1 2 U.S. ENVIRONMENTAL PROTECTION AGENCY 3 4 PESTICIDE PROGRAM DIALOGUE COMMITTEE MEETING 5 6 7 8 Thursday, May 13, 2021 9 11:00a.m. 10 DAY TWO 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 ------- Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 PESTICIDE PROGRAM DIALOGUE COMMITTEE ROSTER May 2021 NAME AFFILIATION User/Grower Groups/ Farmer Representatives Amy Asmus Jim Fredericks Mark Johnson Patrick Johnson Dominic LaJoie Lauren Lurkins Tim Lust Gary Prescher Caleb Ragland Damon Reabe Tim Tucker John Wise Weed Science Society of America National Pest Management Association Golf Course Superintendents Association of America National Cotton Council National Potato Council Illinois Farm Bureau National Sorghum Producers National Corn Growers Association National Soybean Association National Agricultural Aviation Association American Beekeeping Federation American Honey Producers Association IR-4 Project For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 NAME AFFILIATION Environmental/ Public Interest/ Animal Welfare Groups Lori Ann Burd Center for Biological Diversity Gina Hilton PETA Science Consortium David Shaw Mississippi State University Christina Stucker-Gassi Northwest Center for Alternatives to Pesticides Edward Wakem American Veterinary Medical Association Farmworker Representatives Iris Figueroa Farmworker Justice Amy Liebman Migrant Clinicians Network Mily Trevino-Sauceda Alianza Nacional de Campesinas, Inc. Public Health Representatives Joseph Grzywacz Aaron Lloyd Daniel Markowski Department of Family and Child Sciences Florida State University Lee County Mosquito Control District Vector Disease Control International For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 NAME AFFILIATION Chemical and Biopesticides Industry/Trade Associations Manojit Basu Steven Bennett Gary Halvorson Komal Jain Karen Reardon Charlotte Sanson Nina Wilson CropLife America Household and Commercial Products Association Council of Producers and Distributors of Agrotechnology Center for Biocide Chemistries American Chemistry Council RISE, Responsible Industry for a Sound Environment ADAMA Biological Products Industry Alliance For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 NAME AFFILIATION State/Local/Tribal Government Ruben Arroyo Carol Black Jasmine Brown Liza Fleeson Trossbach Federal Agencies Walter Alarcon Douglas Burkett Ed Messina (Chairl Sheryl Kunickis Riverside County Department of Agriculture and Measurements Standards American Association of Pesticide Safety Educators Tribal Pesticide Program Council Association of American Pesticide Control Officials National Institute for Occupational Safety and Health Centers for Disease Control and Prevention Armed Forces Pest Management Board Office of Pesticide Programs Environmental Protection Agency Office of Pest Management Policy US Department of Agriculture For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 6 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 NAME AFFILIATION 2 Charlotte Liang Center for Food Safety and 3 Applied Nutrition 4 US Food and Drug 5 Administration 6 Cathy Tortorici Endangered Species Act 7 8 Interagency Cooperation Division 9 National Oceanic and 10 Atmospheric Agency 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 7 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 PROCEEDINGS 2 DAY TWO - MAY 13, 2 021 MR. MESSINA: Why don't we throw up the 3 4 agenda so folks can see it and I can make sure we're 5 looking at the right one. 7 emerging pathogens, Komal Jain, Taj ah Blackburn, from 8 11:00 to noon. Then we have our pesticide resistance 9 management workgroup update with David Shaw, Bill 10 Chism, Alan Reynolds. And then we have the PPDC 11 member presentations on stakeholder interests. We're 12 going to hear from Charlotte Sanson and Mano Basu 13 from ADAMA and CropLife. 14 We'll have our lunch break, and then 2:00 15 p.m. promptly for about 15 minutes, we'll hear from 16 Michal Freedhoff -- I'll do a brief introduction of 17 her -- who's the current principal deputy assistant 18 administrator for the Office of Chemical Safety and 19 Pollution Prevention. 20 2:15 to 3:00, we'll have another 21 stakeholder presentation. We have the ongoing FIFRA 22 ESA consultation work from Cathy Tortorici from NOAA, 23 and then ESA consultations and species protections 24 from Lori Anne Burd from the Center of Biological 25 Diversity. We'll take some questions and comments 6 So we've got welcome. We've got the For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 8 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 from members for that time frame. Then we'll close 2 it out with what do we expect at the next meeting, 3 kind of really hear from you on topics you'd like to 4 hear, any deliverables or to-dos, takeaway actions 5 that we need to work on, and we can have Shannon 6 maybe review her list as well. And then we'll have 7 time for public comments and then we'll adjourn at 8 4:00. 9 So I would say, you know, make sure if 10 you're wanting to speak at the public comment 11 session, you provide your email and send in your 12 name, and we'll add you to the list and then we'll go 13 through it at 3:30. So welcome your input. And with 14 that, I think we're probably ready to begin. 15 MR. ANNINOS: Excellent, Ed. Thank you 16 very much. And, again, great day yesterday. We have 17 another one in store for you today. We were able to 18 stay on schedule very well yesterday, so I don't 19 think we ever felt rushed, which means that Shannon 2 0 and her team and the workgroup members did a great 21 job of kind of designing the agenda and you all did a 22 great job using that chat window yesterday to get 23 your questions posed kind of in order of precedence. 2 4 So thank you. 25 We're not going to go into details on the For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 9 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 instructions again. You all have got the hang of it. 2 Obviously, if anybody on the call, members of the 3 public, no matter who you are, if you need 4 assistance, you can email Shannon Jewell. It's 5 Jewell.Shannon@EPA.gov, or you can select host from 6 the drop-down list in the chat window and that will 7 put you in touch with Sarah Chadwick who's providing 8 the support -- the platform support today. 9 A reminder that this is an unusual 10 opportunity for the PPDC members to all be together 11 at once and to provide inputs and feedback to the 12 workgroup presentation, so please take advantage of 13 that. And then for those that are not members of the 14 working groups or PPDC, you may find that you don't 15 have access to the chat window. You can open the 16 chat window and you can read what's happening, but 17 you have read-only rights, so to speak. You won't be 18 able to insert your comments into the chat window. 19 And just another final reminder because 20 there was some confusion yesterday on this, and that 21 was if you want to make sure your chats are being 22 seen, then you would go to the drop-down list at the 23 bottom -- near the bottom of the chat window. 24 There's a to, T-0, colon and then a drop-down list. 25 Scroll down almost to the bottom of that list past For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 10 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 everybody's name and select everyone, the word 2 "everyone." And then that will be the default 3 whenever you -- whenever you put a chat in the 4 window, you know that everybody's going to see it. 5 So I think we're ready to get started and 6 we're ready to move to the first working group 7 meeting -- I mean, presentation today. Sorry that we 8 took a few of your minutes for this intro piece. 9 So I'm going to bring Komal Jain and Tajah 10 Blackburn, the co-chairs of the emerging pathogens 11 workgroup, to step up now. And I think that the 12 presenter role is going to go to Tajah, unless that's 13 been -- unless that's changed. So hopefully, you 14 have access now and can run the slides. 15 16 17 18 19 20 21 22 23 24 25 For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 EMERGING PATHOGENS WORKGROUP UPDATE 2 MS. JAIN: Thank you, Paul. Let's give 3 Taj ah a second to get the presentation up. There it 4 is. 5 Taj ah, are you ready? 6 DR. BLACKBURN: Let's do it. 7 MS. JAIN: Okay. So good morning, 8 everyone. I'm going to kick us off. My name is 9 Komal Jain. I am the executive director of the 10 Center for Biocide Chemistries and co-chair the 11 emerging pathogens workgroup with the esteemed Dr. 12 Taj ah Blackburn. For those that do not know Taj ah, 13 she is the current senior scientist in the Product 14 Science Branch in the Antimicrobials Division of EPA 15 and she holds a PhD in microbiology -- sorry, 16 microbiology and infectious diseases. 17 So we are really pleased to be here with 18 you today. This is a really unique and challenging 19 time in history as we combat SARS-CoV-2 and the 20 disease, COVID-19. So this is a time that demands 21 leadership and thoughtfulness and care, and we are 22 pleased to chair a workgroup on this issue and work 23 with so many colleagues to try to assess the 24 situation and better prepare our communities and the 25 EPA if we should be faced with something like this For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 again. 2 So our agenda for this morning is to review 3 with you our membership and, you know, who, in fact, 4 is serving on the workgroup with us, our objectives, 5 the three charge questions and outcomes that we have 6 addressed thus far, and our next steps for the 7 remaining period of time that this workgroup is going 8 to be chartered. And then we will take questions. I 9 will note that we are going to try to take a pause as 10 we go through each one of our charge questions. So 11 anything that is top of mind for you can be addressed 12 along the way. But then, again, there will be time 13 built out at the end to address questions. 14 Next slide. 15 All right. So apologies, I know that this 16 is a difficult slide to read, but you do have copies 17 of it. So as you can see, we are a large workgroup. 18 We have 22 members and our members represent a real 19 mix of constituents. We have federal regulators. We 20 have registrants. We have formulators. We have 21 members of academia and science and legal experts, as 22 well as members of the end use community. 23 Specifically, we have representation from the health 24 care industry, the air transport industry and ground 25 transport. For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 13 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 We have solicited members. Taj ah and I 2 have worked hard to round out this group. And I will 3 say that I think where we could still use feedback 4 and where I would say this group is open is if there 5 are folks in the end-user community that would still 6 have some availability to commit time to us, we would 7 welcome you into the group. 8 So to date, we've answered three questions. 9 The analysis has been thorough and our goal is to 10 ultimately provide EPA with recommendations on how to 11 be even better prepared for any future pandemic or 12 emergencies. And I'll get to that idea of 13 emergencies in just a moment. So through these 14 recommendations, we hope to include recommended 15 processes and recommendations on how to accomplish 16 the goals. 17 So you'll see on the slide we have 18 objectives. This group -- workgroup was formed based 19 on a proposal submitted by my organization, the 20 Centers for Biocide Chemistries, because we thought 21 there was so much to be learned as we make our way 22 through the response to COVID. And so I want to just 23 thank my fellow PPDC members and EPA for supporting 24 this effort. 25 And, again, as proposed by the CBC and For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 14 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 ultimately accepted by this group, we have three 2 objectives. And that is, one, to assess EPA's COVID- 3 19 response and stakeholder experiences with the 4 emerging viral pathogens guidance for antimicrobials; 5 second, assess the user experience with antimicrobial 6 disinfection products registered by the EPA for 7 infection control; and provide recommendations to for 8 policy improvements and identify education gaps. 9 So in keeping with those objectives, I will 10 turn this over to Taj ah and she will run through our 11 first charge question. 12 DR. BLACKBURN: Thanks, Komal. More 13 importantly, thank you for providing the dynamics of 14 the working group, our meetings, highlighting the 15 depth of knowledge in the group, the cross-sectional 16 experience of the membership and, most importantly, 17 their dedication to get and gather substantive 18 information for the agency. 19 Let's spend some time navigating through 20 the current outcomes of our discussion. In the next 21 six months, we do plan to revisit our responses to 22 further enhance the products and deliverables through 23 a couple of mechanisms, prioritization of the answers 24 that have been documented and then develop a process 25 for implementation of those high-priority items. For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 15 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 What I like to say, from concept to completion. 2 As Komal mentioned, I will pause after each 3 charge question and associated information for 4 comments, questions, and suggestions from the larger 5 body. 7 strengths and weaknesses of EPA's first use of the 8 emerging viral pathogens policy during the COVID-19 9 pandemic? As you can imagine, this was a very 10 concentrated experience field question to unpack that 11 required a plan for dissection early in the process 12 to really get to the nuts and bolts of the response. 13 The EVP guidance document was triggered for the first 14 time in January 2020, following a long span of review 15 and reevaluation that was initiated back in 2006 and 16 finalized in 2016. 17 The responses that are highlighted on this 18 slide focus on the identify weaknesses to further 19 assist the agency with clarification of the document 20 and defining items that were really unclear doing 21 this additional implementation process. We 22 approached this question by developing buckets and 23 then sub-buckets working from the center of the 2 4 document and unpacking as we moved towards the 25 perimeter. 6 So charge question number one, what are the For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 16 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 The larger buckets represent the main 2 topics in the emerging viral pathogens guidance 3 document, and these topics being background and 4 purpose -- let's see if I can use the arrow pointer 5 -- background and purpose; viral subgroup 6 classification; product eligibility; and outbreak 7 criteria. 8 The sub-buckets were regenerated based on 9 the relevant topics associated with the buckets or 10 those main topics. The sub-buckets further expanded 11 the background and purpose section, for an example, 12 to communications, trigger, labeling, and hierarchy. 13 For those topics, the following gaps and weaknesses 14 were identified. Communications were limited during 15 the activation phase with the evolving criteria for 16 List N products. There were contradictions with 17 labeling and List N instructions. 18 The trigger timing was unclear and could be 19 enhanced through a public announcement that may 20 minimize confusion. The required label language was 21 thought to be lengthy and prescriptive with limited 22 options for additional language. The pathogen list 23 was difficult to understand. And, lastly, only a few 24 options existed for List N products. So those were 25 the weaknesses associated with the background and For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 purpose section. 2 So let's move to the viral subgroup 3 classification or this List N that you hear me speak 4 about. The members conveyed that the EVP guidance 5 does not direct publication of a list. So this List 6 N isn't explicitly stated in the EVP guidance or any 7 list has to be generated as a function of products 8 that are against a targeted pathogen. The List N 9 could be more user-friendly for products that are 10 difficult to locate. 11 Another weakness was that List N did not 12 include trade names or ABNs, or alternate brand 13 names, and these were not included, and they were 14 rather included under one registration number. 15 Another weakness was the sub-distributor products 16 were not included on List N. Members conveyed the 17 List N products contradicted EVP language for many 18 products and that, lastly, List N was created without 19 any visibility to the registrant community. 20 For the product eligibility criteria in 21 this section, with the sub-buckets of efficacy 22 claims, labeling, CSF, a confidential statement form 23 -- a formula, registered formulations and use sites, 2 4 the members conveyed that the EVP guidance lacked 25 information regarding active ingredient requirements, For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 that the SARS-2 protocol was an overkill and it was 2 too cumbersome to maneuver. Some members conveyed 3 that the guidance lacked temporary amendments for 4 emerging situations and the guidance lacked 5 flexibility for application methods beyond typical 6 applications that expanded to electrostatic sprayers. 7 Members also felt that the guidance lacked 8 information concerning concentrations, contact times 9 and use sites. Members conveyed that the document 10 lacked sensitivities for supply chain constraints and 11 new supplier -- changes to existing supplier 12 information had to go through agency review, which 13 may have delayed product registration. 14 For the outbreak criteria, identified in 15 this yellow section, weaknesses were not identified, 16 but two questions were raised regarding whether the 17 EVP should be applied equally for animal-related 18 outbreaks, such as the African swine flu fever, and 19 whether the agency was concerned about pathogen 20 cross-species transmission or interspecies 21 transmission or, as a layman's term, jump -- as an 22 organism jump species. 23 Some of the strengths, though not 24 explicitly spelled out on this slide, were that 25 preloaded labels did make labeling straightforward For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 19 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 and that sharing of information with global partners 2 through a blessed List N was and still continues to 3 be a valuable tool. 4 So let's just briefly recap the terms EVP, 5 List N, and put some context and definition around 6 those -- those terms for the larger PPDC membership. 7 For context, let's briefly revisit EVP guidance, or 8 formally termed, the process for making claims 9 against emerging viral pathogens not on EPA- 10 registered disinfectant labels. 11 In 2016, as I mentioned, EPA finalized the 12 guidance for making claims against emerging viral 13 pathogens that are not on EPA-registered disinfectant 14 labels. The finalization of the guidance was 15 followed by a 30-day public comment period with a 16 response to comment document. So that's the EVP 17 guidance in a nutshell. 18 As previously mentioned, the EVP was 19 activated for the first time in January 2020. In 20 March of the same year, EPA began announcing that it 21 would begin to expedite products eligible for 22 emerging viral pathogen claims using the disinfectant 23 hierarchy as outlined in the EVP guidance. Also 24 around this time, in March, List N was posted and 25 accessible. In May 2020, EPA expanded its expedited For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 20 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 review program to include new products and amendments 2 to existing product labels that required the review 3 of new efficacy data. 4 So what is this List N and why is it termed 5 List N? List N includes disinfectants for use 6 against SARS-CoV-2. As I mentioned, List N was 7 posted on March 55, 2020. The initial list contained 8 90 products and has grown to approximately 550 9 products. 377 of those products, about 68 percent, 10 are supported by EVP guidance. It is of important 11 note that, as of two weeks ago, the list had 23.5 12 million views. 13 So why is it called List N? Well, it's 14 List N because it represents the next available 15 alphabet in the growing list of products targeted 16 against specific pathogens. 