and
share the results.

FACILITATOR: Okay. Very good. Thank you
very much, Sarah.


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And I can't -- now I'm blanking out. Did we
do a poll earlier where we didn't have time to show
the results, we went right into the next segment?

I just can't recall if that poll is still --

MR. MESSINA: We showed the results, although
we haven't --

FACILITATOR: Oh, we did?

MR. MESSINA: Yeah, but we haven't really
sort of confirmed whether, you know, the audit has
taken place for any of the votes.

FACILITATOR: Okay, Ed, that's right. Okay,
thank you very much.

All right. So that poll is closed.

It looks like, Mano, you have a question.

DR. BASU: Yeah, thanks, Paul. And again,
looking at some of the previous poll numbers, it says
total 32, but if you look at the count it's 24, plus
630. I saw similar numbers even for the emerging
technology. So I don't know what's happening with the
(inaudible) which doesn't fit in the yes, no, abstain?

Where are they going? Or people just didn't vote? So
why is it saying 32 and the count is only 30 out of
32?

FACILITATOR: Yeah. I noticed that, too.

Mano, I don't have an immediate answer. I'm not sure


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if Sarah does. Is it possible that someone isn't
voting at all? Maybe someone has left in the room
when our vote takes place.

FACILITATOR 2: Yeah, if someone doesn't vote
at all, then it doesn't show up in that total number.

So if it's not equaling that exact number of PPDC
members, it's because they haven't voted at all.

DR. BASU: So is 32 the total number of PPDC
member on the call today or is 32 the total number of
PPDC members irrespective if they are on the call or
not on the call.

FACILITATOR 2: That's the number that
participated in the poll. So there could be a few
members on that didn't participate at all.

DR. BASU: So the members are who are on the

call.

FACILITATOR: That's correct, and that is a
changing number throughout the day.

DR. BASU: Yeah, yeah. That's what I noticed.

FACILITATOR: The PPDC members join and
unjoin the meeting throughout the day either by
leaving the meeting and coming back or by just leaving
the room and not being present for a vote. We're not
exactly the U.S. Congress that has like a lit board.


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MR. MESSINA: Yeah. But the good news is
either -- the majority of the PPDC members out of 40,
we've exceeded that number, and of the voting members,
we've exceeded that number of the quorum that's here I
think for all four sessions, assuming that every
single member of the 32 was a PPDC member, which I'm
hoping that's the case, then all four sort of
workgroups' materials moved on is my read, Mano. I
don't know if you have a different read.

FACILITATOR: That's my read as well, Ed. It
was kind of a -- it wasn't close. It I wasn't like a
close vote or close call, but we will -- we can --
we're going to go through -- we have the record of the
votes. We're going to go through just to make sure
that we didn't accept non-PPDC member votes, and we'll
do an audit and confirm with the PPDC the outcomes --
the actual outcomes of the votes if that's okay, Mano.

And Jasmine Brown has a question as well.

MS. BROWN: Thank you, Paul. I was curious,
or maybe I missed it yesterday afternoon, after you
verified the PPDC members voting, this question was
for Ed, did he report back on the actual numbers after
they were confirmed?

MR. MESSINA: We haven't -- that was my
question to Paul. S we've seen the numbers which


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every -- all four workgroups had a majority to move
materials forward. The next thing that needs to
happen -- and I don't know if we're going to be able
to do that today or follow up -- is to determine that
the members that did vote for where there was a
majority to move all the materials forward were PPDC
members that were only voting.

MS. BROWN: Okay, thank you. I just wasn't
sure if I missed it or not. So I was just checking.

MR. MESSINA: No.

FACILITATOR: No, no, we have to do that
offline, Jasmine. We're going to -- you know, after
the meeting closes out today and we've kind of wrapped
up all of the documentation associated with this
meeting, that will be part of the close-out on the
meeting is to do an audit on the actual voting.

MS. BROWN: All right, thank you.

MR. MESSINA: Thanks for the question,

Jasmine.

FACILITATOR: Okay. And then, Mano, you have
a followup question.

DR. BASU: Yeah, yeah. Thank you, Paul. An,
again, I have only attended the PPDC meeting in the
virtual world. How did it work in the in-person
world?


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MR. MESSINA: People raise their hands and
kind of -- again, it's consensus. It's pretty
informal. You know, there was ayes and nays, which is
kind of how we are trying to capture it through the
virtual environment.

DR. BASU: Okay, thank you.

MR. MESSINA: Mm-hmm.

FACILITATOR: So the combination of, you
know, hand vote, voice votes, it was to get really a
reading. It's like just to try to get a reading from
the PPDC where the weighting was, you know, where the
-- where's weight of the consensus? And that would be
weight as in W-E-I-G-H-T.

MR. MESSINA: The other thing, Mano, is a lot
of the PPDC in the past had been EPA presentations all
day long. So this new workgroup format, report-out,
recommendations to PPDC, trying to get real work
product, you know, and more work product from PPDC is
also a shift that's occurred recently, intentionally.

So that's another reason why there's a lot of voting
more than there had been ever in the past.

DR. BASU: That's helpful. Thank you.

MR. MESSINA: Mm-hmm. So what do you -- what
would you like to do, Paul? Do you want to give
people a five-minute break and then we could start and


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then we can kind of do the wrap up?

FACILITATOR: Yeah, that would be fine. I
was going to ask you the same thing. Maybe we --
we've got 45 minutes left before the public meeting
happens.

MR. MESSINA: Yeah.

FACILITATOR: As of this moment. Do you feel
-- I want to make sure you have the time you need, Ed,
to tackle what you want to tackle in your segment. We
got a little 15-minute gift from this workgroup and I
don't know if that's a gift or not, but --

MR. MESSINA: Yeah, and I'd like to take
advantage of that because there's sort of three things
I want to address. Sort of the one question is what
are we going to do with all this stuff that we've
received. So I'd like to address that. I would like
to have a discussion about whether to continue and
which workgroups would like to continue, who might be
the chair of those groups. Maybe we could do voting
on that as well to determine, you know, which of the
four workgroups go ahead. And then the third piece
would be what do we want to build for an agenda for
going forward for the spring meeting, what are our
expectations about that, and are there any other
additional topics or workgroups that we want to form


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now to move forward.

That's pretty aggressive. I don't think we
have to get through all of that, but those are sort of
the loose ends as I see them. And if others have any
other loose ends that we'd like to talk about as well
during that wrap-up, I'm happy to entertain that as
well. So I think we could maybe give folks just a
chance to take a mental break and come back at 3:55,
something like that.

FACILITATOR: Perfect, 3:55. That's eight
minutes from now.

MR. MESSINA: Yeah.

FACILITATOR: We've got an eight-minute
break. We will start -- Ed will be back in front of
you in exactly eight minutes.

MR. MESSINA: Thanks, everyone.

FACILITATOR: Don't leave the meeting or you
can just go on mute and hit stop video and you're
good. Thanks.