17 So that's a lot of information to digest. 18 I will take a brief pause here for questions/comments 19 before we transition to charge question number two. 2 0 MR. ANNINOS: Thank you, Taj ah. Thanks, 21 Komal. We're changing things up a little bit as you 22 can tell. In the other presentations, we waited for 23 everybody to get through their entire deck and then 24 it was open to the PPDC and other workgroup members 25 for comments. This is an opportunity now to pause, For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 21 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 as Taj ah has just indicated, and to get some 2 feedback, some direct feedback and thoughts from the 3 committee, the full committee, on this particular 4 charge question. And then we'll move on to the next 5 charge question. And then at the end, hopefully, 6 we'll have a few extra minutes so that -- in case 7 there's general comments about the whole topic. 8 So let's just open it up. I think you 9 remember the protocol here. You'll go to the chat 10 window. As matter of fact, you should probably just 11 keep the chat window open all day long on the right- 12 hand side of your screen, and just enter your name 13 here if you want to make a -- ask a question or make 14 a comment. Or if you're feeling bold, just blurt 15 something out and suddenly we'll be able to see you 16 and respond to your question. 17 And I'm not worried about dead air because 18 it's just -- as Tajah just said, it's a lot to 19 absorb. Hopefully, you had a chance to look at -- 20 some of you had a chance to look at this deck 21 beforehand, but this is a great chance to provide 22 some feedback or to get some clarifying questions to 23 the team. 24 MS. JAIN: So Paul, if I could 2 5 jump in, something for our members to think about and For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 22 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 that we would love feedback on is particularly List 2 N. Many of you probably are users of List N and have 3 tried to access it, applied it in your businesses or 4 shared it with your community. You know, we would 5 appreciate feedback on the utility of that document 6 and how you could see it being improved. 7 So, Paul, maybe we'll just let that linger 8 with folks and we can move on. 9 MR. ANNINOS: Yep. Absolutely, absolutely. 10 We can definitely continue. And for the folks -- 11 everybody else, be thinking about the questions and 12 the comments you'd like to make in the next segment 13 or at the end of the entire deck. 14 So let's go ahead and continue. Yep. 15 DR. BLACKBURN: Okay. So Komal? 16 MS. JAIN: Okay. So the next charge 17 question that the group addressed is, what, if any, 18 documents, policies, guidances, for example, PR- 19 Notice 98-10 and the EVP, should have increased 20 flexibilities to respond to supply chain challenges 21 during a pandemic or other emergency and what 22 revisions should be made? 23 So first thing to note here is that we 24 decided to broaden our ask of ourselves to more than 25 just a situation of an emerging pathogen. We really For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 23 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 wanted to see, you know, what EPA documents need 2 greater flexibilities to address other emergencies. 3 So when I say other emergencies, things that, you 4 know, could be considered is geo-specific challenges, 5 for example, Brexit or shutdowns that occurred like 6 in Texas or China, Texas being weather-related, China 7 being other emergency type situations, facilities 8 that had to close down. 9 And then when that emergency is declared, 10 the question is when should it be declared? For 11 example, prior to a pathogen arriving on U.S. soil, 12 African swine fever virus or Ebola, you know, do we 13 want to be able to be more proactive to allow users 14 to stock up on current product in advance of arrival 15 to U.S. borders? 16 And, you know, what circumstances might we 17 want to consider? Is it quantitative or is it 18 qualitative? You know, consideration of human or 19 animal morbidity or mortality, economic impact, 20 endangerment to species? So we are working to help 21 define what is, in fact, that emergency situation and 22 trying to identify what it is that would trigger 23 classification of the emergency. 24 Next, we identified the targeted documents 25 within EPA's library that are applicable to these For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 24 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 situations to see what possibly could be needing 2 revision. So the documents that we have, at least 3 initially or immediately identified, include the EVP, 4 which you've just heard a great deal about from 5 Tajah, PR-Notice 98-10. And for those of you that 6 are in the antimicrobial space, you'll know that 7 there is a series of temporary amendments that came 8 into play after COVID or SARS-CoV-2 was declared, all 9 to address the supply chain issues. And there is a 10 petition in place to see whether some of those 11 temporary amendments that are currently in play can 12 be formally adopted. So one of the things we want to 13 do is look at PR-Notice 98-10 in its current version, 14 but also its temporary amendments. 15 We also want to look at the label review 16 manual and the registration review manual, test 17 guidelines, you know, 158w regulations, and then 18 provisions for importation and international supply 19 chains. 20 Next question -- next slide, Tajah. 21 So as I've already gone through, we feel it 22 is an important exercise not to be so narrowly 23 focused on just a situation of another pandemic. We 24 want to consider other possible emergency situations. 25 Something that was suggested to me this morning that For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 25 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 should be part of our definition of emergency 2 possibly is when there's cyber attacks or ransomware, 3 all that can have crippling effects on supply chains. 5 know, we're looking to see how registrants of 6 antimicrobial pesticides can make changes to their 7 suppliers in a more streamlined process than is 8 currently in place. Should it be just a notice? 9 Should it be via a self-certification? 10 We're also considering whether or not we 11 can take advantage of work that is done on a more 12 global scale. We have sister jurisdictions that are 13 faced with some of the same questions that we are in 14 the U.S. Can EPA rely on the work of the agencies in 15 the EU and those member countries, Asia? You know, 16 if it's not total reciprocity, can it be a work- 17 sharing environment such that some of the hard work 18 is done and the reviews are shared and then EPA goes 19 through its own analysis and makes its own 20 determination? 21 Another solution is, can, you know, 22 chemistries and formulations be changed for these 23 products, again, based on the self-certification 24 process versus amendments and a thorough review by 25 the agency. 4 And then when we think about solutions, you For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 26 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 I should be clear, though, that, in no way 2 are we talking about sacrificing the efficacy or the 3 safety of these products. We're really just looking 4 to see how we can streamline the paperwork exercises 6 antimicrobial pesticide products, but there are other 7 products that go beyond disinfectants that have been 8 critical in the response to COVID. So under this 9 charge question, should we be looking at other 10 pesticides, because we do want to at least keep it 11 narrow to OPP matters, but, you know, is it beyond 12 disinfectants and, you know, is it beyond surface 13 contamination and surface transmission? 14 So those are, again, some in -- some of our 15 pending questions that we do hope to better answer. 16 So I think that is it for the work that 17 we've done thus far on charge question two. 18 Something that maybe Taj ah and I haven't pointed out 19 yet is by no means do we -- do the two of us or the 20 workgroup members feel like any of these charge 21 questions and responses have come to closure. I 22 think this is going to be an evolving process, 23 particularly as we work towards the final report to 24 EPA. 25 So again, we're soliciting feedback from 5 And then, lastly, I keep on saying For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 27 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 you and from others that we can reach out to because 2 we really want our final report and our guidance to 3 the agency to be as comprehensive as possible. 4 So with that, let me take a pause and see 5 if there is any feedback. 6 MR. ANNINOS: Thank you, Komal. And, 7 folks, we're taking a pause again. This is a chance 8 to weigh in on charge question two and some of the 9 recommendations that this team has -- is considering. 10 MS. JAIN: I will also invite we have two 11 members of our workgroup that are on the line with 12 us, and I'll invite to Alex Cook or Elaine Black to 13 chime in if you feel like we've missed anything or 14 I've missed anything on charge question two. And 15 then we have other PPDC members that serve on this 16 workgroup, and I believe they can also unmute 17 themselves and chime in. 18 MR. ANNINOS: Absolutely. The mic is open. 19 MS. BLACK: This is Elaine. I'll just say 20 you've covered everything very well. Thanks, Komal. 21 MS. JAIN: Thanks, Elaine. 22 MR. WISE: This is John Wise. I have a 2 3 comment. 2 4 MS. JAIN: Yes. 25 MR. WISE: I was thinking about your For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 28 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 question about how the work you've done might relate 2 to pesticide use and/or I'm thinking agricultural 3 pest management, and it did strike me that there is a 4 hydrogen peroxide product called Jet-Ag that's being 5 used in specialty crops and it doesn't have direct 6 lethal effects on the target pest, but it eliminates 7 some of the yeast and other necessary foods for 8 Drosophila flies and, thus, is useful in the field to 9 be sprayed like a pesticide. So that's one that has 10 some relationship to the work you folks are working 11 on. 12 And the other thing that comes to my mind 13 is post-harvest, many fruits and vegetables, once 14 they're in a sorting or processing plant, go through 15 a series of washing steps that, in some cases, 16 include some kind of sterilant or agent that is 17 disinfecting fruit. 18 So those areas have some tangent 19 relationship to the work you're doing. So I just 20 wanted to share that as a source of information. 21 MS. JAIN: Thank you. That's very helpful. 22 I appreciate it. And I've taken notes. 2 3 DR. BLACKBURN: Yes, and thanks, John, for 24 that. I think that's critically important to 25 feedback. And so that charge question number one, For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 29 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 where possibly expanding that EVP guidance to other 2 use sites, other applications, you know, and just 3 kind of looking at this thing comprehensively so 4 that we can -- you know, we can think of all these 5 other industries -- and that's going to lead me to 6 charge question number three -- but all these other 7 industries that may be impacted while we're operating 8 in our silo, just the importance of expanding that to 9 these other entities. So thanks so much for sharing 10 that. 11 MR. WISE: You're welcome. 12 MS. BLACK: I want to just build on that. 13 This is Elaine. Yeah, we saw lots of kind of knock- 14 on effects of high demand for certain ingredients 15 that went into disinfectants that were on the List N. 16 But that, you know, once we saw stresses on that 17 supply chain, other products that were not considered 18 definitely kind of felt the pain, and we saw it in, 19 you know, rising prices and other issues and 20 availability of ingredients. 21 So, yeah, thanks, John. I think those 22 products, in particular, are very important. We know 23 that just the -- you know, like for the food supply, 24 we have to -- for all of these emergencies, we have 25 to consider all the things that we need when we're in For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 30 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 an emergency. So thank you. 2 DR. BLACKBURN: And then, too, I think it's 3 important that as Komal mentioned, we're expanding 4 that to beyond a pandemic, but considering 5 emergencies as well. And then what we're going to do 6 -- and what I'm going to mention as it relates to 7 charge question number three -- is we're going to go 8 back and try to define what an emergency is and make 9 that a quantitative type of approach so that, you 10 know, if it's impacting multiple industries, if it's 11 impacting the supply chain, that could feed into the 12 emergency and then may trigger some of these 13 documents and policies so that these items can be 14 addressed in a timely fashion and products can still 15 be made available. So thanks very much for that 16 insight Elaine as well. 17 So charge question number three, as we seek 18 to wrap this up and have further discussion, is, what 19 education is needed during a pandemic or other 20 emergency for the public end-users and other 21 regulating authority? Again, this is a very, very 22 weighted question. We're still unpacking it and 23 really trying to get to, again, the nuts and bolts to 24 get this question addressed. 25 So we utilize a bucket approach, again, but For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 across time as well. We analyze across multiple 2 industries and sectors to include ground 3 transportation, airlines, the cruise industry, 4 government facilities, office buildings, 5 entertainment venues, the food service from 6 agriculture through process to retail, restaurants 7 and bars as well, healthcare, and schools across the 8 time periods of pre-pandemic/emergency, during the 9 pandemic and emergency, and then finally post- 10 pandemic and emergency. 11 Again, we're going to have additional 12 discussions around defining what those emergencies 13 are, so be assured that it's going to be a 14 quantitative type of approach that's -- you know, 15 it's not a gray area, if you will. It's really clear 16 as to when an emergency is triggered. But as it 17 relates to the industry's outline on this slide, I 18 tried to not include a whole lot of information, but 19 focus on those industries that provide unique, 20 isolated challenges and gaps and potentially 21 conflicting messaging with their respective 22 industries. 23 To some of these -- these isolated 24 challenges include compatibility concerns, conflicts 25 with sister agency regulations provided maybe by DOT For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 32 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 or FAA -- and/or FAA for materials incompatibility 2 and corrosivity testing, challenges with 3 international regulations for vessels that travel 4 into the international spaces. So we first have to 5 identify those nuances, if you will, against all of 6 those industries and those sectors, so then we can 7 better understand what those educational gaps are. 8 So just still kind of high level as we're 9 working through this question, significant 10 educational gaps during the pre-pandemic or during a 11 pandemic or emergency phase were identified and we 12 felt that there was a need for consistent and 13 centralized messaging from our government partners 14 and even on the state level, but including the trade 15 associations as well, to bridge those gaps as it 16 relates to education and training. And this can be 17 accomplished through informational webinars, to 18 address and mitigate conflicting messaging with 19 ongoing dialogues to address and convey changes and 20 updates through a timely and centralized matter. 21 As it relates to materials compatibility, 22 concerns require awareness across EPA's landscape to 23 better understand these issues and the potential 24 limitations of the FAA list, of compatible products 25 for use on airplanes and DOT's challenges and even For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 the impact on the food service sector as it relates 2 to compatibility as well. 3 Another gap across all industries was how 4 do we manage these high-touch surfaces? And how does 5 that translate into proper use of the products via 6 what the label is stating and translating that, like 7 I say, from prose to practice. How do you take that 8 word -- take those words on a label and make those 9 mean something when they're actually being used? 10 So post-pandemic/emergency and ongoing 11 through a pandemic, and I was thinking about the 12 different phases of a pandemic, but the working group 13 highlighted that surveys, high wash -- hot washes may 14 prove useful in gathering lessons learned and 15 understanding lessons and best practices from past 16 maybe isolated contained outbreaks on a large or 17 small scale. And what brings -- what comes to mind 18 is maybe the cruise ship industry and how they manage 19 outbreaks on their vessels or maybe an outbreak 20 within a health care suite in the hospital. 21 So in closing, as it relates to our charge 22 questions, one of the members provided this context 23 that really kind of frames these educational gaps in 24 our exercises in answering these charge questions, in 25 that these educational gaps and challenges seem to be For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 34 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 getting to this idea, and I like this, of competing 2 commitments or competing priorities, where one set of 3 rules of best practices is at odds with another. 4 And working through this space to better understand 5 the individual gaps and the collective processes for 6 it is what we're challenged to do in this space and 7 for the next six months. 8 So I'll pause there for any questions and 9 clarification. 10 MS. JAIN: I'll just chime in to say, in 11 many ways, I think this is one of the harder charge 12 questions that the workgroup is faced with. Look, we 13 know education is needed. We know that it can be 14 improved. But when we think about how to accomplish 15 that, it's really challenging because we're talking 16 about anyone and everyone. So that means, you know, 17 how we approach our communications can be -- might 18 need to be really technical and might need to be 19 really basic. It should be bilingual. What type of 20 platform should we use? Does everybody have access 21 to the platforms that we want to use and how we go 22 about crafting the proper messaging that can be 23 easily understood by our targeted audiences. So I 24 really do believe this is the hardest one and 25 probably the one that we're going to spend the For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 35 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 greatest amount of time trying to unpack. 2 And, again, as all of you on the phone are 3 users of disinfectant products, hopefully, you have 4 guidance or thoughts that you can share with us. 6 much. We do have some time here, so let's just -- 7 oh, I see, you have more slides. I'm sorry, I 8 thought that was the last slide. So go ahead. I'll 9 let you finish up the deck and then we'll open it up 10 to insights, comments, questions from the larger 11 group. 12 MS. JAIN: Sounds great. So I think we've 13 really said this repeatedly, but for the next six 14 months we really hope to go back to the three charge 15 questions that we've already identified and 16 prioritize our responses, and we really do want to 17 rank in order of priority what some of those 18 solutions are and provide specific processes or 19 guidance to the EPA or others that should be, you 20 know, a part of the solution to work our way to a 21 better situation in in the future. 22 So we do have these three charge questions. 23 We feel like they're pretty comprehensive. And while 24 we have toyed with additional questions, we feel like 25 the ones that we've identified thus far get wrapped 5 MR. ANNINOS: Taj ah, Komal, thank you very For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 36 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 up in our original three. So this last bullet here 2 is we are open to addressing additional charge 3 questions if we feel like they haven't already been 4 covered. So again, this is another area where we 5 invite feedback. If you think this group has missed 6 something thus far, there is an area that really 7 should be addressed that hasn't been, then there's 8 time in the next six months for us to dig in. 9 So with that, I will say on behalf of Tajah 10 and our workgroup members, thanks for giving us time 11 today to explain what we've been doing thus far, and 12 we'll open it up to questions. 13 MR. ANNINOS: Mily Trevino-Sauceda has a 14 question. So, Mily, go ahead and unmute yourself and 15 join us. 16 MS. TREVINO-SAUCEDA: Yes, I'm leaving my 17 screen off because I'm having problems with my 18 internet. Yesterday, I just got cut off and for 19 whatever reason I could not get back, too much wind. 20 I'm in another place right now, but nonetheless. 21 Can we go back to the prior slide that you 22 used, please? 23 MS. JAIN: This one? 24 MS. TREVINO-SAUCEDA: No, the other one 25 before. For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 37 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 2 4 3 1 MS. JAIN: Charge question three? MS. TREVINO-SAUCEDA: Yes, please, yeah. MS. JAIN: Okay. MS. TREVINO-SAUCEDA: Okay. So because of 5 what -- I remember that when we were presenting 6 yesterday and we were talking about any -- and this 7 goes for any group or any community, any whatsoever 8 and this also goes for any kind of industry. It is 9 whatever the -- whatever is -- following, you know, 10 the questions and it's talking about education with 11 -- about pandemic and other any other kind of 12 emergency, in terms of get prepared whatsoever. 13 Are we also thinking, you know, what, you 14 know, mainstream end uses, cultural competency, all 15 these other -- all these other areas of how people 16 will understand the messages or the education that 17 would be provided so that people get the message 18 based on how they really, you know, would understand 19 it. Am I making sense in terms of my question? 20 MS. JAIN: Maybe I can take a stab at it. 21 I think what you're trying to say is that as we 22 develop education material and communications, we 23 really need to do so with the lens of the receiving 24 audience and make sure that -- 25 MS. TREVINO-SAUCEDA: Yes. For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 38 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 MS. JAIN: in fact, we're talking their 2 talk. Right? 3 MS. TREVINO-SAUCEDA: Yes, yes. MS. JAIN: So if we're trying to reach out 4 5 to a largely Spanish-speaking population, have we 6 taken effort to, one, develop material in Spanish; 7 two, are we shying away from vocabulary that they 8 might not be familiar with because it's so colloquial 9 to English speakers, things like that. Do I have 10 that? Have I captured it? 11 MS. TREVINO-SAUCEDA: Yes, yes. And I 12 would just think about -- because this is -- you're 13 doing it to a wider audience -- audiences and this 14 would be multiple languages and multicultural, 15 whatsoever. I mean, it just -- I'm not saying, you 16 know, that this group would be providing everything, 17 all the details, but it would help if that is taken 18 into our account, especially because we're talking 19 about -- you're talking about education using 20 materials, you know, and whatsoever with anything 21 that -- that's going to be used to get to the 22 audiences. 23 MS. JAIN: I think you make a really good 24 point. And, certainly, as we provide recommendations 25 to the educators -- and when I say that, you know, I For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 39 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 think that's going to be a shared responsibility as 2 Tajah mentioned. It's not just the Government; it's 3 industry, you know, those that produce the products 4 that would be responsive to a pandemic or an 5 emergency. The onus is also on the trade 6 associations, you know. And perhaps we can partner 7 with academia, so -- but that has to be part of our 8 recommendation. I absolutely agree. 9 Tajah, any -- 10 MS. TREVINO-SAUCEDA: Yeah, and just yeah, 11 I'm sorry. I just want to add in terms of -- based 12 on your response and looking at, you know, your -- 13 there's a large gap many more times in terms of how 14 government, either agencies and community and even 15 community organizations have, based on terminologies, 16 even in English, based on terminologies, based on 17 anything, there's a lot more times that people will 18 not understand what you're talking about or -- and 19 will -- I mean, we're talking about communicating and 20 it -- we have found in our 30-plus years of 21 organizing with just farmworker women, we just -- 22 it's -- there's more details to look at than just 23 thinking that everybody will understand because we 24 think we're talking the same language. Even if it's 25 the same language, that's where I'm getting at. For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 40 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 And this is why we call it the -- working 2 within the cultural context of those audiences. It's 3 not just, oh, she's a Latina or she's an Asian or -- 4 no, it's looking at wider -- so it's not black and 5 white. It's not English/Spanish. It's not -- you 6 know, it's a little bit more than that to be 7 efficient, yes. 8 DR. BLACKBURN: I really agree about the 9 cultural sensitivities, and I know, as an officer, 10 when we get dropped into certain places, that's some 11 of the first training that we go through is better 12 understanding the population that we're going to work 13 with and what we do and how it impacts that. So I 14 think -- I thank you for raising that salient point 15 and we will take note of that as we move through our 16 recommendations. Thank you so much. 17 MR. ANNINOS: Absolutely, thank you. 18 And thank you, Mily. 19 Liza Fleeson Trossbach has also requested a 20 moment for a question or a comment. Go ahead, Liza. 21 You can unmute yourself. 2 2 MS. FLEESON TROSSBACH: Thank you. Can you 23 hear me? 2 4 MR. ANNINOS: Yep. 25 MS. FLEESON TROSSBACH: Okay. Fantastic. For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 41 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 I appreciate the presentation. Obviously, with SARS- 2 CoV-2, this is near and dear to all of us. And just 3 a somewhat related comment, throughout this, as 4 pesticide regulatory officials, we obviously are 5 directly involved with the use of pesticides, and 6 then also with the registration process, particularly 7 for those products that are trying to be approved 8 under an emergency exemption, one of the challenges 9 that we had as pesticide regulators, and I think some 10 of those registrants had, was understanding what the 11 data requirements are going to be for this. You 12 know, we have a new pathogen, we have a new 13 situation. 14 And there were quite a few states that had 15 emergency exemptions that were submitted, but there 16 was a lack of information or it wasn't really clear 17 necessarily what the data requirements would be for 18 registrants on some of those processes for quite 19 long. And so I think as part of this education, it 20 should really include educating the registrants and 21 the peptide regulators about how you meet these 22 during an emerging pathogen. I don't know what might 23 be next, but certainly we'd like to be prepared. 24 And I think there needs to be a little -- 25 maybe a quicker response or an ability to get some of For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 42 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 that information out. You know, maybe there's a way 2 that there can be kind of a baseline of information 3 and then maybe there are things that could be 4 specific to certain pathogens. I don't really know. 5 That's not my area of expertise, but I think there 6 were some -- potentially some pesticides that could 7 potentially have helped at least a certain -- during 8 certain periods that perhaps couldn't get to market 9 soon enough or couldn't get through the approval 10 process. So just a little bit about that to let 11 regulators help registrants and vice versa. 12 So thank you. 13 MS. JAIN: That is really helpful, Liza. 14 Thank you. And I know that's also responsive to 15 challenges that AD specifically faced. There were a 16 lot of new registrants that entered the market and, 17 you know, to AD's credit, they spent a lot of time 18 walking these newcomers through the regulatory 19 process. And it would be nice if there was some go- 20 to material that could at least provide that baseline 21 that you referenced. So yes, we will add that to the 22 list. 23 Taj ah, anything you want to add? 2 4 DR. BLACKBURN: No, nothing on that point. 25 I mean, even though I work with a lot of the Section For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 43 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 18 data, we did see -- the standard, of course, is a 2 little different for the Section 3 data, but I can 3 understand some of the frustration that may have been 4 experienced as it relates to that. So it's noted. 5 Thank you. 6 MR. ANNINOS: And, Liza, this is Paul. I 7 apologize for mispronouncing your name when I 8 introduced you. I have a staff member with the same 9 spelling of your name and she goes by Lisa and so I 10 -- it was like an automatic mispronunciation of your 11 name. So I apologize. 12 And the floor is still open. We have a few 13 minutes left, two or three, four minutes left. If 14 anybody has a final thought, comment, question, 15 insight, advice for this hard-working working group. 16 And hearing none, I can turn the floor back 17 to you, Komal or Tasha or any member of your working 18 group, if you have any -- if you all have any final 19 thoughts or comments. 20 DR. BLACKBURN: I would just like to say if 21 things come up and you have additional questions, 22 comments and suggestions, please send those to 23 Shannon and she will get those to us, and we will 24 definitely add them to our list of things to consider 25 as we work through the rest of our six months in For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 44 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 answering questions and prioritizing and developing 2 new processes forward. So that's all I have. 3 Komal? 4 MS. JAIN: I just echo that we welcome the 5 feedback and, again, for those that are on the 6 workgroup with us and you're listening in, we thank 7 you for all your hard work. So hopefully more to 8 come, I guess, with the next PPDC meeting. 9 Paul, I'm going to turn it over to you. 10 MR. ANNINOS: Okay, all right. Very good. 11 Well, listen, thank you very much. Excellent 12 presentation. Really appreciate the feedback that we 13 did get and, obviously, people know they can contact 14 you offline with anything that relates to your 15 objectives and charge questions and even the work 16 over the next several months. So thank you very 17 much. Great job to all of you. 18 I think with that we're -- even though 19 we're kind of three minutes early, I think we should 20 move into the next part of our agenda, and for that, 21 we're talking about pesticide resistance management. 22 The co-chairs for this workgroup are David Shaw from 23 Mississippi State University and both Bill Chism and 24 Alan Reynolds from EPA as the government co-chairs. 25 And so I'm actually not sure who we're handing this For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 45 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 off to first. I think Alan might be the one kicking 2 it off. I could be wrong, but let's try that. 3 MR. REYNOLDS: You're correct, Paul. It's 4 going to be me to get the presentation started. 5 MR. ANNINOS: Great. 6 MR. REYNOLDS: So if it's okay with you, 7 I'll just go ahead and dive right into it then. 8 MR. ANNINOS: Yeah, that's -- absolutely, 9 you know, you're up. 10 MR. REYNOLDS: Okay. Terrific. 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 46 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 PESTICIDE RESISTANCE MANAGEMENT WORKGROUP UPDATE 2 MR. REYNOLDS: Okay. So along with my co- 3 chairs, Drs. Bill Chism and David Shaw, I'm going to 4 be presenting our interim progress report on our 5 resistance management workgroup. And just some quick 6 intros, I'm -- both Bill and myself are in EPA's 7 Office of Pesticide Programs. I'm a lead biologist 8 in the Biopesticides and Pollution Prevention 9 Division. Bill is a senior scientist in our 10 Biological and Economic Analysis Division. And Dr. 11 Shaw is a distinguished Professor of Weed Science and 12 Provost at Mississippi State University. 13 Okay, so just to recap our workgroup goal, 14 what we're looking at is we're looking to develop 15 recommendations to EPA on how the agency can assist 16 stakeholders, addressing the challenges of 17 conventional pesticide resistance. And just a 18 reminder that what we'll be talking about today, 19 we're not going to be talking about final 20 recommendations. This is really a progress report 21 and we'll be going through the topics of discussion 22 that we've been focusing on so far over the past few 2 3 months. 24 Okay, so for our group, we have four charge 25 questions. And I'm just going to read through these For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 47 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 really quickly to recap. So the first question is, 2 are there current EPA policies that positively or 3 negatively affect conventional pesticide resistance 4 management and what policies could be reworked to 5 more positively address resistance management? 6 The second charge question is, are there 7 current industry programs that positively or 8 negatively affect conventional pesticide resistance 9 management and would EPA have a role in those 10 programs and what might that be to positively 11 influence industry? 12 The third question is, are there incentives 13 for registrants or pesticide users that could be 14 considered related to conventional pesticide 15 regulation that might positively affect resistance 16 management and are there other ways in which the 17 agency can work with stakeholders, for instance, 18 growers, commodity groups and academics, to 19 cooperatively address resistance management? 20 And then, finally, the fourth question is, 21 are there elements from EPA's current Bt PIP 22 resistance management program that could be used in 23 conventional pesticide resistance management? 24 So given the broad depth and breadth of 25 these charge questions, we felt it would be better to For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 48 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 create breakout groups within our workgroup to 2 individually address each one of these charge 3 questions. And on the next slide, I'll show how 4 we've done that. 6 roster, and first, I'll just point out that like the 7 emerging pathogens workgroup, we are also a very big 8 group. And it's a terrific group to work with. We 9 have very diverse stakeholder viewpoints represented, 10 including industry pesticide developers. We've got 11 grower groups, independent growers. We've got 12 academia as well as government and regulatory. So 13 for each of our groups, we've identified a organizer 14 to help moderate the discussions, and also in each 15 group, there's also an EPA representative. 16 So what we'll be doing is, for the next 17 part of the presentation, we'll be going through each 18 group. Each group will be presenting what they've 19 been talking about, what their progress has been to 20 date, as well as identifying some of the questions we 21 have and some of the opportunities for input from the 22 larger PPDC group. 23 So for Group 1, we're going to have Bill 24 Chism from EPA is going to give that update. From 25 Group 2, it will be Caydee Savinelli, will give the 5 So on this slide, we've got our workgroup For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 49 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 update there. From Group 3, it will be Amy Asmus. 2 And then it will circle back to me for the Group 4 3 update. 5 shout out to our PPDC program support folks, Shannon 6 Jewell and Carla Theriault. Without their 7 assistance, this workgroup would not have gone very 8 far at all. They've been just absolutely invaluable 9 to helping us make this work. 10 And so with that, I'm going to turn the 11 next part of the presentation over to Bill Chism to 12 go through our workgroup 1 -- or our breakout group 1 13 progress. 14 DR. CHISM: [Audio issue] EPA policies that 15 positively or negatively affect conventional 16 pesticide resistance management? 17 Next slide. 18 And I want to just reiterate what Alan 19 said, these aren't really recommendations at this 20 point. These are just some of the areas of 21 discussion that we've had so far. So we've talked 22 about establishing a federal interagency workgroup on 23 resistance management. There's a lot of federal 24 agencies that have a potential role in resistance 25 management. Regulations clearly can help or hinder 4 Before we dive in, I also want to give a For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 50 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 resistance management. And there's also cross- 2 country movement of weed seeds, insects, pathogens. 3 So there's lots of agencies that interact on this 4 topic. 6 resistance management meeting, and with the 7 recommendations that stakeholders, both public and 8 private, be involved, have a yearly meeting to 9 coordinate and discuss resistance management plans 10 across disciplines, and specifically we've been 11 thinking in terms of insects, plant pathogens and 12 weed so far. 13 Establish a grant program to support 14 community-based programs. There's a lot of research 15 that suggests community-based programs are much more 16 effective. And then think about some sort of 17 reporting incentives, getting people to report early 18 signs of resistance. There's those first key years 19 when we hear about resistance are really important. 20 So see if we could develop incentives for researchers 21 users and suppliers to reward people who report 22 suspected resistance or reveal lack of performance 23 patterns very early on. 24 Also, develop tools and regional centers, 25 through the universities or IPM centers for rapid 5 We've also discussed having a yearly For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 51 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 identification of resistance. 2 Next slide. 3 Educational topics: Consider updating 4 training modules from -- and provide them from OPP on 5 resistance management, provide those training modules 6 to states for applicator training. The Weed Science 7 Society has a series of educational trainings that 8 would be a good framework to consider for starting to 9 provide resistance management training for NRCS 10 staff. Provide mode of action training. OPP should 11 consider having a training requirement for resistance 12 management as part of pesticide licensing. And the 13 training should obviously include retailers and 14 distributors because if they are [audio issue] then 15 they're not able to help when their -- when their 16 part of the role is called. 17 There's conflicting impacts of some of our 18 current policies. We need to consider balancing off- 19 target movement and weed resistance. Off-target 20 movement guidelines, for example, buffers, can have a 21 negative effect on weed management, and the 22 Endangered Species Act may have indirect effects on 23 resistance management. We should consider leveraging 24 the reduced risk status for faster registration of 25 pesticide for resistance management and also create For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 an incentive to develop tank mixes for resistance 2 management. 5 wanted to point out, we will come back at the end for 6 all these questions, but I wanted to read through our 7 section first, and we will be coming back to these at 8 the end for your input. So did we miss any policies 9 or topics? Do you have any suggestions on incentives 10 to raise awareness and actions to help on resistance 11 management? 