(Break.)

FACILITATOR: Okay, everyone, that was a very
fast eight minutes. I'm showing 3:55. And I'm going
to suggest that we remove -- since this was the last
slide of the pesticide management workgroup or
resistance management group, we probably can get rid


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of that. And it might be that Shannon is going to be
sharing her screen, maybe with a Word file or taking
some notes.

MS. JEWELL: Yeah, you want to go ahead and
do a white board for this session I'm presuming,
right, Ed?

MR. MESSINA: Yeah, let me talk for a little
bit and then let definitely let's throw that up there.

MS. JEWELL: All righty, great.

MR. MESSINA: Thank you. Yeah, so thanks,
everyone. This is the beginning of the last session
before our public comments. And, first, I just want
to say I'm incredibly impressed with the presentations
we had, all of the work that went into it, all of the
workgroup meetings that occurred to make this just,
for me, one of the most informative PPDC meetings I've
ever attended.

I was just looking over the charter and, you
know, part of what the charter says is the PPDC is a
policy-oriented committee that will provide policy
advice, information, and recommendations to EPA, will
provide a cooperative public forum to collaboratively
discuss a wide variety of pesticide regulatory
development and reform initiatives, evolving public
policy, and program implementation issues and policy


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issues associated with evaluating and reducing risks
from the use of pesticides, I think that all evidence
that this group has taken their role seriously with
regard to that and has devoted a number of cycles to
really helping the agency.

When I think back on the discussions we had,
even starting yesterday, and today, what I was struck
with was just how invaluable it is to hear from the
people who are outside the walls of EPA about the
impact of their policy decisions on those individuals,
and you guys see that firsthand. The COVID session
was really interesting because the view from industry
looking in to the agency and really kind of working
collaboratively on sort of how we were doing during
that pandemic -- because we don't really know. We're
just doing our work, we were trying to coordinate.

But it was really nice to hear how that was viewed
from outside the walls of the agency.

On the farmworker clinician working groups,

I think there was a lot of thought. I think the
complexity of those issues and the differences of
opinions were really great to surface. And as folks
know, we have a quarterly meeting with members of
those groups as well and I think we'11 borrow from
some of the really great ideas that occurred on that


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session.

Resistance management, always an impressive
issue and pretty provocative and a lot of needs to
happen there. And then certainly on the emerging
technologies piece, an area that I'm fond of, I just
was blown away by the input and the advice that we got
for that workgroup.

So one of the recurring questions was, you
know, what are we going to do about this? You know,
what happens to these reports? You guys put a lot of
work into it. How's the agency going to respond?

So I think, as a first step, it is building
our agenda for the [connection issue] that we put on
the agenda, Shannon -- and maybe we can start sharing
the whiteboard -- you know, a session what the agency
has done with the recommendations and kind of a
report-out and make that kind of a recurring topic. I
will say if people are wondering sort of what happens,

I mentioned this yesterday, but the emerging pathogens
workgroup, which is a somewhat of a continuation -- it
had sort of stopped for a while -- but the PPDC
workgroup in the past, as you heard, had developed
that emerging viral pathogen policy, which enabled the
agency to better respond to the COVID pandemic.

So if you're looking for an example of how


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the recommendations are used and -- like that's, to
me, one of the -- the shining example of how it can
really work, where there was a recommendation that
there be an EVP, there was recommendations about what
that EVP should entail. We developed it; we launched
it; we issued it; and then we actually used it. So I
would use that as an example of how the best of these
recommendations can show themselves later on as part
of EPA policies.

And I think the emerging technologies
workgroup, just the momentum that that has created,
not just within EPA, but with industry and academia
and other stakeholders, is an indication that if we
just even have these workgroups and we're talking
about the issues, we're pulling in those experts that
we need to talk to from around the country and around
the world so that the policies and the thinking around
them are actually advanced.

So that's another area where, you know, we
haven't finished that, but we continue to move that
ball forward and continue to evaluate where we want to
be there.

On the farmworker groups, we've been taking
those -- you know, what's going to happen in PPDC, and
we'll definitely talk about it on Friday and maybe


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prioritize and think about what we want to do.

Certainly, the certification and training, worker
protection rules, how we deliver the grants when we do
a new grant. I think you'll see some of those
recommendations pop up there, where specifically, you
know, trying to measure the success of the grant and
making sure that we are seeking counsel from the
farmworkers themselves about what's the best format
that they can arrive receiving that communication.

So I also -- you know, you heard me do the
presentation kind of how the workload picture looked
like for OPP. So I do want to manage folks'
expectations that, you know, I don't think by the
spring session for all 18 of the farmworker
recommendations and the [connection issue] or so from
the, you know, emerging technologies group that we're
going to have checked every single one of those boxes.

But I can commit that we'll continue to look at these
reports, evaluate them based on our policies, and try
to take the good stuff from this, which there was a
lot of good, and try to move and turn our policy ship
in the direction that's going to, you know, be best
for the American public.

So that's kind of what I wanted to say about
how we're going to use those reports, and I'm happy to


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entertain additional questions.

It might be good to to shift quickly. We've
got about 30 minutes left to talk about how folks
thought the presentations were, what additional topics
we want to talk about for a future agenda, and then
how we want to continue, if at all, the efforts of
these workgroups, or are we ready to sort of sunset
them and then have something different occur. I'm
totally open and really would value the opinions from
the PPDC members on that topic.

So with that, Shannon, we can throw up the
white paper -- whiteboard and kind of start listening.

MS. ASMUS: So, Ed, I would like to ask a
clarifying question. You said, do you want the
workgroups to continue. What would the workgroups do
as they continue? The recommendations are made and so
my thought would be that those that requested or
recommended that there be advisory groups or the
ability to work within the EPA to work on the
recommendations, I think that's different than
allowing a PPDC workgroup to continue in the format
and the charge that we were given. So I guess I would
just like some clarification your ideas of what moving
forward with this workgroup means.

MR. MESSINA: It's really open-ended. So


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when I think about each of the workgroups, and I don't
know because I wasn't in each of them -- I know for
the emerging technology one -- and Mano mentioned it
today -- there was a sense that there was a
recommendation that that workgroup continue.

I know that on that workgroup, you know, the
question is the term of service for the chair. You
know, it's a lot of work and Mano put in a lot of work
and all the chairs did. So if that workgroup were
going to continue, who really wants to take
[connection issue] responsibility for kind of, you
know, convening meetings and I don't think it has to
be anything big, like new recommendations, or it
doesn't have to be as formal. It's just, you know,
meeting, having a place to convene where that topic,
which is such an important topic, can continue to be
discussed. There could be -- you know, EPA is there
at the table. You know, the co-workgroup chair that
can bring that information back to the agency.

And then even like, you know, some additional
prioritization that could happen or feedback from EPA
as to like what we've been doing in the background and
any updates and then we could -- it just -- it seems
to me that at the next agenda in the spring, we'd
still want to talk about some of these issues and see


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where we're at and it would be nice to know that
there's a group of people -- a subgroup that are
interested in that topic. And then, you know, we can
kind of talk about what's been happening.

So hopefully that answers your question, Amy.

And I've got to switch my ear buds, because
I'm losing battery and my sound is cutting out. So
let me transition there.

Does that answer your question?

FACILITATOR: While Ed is transitioning, I'll
just to make a comment that probably the best way -- I
know there's pent-up demand to respond to this
question and any future questions that Ed is going to
discuss during this block. So if you just put your --
like a lot of you are putting your request to speak in
the chat, that way I can get you the order that you
that you spoke up, so to speak.

So Damon, you're up, followed by Iris.

MR. REABE: Yeah, my comment is just to help
move things along. It seems like of the four
workgroups, the emerging technology workgroup formally
did request to continue its work, and this might be a
great opportunity for the other representatives from
the other three workgroups to express an interest --
none of them did in their recommendations, but maybe


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there are some that want to and that would direct
where we're headed here.

MR. MESSINA: And then Charlotte had a
question, Shannon, which if you don't mind answering.

It's just, does the chair of the workgroup need to be
a PPDC member? And I don't know that that's true. I
know that members don't need to be PPDC members, but
does the chair need to be a member of PPDC?

MS. JEWELL: Sorry about that. I didn't have
an unmute option there. No, I don't believe so. I
think that there needs to be at least one member on a
workgroup and that that's the limitation, yeah.

MR. MESSINA: Thanks, Shannon.

FACILITATOR: Okay. Iris, you are up next.

MS. FIGUEROA: Sure. So just two things.

One, just a practical flag for this discussion is that
for many of us on the workgroups, this is our last
PPDC meeting and there will be new members coming in.

So just realistically, how feasible do we think that
between this meeting and the next one when folks are
being onboarded, you know, how's that going to work if
the workgroup composition is changing?

And then I do think that it's really
important, perhaps as a next step, to have the agency
weigh in on the recommendations and what they see as


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feasible and what progress has been made.

MR. MESSINA: Great, yeah. So we'll
definitely put that as an agenda item for the spring
and we'll commit to reporting out.

So, Mano, since your group officially had
talked about moving forward, had the group thought
about who a new chair might be for emerging
technologies group?

DR. BASU: We haven't had that discussion,

Ed, but certainly there are a few recommendations that
I can make and we can circulate it, if those people
are willing. If we don't get a volunteer, we may have
to volun-told someone. So let's wait and see if
anyone from the current working group is willing to
volunteer.

MR. MESSINA: Okay. And then if somebody
wants to put a motion to continue that workgroup and
then have that second and we can kind of review that.

DR. BASU: I am willing to put that motion to
continue the emerging technology workgroup.

MR. REABE: This is Damon. I'll second.

MR. MESSINA: Okay. Would we like to vote on
that now, Paul?

FACILITATOR: Well, we haven't constructed a
poll for that, so -- but let's see how quickly we can


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do that. Sarah can create a poll on the fly, I
think, but we just have to narrate what that motion
is. I'm assuming it's as simple as it sounds. This
is a do we approve the motion to continue this
workgroup into the next year.

MR. MESSINA: Yeah.

FACILITATOR: I think it's as simple as that.

MR. MESSINA: Yes, and then we can use that
for the other --

FACILITATOR: I know I'm putting Sarah on the
spot. So, Sarah, can we create that poll?

And I'm assuming this is also a PPDC -- there
we go. Look how fast that happened.

MS. BROWN: I have a question. This is
Jasmine. As it pertains to the working groups, I
really like the idea of having the PPDC have like a
standing working group that just focuses on emerging
issues and emerging technologies. I just want to
throw that idea out there as maybe for future
discussion.

MR. MESSINA: Yeah, so that's -- so we do
have an emerging technologies workgroup that currently
exists. The question is whether to continue it. It's
hard to have a standing workgroup because folks are
sort of rolling off. So we did it for a year. That's


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sort of the term. So the question now is do we
continue it into the next year. And we will have some
members rolling on and rolling off, and that's okay,
the chairs can kind of handle that throughout the
year. On the emerging issues group, then maybe at the
spring meeting, we can determine if we want to add
another workgroup on just emerging issues and see if
that wants to be convened and who wants to chair that.

So why don't we put that on for the spring meeting
question, if that works.

I'm trying to keep track of the chats. And I
know we had -- we've got a motion and a second or did
we even get a motion and a second on the subject of
continuing the -- which workgroup are we actually
talking about right now?

MR. MESSINA: Yeah, we did. On the emerging
technologies, we did have a second.

FACILITATOR: Okay.

MR. MESSINA: I guess it is -- you generally
ask is there a question the motion before we vote.

FACILITATOR: Right. And it looks like Liza
had a comment. She says I have a comment prior to the
vote.

MR. MESSINA: Sounds good.

FACILITATOR: So I want to make sure I catch


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that.

MS. FLEESON TROSSBACH: Thank you so much.

First, I support all of the workgroups and I think
there's a lot of work to continue to do, you know, in
these important topic areas.

I do have a question about continuing the
workgroup. Ed, you read off and talked a little bit
about the charter and what PPDC does and how these
workgroups fit into it. And so it appears to me that
the current workgroups have completed their charge
based on the previous charge questions and they've
done what they've been asked. And I think prior to
continuing the work of a specific workgroup, I do
think that the EPA should look at the recommendations
of the workgroup and determine which are appropriate
or need continued work and input from PPDC.

And this kind of goes back to some of the --
I think the comment that Nina has made after mine was,
you know, maybe a review of the charge questions and
kind of what particular piece of that needs to be
further, you know, researched or refined.

Again, I support the work of all the groups,
but I do believe that the workgroup needs to have a
specific charge and I feel like from these
presentations that they met the initial charge. And


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in lieu of going down a path that perhaps cannot be a
priority right now or maybe there -- you know, some of
these things are more important that perhaps that
would be a better way to do it and then consider it
again at the spring meeting when the EPA has an
opportunity to at least review, you know, some of the
workgroups' recommendations, or at least perhaps have
like preliminary information about those.

Thank you.

MR. MESSINA: Yeah, thanks Liza.

One advantage of having the workgroups stick
around, even if there isn't a lot of work that the
group needs to do in the next year, which there isn't,
is if we had a question about prioritization
particular topics or, you know, what if we did this
first, if there was some back and forth, then the
workgroup would sort of -- we could kind of convene
the workgroup and then help the agency prioritize or,
you know, come up to speed on some of the things that
are continuing to happen throughout the year.

Otherwise, we're kind of like going inside our little
ivory tower, and then at the PPDC in the spring, kind
of getting the reaction there.