12 And with that, I'd like to turn it over to 13 Caydee Savinelli for the second question. 14 MS. SAVINELLI: So thank you, Bill. Can 15 you hear me okay? Good, excellent, thank you. 16 So just as a reminder, I was the organizer 17 for the breakout group 2 and this shows the question 18 that we're dealing with. And we had a number of 19 clarifying questions for the EPA as we went through 20 this. And the other comment I want to make is, as I 21 go through the various slides, you'll start seeing 22 some overlap because each group has kind of worked in 23 isolation. So there's some overlap between a lot of 24 our recommendations. So that's actually a good 25 thing. 3 Next slide. 4 We have a series of questions -- and I just For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 53 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 So in this slide, the few things I wanted 2 to point out is really about industry. What is 3 industry? What's a program? Because I was 4 originally thinking it was just resistance 5 management, but I'll show you that it's actually 6 more. And then also, you know, elaborate on some of 7 the roles that EPA can have. 8 Next slide. 9 So the first area of discussion, you know, 10 when we were first talking about it, industry was 11 viewed as just the registrants, but between our group 12 and some other input from the other groups, when we 13 were having trouble getting into our rooms, we really 14 came up with an extensive list. And you can see 15 there's commodity groups, community-based, 16 government, can't forget government, NOGs, 17 professional societies, such as like the RAC, the 18 resistance action committees, registrants, and 19 retailers. And so this is the list that we've come 20 up with so far. It's a pretty comprehensive list and 21 it definitely goes beyond just to registrants. 22 Next slide, please. 23 And to me, this is probably one of the most 24 important slides I'm going to show you. And the way 25 I view just all of this is really the farmers, the For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 54 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 golf course managers, the mosquito control operators, 2 everybody, they're really talking about managing the 3 pests. I mean, they think of resistance management 4 as part of it, but you're not saying I will use this 5 product because of resistance management. That could 6 be part of it, but they're really trying to control 7 the pests. And what I believe is that the pest 8 management programs will use the same tools as 9 resistance management. How they deploy that may be 10 different, but I think it's something important to 11 remember. 12 And then really the outcome is to manage 13 the pest while minimizing resistance. So that's kind 14 of what farmers and others are looking for. It's 15 just a pest is eliminated or controlled. And that's 16 a good thing. 17 And the other thing that I think that's 18 going to be developed in our group and across our 19 groups, there's really multiple tools. We have 20 tended in all of our groups to really focus on the 21 pesticides, but I think we need to really think about 22 others tools in the toolbox because that will 23 certainly help with resistance management. 24 I just want to give a couple of examples. 25 Certainly, when you think about mechanical control, For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 55 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 so when you're thinking about mosquitos and you have 2 pots with saucers underneath and it collects water, 3 it's probably a good idea to empty that out for the 4 mosquito control. And then a cultural control is 5 really about, there's this fly, it's called Hessian 6 fly, and it attacks wheat, and there's these Hessian- 7 fly-free, wheat-planting dates, in other words, you 8 plant it after the fly is a problem. So there's a 9 lot of other tools that can be used in the toolbox. 10 Next slide, please. 11 And, as I mentioned, though, there will be 12 some overlap. So certainly, education is probably 13 foremost in underpinning a lot of the things that we 14 do and it's not just one group that educates, there's 15 lots of different groups that educate. I think Bill 16 mentioned fast track registrations. Certainly, that 17 would help if there's a new active ingredient that 18 could actually control some of these resistance 19 pests. 20 I think there's some opportunities with EPA 21 to participate in either consortiums that are looking 22 at pest management and resistance management. I'm 23 part of the Insecticide Resistance Action Committee, 24 and we typically annually meet with BE just to talk 25 about what's happening in the insect world and For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 56 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 (inaudible) and I think just kind of get a handle on 2 what's going on. So I think that's important. 4 pesticide safety -- sorry, that was my cat -- the 5 pesticide safety education programs. And, finally, I 6 just said work with the federal governments and 7 agencies. There's probably so many I can't even 8 count on one hand. But, certainly, I think that's 9 another area that could be considered in these 10 recommendations. 11 Next slide. 12 So that was just sort of a highlight of 13 sort of the three key areas, but some of the other 14 things that we've been having some discussions but 15 haven't really necessarily gotten into it very much 16 is what programs are being used. And a lot of times 17 when we talk about programs, they differ by what 18 you're trying to control. So controlling mosquitoes 19 is a lot different than, let's say, controlling 20 weeds. And we always have to keep that in the back 21 of our mind when we're making recommendations. 22 Some of the behavior considerations are 23 important. And we have an economist who also, you 24 know, thinks about social recommendations. So that's 2 5 important. 3 Promoting programs, and then also the For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 Economic motivation, a lot of times some of 2 what we're recommending is really long term versus 3 short term. And so there's -- you know, there's some 4 tradeoffs there. 5 Risk versus reward, a lot of people are 6 very risk averse. So there's a reward with that. So 7 that's something else we're going to delve into. 8 And, finally, you know, it's all good to 9 have all of these things, but if you can't engage and 10 get commitment from the stakeholders or the people 11 that are using products or growing crops or managing 12 golf courses, et cetera, then all the work that we've 13 done is for naught. 14 And the last -- next slide and this is my 15 last slide. 16 So really these are the questions to the 17 PPDC, and as Bill mentioned, we're going to be taking 18 questions at the end of the session, but I wanted to 19 put these out to everybody just to see them. So with 20 regards to industry types, have we missed any as we 21 go through this extensive list? With regards to 22 programs, are there other areas regarding EPA's role 23 in pest management? 24 And then also, you know, some other 25 considerations, as I mentioned, social behavior, that For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 58 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 type of thing. 2 So that is all that I have and I would like 3 to turn it over to Amy Asmus. 4 MS. ASMUS: Hello. Hopefully, you can hear 5 me. I was having some voice issues earlier. 6 Breakout group number 3, we had a very, 7 very broad ask. So we've taken our question and kind 8 of broken it down into two different questions, and 9 one is to consider incentives for registrants or 10 pesticide users that could be considered related to 11 conventional pesticide regulation that might 12 positively affect resistance management. The second 13 half is, are there other ways in which the agency, in 14 this case EPA, can work with their stakeholders to 15 cooperatively address resistance management? 16 Like the others, I'd like to say we're just 17 in the exploratory stage of our task and our comments 18 today are a brainstorming session. They are not 19 weighted comments at this time to pros, cons, and 20 their ability to be implemented. Right now, it's 21 just a thought process. 22 So if you go to the next stage, I'd kind of 23 like you -- to walk you through the thought process 24 that our group took as we addressed these questions. 25 So next slide, please. For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 59 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 So the first thing we looked at is the 2 target audience for our incentive. The charge 3 question asked us to look at registrants or pesticide 4 users. We will eventually look at both, but for this 5 time being, we have focused less on the registrants 6 for incentives and more on the end pesticide users, 7 which would include retailers, consultants, 8 applicators, producers, landowners, municipalities. 9 And we also want to look at -- I live in a world of 10 annual row crops. We also need to make sure that 11 we're looking at some of the perennial crops and 12 maybe some of the pesticides used to control pests in 13 municipalities, tribals, and other areas and try not 14 to get just focused on the annual row crops. 15 So one thing I would like to point out as 16 we look at the users is the bullet point that says 17 some users may need additional incentives to overcome 18 the hurdles to implementation of those practices. 19 And how do we segment the users to address those 20 hurdles? Because not all incentives will apply to 21 all end-users and so it's going to be really 22 important for us to segment those users. And how do 23 we structure those incentives not to penalize the 24 good actors while encouraging the bad actors in this 25 space? For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 60 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 2 1 Next slide, please. So we tried to identify some of the hurdles 3 to adoption. We took some of these from the 4 expertise of my group, and I have a really great 5 group that brings a lot of different perspectives. 6 We also took some of this from listing sessions that 7 the Weed Science Society had held across the U.S. So 8 some of the hurdles that we identified, our growers 9 may not implement best management practices until 10 resistance is in their area or field. 11 There are economic thresholds that cost -- 12 the added cost of resistance management best 13 management practices may be a hurdle to some growers 14 to implementing that. There's issues affecting 15 efficacy of the products. And so one of the things 16 we want to make sure we don't jump to is not every 17 time a weed doesn't die, can we contribute that to 18 resistance? We have to look at some of the other 19 issues with the efficacy and how do we address those 20 as well? 21 There's social factors, what's acceptable 22 if I'm spraying next to a school, I really want to 23 time that out while there's no children in the 24 school, which may then affect the efficacy of that 25 application, may apply a reduced rate because maybe For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 the plant is not growing or the pest is not present 2 or active at that time when the spraying is socially 3 acceptable, and that can have effects on resistance. 4 We also have conflicting messages from 5 trusted advisors. Trusted advisors may include 6 people like landlords or the banker that controls 7 your operating loan, and that gets us back to the 8 economic issues. So there may be priorities of some 9 of your trusted advisor partners that have 10 conflicting messages. 11 And also we looked at if we use label 12 language exclusively, that does not reach all 13 audiences and really doesn't touch on the integrated 14 pest management aspect of resistance management. 15 Next slide, please. 16 So we tried to figure out what we needed to 17 address some of these hurdles. Education has been 18 talked about in every group so far. So that's a 19 biggie. Incentives to address the hurdles to 20 adoption, so we need to look at each of those hurdles 21 and see if there are incentives and then to take it a 22 step further and see if EPA has control over those 23 incentives or we need to move to some of their 24 stakeholders, to provide those incentives. 25 And that leads to the next one, which is For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 the realization that the EPA can't do this alone. 2 Integrated pest management, including nonchemical 3 practices, must be included in education and 4 resistance management plans. And a community of 5 stakeholders would more completely influence all 6 pesticide users. 7 So this will take us to the next slide, 8 please, which is, are there ways or are there 9 incentives that the EPA can do, or work with their 10 stakeholders to do, to cooperatively address 11 resistance. So we looked at -- a lot of you have 12 heard the terminology carrots, which is an incentive; 13 sticks, which is some of our sticks are very big 14 hammers and we don't want to go there, or are we 15 throwing carrot sticks, which would be incentives 16 that are backed by regulations. 17 So again, education is one of our big 18 things. It would be a carrot definitely to 19 incentivize more knowledge and better implementation 20 of best management practices. We can look at what 21 are the long-term economic benefits of good pest 22 control. So there may be some short-term economic 23 difficulties, but education around the long-term 24 benefits of resistance management. How do we reach 25 that decision-maker? How do we include those people For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 that are private or commercial applicators and the 2 trainings that they are required to take? Can we 3 include resistance management? 4 And then how do we link education with 5 information gathering as well? If we educate these 6 growers as to what to look for, retailers, 7 applicators how do we get some feedback on their in- 8 field practices? And we can use that to fuel further 9 education. 10 Again, we talked about a points program for 11 participation in those practices. That's kind of a 12 carrot stick, this is what we'd like you to do. 13 We'll incentivize you to do them. USDA has some 14 models for that we'll be looking at. We can 15 incentivize stakeholder community involvement. How 16 do we get communities to come together around 17 resistance management and address it in their 18 cropping systems and their local environmental and 19 social aspects around resistance management? 20 What are the role of industry marketing 21 programs? We're looking at how do you make it a 22 mandatory enforceable part of the label. This is a 23 big stick. Our group would favor more incentives 24 than support heavy regulation, but it's on this list 25 to consider. Pest commissioners to control For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 uncontrolled pests. Again, that's a very big stick 2 at the state and local level. And mandatory 3 reporting and mapping of target resistance issues. 4 We'd like this accessible to all stakeholders who are 5 involved in creating resistance management plans and 6 carrying those plans out, but we do have a lot of 7 conversation to have around suspected resistance 8 versus proven resistance. 9 Next slide, please. 10 So these are some of our questions that we 11 can talk about at the end. It's our conclusion that 12 registrants have internal incentives to steward their 13 products for resistance management and should not 14 need external incentives. That's a question. 15 Have we identified the hurdles to adoption 16 of resistance management? Are there other categories 17 that we need to address in resistance management? In 18 our discussions of carrots/sticks and carrot sticks, 19 are there are other types of incentives we should 20 explore that we haven't yet? And do you have any 21 other considerations you'd like us to look at as we 22 move forward with our charge? 23 Thank you. I will turn it back to Alan for 2 4 Group 4. 2 5 MR. REYNOLDS: Thanks, Amy. For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 65 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 So for breakout group 4, we were tasked 2 with looking at EPA's current Bt PIP resistance 3 management program and determining whether there are 4 any elements from that program that could be used for 5 a conventional pesticide resistance management 6 strategy. 7 So the first thing we did is we really 8 drilled into the core elements of the current PIP 9 resistance management strategy. And so that really 10 consists of, you know, different mitigation 11 strategies for PIPs. So it's primarily been the use 12 of non-PIPs refuges, IPM stewardship, best management 13 practices, acreage limitations in some cases. There 14 have also been crop destruct measures for -- in other 15 scenarios. 16 Also, our resistance monitoring and 17 scouting is a very important part of the PIP 18 strategy. And then the remedial action plan, if we 19 actually do find a resistance developing to PIPs. 20 Grower education, another critical aspect of the 21 resistance management strategy. And then the 22 respective roles and responsibilities of the 23 registrants and EPA as far as overseeing the 24 resistance management program. 25 So so far in our group discussions, we For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 66 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 really have drilled down primarily into the 2 mitigation and the resistance monitoring aspects. 3 We've had some discussions on remedial action, grower 4 education, but those have been relatively preliminary 5 and we're going to be following those up with that 6 more detailed discussion in the next months. 7 Okay. So what have we talked about so far? 8 So in terms of mitigation, the first thing we really 9 looked at were some of the PIP-specific mitigation 10 measures, particularly refuges or acreage 11 limitations. Crop destruct-type scenarios are really 12 not going to be adaptable to most conventional 13 pesticides. So instead, we've really focused on the 14 IPM stewardship aspect and is that something that we 15 could really work on and develop for conventional 16 pesticides. 17 So that's led to some general questions and 18 the challenges that we've identified. So first, in 19 terms of an overall goal, should we be looking at IPM 20 stewardship as a measure to be taken proactively to 21 prevent resistance, or is this something that we 22 should really be focusing on when we see cases of 23 resistance in the field to deal with those cases in a 24 more reactive manner. 25 There are some challenges. So who would be For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 responsible for implementing a a stewardship program? 2 You know, as we've -- as some of the other groups 3 have talked about, you know, the EPA has authority 4 over the product registrations and the product label. 5 But as far as the registrant goes, you know, there 6 may not be a direct link from the registrant right to 7 the user of that product given the distribution 8 network can be quite complicated. That's a little 9 different than the scenario we have in PIPs where 10 there's an actual contractual relationship between 11 the registrant and that grower, which can be 12 leveraged to implement resistance management. 13 Another challenge, you know, we've been -- 14 particularly for PIPs, one of the things we've been 15 criticized is that the resistance management strategy 16 is more or less a "one size fits all" approach, 17 particularly at the federal level, and has really not 18 been able to account for regional differences or 19 regional distinctions as far as (inaudible) 20 resistance. And so thinking about how we would look 21 at conventional pesticides, is that something that we 22 could look at? Can we make a program flexible enough 23 that we can respond on a more regional or local 24 level? 25 So also in terms of mitigation, we've been For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 talking about the role of product labeling and 2 particularly the role of growers, so where do growers 3 get their information and how do they make decisions? 4 So, you know, can a product label actually influence 5 a grower's behavior. And how would we modify that 6 label to accomplish those goals? 