It's just nice -- for me, it's been great to
have that interaction that particular issue on the


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workgroup that I've been on, because there is so much
happening all the time and it is s new and cutting
edge.

MS. JEWELL: Ed, I'm sorry to interject.

This is Shannon. So I do want to point out a FACA
issue here, and it's that working groups are to have
specific time-limited charges, and this is part of the
question that's come up several times during the
meeting regarding voting. It's kind of in the vein of
why would the PPDC vote on this. The purpose of
working groups is to prepare documents, prepare ideas,
research, et cetera, for the PPDC that has been
invited by the EPA Administrator. Working groups
don't have to have all of the same, you know, public
meeting requirements, et cetera.

And so that is one thing we're going to want
to be very careful around is that it's a time-limited
and very specific kind of charge that working groups
do for the overall PPDC.

MR. MESSINA: Yeah. So the new charge, if we
were looking for a charge, would be, you know, to
consult with you on the recommendations that were
presented and to help prioritize them. So that could
be a charge, if we wanted to, you know, continue that.

Again, this is part of that discussion.


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FACILITATOR: Ed, one possibility, if it is
potentially informative to EPA to have these
workgroups kind of available on call, so to speak, but
in the same mode that you're talking about, you could
just maybe by default say that we're not going to
sunset these workgroups right now. We want them to
continue to exist over the next few months in a
consultative way, you know, for your purposes, in
other words, as opposed to their purposes.

I don't know. I'm just trying to think of a
way to make this easy so that -- like, what, what, if
two workgroups decide they're done, you know, are you
going to give them a chance to say, we're done, we're
not going to consult anymore or do you want to appeal
to them to stay available for the next few months
while EPA considers these recommendations and may need
to come back with some additional conversations or
dialogue?

MR. MESSINA: Yeah. So again, certainly, for
me, the emerging technologies workgroup was really
great and really helpful. And I think as we think
about what we want to do next there, that's going to
be helpful. For the other three, I wasn't as close,
and so I would rely on that the chairs of those groups
and the members to see if a similar model works for


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them, or if you guys want to take a break from the
workgroups and don't feel like the need to meet, then,
you know, that works as well. It's kind of a
discussion So yeah, that would be my [connection
issue]. That would be my --

FACILITATOR: So we could poll real quick,
and I don't mean like the actual official poll, but
what have we just got some comments from the other
workgroup chairs, at least as a start from the
workgroup chairs, to give you some feedback right now
on that topic.

MR. MESSINA: Yeah, and maybe how about from
the farmworker and clinician training workgroup.

Yeah, what are your thoughts there on continuing the
group or not?

FACILITATOR: I see a comment from Amy, but
others may -- Amy Liebman.

MS. TREVINO-SAUCEDA: Okay, this is Mily. I
feel the same way as Amy and the whole group, that we
have finished with our charges and -- but I'm just
concerned in terms of what's going to go next. That's
why I was raising my hand. And it was my
understanding that every single group was supposed to
come up with recommendations, and my concern now is
that wasn't the case. Nonetheless, it's just up in


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the air in my head right now.

But we have finished, but it's more of a
concern in terms of what's going to be a followup.

And if some of the people that are representing
farmworkers that are leaving, is EPA -- is the PPDC
going to make sure that we do get the same kind of
representation. Sometimes I feel that because we're
doing -- right now, I'm actually also doing the
evaluation -- as going through a process of voting,
sometimes I feel like we're outvoted. Yesterday, I
think there were only 16 people that voted, when today
how many other people were voting. So it's like it's
unbalanced. That's that's how I feel.

MR. MESSINA: So I'm getting the sense -- I
just want to make sure I understand -- that the
farmworker groups feel like they don't have a need to
continue to keep the workgroup formed because you guys
submitted your recommendations and we can kind of work
from there. And then maybe in the spring, if we need
to reconvene, we can continue, but certainly this is
going to be a big topic. And as I mentioned, you
know, we're going to have our quarterly meetings with
the farmworker group. So a lot of these issues, I
imagine, that they're not a spillover and we talked
about that as well.


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MS. TREVINO-SAUCEDA: Yes, I mean, in terms
of the charges that were posed, we did finish with
that. It's about, you know, the followup. And if the
working group will continue, I see it more in terms of
the implementation, not necessarily working on more
charges. I mean, I don't know how else can we explain
more in terms of everything that was already
explained. If you want more thorough, then we can get
together and explain that.

MR. MESSINA: Okay, well, I'm comfortable
with that. How do other BBC members feel where there
isn't a need to continue the subgroup, but we'11
continue to talk about it at the larger PPDC and
continue to talk about the issues at the farmworker
quarterlies.

Anybody else want to weigh in on that?

(No response.)

MR. MESSINA: Okay. How about the emerging
viral pathogens group?

MS. JAIN: Ed, I will speak as chair.

As far as our initial charter is concerned,
we have completed our mission of reviewing and putting
together lessons learned. So we have a series of
recommendations. One of those recommendations,
however, was to pull together an implementation


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workgroup. So that would be a separate charter to
collaborate and assist the EPA in prioritizing and
implementing our recommendations.

I don't have -- you know, I'm not clear as to
who would chair that group. It may be me; it may be
somebody else, but we do have a quorum of individuals
that would like to participate.

MR. MESSINA: So would you like to put that
for the spring meeting and think about whether we
initiate an implementation group or do you feel like
there's enough to talk about today whether we should
initiate that implementation group?

MS. JAIN: I think we have more than enough
information to move ahead and take a vote today on
forming that group.

MR. MESSINA: Okay, wonderful. Thank you.

So we'll put that as one of the voting questions.

For the resistance management group --

UNIDENTIFIED FEMALE: I'm sorry. David had
to step away so he asked me to comment. It was in our
recommendations that the group that was formed
continue more as an information group like was
pointed out with the last group, and also set up
stakeholder groups because we believe in our
recommendations that our group is a good group for


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help with implementation, clarification, prioritizing
some of our recommendations. But it's very important
as well that stakeholder groups be allowed to chime in
on some of the issues and some of the ways we can
implement moving forward.

MR. MESSINA: And would you like to put a
vote today to continue?

UNIDENTIFIED FEMALE: Yes, I believe that if
you're voting on the other ones, we have enough
information to vote on continuing today.

MR. MESSINA: Okay. So, Paul, do we want to
do a poll for the three groups each individually? We
can call them out and then move on, and then we can --
for folks that want to build the future agenda, as,
you know, prior to our PPDC meeting we put out a call
for agenda items, we'll continue to do that for the
members of the PPDC group. And then if you'd like,
and then throughout the day, if you want to put
something in the chat to talk about future meetings.

And then, I think, depending on how the vote goes,
we'll definitely have those three topics on the agenda
for the spring as well.

So I'm pretty good with that piece. So if
folks want to move towards voting, I'm good with that.

And then if there's any loose ends or things people --


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other questions, we can kind of open the floor there
as well.

FACILITATOR: Okay. So let me just make sure
I understand, Ed, so we do this -- we just heard from
four chairs, three of whom are saying move forward.

We heard one voice from each of the workgroups. We
also heard from the fourth that, no, we're good, we're
done with our work. Is the voting -- now the PPDC is
actually voting on whether to agree with those chairs
or not?

MR. MESSINA: Yes, so just for the three

groups.

FACILITATOR: Okay.

MR. MESSINA: We would need somebody to make
a motion and, in fact, we have the motion for the
emerging technologies group. We had a second. That
full was put up and is still up and so we could go
ahead with that being the first one, and then do the
other two in the time we have left. And is there --
but before we do that, are there any questions about
that particular motion and that second? So this poll
that you've got in front of you now would just be for
the emerging technologies workgroup. Are there any
questions about that or comments before we --

MR. FREDERICKS: And this is Jim Fredericks


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with MPMA. You're reading my mind on the questions
because it feels -- although it was the recommendation
of our workgroup that it be continued, it almost -- it
feels a little bit strange for me to vote on
continuing a workgroup that doesn't really have a
charge. And I get the idea of a consultancy or an
implementation, but I'd hate to have work these
workgroups last forever when maybe there's other
workgroups that could be formed.

And so I just want to put that out there. I'm
struggling with that as I'm trying to decide which
button to click on this end. (Inaudible) others may
be feeling that way.

MR. MESSINA: (Inaudible). Yeah, that's why
we asked the question. So would like helping EPA with
implementation of the recommendations be a potential
charge. That was one of the charges we've heard from
the emerging viral pathogens workgroup.

MR. FREDERICKS: Perhaps. I think that's
something to discuss. I feel like my video is still
on, so you and I are having this conversation
together.

MR. MESSINA: That's fine.

MR. FREDERICKS: (Inaudible) does that look
like, right? So what does that -- helping with the


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implementation look like? I love the idea of
stakeholder engagement. I love that idea. I'm trying
to figure out how the workgroup actually does that at
this point.

MR. MESSINA: Mm-hmm.

MS. JAIN: Jim, maybe I can jump in since the
emerging viral pathogens group was brought up. So we
have, you know, a 20-page report we put together.

There are probably 5 0 recommendations there. They
need to be prioritized, but we couldn't do that
independent of feedback from the agency. So we'd like
an implementation group so we can work alongside the
agency to prioritize and then develop whatever needs
to be developed to implement, whether that be that
guidance documents need to be authored whether it
means that we need to petition for rulemaking,
whatever the case may be.

So the report alone isn't going to do enough
because it really is almost too much for the agency to
read through and assimilate. So I feel like it's our
continuing job to talk them through and work through
that process with them.

MR. FREDERICKS: Okay, yeah. And so I think
a well stated charge like that is appropriate to make
a decision.


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MS. JAIN: Okay, great.

Shannon, I hope you noted that for the point
when we may vote on the continuation or actually the
new charter for the emerging pathogens group.

MS. JEWELL: I'm sorry, could you repeat
that? I got another message and I did get pulled away
for just a second, if you wouldn't mind repeating,

Komal.

MS. JAIN: Don't worry. When we get to my
group, I'll restate it.

MS. JEWELL: Thank you so much.

MR. MESSINA: All right, so can we take the
polling that's -- has anyone voted on this -- or the
voting hasn't opened up yet, correct, which is good.

Okay. So for the emerging viral pathogen
workgroup folks and to respond to Jim's question, do
you have a charter-like proposal for what you would
continue to work on?

FACILITATOR: I just want to -- this is Paul.

I just want to jump in. I'm sorry, Ed, to interrupt.

I'm watching the time. At 4:30, we're opening a
public comment period.

MR. MESSINA: Yep.

FACILITATOR: This is a complex topic that
we're bringing up here and with four separate votes,


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and now we have the concept of we want to combine
charters with the votes. It's getting a little bit
complex. Just from a procedural perspective, and I
see people chiming in quickly here, I haven't had a
chance to speak on this topic. So there's some energy
around this topic and it's (inaudible) clean-cut as --

MR. MESSINA: So why don't we do this. Yeah,
there's not poll open at the moment. I think what
we'll do is, at the spring meeting, we'll have this be
a topic and maybe, you know, as the workgroups are
finishing their work and -- which they've done if any
of them want to continue, we can think about what good
charge questions would be to continue [connection
issue] but we can pick us up in the spring. I agree
it's complex and I wasn't sure we would finish all of
this, but I think for the wrap-up as we continue to
think about, you know, we've got these great
workgroups, we've got these great connections. How do
we maintain that momentum where we'd like and then how
do we -- as folks highlighted, there's a lot of
information for EPA to go through here. How can the
workgroups sort of help?

So we'll add that as a topic for the spring
session and, in the interim, you know, we all have
each other's phone numbers if there's questions or


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comments to talk about.

MS. JAIN: Ed, I'm sorry. It's Komal again.

Just to be clear, we're not saying then these
workgroups have been sunset, right? I mean, we can at
least agree that until a decision's made in the
spring, we can move forward.

MR. MESSINA: Yeah, we guys can keep

chatting.

MS. JAIN: Okay.

FACILITATOR: And EPA has the option --
MS. JAIN: And to engage with EPA? Okay.

FACILITATOR: Oh, go ahead.

MS. JAIN: Paul, I think you were getting to
my point. And move forward with engagement with the
EPA.

FACILITATOR: Exactly.

MR. MESSINA: Yep.

MS. JAIN: Okay.

MR. MESSINA: Where there's conversations
that need to happen with the folks that put the
recommendations forward, we can definitely talk with
you. So there's nothing prohibiting --
MS. JAIN: Okay.

FACILITATOR: Exactly.

MR. MESSINA: All right. But we'll


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definitely, you know, from a formality standpoint, put
this is a topic in the spring.

And so let me just conclude, great meeting,
great topics. You know, a lot a lot of discussion
this time. I feel like, in the past, you know, when
we were starting virtually, it was hard to get people
to speak up or to call, but this meeting was really
great. Lots of great comments and as you see we sort
of ran out of time to continue talking about it. But
that's great because we do meet periodically and I'm
looking forward to the spring session and we'll work
on building yet another great agenda that's
informative, impact, and we'11 get to continue to work
on these issues.

So thanks again to the workgroups, everyone
that participated [connection issue] just really great
things for us to consider [connection issue]. So
thanks, everyone.

With that, I think we're ready to go to the
public comment session, Paul.

FACILITATOR: Right. Thank you. Thank you,

Ed. And thanks to everyone, also. Ed, please stick
around. I think you're going to officially close the
meeting at the end of the public comment period.

So you're not quite off the hook yet.


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MR. MESSINA: Yeah, I'll be here. I want to
hear the public comment, so I'll be sticking around.