7 You know, how do growers play into this? 8 Where are they getting their information? You know, 9 where are they -- what would be impactful ways to 10 interact with growers? We talked about grower 11 meetings that can be conducted by registrants or the 12 role of extension personnel. And, of course, social 13 media in this day and age has a critical role in 14 reaching users. So all of those aspects could play 15 into how we use stewardship and how we implement a 16 stewardship type program. 17 This leads to the question, you know, how 18 can we make pesticide users into good stewards, 19 particularly when most growers already consider 20 themselves good stewards? So, you know, convincing 21 folks to actually implement sound resistance 22 management strategies in addition to measures they 23 may already be taking. 24 One of the interesting things we've talked 25 about is a certification type program to incentivize For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 69 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 stewardship. There are examples of that that we 2 talked about. One is a water quality program that 3 was developed in Illinois, the STAR program, that 4 awards points for growers who adopt certain measures 5 to deal with nutrient and soil loss. And they could 6 get those points and work towards a certification. 7 So we thought about, is there something similar that 8 we think about for resistance management? You know, 9 users who are adopting good practices, can they be -- 10 essentially get points for -- to show that they've 11 employed these good practices? 12 Pivoting to resistance monitoring and 13 scouting, so for the PIPs, EPA has historically 14 employed two strategies. The first is a more 15 proactive measure in which the registrants will go 16 out and actively sample for -- sample target pests 17 and then conduct bioassays in high selection pressure 18 areas, trying to more actively look for shifts in 19 susceptibility before you would see field level 20 effects. 21 The second component has been to 22 investigate cases where we have had field damage in 23 PIP fields where you would have the unexpected pest 24 pressure or pest damage, and conducting 25 investigations to see if those are actually resistant For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 70 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 insects. That, of course, is more of a reactive 2 approach. So our group has been deliberating, you 3 know, which of those approaches would make sense for 4 conventional pesticides. 6 challenges when we think about resistance monitoring, 7 the first being, you know, who's responsible for 8 doing it. On the PIP side, there's an industry 9 group, ABSTC, that essentially conducts some of the 10 resistance monitoring activities. So they have been 11 able to essentially pool resources between different 12 registrants, so they conduct one monitoring effort. 13 But would that really be feasible for other types of 14 pesticides, particularly when you have a lot of 15 different companies registering similar chemistries? 16 The question of resources is a huge one. 17 You know, resistance monitoring is -- it is resource 18 heavy, so who would be doing the work, who would be 19 managing the populations that are collected, doing 20 the testing, those types of activities? And, of 21 course, there's a huge financial investment there. 22 So who's paying for that? 23 In terms of damage investigations, can they 24 be standardized or would each company kind of be on 25 their own to conduct their own type of investigation 5 Of course, there are questions and For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 and then their own follow-up based on that? So 2 there's a lot of questions that need to be answered 3 there. 4 So our discussions have led to a number of 5 overarching questions, and these -- so a lot of these 6 questions have cut across our breakout groups. So we 7 do have some common themes here. So a first basic 8 question we've been asking is, should we be 9 conducting resistant management for all different 10 types of pesticide chemistries? For the Bt PIPs, it 11 was the PPDC back in the 1990s that actually 12 established a public grid criteria for Bt, and that 13 was due to the lack of human and environmental risks 14 and, you know, the very favorable safety profile of 15 Bt being in the public interest and public good and, 16 you know, the need to maintain that. You know, is 17 that true for all chemistries, though? 18 Of course, our breakout group, and I think 19 some of the other breakout groups, have been largely 20 ag-centric in our discussions, but that leaves out 21 other pesticides and other pesticide type uses, 22 things like vector management or, you know, 23 structural pesticides, residential use pesticides. 24 You know, should they be considered? 25 The question of voluntary versus mandatory, For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 72 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 you know, should the program be voluntary? That 2 might be easier to implement, but what kind of 3 adherence would we get to that? You know, that might 4 depend on a number of socioeconomic factors. 5 If the program is mandatory, who's going to 6 enforce it? You know, it could be EPA via pesticide 7 labeling. You know, we've talked about that. But 8 certainly overly complicated or complex labels could 9 be a burden for the user and could lessen the 10 likelihood that they'll actually comply with those 11 measures. 12 And then the question as to what role EPA 13 should have and what level of oversight. With the 14 PIPs, we've had a very prescriptive program in place, 15 so they're at a very high level of oversight. But 16 should that be the case for -- you know, for other 17 types of pesticides. 18 Okay. So those are our breakout questions. 19 And so at this point, I'm going to just give a very 20 quick update on what we conceive to be our next steps 21 in the process here before we pivot to the overall 22 question and answer and discussion period. So as far 23 as our next steps, after this meeting today, we'll 24 reconvene our full workgroup. That will be next 25 week. For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 We'll be asking ourselves based on the 2 input we get today, do we need to make any course 3 corrections, you know, in terms of the general 4 direction of our discussions? Is there anything else 5 we need to consider, any other topics? Should we 6 tweak the charge questions in any way to, you know, 7 to better focus our discussions? 8 We, of course, are planning to continue our 9 breakout group discussions. You know, we'll be 10 ongoing with those and then the strategy or the plan 11 is going to be to make recommendations to the full 12 group in the September time frame with the goal of 13 creating a final workgroup report and full 14 recommendations to the PPDC at the October meeting. 15 Okay. And so with that, I think we can 16 pivot to the Q&A/discussion portion of the hour here. 17 And I'm going to turn to our session moderator, Paul, 18 as to how he would like to have this work. So I've 19 got the breakout group questions up here and I don't 20 know if you want to just go through them one by one 21 or just open it up for a larger discussion. 22 MR. ANNINOS: Thank you very much, Alan. 23 Thanks to this whole team. Really well done 24 presentation. And I really liked that as you moved 25 through these breakout groups, you had very specific For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 74 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 requests to the PPDC, we need your feedback, we need 2 your input on these very specific topics. And, 3 again, it's a lot to absorb in a 30-minute 4 presentation. We do have a fair amount of time now 5 to just get into conversations. 6 I'm assuming that this slide and the next 7 one are the -- there must be a breakout group 3 and 8 4, also. For those of you -- I think we have a link 9 in the chat that takes you to all the presentations 10 for yesterday and today. If you go open that link 11 and then select the pesticide resistance management 12 presentation, you can, yourself, go through and have 13 those questions in front of you. But we -- I'm going 14 to suggest that we open it up. If someone has a 15 response -- there we go, Sarah just posted. Sorry, 16 Shannon -- Shannon and Sarah just both posted the 17 links in the chat if you wanted to have those kind of 18 front and center for you. 19 I'm going to suggest we kind of open it up 20 broadly. If someone has an insight or a comment or a 21 question that pertains to a specific breakout group, 22 they can say that. But I think we should open it up 23 broadly for any kind of comments, insights, 24 questions, clarifying questions for your team. A 25 really fantastic job. So let's pause and we will For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 75 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 wait to hear from folks. 2 And Damon Reabe has a comment. So, Damon, 3 go ahead and unmute yourself and join us. 4 MR. REABE: Hey, thank you, Paul. I really 5 appreciate this presentation, a lot of great 6 information. On behalf of the National Aerial 7 Applicators Association, I'm formally requesting that 8 that -- the aerial applicators in the United States 9 are very much okay with more complex label language 10 for the purposes of better risk assessments. You 11 know, right now, the -- and the EPA has worked very 12 closely with the National Ag Aviation Association, 13 but -- and continues to do so, but we welcome the 14 idea of more prescriptive label language as it 15 regards to aerial applications so that risk 16 assessment that is based on worst case scenario is 17 based upon best management practice. And I think 18 what that will do is better risk assessment outcomes. 19 And then the additional benefit to that 20 will be reducing the size of buffer zones, which in- 21 field buffer zones are, in fact, the place where the 22 resistance is born. And we can work towards making 23 these wind-directional. Currently, buffer zones 24 typically, on most pesticide labels, are not wind- 25 directional. So we're leaving a buffer in a place For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 76 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 where the pesticide can't drift to on the up-wind 2 side. And then on the downwind side, we're getting 3 partial rate applications performed there, which 4 accelerates the resistance to pesticides. And we 5 don't have the ability after the wind has switched to 6 go back and re-treat that area to prevent that 7 resistance development. 8 The other final thing I'd like to mention 9 is our state regulatory officials -- Liza's here and 10 she can comment on this -- right now, a lot of state 11 enforcement policy is when there is a drift 12 allegation, the investigation is based on foliar 13 resident testing as far as what the offsite drift was 14 and that is driven primarily by the science -- the 15 science of being able to find the product itself and 16 is not weighted in any way as to what that amount -- 17 if that amount of product is, in fact, actually 18 harmful. 19 So I think the EPA could work really 20 closely with state lead agencies on sharing what 21 actually is an amount of offsite deposition that, in 22 fact, is in no way harmful. And so that would then 23 allow applicators to, again, get more of that field 24 actually treated at the intended use rate. 25 Thank you for all the hard work on this For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 77 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 subject. 2 MR. REYNOLDS: Thank you very much. Great 3 comments to consider. Absolutely. And something we 4 should -- you know, as we think about pesticide 5 labels, you know, over a huge range of products, 6 different types of chemistries, there's a lot to 7 think about there. So very good -- great insights. 8 Thanks a lot. 9 MR. REABE: I mean, it's a call out to the 10 registrants as well because obviously the EPA is 11 doing risk assessments based upon what the 12 registrants submit. So, you know, I'm addressing the 13 EPA, but, of course, obviously our registrant 14 community as well. 15 MR. ANNINOS: Thank you very much, Damon. 16 Very, very thoughtful comments. I'm sure the 17 workgroup appreciates that. 18 We have a line forming for you all. This 19 is great. So we're going to hear from the four 20 people in line right now. You can kind of follow 21 along with me in chat window. First, we'll hear from 22 John Wise and then Cathy Tortorici and then there's 2 3 two more beyond that. 24 So, John, you're up. 25 MR. WISE: Okay, thank you. I have just a For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 78 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 short suggestion in relation to Caydee's presentation 2 of the breakout group. And her question was, are 3 there other industry types that should be considered? 4 And I thought about food processors of, at a minimum, 5 of fruits and vegetables that are becoming more 6 prescriptive to growers on what their past management 7 programs should be and what MRLs they accept for 8 their products as they're being sold around the 9 globe. And I think about Nestle Gerber and other 10 packers, processors. 11 So it's just a thought to be considered 12 that's an industry type. That's all I had. 13 MR. ANNINOS: Great. Thank you, John. 14 Thanks very much. 15 MR. SAVINELLI: I just wanted to thank 16 John. It was good to see you. Thanks. 17 MR. ANNINOS: All right. Thank you, 18 Caydee. So Cathy Tortorici from NOAA Office of 19 Protected Resources at Fisheries. 20 MS. TORTORICI: I just — thank you. I 21 just have a quick question. Early on in the 22 presentations, you made mention of the ESA having 23 some kind of an indirect influence or effect on what 24 you all were doing or thinking about. I'm not 25 phrasing this correctly. I should have written down For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 79 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 the bullet. But I think you know what I'm referring 2 to and I'm hoping you can go into a little bit more 3 detail on what you were thinking of when you said 4 that. Thanks. 6 Chism. One example might be because of endangered 7 species, we have a larger buffer area between the 8 treated area. So an area in which pesticides cannot 9 be applied, so that potentially leaves a large area 10 for pests to accumulate in and potentially 11 accumulate, survive and thrive in. So is that 12 helpful? 13 MS. TORTORICI: That is helpful and maybe 14 we should talk more about those sort of items that 15 you might be thinking of indirect effects because 16 that would be interesting to have that conversation 17 with you all, because we would -- I think that's 18 important. If you have concerns along those lines, 19 we should know that. Thank you. 2 0 MR. ANNINOS: Very good. Thank you very 21 much, Cathy. 22 Thanks, Bill, for your response as well. 23 We're going to move now to Liza, Liza 24 Trossbach, and then followed by Mark Johnson. 25 Liza, go ahead. 5 DR. CHISM: Yeah, thank you. This is Bill For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 80 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 MS. FLEESON TROSSBACH: Thank you very 2 much. Again, another great presentation as all of 3 them have been over the last two days. A lot of 4 great information and discussion. I just wanted to 5 kind of mention from a pesticide regulatory 6 official's standpoint -- and we certainly believe 7 that an educated community is a compliant community. 8 And so we're always very happy to participate in 9 training. We absolutely believe in training. I 10 would just caution or just bring up that there have 11 been -- there seems to be a move towards requiring 12 additional training for the use of certain products 13 and we've seen that as pesticide regulatory officials 14 and end-users and registrants. 15 And while -- again, while we appreciate 16 training, you know, all states have a pesticide 17 certification program that determines the minimum 18 competencies of applicators. They go through annual 19 training. They are certified or recertified. And to 20 add additional training for specific product uses or 21 to put something on top of that can be burdensome. 22 And, again, I do think it's important, but I also 23 think that, you know, all of us, as pesticide 24 regulatory officials and end-users, the pesticide 25 application begins with the label. And there's been For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 mentioned about labels being complicated, and they 2 are, but pesticides are complicated. 3 And just because a pesticide provides a lot 4 of information doesn't mean it can't be -- you know, 5 that the language can't be clear and we can make it 6 clear how it needs to be applied. And I think if 7 there are use requirements or use directions that can 8 help facilitate a reduction in resistance or can 9 further resistance management, then they should be on 10 the label. 11 The label is the law. We preach it all the 12 time. The EPA preaches it all the time. That's 13 where users go to when they're making their product 14 selections. And so I would really encourage, to the 15 extent possible, in addition to continuing to educate 16 and perhaps be able to incentivize users, is really 17 that those requirements -- I mean, they should be 18 requirements and I think that they should be on the 19 pesticides label. 20 And just real quick to Damon's comments 21 about, you know, enforcing the proper use and drift. 22 Damon is correct. You know, I would say, in general 23 -- I mean, there may be some limited exceptions -- 24 but, in general, in drift cases, pesticide regulatory 25 officials are looking for absence or presence of a For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 pesticide residue. There are no harm standards. 2 It's been discussed over the years. There's been a 3 lot of conversations about that, but currently it is 4 presence or absence. 5 So thank you very much. 6 MR. ANNINOS: Thank you, Liza. Thanks. I 7 don't know if the workgroup wanted to respond to any 8 of that, but that's really good feedback and input 9 for the team. 10 MR. REYNOLDS: Yeah, I would just say 11 thanks for those comments. They're very helpful. I 12 really appreciate it. Good points. 13 MR. ANNINOS: Thank you, thank you. 14 Mark Johnson is up and then followed by 15 Nina Wilson. 16 MR. M. JOHNSON: Yeah, I want to say great 17 work. I think the work of the policies is pretty 18 comprehensive. Thank you. And as the other breakout 19 groups were, too. 20 I'd like to make a couple of points, you 21 know, and as far as in light as a professional 22 industry, in applications, the label is the law. We 23 fully support that. Before things boil down to the 24 label, though, I want to address a couple of things. 25 You know, we rely upon the resistance action For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 83 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 committees for both herbicides, insecticides, and the 2 information that comes out of that with the 3 researchers that are involved there as, you know, the 4 researchers provide a lot of education to the 5 extension agencies and to -- especially through the 6 state level, and turf grass programs in golf 7 specifically are continuing professional education 8 and professional applicator points. Right? 9 So the education venues exist. What's 10 missing perhaps is a lot of research that's necessary 11 in specific crops, and there are a few in the turf 12 grass industry that are doing research related to 13 weeds, insects, et cetera, and then the whole 14 fungicide aspect. You know, in industry, we do 15 provide best management practices for pesticide 16 selection. We're strong in IPM. We're strong in 17 providing that education on IPM and setting that 18 stage. And, also, pesticide selection is stepping up 19 some in resistance management. 20 It's important that these university 21 programs are supported. So if you want to think 22 about incentives, we might be able to incentivize 23 golf course superintendents through our association, 24 but what's probably going to be more important is 25 making sure that the resistance management topics are For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 adequate and presented at the education, that not 2 only our members take, but everyone in the turf grass 3 professional aspect, right? 