FACILITATOR: Perfect. Perfect. So we're
now in that public comment period, which is part of
the agenda yesterday and today, an opportunity to hear
for the public on any issues that they have associated
with pesticides, pesticide-related programs. We've
got a few attendees who are registered. Just like
yesterday, we may not have all of them on the line at
the moment. So we are going to flash a slide up here
and maybe it's already up -- here we go. We're going
to flash this slide and I'm going to call on these
people in sequence. We will be able to tell if you're
here or not. And Sarah and I will interact kind of
live on that topic.

We'd ask you to limit your comments to, you
know, two to three minutes, and we would also just
reiterate that this is for us to receive -- for EPA
and the PPDC to receive your comments. It's not a
discussion nor is there an opportunity to ask
questions and expect answers live. You can certainly
ask rhetorical questions and you always have the
opportunity to send in your comments in a more formal
way in writing to Shannon Jewel at EPA. That's
Jewell, J-E-W-E-L-L, .shannon@epa.gov.


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So with that, I think we'11 move into the
public comment period. We have eight people listed.

And, Sarah, I'm just going to go down the
list unless you want to tell me who's actually here.

FACILITATOR 2: Sure, yeah. So the first
person I see here in the meeting is the fourth person
the list, Jessica. I don't see any of the other three
-- the first three people on, but certainly if I've
missed your name, feel free to let me know in the chat
and I will make sure that you are unmuted and can make
your comment. But the first person I see is Jessica
Ponder.

So I can go ahead and unmute your line,

Jessica.

FACILITATOR: Thank you, Sarah. And let's
have an audio test for Jessica real quick.

MS. PONDER: Can everybody hear me?

FACILITATOR: Just barely. Try again.

JESSICA PONDER: I can sit a little bit
closer to the computer. Did that help?

FACILITATOR: That didn't help a whole lot.

Maybe other people could give some feedback to Jessica
on her audio.

MS. SANSON: Turn off the —

FACILITATOR: I here very faint coming from


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Charlotte.

Jessica, could you -- is there any way to
move -- I'm not sure if you're on a laptop. Is there
any way to move closer to your device, whatever it is.

MS. PONDER: Is that any better?

FACILITATOR: No, it's not. Now, we can go
ahead and take your comments. I'm not sure if the
recording is going to pick it up and let's actually
make sure that we're -- that the recording is in
progress. It is. Okay. That's good. So I'll ask you
to make your comments. We'll strain and listen, but
you might consider -- if you've got written comments,
you might consider sending those in for the record.

MS. PONDER: Can you hear me now?

FACILITATOR: Wow. That's a complete
difference.

MS. PONDER: Fantastic. I think it was my
headset. I apologize.

FACILITATOR: Okay. You're up then, Jessica.

Your name and the organization that you are
representing today?

MS. PONDER: Sure thing. So thank you,
everyone, for this opportunity to provide a public
comment at today's meeting. My name is Jessica Ponder
and I am commenting on behalf of the Physicians


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Committee for Responsible Medicine. The Physicians
Committee is a nationwide nonprofit organization
representing over 17,000 physicians and more than
175,000 members, who advocate for efficient, effective
and ethical medical and scientific practices. These
comments are my own professional opinion as a PhD
toxicologist and also the input of my colleagues at
the Physicians Committee.

First, I want to think the PPDC for their
dedication to working together to advanced the
strategic goals of the EPA, and I also want to echo Ed
Messina's admiration for this cross-section of
stakeholders as an example of how government and
engagement should work. We, at the Physicians
Committee, were also happy to hear from Mr. Li the
OSCPP is ready to make progress in addressing health
disparities and addressing environmental justice. As
engaged stakeholders, we appreciate that Mr. Li
himself takes time to review public comments that play
a critical role in this committee.

As these issues are important and stakes are
high for everyone involved, I will be practicing what
I learned yesterday from Ms. Buhl about risk
communication in today's comment. We understand that
the PPDC has had an unprecedented workload responding


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to the pandemic and we applaud your resilience and
efficacy in handling the insurmountable number of
pesticide registrations. Emergencies are always
effective tests of character, and I think in light of
where we are today, that Ed's comment about the
successful collaboration of the PPDC over the past
year speaks volumes about that character.

And as we all start to move forward, it is a
good time to reflect on lessons learned from the
COVID-19 pandemic. That evidence (inaudible) is still
needed.

Key takeaways that have been covered in this
meeting have a common thread, that protecting
vulnerable populations in the 21st century requires an
agency-wide commitment to new methodologies, not only
for the dissemination of pesticides, but for
understanding the health risks from chemical
exposures, not just from the perspective of laboratory
control, but in real-world scenarios, with real-world
human variability.

I do want to highlight a few examples of the
drawbacks of an overreliance on animal testing for
understanding health risks that we've heard in the
past couple of days. We still don't have a good
understanding of the effects of chronic low dose


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exposure to agrochemicals for rural communities and
farmworkers. We don't have a system in place to
understand chronic exposures of children to new
disinfectants in schools. We don't understand how
chemicals disproportionately impact marginalized
individuals and communities. And last, but not least,
we still need to be able to respond to risks and make
decisions in real time with real limitations on
resources.

The Physicians Committee has long been an
advocate of putting agency resources behind the
development and implementation of modern testing
methods, as outlined in the EPA's new approach methods
work plan published last year. We hope that Mr. Li,

Ms. Messina, and others in leadership appreciate that
in vivo testing cannot address the myriad of
challenges involved in protecting health and the
adoption of new technologies for characterizing risks
and hazards is paramount to addressing the very real
threats to humans and the environment in real time.

Understanding real-world exposures are a
critical first step in next generation risk
assessment, and the PPDC has emphasized the important
role of communication and outreach for understanding
pesticide exposures in the population's most affected.


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We applaud the PPDC for these efforts and we encourage
the EPA to invest similarly in the in vitro methods
that allow us to characterize human responses and
human variability, and also the in silicone methods,
including read across that allow us to make the most
of the data we already have, to characterize the risks
of data poor pesticides and new formulations.

And finally, we appreciate the agency's
efforts to eliminate duplicative in vivo testing
through the implementation of dermal toxicity waivers
and, in particular, we encourage the EPA to take pride
in these efforts and not only report the number of
animal lives spared from testing, but also the
resources saved by these policies. We would like to
see the EPA formally announce policies like these and
share these positive effects with all stakeholders to
encourage innovation and continued progress.

And as the PPDC plans the spring meeting
agenda, we encourage members to think about how to
accelerate the implementation of new approach
methodologies to achieve the agency's strategic goals
to protect human and environmental health and work to
achieve environmental justice in the 21st century. It
is critical that the advancement of new approach
methodologies be included as a focus of this meeting.


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Again, thank you for the opportunity to
comment today and thank you for your attention.

FACILITATOR: Thank you very much, Jessica.

Thank you for your comments.

Sarah, is Nina Wilson available?

FACILITATOR 2: Yes.