4 And so I would encourage you, as you think 5 about those incentives, think about the existing 6 venues to educate professionals applying pesticides, 7 herbicides and fungicides, right, in the outdoor 8 landscape setting, you may be better suited to ensure 9 that resistance is addressed in those education 10 venues with incentives. I'm not saying no to 11 incentives. We'd certainly take a look at how we 12 could participate with that as an organization and 13 would encourage you to do that. 14 I will post a link to everyone for where 15 our BNPs are located. They do the conversations on 16 buffer strips and, you know, pollinators alone and 17 making that selection. This is a very deep important 18 project not only to water quality, habitat, wildlife, 19 it's across the board and it's the future of ensuring 20 sustainable businesses. 21 So we want to make sure when we make policy 22 recommendations to be represented in the label that 23 you do address everyone and the application of those 24 pesticides in, like, turf and the approaches as you 25 do so well now. And, second, you know, the regional For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 85 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 aspect that was brought up is critical. It's going 2 to be critical for the growing season, the species 3 that are available, right? If you build it, they 4 will come, right? And you know what I mean by they 5 will come, the disease, the insects, and they're 6 going to be pertinent to those regions, warm season 7 versus cool season to be very specific to you. 8 And across the 50 states and what we deal 9 with with the 50 states, we do want to adhere to the 10 label. It is the law. It's what we train. It's 11 what we preach. We need the resources in order to 12 ensure that we minimize resistance out there. And 13 the stage is set to do that, we just need to be able 14 to do it effectively while not closing the door when 15 there's no alternative products. 16 So thank you for the time and for the 17 comments. Congratulations on great work. Keep 18 ramping it up and we're here to support you. Thank 19 you. 2 0 MR. ANNINOS: Thanks very much, Mark. I 21 think those are also very, very helpful comments for 22 the workgroup going forward. So thank you. 23 Also, so Nina is up, Nina Wilson, followed 24 by Charlotte Sanson. 25 So, Nina, you're up, if you can unmute For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 86 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 yourself. 2 MS. WILSON: Hi. Hey, Alan, how are you? 3 Thanks very much for those presentations. They were 4 great. 6 missed it. I was trying to listen for it, but what 7 interaction have you had with the HRAC, IRAC, you 8 know, the FAC, these people -- you know, the 9 resistance management groups that have been 10 categorizing the families and that I think we're 11 using on our labels? Because they've been thinking 12 about this for a long time. And I think as well as 13 if we're going to be using them to annotate or 14 identify different products and families, that we 15 just make sure we use the same language whenever 16 we're talking about our labeling and whether or not 17 we're talking about any education. 18 Because I know, like, when gallon -- when 19 we try to do resistance management, we tend to -- we 20 try to use the same language because it gets very 21 confusing when people start branching out. So I 22 didn't know whether or not they're a part of it or 23 that we had reached out to them or incorporated them 24 in any thinking about the training. 25 DR. CHISM: Alan, shall I take this? 5 I wanted to make one -- and I may have For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 87 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 MR. REYNOLDS: I was going to suggest just 2 that, Bill. Thanks. 3 DR. CHISM: Okay. Nina, that's an 4 excellent point. In my workgroup, we have -- I 5 believe he's the chair of a HRAC and, in general we 6 meet with the different RACs -- well, in the past 7 before the pandemic, we used to meet with RACs about 8 once a year, the HRAC and IRAC, and then we would 9 have conversations with FRAC. So we do meet with 10 them on a regular basis and they are represented here 11 in our meeting, in our workgroup. 12 MS. WILSON: Great, thank you. 13 MR. ANNINOS: Excellent, Nina. 14 Thank you very much for your comments, 15 Bill. Thanks for your response. 16 Charlotte Sanson is up. 17 And, Charlotte, you might be on mute or 18 unmuting yourself at the moment. 19 MS. SANSON: Well, maybe it's better if I 20 take my headset off, that might be the problem. 21 MR. ANNINOS: Oh, there you go. You're 22 loud and clear right now. 23 MS. SANSON: Yeah. Sorry about that. So, 24 yeah, there is so much information packed into here. 25 It's a very complex topic. I see there are questions For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 directed to registrants, which are good questions. 2 And I think it probably would be helpful for us 3 registrants to take this offline. On the spot, it's 4 a little challenging to provide some direct feedback. 5 I see there are some registrants obviously in the 6 breakout groups. So it's just a comment. We'll get 7 back. Thank you. 8 MR. REYNOLDS: Thanks, Charlotte. 9 MR. ANNINOS: Thanks, Charlotte. 10 MR. REYNOLDS: Yeah, and I would just say 11 to -- you know, to anybody, please feel free to, you 12 know, after this meeting to email us any additional 13 suggestions or input that you might have or 14 questions. Certainly, you can direct those to 15 Shannon Jewell or myself or my co-chairs. And we'd 16 certainly be happy to entertain further discussion. 17 MR. ANNINOS: Thanks, Alan. I think that 18 goes for all the workgroups. Obviously, this two-day 19 meeting is like an event in time, but time is going 20 to move on past today and I know these workgroups 21 have a lot of work to do between now and October. So 22 your feedback to them, one on one, one on multiple, 23 however you want to provide it, I know they're 24 anxious to get it. So thanks. 25 We have a few minutes left in this segment For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 89 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 if -- let me just pause for a moment just to see if 2 anybody else from PPDC, the other workgroup members, 3 anybody that's participating that wants to pose a 4 question, make a comment, et cetera. So let's just 5 see. 6 You had a lot of engagement on this -- so 7 oh, did someone say something? I'm sorry. I might 8 have cut someone off. Maybe not. 9 So we've had a lot of engagement on the 10 topic, so you got some really good feedback here 11 real-time. And not surprising, you had a really good 12 set of trigger questions that you were, like, really 13 anxious to hear feedback on. So I think you got some 14 of that today. 15 And any other -- again, any other last- 16 minute comments or even members, the co-chairs, our 17 presenters today, you know, Alan, Bill, David, Amy, 18 Caydee, any last or final words you'd like to -- 19 MR. BURKETT: Yeah. Hi. Can you hear me? 20 For some reason, my chat doesn't seem to be working. 21 MR. ANNINOS: Oh, okay, yeah. 22 MR. BURKETT: This is Doug Burkett from the 23 Department of Defense. And I have a question for the 24 various working groups. I did see in the membership 25 list that you do have some members that are involved For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 90 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 in public health, insecticides and resistance, I 2 think Janet McAllister there from the CDC and maybe 3 some others. 5 terms of -- and maybe this is way outside the scope 6 of this particular group, but, you know, periodically 7 in Defense, we're always kind of asking whether or 8 not there's a standardized or a preferred list of 9 places you can go to for the best methods for using 10 insecticide resistance testing, as an example, 11 whether it's molecular testing for KDR or whether 12 it's bioassays or for various forms of resistance, if 13 there's any kind of standards or [audio issue] that 14 outline the preferred bioassay methods for 15 determining resistance for various pests that are out 16 there, particularly in the public health career field 17 but others as well. 18 MS. SAVINELLI: I'd like to answer the 19 question. It's okay, Paul. So this is Caydee 20 Savinelli and I'm -- you know, I represent -- I work 21 for Syngenta. They pay my salary, but I also 22 represent the Insecticide Resistance Action 23 Committee. And you can go into the Insecticide 24 Resistance Action Committee and find standards for 25 testing. And we definitely recommend it because it's 4 But I have a question for the group in For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 a lot easier to compare across studies. And this is 2 publicly available. You don't have to be a member of 3 IRAC. And I can talk to Janet McAllister because 4 she's on the subgroup to just make sure that she has 5 the right information. 6 MR. ANNINOS: Thank you, Caydee. That's 7 helpful. And also Dan Markowski has chimed in to say 8 he might be able to comment on this as well. 9 MR. MARKOWSKI: Yes, this is Dan Markowski. 10 I'm with VDCI. I've worked with Janet quite a bit. 11 And probably the easiest and most standard tool for 12 testing in the public health field, mosquitoes in 13 general, is the CDC bottle bioassay. It's a fairly 14 simple tool. They actually have free kits that they 15 send out to most of the mosquito control districts, 16 if requested, and have standardized the testing of 17 mosquitoes for resistance. So that's probably the 18 most standard and simple. 19 There are other assays you can do. 20 Certainly, if anyone wants to contact her she'll tell 21 you all about that. But the CDC bottle bioassay is a 22 pretty standard and simple tool to use. Thank you. 23 MR. ANNINOS: There you go, Doug, you ask a 24 question and you get two really great responses right 25 on the spot. For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 92 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 MR. BURKETT: Awesome. The PPDC is 2 working, yeah. Thank you very much. That was pretty 3 useful. So the Insecticide Resistance Action Committee, their 4 website you say has some recommended insect 5 resistance or pesticide resistance testing protocols 6 there. I'll have to check that out. So thank you so 7 much for your feedback. Appreciate it. 8 MR. ANNINOS: Well, thank you for your 9 question, Doug. 10 And Dan and Caydee, thanks for providing 11 some help to Doug right here in the midst of things. 12 So that's great. 13 We're about out of time and, again, I've 14 just got to -- I got to thank, you know, Alan, Bill, 15 David, Amy, and Caydee for your presentations today. 16 Really well done. I hope you got some good feedback 17 that you can put to action over the next few weeks 18 and months. And, again, that's an open-ended -- 19 that's an open-ended ask, right, for all the 20 workgroups. So thank you all very much. 21 Any final words by any of you? 22 MR. REYNOLDS: I'd just like to thank the 23 PPDC group. We really appreciate your feedback and 24 input today. It's invaluable for us and we look 25 forward to working with you over the next few months. For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 93 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 MR. CHISM: Yes, thank you very 2 much. 3 MR. ANNINOS: Thanks. Thanks, everybody. 4 And so with that, what we can do is we can move to 5 the next segment of the agenda. And so yesterday we 6 had the first of four segments, what we're calling 7 the PPDC member presentations on stakeholder 8 interests. So now we're on the second of the four, 9 information and perspectives on the crop protection 10 industry, and Charlotte Sanson and Mano Basu are our 11 co-presenters here today. 12 And so we'll go ahead -- I think this is a 13 15 or 20-minute segment. Actually, my notes are a 14 little bit fuzzy on that. We have until 1:20 Eastern 15 time for this segment. Is that right, Shannon? 16 MS. JEWELL: That's right. Yep. 17 MR. ANNINOS: Okay, very good. Very good. 18 So let me turn it over -- I think Mano is getting the 19 presenter role, so maybe that is happening as we 20 speak. And whoever's going to take it away, go 21 ahead. 22 23 24 25 For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 PPDC MEMBER PRESENTATION ON STAKEHOLDER INTERESTS 2 INFORMATION AND PERSPECTIVE ON THE CROP PROTECTION 3 INDUSTRY 4 MR. BASU: Thank you very much, Paul. 5 Yeah, I have the presenter role now. Shannon -- 6 sorry, Charlotte was going to start on this 7 presentation. So, Charlotte, please say next and I 8 will move the slides. 9 MS. SANSON: Okay, sounds good. Thanks, 10 Mano. 11 And thank you for the opportunity for this 12 presentation. 13 So, okay, next. 14 I'm going to share a brief overview of the 15 product development process for a conventional active 16 ingredient and describe the underlying robust process 17 that ensures the associated scientific integrity. 18 And then Mano will share the strategic priorities of 19 our trade association, CropLife America. 20 Okay, next slide. 21 So this slide of -- I could speak to this 22 slide all day, but I'll try and condense it here. 23 This is a high level illustration of the typical 24 timeline and investment relative to a registrant's 25 path to obtain registration of a new conventional For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 95 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 active ingredient, be it a fungicide, a herbicides, 2 insecticide or plant growth regulator. A company 3 will initially screen thousands of potential 4 compounds at the discovery phase before selecting the 5 one that has the best market potential and chance of 6 success going through the regulatory development 7 process. 8 So it all starts with biological screening 9 in the lab, in the field, while toxicology screening 10 is done and a business case is developed. And as you 11 can see, there are several processes that can occur 12 in parallel. When things are looking favorable, by 13 the end of year three and upon approval of the 14 business case by company management, the required 15 regulatory studies are initiated. Some cases are 16 already started. But that process can typically take 17 about three years and sometimes even up to four years 18 to complete. And, of course, that depends on the 19 complexity of the molecule, the target uses, the 20 formulations, et cetera, with an overall cost for all 21 these activities that can run more than $250 million, 22 over a period that can take up to 11 years from 23 discovery to market. 24 So during the development phase, the 25 company usually plans pre-submission meetings with For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 96 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 EPA and also with PMRA in the event the review is 2 planned to be a joint review between U.S. and Canada, 3 and this is to inform the agency of the intention to 4 register the product and then also an opportunity to 5 obtain guidance or feedback on the study strategies. 6 So the application to register the active ingredient 7 and the associated end use products is submitted to 8 OPP after the data package is complete. And this can 9 contain over 200 individual study reports. And, of 10 course, that's quite an overwhelming job at both 11 ends. But then the PRIA timeline is designated at 24 12 months. I think we've noticed an average of about 33 13 to 34 months in terms of EPA review. 14 If a company's applied for reduced risk 15 status or goes through review as a reduced risk 16 candidate, the PRIA timeline is 18 months, and that's 17 as an incentive, and PRIA 4 also established a 18 reduced fee for a reduced risk chemical, as you can 19 see. So this slide is sort of simplified, but it 20 encompasses the whole process. 21 Okay. So next slide. 22 So from a registrant's perspective, there 23 are key expectations at the foundation of a sound 24 regulatory process, and this is what I would consider 25 priority areas. We rely on scientific integrity both For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 on our part, as well as the agencies, for sound 2 decisions. The studies that a company conducts and 3 submits to EPA in support of a product's registration 4 are done under strict conditions, and that's in 5 accordance with good laboratory practice or GLP. 6 This ensures such things as data integrity, quality, 7 and reproducibility, and I'll speak to those further 8 in a minute. 9 We rely on consistency of EPA reviews and 10 interpretation of supporting data and the companion 11 product labels. And we know that predictability for 12 when to expect a PRIA decision does not guarantee 13 registration will happen by that date. However, with 14 a business that is so seasonal-driven as ours is, 15 it's critically important that surprises are 16 minimized and unexpected issues are addressed along 17 the way. 18 And then the one thing that we've all 19 experienced internally, especially in the past year, 20 is the value of efficient processes, which are 21 critically important to maintain timelines and help 22 ensure that predictability. And I'm encouraged that 23 at the OPP end, a lean initiative is underway as 24 presented by Ed during the previous PPDC, and look 25 forward with the expectation when the registration For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 98 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 division will begin to employ that. 2 Next slide. 3 So as everyone knows FIFRA regulation of 4 pesticides is data driven and the PPDC panel members 5 were well educated on this topic as well as the 6 associated risk assessment and evaluation process by 7 the OPP teams during our onboarding session. So I 8 don't intend to repeat any of that, just except to 9 emphasize the GLP, or good laboratory practice, 10 aspect of data generated in support of a product's 11 registration. 12 So next slide. 13 So in the previous version of this week's 14 PPDC agenda, we noticed that there was originally a 15 presentation planned OECA that was going to discuss 16 the topic of the GLP inspection process, which 17 hopefully we'll still get to here at a future 18 meeting. So maybe in preparation for that, we 19 thought we would take the opportunity to provide a 20 very high-level overview of GLP and describe what it 21 is for those who may not be familiar and the efforts 22 that registrants put into ensuring compliance. And 23 so GLP is a quality system of controls for research 24 laboratories and organizations, and in the end, EPA 25 should be able to reconstruct a study in its For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 99 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 entirety. 2 Adherence to GLP ensures uniformity, 3 consistency, reliability, reproducibility, quality, 4 and data integrity. And you can find more about GLP 5 requirements and the compliance standards in 40 CFR 6 Part 160. It is all spelled out in there in great 7 detail. 8 So next slide. 9 So the main elements of GLP include 10 organization and personnel and companies who generate 11 their own data have their own QA staff who serve to 12 make certain that GLP procedures are being followed. 13 They'll audit a study that's in process and ensure 14 the integrity of the study's final report. They also 15 will audit CROs with whom the company might outsource 16 a study to ensure that the lab is adhering to GLP 17 because the sponsor company is ultimately 18 responsible. 19 Roles for others involved in the study are 20 also defined and GLP also addresses, as shown here, 21 the test facilities, equipment, how the test 22 facilities should operate, which is using SOPs, the 23 test substances, study protocols, as well as study 24 reports and records. 25 So next slide. For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 100 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 So I'm only going to discuss a couple of 2 those areas and primarily the study protocol and the 3 record-keeping requirements. So within the company 4 and in coordination with the CRO if a study is 5 outsourced, a study protocol is created and agreed by 6 all parties involved and signed off. And at that 7 point, any changes to the study protocol must be 8 fully documented. 9 Okay. Next slide. 