MS. WILSON: I am.

FACILITATOR: Oh, excellent. Okay, Nina,
you're off mute and you're live. Just your name and
your organization you represent for the record.

MS. WILSON: [Connection issue] Alliance
where I serve on the board of vice chair and I have
been a member of the PPDC for six years. So this is
my twelfth and last meeting at the PPDC and I want to
thank both EPA and the current administration and the
past and all the fellow committee members for their
time and dedication, and for all those that I got to
meet and talk about my passion, which is the
biological products industry.

I think it's great that Ed is mixing things
up and keeping everybody on their toes. You know, it
is a little bit disconcerting, but I can kind of see
where he's trying to go. And I agree, the
presentations that the workgroups had were great
because I think they had to clear charge questions,


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they had the appropriate expertise, and they obviously
put a lot of work into what they did and I think it
really was one of the better set of presentations that
I've heard over the last few years.

I hope EPA can use the recommendations in a
tangible way. You know, I always listen to them and
think back as to my own industry and what we can do to
take those sort of viewpoints and weave them into some
of the work that we're doing. And I think that -- I'm
hoping that the feedback -- and I think Ed went there
and didn't get a chance to really talk about that
tremendously, but it sounds like it will be done in
the future, that the feedback that EPA can give the
PPDC as to how useful they are -- how useful some of
these recommendations are and what they can work with
and having the PPDC workgroup members be a resource to
them, without it being a huge burden to EPA for those
-- for that feedback, I think is important.

I think the one common thread in all the
disparate topics that we've heard and that was pretty
nicely illustrated in the risk communication
presentation, most of our topics seem to fall into
discussion the outcome of assigned space risk
assessment. And I know EPA, based on some other
comments, has, you know, tried to have some


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presentations and some training on what a risk
assessment is, but I think it is helpful to have
committee members. It's difficult to have a
discussion for those members who are well versed in
both the policy, as I know this is a policy and not an
SAP, but for both policy and science behind the policy
and what the risk assessment means. There are
obviously some major disconnect about what a
refinement is or how degradation is used and worst
case scenarios.

But, listening to the evolution of the
workgroups, perhaps that's a place where the rubber
meets the road where the policy and the science meets
and I actually am pleased to hear that there was some
disparate sort of recommendations from the group
because that's where, you know, that's where you get
some of the good information and where you learn and
where you try to figure out why is -- somebody or
someone has the different opinion than mine and I
think that's where your communication really starts.

So I, again, appreciate all the hard work
that EPA did to keep this going and I wish everybody
good luck and I hope to see you soon.

FACILITATOR: Thank you, Nina. Thank you
very much for your comments.


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I believe the next person that's on this list
that had registered that is actually present in the
meeting currently is Ray McAllister from CropLife.

America.

MR. MCALLISTER: Good afternoon. Can you

hear me?

FACILITATOR: Yes, sir.

MR. MCALLISTER: Well, thank you very much
for this opportunity to comment.

Labels were a central theme in the
recommendations of all of the workgroups, as well as
other presentations over the past few days. There are
several aspects of labels that would benefit from a
comprehensive review across stakeholders, content,
format, order of information, means of distribution,
et cetera, et cetera. Labels have been subject matter
for previous PPDC workgroups as well in bits and
pieces.

State regulators have an abiding interest in
the subject. In the mid 1990s, a consumer label
initiative was set in motion by then EPA
Administrator, Carol Browner, who was dismayed by
pesticide labels she found in the local hardware
store. Its findings are likely still relevant today,
and perhaps OPP wearies of this subject.


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We understand that the OPP electronic label
project, or OPPEL, is planned for public launch early
next year. However, the current status of that
project is something of a mystery, and closer
collaboration with the owners and authors of those
labels is essential for a successful launch. It is
very important for all to understand, registrants must
put on the label the statements and information
required by EPA's reviewers in the order, format, font
size, and even color that they prescribe.

We recognize the critical need for
improvements to readability and comprehension, but we
need the cooperation of EPA reviewers, management, and
leadership, and the recognition of their influence
over the end user's experience with the label. We
would support a new PPDC workgroup or other
appropriate forum to further explore label improvement
and its multiple facets.

Thank you.

FACILITATOR: Ray, thank you very much for
your comments.

I'm checking and I think William Jordan is --
let me just make sure I get this right -- is
available. Is that right, Sarah?

FACILITATOR 2: Yes, William is online.


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FACILITATOR: Very good. William, you're up.

MR. JORDAN: Thank you very much for the
opportunity to comment. I've been participating in
PPDC meetings for over 25 years, first, as an EPA
employee, and then more recently as a member of the
public, and I've got to say that this meeting of the
last two days has been one of the most productive that
I've seen, and I commend the workgroups and the EPA
folks who work with them on having such a productive
meeting.

And I think the secret to it is bringing
together stakeholders from different perspectives to
pool their knowledge to dive into the issues in depth
to come up with practical suggestions. And that's
really been evident and I think that this kind of
collaboration is a good sign for the health of this
particular effort of the PPDC, and I think that the
time is right, as Ray McAllister suggested, for the
PPDC to have a labeling workgroup that tackles some of
the cross-cutting issues that were pointed out by each
of the four different workgroups.

So I hope that the next PPDC meeting looks at
developing charges for that workgroup and sets them to
work to see if they can bring the same kind of
productivity that we've seen in these first four


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groups.

I want to comment about the other workgroups
and their reports, starting with the emerging
technologies group, and I want to do that in the
context of the hierarchy of control. As some of you
may know, public health and public safety officials
recommend a series of different types of controls to
deal with risky situations, where possible eliminate
the risk or substitute something that's safer. If
those things can't work resort to engineering controls
making it -- the risk as small as possible, or
administrative controls changing the way work is done,
or finally using PPE. The last resort should be PPE
in this hierarchy. Changing the way of work is the
next choice and a better choice. But the best choice
is engineering controls. And the emerging technology
group pointed to lots of different technologies that
would be safer engineering controls.

I encourage people to look at those. I just
want to give you an example using the pesticide world.

Farmworkers go into sites that have been treated with
pesticides and they come in contact with the foliage
of crops or soil that have pesticide residues.

They're exposed, and if the exposure is too high, then
they get sick. And that's not a good thing.


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The way that's dealt with in a lot of cases
is by using PPE, cut down on exposure by blocking it
from getting to people. But there's a better way,
like restricted entry intervals which say don't go
into the site until the residues have declined. The
best way would be to use even less pesticide through
the see-and-treat technology, for example.

So I encourage the people at EPA not just to
wait until registrants come to you and propose ideas
about using these new emerging technologies, but
actively look at requiring them to get away from PPE,
get away from administrative controls, and make the
workplace safer in ways that are consistent with this
hierarchy.