10 There's also strict record-keeping 11 requirements that apply to SOPs detailing how a 12 specific task is done, by whom, et cetera. Persons 13 who perform these duties are required to sign off on 14 the SOP to certify they understand the procedures as 15 written. 16 Okay, next slide. 17 And record-keeping is intended to provide 18 the Government with a fully auditable study record, 19 allowing them to reconstruct the study according -- 20 that's done according to GLP, and the raw data that 21 has to do with GLP are maintained for long periods of 22 time. Companies typically maintain these records for 23 as long as the product is registered and usually for 24 a period of five additional years after that. 25 So okay, next slide. For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 101 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 So there is an audit component. 2 Independent audits are done to ensure study integrity 3 and, typically, study auditors are employed by the 4 same organization as the laboratory staff, but 5 they're removed from participating in the study 6 itself. So one of the things an auditor does is to 7 ensure the raw data matches that which is reported 8 and that calculations are correct and so on. 9 And then EPA's Office of Enforcement and 10 Compliance and Assurance, or OECA, they'll do public 11 or, excuse me, periodic audits of studies and 12 facilities. 13 So next slide. 14 So here's an example of a GLP statement 15 that's required for inclusion in every study report 16 that's submitted in support of a registration action. 17 As you can see, it's signed by the study director, 18 the study sponsor, the person who submits the study 19 itself. If a report is submitted and the information 20 contained was not done according to GLP, that needs 21 to be stated and explained here. And an example 22 would be maybe a waiver rationale where there's no 23 data generated, but the information is relevant and 24 important for consideration by reviewers. And a 25 separate quality assurance page is also included that For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 102 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 is signed by the QA personnel. 2 So in the end, the process is very robust, 3 it's taken seriously by all parties involved to 4 ensure the scientific integrity. And I hope this 5 provides some useful insights into GLP compliance and 6 helps inform GLP members in advance of a future 7 presentation by EPA on the GLP inspection process. 8 So now I will turn it over to Mano who will 9 discuss CLA's strategic priorities. Thanks. 10 MR. BASU: Thank you very much, Charlotte. 11 And my presentation is just before a very 12 timely lunch break for those on the East Coast, so 13 I'11 be quick. 14 Again, as Charlotte mentioned, CropLife 15 America, we are a trade association representing 16 manufacturers, formulators, distributors of 17 pesticides and plant science solutions for ag and 18 pest management in the U.S. 19 From an organization point of view, we have 20 identified three strategic imperatives, priorities 21 for us, one around environmental sustainability, 22 industry perception, and regulatory integrity. For 23 today's presentation, what I'm going to do is focus 24 on two of our priorities, one around environmental 25 sustainability and some of the work we are doing on For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 103 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 regulatory integrity. 2 So what the industry is looking into is 3 continually improve our environmental outcomes 4 through voluntary conservation measures and 5 innovative technologies. There's a lot of innovation 6 that is going on within our industry. You heard some 7 of the innovative technology, emerging technologies 8 that are coming out on the application side 9 yesterday, but there's also work on the chemistry 10 side that our members are doing on almost a daily 11 basis. 12 As we were thinking about agricultural 13 sustainability and how do we define sustainability 14 for ourselves, we started this journey where we said, 15 let's see what's the best way for defining 16 sustainability for us as an industry. We were aware 17 of the United Nations' sustainable development goals 18 that were out there. The staff conducted a series of 19 interviews from members, NGOs, other associations, 20 the food industry, people on the Hill to see what are 21 those -- out of the 17 UN SDGs, what are the ones 22 which are relevant to our industry? 23 What we did, based on the effort, is 24 identify three UN SDGs, one around innovation and 25 agricultural productivity, the second on For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 104 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 biodiversity, and the third on climate change. As 2 part of our ag sustainability work, once we have 3 defined what sustainability means, what are the focus 4 areas we have that we will be working on in the next 5 five years? We were looking for engagement. So 6 what we are looking into is outreach to academics 7 where research is going on on agriculture 8 productivity, biodiversity, climate change. We are 9 engaging with a few environmental NGOs -- we would 10 like to engage with more -- and conservation 11 organizations where we are having discussions. 12 Finally, the goal is, from a communication 13 perspective, talk about pesticides and 14 sustainability, talk about what our members are 15 doing, the amount of work that they are doing around 16 sustainability, develop some of the fact sheets on 17 greenhouse gas emissions, habitat restored, some of 18 the soil health productivity work. Our research plan 19 is to focus on life cycle analysis and do some 20 monitoring and reporting on ag sustainability 21 overall. 22 Thinking specifically on defining 23 sustainability and what does it mean from a 24 biodiversity perspective, we then started looking 25 into specific metrics or indicators that would help For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 us understand how biodiversity is being improved, 2 3 looking specifically into improving soil health and 4 resiliency, reducing topsoil erosion -- we know 5 topsoil erosion is a major issue -- cover crop, 6 reduce stale agronomic practices, reduce topsoil 7 erosion, how our products help in reduction of 8 topsoil erosion. Contributing to soil health is 9 something we are going to look into. Improving 10 pollinator health and then, again, promoting 11 conservation. There's a lot of effort going on 12 within our member companies. How do we bring those 13 efforts and share that with the audience. 14 MR. BASU: From a climate change 15 perspective, focusing again on lowering greenhouse 16 gases, whether it's through cutting fuel consumption 17 because of few tractor runs that need to happen with 18 a cover crop or reduced-till practices and in 19 promoting reduced-till practices in itself. 20 Moving on to the innovation and 21 productivity, looking into newer chemistries. You 22 heard about robotics and precision ag yesterday, 23 looking into decreasing yield and also focusing on 24 enhancing farmer education on the use of these tools. 25 Just to give you some example of some of For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 106 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 the conservation work our member companies have done, 2 and these are just a few examples, there are several 3 examples out there, last year, Corteva Agriscience 4 announced a two-year agreement to support efforts of 5 the Nature Conservancy, and this work was around 6 growing more sustainability while protecting water 7 quality. 8 Another example was pollinator health, and 9 since 2011 Bayer Bee Care Program has supported more 10 than 30 collaborative projects, addressing local and 11 regional threats and opportunities facing 12 pollinators. 13 Finally, another example on rescuing 14 farmland, and this is Syngenta's Good Growth Plan 15 Program, where the company benefitted about 2 6.7 16 million acres of farmland on the brink of 17 degradation, roughly the size of Tennessee. 18 So you can imagine these conservation 19 programs, these programs our members are supporting, 20 has a huge impact on environmental sustainability. 21 And what we are looking into is how can we promote 22 these efforts and how can we advocate for -- on these 23 efforts. 24 The second issue I want to talk about 25 briefly here is around regulator integrity. Again, For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 107 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 we are committed to a transparent and reliable 2 federal risk-based pesticide regulatory process. And 3 within that, the one area I want to focus today is on 4 the endangered species evaluation. Talking 5 specifically on the endangered species, ESA FIFRA, we 6 at CLA have submitted several comments on the 7 challenges that we see with the biological evaluation 8 process. There are lots of conservative assumptions 9 that are being made. 10 In the BE, we have submitted extensive 11 comments whether it be on the revised methods or the 12 BE's -- some (inaudible) have come in. We are aware 13 of challenges with limited expertise. On the 14 services side, a lack of transparency with the whole 15 handoff process, a 12,000-page document being handed 16 off to the services. Errors with the modeling, 17 issues with the legal standard, the limited 18 collaboration and the BE workload that's going to be 19 there in the next few years. 20 This is not, again, the full list of 21 problems we have identified, but you could boil all 22 these problems down into three issues, one around 23 inefficient process, the second around opaque 24 communication, again that huge technical complex 25 document being passed over to services, and the lack For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 108 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 of resources within services who are doing all the 2 work that is coming their way in the next few years. 4 challenges? I mean, we know -- we are aware of the 5 registration delays, litigation and farmers' access 6 to key tools, maybe in the middle of the growing 7 season or just before the growing season. These are 8 real concerns and issues. But, most importantly, the 9 current process does not provide any benefit to 10 species. So what we propose and what we are looking 11 at from a CLA strategy -- industry strategy 12 perspective is how can we benefit species and at the 13 same time ensure legal certainty. 14 Working around efficiency, as I said, there 15 are challenges with efficiency. Working on 16 resources, what are the resource allocation that 17 needs to happen? And, finally, stakeholder 18 engagement, we truly believe that more stakeholder 19 engagement needs to happen between the federal 20 family, the registrant, NGOs, grower groups, and 21 everyone who is involved in the process. 22 Finally, from the presentation on ESA, some 23 key takeaways, what we support and we request is more 24 collaboration between the federal family, EPA 25 services, USDA, the stakeholder engagement around 3 So what happens because of these For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 109 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 federal family, registrants, farmers. Better 2 communication within the federal family. Explaining 3 the limited purpose of the biological evaluation in 4 non-tech -- for the non-technical audience. There's 5 a lot of details in those. And the biological 6 evaluation is not the end of the risk assessment 7 process. There is the bio (inaudible). There is the 8 whole registration process. So how can the agency 9 help explain the limited purpose of the biological 10 evaluation? 11 Explain avoidance and minimization aspects 12 of pesticide registration, these are key. There's so 13 much of avoidance and minimization as part of the 14 label registration that happens, and there is no 15 recognition for those avoidance and minimization. 16 Finally, around improving efficiency, we 17 know the risk assessment, it's a continuous 18 improvement process and there are challenges that we 19 have identified with the risk assessment. Those 20 issues with the risk assessment need to be fixed. 21 And the second part of improving efficiency is on 22 leveraging existing and seeking additional resources 23 for conservation of listed species. 24 We know, I mean, last year Congress 25 appropriated about $8 billion towards ag For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 110 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 conservation. How can we utilize some of those funds 2 towards benefitting the species? What are the 3 additional requirements from a funding perspective 4 that we can consider for benefitting the species? At 5 the end of the day, we are looking at benefit to the 6 species and the legal certainty. 7 Paul, back to you. I saw the reminder. 8 Thank you. 9 MR. ANNINOS: No problem at all, Mano. No 10 problem at all. And thank you. Thank you, 11 Charlotte. Thank you, Mano, for these great 12 presentations. Maybe we have time for one question, 13 just to see if there's anybody that has a burning 14 question for -- or a comment for either or both of 15 you on your presentations. I don't see anything in 16 the chat window, but I'll just make it open for one 17 person. 18 (No response.) 19 MR. ANNINOS: Hearing none, I think I just 20 wanted to thank you very much for the presentations. 21 We're ready to move to the lunch break. I see that 22 Ed has come on the screen there. I didn't know if 23 you had anything you wanted to add before we broke 24 for lunch, Ed. 25 MR. MESSINA: No, just thanks for the great For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- Ill Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 presentations today, the great discussions. We 2 really appreciate it. And be back promptly at 2:00, 3 where we'll hear from Michal Freedhoff. 4 MR. ANNINOS: Exactly, exactly. So I would 5 suggest people just stay connected to the Webex. 6 They just go -- maybe just turn off your video, turn 7 off your audio, set a reminder on your calendar on 8 your phone to ping you at 1:55 p.m. Eastern time. 9 Log in a little bit early so we can get started right 10 at 2:00 Eastern time. Okay? 11 Thank you very much. Enjoy your lunch. 12 Take a break. 13 (Lunch break.) 14 15 16 17 18 19 20 21 22 23 24 25 For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 112 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 WELCOME FROM PRINCIPAL DEPUTY ASSISTANT 2 ADMINISTRATOR 3 MR. MESSINA: So welcome, Michal. Thank 4 you so much for joining the PPDC meeting that we've 5 been having for the last couple of days. 7 she is currently the Principal Deputy Assistant 8 Administrator for Chemical Safety and Pollution 9 Prevention, which is the office that sits above the 10 Office of Pesticide Programs. So she is my boss. 11 And she's been here for a couple of months and I've 12 gotten a chance to know her a little bit and it's 13 very obvious to anyone who meets her that she's 14 incredibly smart, shows great judgment, and is 15 extremely willing to listen to the career scientists 16 and the professionals at EPA. So it's really been a 17 delight to work with her for the past couple of 18 months. 19 But my introduction here really pales in 20 comparison to the reception that Michal had yesterday 21 at her hearing. I'm going to call it, quote, 22 unquote, "hearing." It was almost like a homecoming. 23 President Biden recently nominated Michal to be the 24 Assistant Administrator for the Office of Chemical 25 Safety and Pollution Prevention. And as I mentioned 6 So for those of you who don't know Michal For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 113 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 yesterday, her confirmation hearing was yesterday, 2 which is why we're hearing from her today. 4 at that hearing were that Michal was referred to as a 5 brilliant scientist. Senator Inhofe, in his own 6 words, said that it was basically the only thing that 7 Senator Markey and he agreed upon was Michal's 8 qualifications. She was credited for making Senator 9 Markey sing on the Senate floor, a song about TSCA 10 and chemicals. She's received numerous endorsements 11 from various organizations, including multiple past 12 administrators and assistant administrators. 13 And then, lastly, near and dear to my 14 heart, when she was asked sort of a final question, 15 which was was there any question that she wished she 16 had been asked but wasn't, she chose to highlight the 17 great work of OPP in response to COVID as something 18 that she wanted to talk about. And so that was 19 really great to see her continuing to be a 20 cheerleader for the office that she is representing. 21 So it's safe to say she did a pretty good 22 job yesterday visiting with the committee, for which 23 she has obviously -- which obviously has assessed her 24 abilities quite well. And it's where she worked in 25 the past. So it's great when your colleagues and 3 And some of the things that were mentioned For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 114 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 your boss sing your praises at the hearing. 2 So please join me in welcoming Michal to 3 talk to us at the PPDC and thank her for her time 4 today. With that, over to Michal. 6 was really nice. And I promise everybody there will 7 be no singing. Like for the whole four years if I'm 8 lucky enough to be here, there will be no singing. 10 work we do to partner with EPA and other stakeholders 11 to develop practical and protective approaches for 12 pesticide regulatory policy implementation. And, you 13 know, I really first wanted to say that I appreciate 14 your flexibility on scheduling and I was kind of busy 15 yesterday morning, as Ed let you know, and I'm very 16 glad I was able to join you this afternoon. 17 So I'd like to just share briefly some of 18 the priorities that I see our office addressing over 19 the coming year. And let me start by saying that I 20 want you all to know how important it is to me that 21 EPA prosper a meaningful and cooperative relationship 22 with our stakeholders. And, you know, coming to EPA 23 after spending more than two decades in Congress, 24 most recently with the Senate Environment and Public 25 Works Committee, I really did develop a tremendous 5 DR. FREEDHOFF: Thanks so much, Ed. That 9 So thanks to all of you on the PPDC for the For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 115 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 respect for the role that all stakeholders play in 2 moving environmental and health policies forward, and 3 even more importantly than that, making sure that 4 they're robust and long-lasting. And I think that 5 when you can find consensus in as many places as 6 possible, that's when we end up with the most 7 durable and lasting policies, outcomes, and 8 solutions. 9 I also know that in many, if not most, 10 cases, you know the issues you're concerned about 11 better than we do because you're the ones who see 12 firsthand how EPA's policies play out in the real 13 world. So I know and value the importance of the 14 collaboration that regulators at EPA must have [audio 15 issue]. 16 So the first step towards effective 17 environmental protection is ensuring the integrity of 18 our science because our actions are really only as 19 effective as the [audio issue]. And as you know, 20 President Biden has issued executive orders and 21 direction to review all Trump-era environment rules. 22 And that will ensure that what we do is protected and 23 will restore scientific integrity to EPA's decision- 24 making process. 25 Political interference with the work of For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 116 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 scientists and blocking the communication and 2 critical information to the American people was 3 unfortunately a bit too commonplace in the last 4 administration, even though I just want to say a 5 great deal of a fantastic science and work did happen 6 in the last four years as well. 7 But one high-profile example of a time when 8 science wasn't really the driver of our policy was 9 when OCSPP's previous senior leadership interfered 10 with the 2018 Dicamba decision by discounting 11 (inaudible) facts assessments of Dicamba's risks and 12 benefits. And that probably contributed to a court 13 vacating EPA's 2018 Dicamba pesticide registrations. 