And another aspect that I wanted to point to
that got little attention, but Greg Watson mentioned
it, and that is again labeling. The emerging
technologies that we have today in our phones and the
internet system, and the ability of computers to sort
and provide information in an instant means that we
ought to be bringing -- the world ought to be bringing
labeling information to users in a much more user-
friendly fashion than the labels that are poorly
formatted, they're long, where information is hard to
find. So emerging technologies really needs to look at


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labeling, as well as all these pesticide delivery
mechanisms.

I want to shift over to resistance
management. The workgroup there, I think, would
benefit from having more folks from environmental
advocacy and worker advocacy organizations
participate, and I think you would see a request on
advocacy for even more aggressive action. EPA had, I
think, one of the strongest sets of resistance
management requirements imposed on a registrant when
they issued the registration for Enlist Duo.

Getting those kinds of programs applicable to
all of the different products that have resistance
management issues would be a good idea. At the very
least, at the very least, EPA should require all
registrants to have the language that's recommended in
the PR notices about resistance management practices.

It seems to me just unexplainable and indefensible for
some registrants to do the right thing and put those
statements on their labels, but other registrants, for
whatever reason, decide not to do that. That creates
an unlevel playing field for registrants and EPA
should step in and compel everybody to do that.

The last topic I want to talk about is the
emerging viral pathogen workgroup. I thought their


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recommendations and their work was really astounding
and great, and they commended OPP's Antimicrobials
Division for their efforts, and I also want to just
join and say that they did a terrific job, too, and
continue to do a terrific job. The American citizens
should be really proud to have such hardworking, smart
folks putting their minds and their energies to
addressing the pandemic.

The one thing that the emerging pathogens
workgroup did not talk about is the universe of
products called pesticide devices. There are a lot of
pesticides out -- pesticide devices in the marketplace
today that are making claims that are unsubstantiated,
that are exaggerated about their ability to address
pathogens and EPA, I think, needs to look hard at
those products, and where they find those products are
making statements that are misbranded, use their
enforcement authority to address and get those
products off the market.

Fortunately, EPA's Office of Research and
Development has studied the efficacy of these products
and demonstrated that the really just don't work. And
a lot of people are losing money and a lot of people
are relying on these products for protecting them from
exposure to pathogens and they're not getting what


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they pay for and they may be getting sick instead. So
for those reasons, I think that it's important for
that group to continue to work and find ways to
address the device universe, as well as pesticide
products.

I want to thank you all for the opportunity
to comment and wish all of you good luck. Thank you.

FACILITATOR: Thank you very much. Mr.

Jordan. Appreciate it. Thanks for your comments.

We have one final speaker and hope I get the
name right, Julie -- it's Julie Spagnoli (phonetic)

MS. SPAGNOLI: Can you hear me?

FACILITATOR: Yes.

MS. SPAGNOLI: Okay. Actually, my comments,
some of it has already been brought up. Like Bill,

I've been around for more than 25 years participating
in these committee meetings, and 25 years ago, I also
participated in an agency initiative known as the
consumer label initiative. It was a partnership of
EPA, consumer products, marketers, and other
stakeholders. And we did exhaustive consumer
research, both qualitative and quantitative research,
into consumers' understanding of label language, how
they use label language, what they read, what they
didn't read, what was important and just their, you


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know, basically understanding.

So from that effort, there was a number of
recommendations made to the agency and many that were
adopted. First aid was adopted from statements of
practical treatment. Inert ingredients was changed to
other ingredients. 800 numbers were added. We also
had a project, we were working on developing a box on
the -- it was called either product facts or facts
box, which would be similar to the drug facts box on
labels. We adopt -- we were working on this, but no
real standardized format had ever been finalized.

However, a lot of companies did kind of adopt these
kind of formats, if you look at a lot of -- especially
lawn and garden products that have the booklet labels,
a lot of them will have a product facts or quick facts
box on the outside of the label. And, you know, I
definitely support efforts to continue that work and
maybe come up with standardized information and
formats for that.

And then also we came up with a lot of
formatting and other types of recommendations, going
from block texts to bullet points, and putting things
in boxes to separate information and make it clearer,
you know. And so there was a lot that came out of
that. And that research is still available. It's in


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the agency's archives. And those recommendations and
the work that that group did, you know, like many
other things, a new administration had come in and
some of that work was just kind of left by the wayside
as people changed and priorities changed and FQPA was
being enacted.

So I would just encourage if a label group is
initiated and they're going to look at consumer labels
that they may want to go back and look at that
research, because I think a lot of it is still very
valid because it really had more to do with, you know,
what's important to people. And I don't think a lot
of that has really changed.

And I wish everyone good luck on that,
because it was a great project and I'd like -- I
wouldn't mind to see it continue.

FACILITATOR: Thank you, Julie. Thank you
very much for your comments.

Sarah,. I'm just going to check in with you
one last time. We've come to the 5:00 mark. I've
been watching the participant roster. I don't see
anybody else's name that's listed here present on the
participant roster. Maybe you can correct me if I'm
wrong.

FACILITATOR: No, that's correct. I don't


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see any of them on the line.

FACILITATOR: Okay, very good. So that
concludes the public comment portion of the agenda.

And before I hand this over to Ed to the
formally close the meeting, I'd just -- on behalf of
Sarah Chadwick, who's been in the background here
helping us make it through the technology for the last
couple of days and on behalf of certainly many of my
colleagues at Apt Associates that have supported the
EPA mission for decades, thanks for entrusting us to
support, Ed, you, and Shannon and the workgroups and
the PPDC for these important public meetings. We wish
all of you well as you continue to evaluate and
prioritize these really important recommendations. So
thank you very much.

And, Ed, it's over to you.

MR. MESSINA: Thanks, Paul.

So let me thank a couple of individuals and
call them out. I know the workgroup leaders did an
amazing job, but I did want to acknowledge and
recognize a special thank you -- the slide is up there
-- to Lori Ann Burd, Center for Biological Diversity,

Komal Jain, ACC Center for Biocide Chemistries, and
Amy Liebman, Migrant Clinicians Network, and Nina
Wilson. You did get to hear from many of them today


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and they are finishing out their term-limited six
years with PPDC. So I really appreciate [connection
issue] service to this group.

Lori Ann, I noticed you put something in the
chat and wanted to see if you wanted to make any
statements. We could kind of extend the public.

Comment period or if you felt like what you provided
in the chat was enough.

MS. BURD: Oh, that's okay. Thanks.

MR. MESSINA: Okay. So thank you all for
your service. Thank you for a great meeting. To all
the workgroup chairs again, to Paul and Sarah and
Shannon Jewell, a special thanks for her coordinating
this meeting and doing a great job reaching out and
providing all the materials in a timely manner.

I look forward to the next time we can get
together and appreciate your thoughtful comments
throughout the entire day, the public comments, and
the workgroup recommendations. So we will convene in
the spring and reach out. Until then, have a
wonderful evening, stay safe, and we'll be in touch.

Take care of everyone.

(The meeting was concluded.)


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