14 And the court found that EPA failed to even consider 15 reports of damage to millions of acres of crops, for 16 example, to non-Dicamba resistant varieties of 17 soybeans, along with damage to high-value crops like 18 peaches and tomatoes, which affected many farmers. 19 And, in addition, there were other reports of damage 20 From Dicamba to residential gardens and ornamental 21 plantings. 22 And so the political interference that the 23 2018 decision had and the court's subsequent decision 24 to throw it out impacted all of growers' ability to 25 (inaudible) product. And it also contributed to an For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 117 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 aversion in the trust that the public has in the 2 agency. 3 When EPA says that a pesticide can be used 4 safely, it's in everyone's interests that the people 5 believe that what we're saying is grounded in the 6 science and the law. And it's also in the industry's interest 7 because if the public has confidence in 8 the safety of the product industry makes that's good 9 for industry, too. And, right now, I don't think the 10 agency's trusted in the way that it needs to be. 11 Unlike 2018, the 2020 decision on Dicamba 12 does reflect the insight of EPA scientists. EPA 13 stands behind that decision. 14 More generally, I want to affirm my 15 commitment to scientific integrity, communication, 16 trust and transparency in EPA's decision-making 17 process. And I want to know that OCSPP is home to 18 world class scientists and I will ensure their voices 19 will guide our decisions during this administration. 20 So part of our commitment to sound science 21 involves keeping pace with scientific investments and 22 adjusting our regulatory approaches when necessary to 23 align with those advancements. And in recent years, 24 our agency has made strides towards reducing the use 25 of laboratory animals in testing -- in pesticide For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 118 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 testing. Some of the briefings that I've had on that 2 have been really, really exciting. 4 evaluating new technologies in molecular, cellular, 5 and computational sciences to reduce and replace more 6 traditional methods of toxicity testing in risk 7 assessment, and OPP is also modernizing data used in 8 risk assessment. And the transition from relying 9 primarily on laboratory animal studies to non-animal 10 approaches is being done in a transparent and 11 scientifically robust way (inaudible). We're working 12 collaboratively with stakeholder groups, including 13 animal welfare groups, states, academic and industry 14 scientists to ensure that new methods made agency 15 needs to protect human health and the environment. 16 We're also encouraging and implementing 17 novel effective ways to minimize pesticide drift. 18 Spray draft is routinely evaluated in the 19 registration review process using peer review 20 risk assessment (inaudible). And I'm sure you all 21 know there's multiple ways to reduce spray drift, 22 including changes in nozzle selection, hooded 23 sprayers, choice of application method and 24 application rate changes. And we're also supporting 25 precision agriculture approaches that better manage 3 Our pesticide program is developing and For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 the use of pesticides and application processes, like 2 GPA guidance and (inaudible) which can turn sprayers 3 on and off as appropriate. We need to help growers 4 use pesticides efficiently and better ensure 5 chemicals stay within (inaudible). 6 As a country, we're also facing the crisis 7 of a rapidly changing climate. We know many of our 8 stakeholders are already grappling with climate- 9 related challenges, like changing weather patterns 10 and increasing temperatures, changes in insect and 11 pest behavior, more frequent and extreme 12 precipitation and drought, all of which can 13 dramatically alter plant growth patterns. 14 Within hours of taking office, President 15 Biden issued an executive order that made clear his 16 commitment to tackling climate change in the ways 17 this administration [audio issue]. 18 Looking through an expanded lens for OCSPP, 19 we're thinking creatively of ways to manage some of 20 the effects of climate change, like further 21 leveraging integrated pest management, or IPM. We 22 want to build IPM capacities and evaluate the 23 feasibility of new innovative IPM approaches and 24 methodologies that will combat pesticide resistance, 25 reduce risk, and protect the environment. In some For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 120 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 instances, the flexibility of using IPM as an 2 alternative to conventional pesticides will also 3 reduce the impact to climate change. 5 cover crops to grow can keep moisture and nutrients 6 in the ground and that will lower greenhouse gases. 7 And pesticide use itself, particularly the use of 8 fumigants, can be a contributor of climate change. 9 So it's important to ensure that we're using these 10 chemicals just when and where they're needed. A 11 significant percentage of the world's food supply is 12 lost annually to pests and climate change has rapidly 13 introduced new pests. So improving pest management 14 with a focus on integrated sustainable practices is a 15 way to ensure (inaudible) security while decreasing 16 greenhouse gas emissions. 17 And decreased pesticides are also 18 Often an outcome when IPM practices are 19 implemented. Less pesticide use and reduced use of 20 the equipment needed for those applications would 21 also reduce greenhouse gas emissions, furthering the 22 fight against climate change. 23 In addition, in January, EPA renewed its 24 commitment to working with the agricultural community 25 as a partner in the pesticide environmental 4 There's a couple of examples. Allowing For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 stewardship program. We're reinstating the PESP 2 grants for projects that explore innovative 3 solutions, that promote adoption of IPM, furthering 4 the agency's role of providing a healthier 5 environment for all Americans. We expect a call for 6 submissions sometime in the next few weeks, so we 7 need to be on the lookout for that. 8 The President has also directed EPA and 9 other agencies to advance equity for all Americans, 10 including people of color and others who've been 11 historically underserved, marginalized, and adversely 12 impacted by persistent poverty and equality 13 (inaudible). And this also includes some of our 14 nation's farmworkers, their families, and residents 15 of agricultural communities, all of whom would 16 benefit most from our national pesticide safety 17 training, education, and outreach efforts. 18 As a part of our commitment to farmworker 19 protection, we're continuing our important work with 20 the Association of Farmworker Opportunity Programs, 21 or AFOP, toward our common goal of protecting our 22 farmworkers and their families. Starting this year 23 through 2025, AFOP will receive up to $500,000 24 annually through our National Farmworker Training 25 Grants Program to conduct training across the For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 122 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 country. They'll provide occupational health and 2 pesticides safety training to migrant and seasonal 3 farmworkers in more than 25 states with a network of 4 over 200 (inaudible) and we know this will have a big 5 impact because through our previous cooperative 6 agreement with AFOP, the program trained 184,000 7 farmworkers and 40,000 children. 8 We're also committed to upholding 9 farmworker protections through the historic 2015 10 Agricultural Worker Protection Standard, which 11 improved protections against pesticide poisoning and 12 injuries for more than 2 million workers. 13 Now, I mentioned that I brought up COVID 14 and the agency's response to that in my hearing 15 yesterday and I really had hoped to get a question on 16 that and was really very happy to have the 17 opportunity to talk about it, because EPA really 18 played an important role in the nation's response to 19 (inaudible). Since the declaration of the public 20 health emergency, EPA worked aggressively to ensure 21 that Americans are aware of the facts as to surface 22 disinfectant products that would be used effectively 23 against the virus. 24 And in OCSPP, we expedited the review 25 process for products eligible for emerging viral For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 123 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 pathogen claims (inaudible) requiring the review of 2 new data. We expedited applications to add 3 directions for use with electrostatic sprayers to 4 products intended to kill SARS-CoV-2. We created 5 flexibilities for manufacturers by temporarily 6 allowing registrants to notify EPA of certain 7 formulation and manufacturing facility changes and 8 immediately released the product for sale without 9 first waiting for EPA approval. We provided 10 flexibility for the annual worker protection training 11 requirements, pesticide applicator certifications, 12 and to address respiratory equipment shortages. 13 And over the course of the past year, we 14 also learn a lot more about COVID-19, how it spreads 15 and the role contaminated surfaces play in the 16 transmission process. And the more we learned, the 17 more we were able to adjust our decisions, actions, 18 and requirements to make some of these changes 19 accordingly. 20 So recent information from the CDC notes 21 that the risk of being infested with COVID-19 by 22 touching contaminated services is actually pretty low 23 and that airborne transmission is a much higher risk. 24 So given the release of that new information, we've 25 updated our disinfectant policy to align with new CDC For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 124 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 science. 2 And two weeks ago, we announced the agency 3 was no longer prioritizing public health emergency 4 requests for new products that address surface 5 transmission of SARS-CoV-2. And, instead, we're 6 going to shift our resources to the evaluation of 7 innovative and novel products, like those that kill 8 airborne SARS-CoV-2. And, in addition, in light of 9 the hundreds -- I think we're up to 550 -- of EPA 10 registered surface disinfectants, we won't be 11 expediting new product registrations and other 12 actions for products intended to kill SARS-CoV-2 on 13 surfaces. We'll just continue to review them using 14 standard registration process (inaudible). Working 15 with our counterparts at CDC and other federal and 16 state agencies, we ensure our guidance continues to 17 reflect the most up-to-date findings. 18 In closing, I'd just like to to reiterate 19 our commitment to returning to our core mission of 20 protecting human health and the environment, which 21 starts with effective cooperation with our 22 stakeholders. It's an exciting time at EPA. We're 23 moving ahead with fresh ideas and a renewed 24 commitment to our mission, science, and transparency. 25 We'll be taking on the climate crisis and deliver environmental(inaudible) For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 125 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 justice. 2 I'm looking forward to your advice and 3 input over the rest of this meeting on important 4 topics that PPDC (inaudible) minimizing pesticide 5 resistance, how to bring new agricultural 6 technologies to the market, and how we can enhance 7 existing policies to better respond to challenges 8 from viral pathogens. It's all very important work. 9 And I thank you all again for your time and service. 10 And I'll turn it back to Ed so you can 11 resume with this meeting. Thanks again. 12 MR. MESSINA: Thank you so much for joining 13 us, Michal. 14 All right. So we are -- I know your 15 schedule is tight and I know Michal has got to run, 16 so it was great to have her. So I appreciate her 17 stopping in. 18 So now we're going to go on and hear about 19 the Endangered Species Act. We've got some great 20 presenters on this topic. Obviously, a topic of 21 great interest to the agency and the public and we've 22 heard some initial information from industry and 23 we're going to hear from the Government and then also 24 hear from NOGs on this topic. 25 So with that, I'll kick it over to you, For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 126 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 Paul. 2 MR. ANNINOS: Thank you. Thanks a lot, Ed. 3 And for those of you that want a chance to see Dr. 4 Freedhoff's testimony yesterday, it's all online. 5 And I have a chance to peek into that today, this 6 morning before this meeting, really great comments 7 that she made in front of the Congressional members 8 and a great ambassador of EPA and, of course, very 9 focused on the mission of OCSPP. 10 So we're going to move now, but before I 11 introduce Cathy, I think Charlotte Samson wanted to 12 -- I'm not sure if it was like correcting a statement 13 or maybe expanding on a statement from earlier in the 14 day. 15 So, Charlotte, let me just hand it to you 16 for just a minute to do that. 17 MS. SANSON: Yeah, thank you. Thank you so 18 much, Paul. This will be really quick. 19 During my talk, I had referenced Ed's 20 presentation from the last PPDC where he described 21 OPP's Lean initiative. And I just wanted to make a 22 correction in something I had said. And I meant to 23 say that we understand that the Registration Division 24 is already putting Lean into practice and we know 25 that they'll be implementing some -- a Salesforce For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 127 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 that is intended to replace legacy tracking systems. 2 And we expect this will greatly contribute to 3 efficiencies once it's implemented following the 4 pilot that is being done with the Antimicrobial 5 Division and BPPD. So I just wanted to be sure that I 6 was clear on what I had said there with regard to 7 efficiency. 8 So thank you, Paul. I appreciate it. 9 MR. ANNINOS: You bet, you bet, Charlotte. 10 No problem at all. Thank you. 11 MR. MESSINA: Thank you, Charlotte. 12 MR. ANNINOS: Okay. 13 MR. MESSINA: Yeah. At some point, when we 14 deploy the Salesforce instance in the Registration 15 Division, we'll definitely come to this group and 16 talk to you about what that looks like, maybe even do 17 a demo. It's a pilot right now for BPPD and the 18 Antimicrobials Division. And I have presented on 19 that topic. I'm happy to put that on maybe as a 20 future deliverable for us to talk about at the PPDC. 21 It might be good timing in the fall. 22 MR. ANNINOS: Perfect, perfect. 23 So we've heard two stakeholder interest 24 presentations so far. Now we're going to hear, back- 25 to-back, numbers 3 and 4 of 4. So both topics are For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 128 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 ESA related. Cathy Tortorici from the Office Of 2 Protected Resources, focused on endangered species at 3 NOAA fisheries. And so we're very happy to have her 4 with us today. 5 And I'm assuming by now you've been handed 6 the -- oh, actually, I think Sarah Chadwick may be 7 actually running the slides. 8 MS. TORTORICI: Yes, that's correct. 9 MR. ANNINOS: So all you have to do is give 10 her a verbal cue and she'll know when to move to the 11 next slide. 12 So, Cathy, you're up. And then -- you're 13 up at this point. So good. 14 15 16 17 18 19 20 21 22 23 24 25 For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 129 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 2 PPDC MEMBER PRESENTATIONS ON STAKEHOLDER INTERESTS 5 much. It's great to be here, and I want to spend the 6 next few minutes just giving everybody some updates 7 on what we've been doing from the ESA-FIFRA 8 consultation standpoint. And I'm presenting some 9 information not only from the Fisheries Service, but 10 also from Fish and Wildlife and EPA as well. So it's 11 kind of a round-up of where we are right now. 12 So let's take it away. Next slide, please. 13 So you've been -- you've heard about the 14 ESA already in this meeting, and just to orient folks 15 who may not be aware in terms of the Endangered 16 Species Act, it's really a -- it's a law that's based 17 on species conservation in terms of protecting 18 species and the environments in which they live. 19 Ed had brought up this issue earlier in the 20 meeting about Section 7(a)(2). This is what we call 21 interagency consultation and this is where the 22 Fisheries Service and also the Fish and Wildlife 23 Service, because we share responsibility to implement 24 this act, are working with federal agencies to ensure 25 that the federal agency -- and you can see the text 3 ON-GOING FIFRA-ESA CONSULTATION WORK 4 MS. TORTORICI: Thank you. Thank you so For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 130 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 there -- their actions are not resulting in adversely 2 affecting species or resulting in destruction or 3 adverse modification of what we call critical 4 habitat. And so we've been working with EPA on this 5 for a number of years, many years. So this is not 6 new to us, not new to EPA in the work that we're 7 doing here. 8 Mano brought up the biological evaluation, 9 and just quickly in terms of the process, I'll speak 10 generically now, but when an action agency, like EPA, 11 comes to us and they're asking for consultation on a 12 particular action, they prepare a document called a 13 biological evaluation that basically summarizes what 14 is the action that they're going to give to us, 15 either NMFS or Fish and Wildlife to consult on, and 16 that document also describes what they believe the 17 effects of their action are to the ESA-listed species 18 that are within the action area of the project. 19 And then if we believe that there's going 20 to be some level of take associated with this action, 21 we're preparing what we call a biological opinion. 22 And in this case, it's about how pesticides could or 23 could not jeopardize, threaten endangered species or 24 destroy or modify critical habitat. So that's the 25 mini, mini version of the process that we've been For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 131 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 engaged in for years on this particular topic. 2 3 Next slide please. So I think Ed might have mentioned this, 4 EPA recently released, in March 2020, a revised 5 method document for the way that they're conducting 6 the analytical assessments around the development of 7 their biological evaluations. Okay? This is 8 important because it really sets the stage for what's 9 in those documents that then we, as the Fisheries 10 Service or Fish and Wildlife Service, are going to 11 react to in terms of the development of the 12 biological opinion. We certainly consider everything 13 that's in that biological evaluation when we're 14 making determinations. We may also include 15 additional information that we've determined to be 16 best available science. 17 So we're bringing that all together in the 18 biological opinion, but the core of it is with the 19 biological evaluation, and this revised methods 20 document is the core of what EPA is using to develop 21 their documents. 22 Next slide, please. 23 So EPA has been working on biological 24 evaluations using this revised method for the 25 chemicals, carbaryl and methomyl, atrazine, simazine, For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 132 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 propazine and glyphosate, and there's a website that 2 Ed mentioned as well, and here's the link to it and I 3 invite you to go to that website because I think that 4 it has a lot of really good information to help 5 understand the process of what we're trying to 6 accomplish, at least from the EPA side, with the 7 consultation process. 8 Next slide. 9 So we have a schedule for biological 10 evaluation development that EPA has put together. 11 We've actually completed some of this, which is great 12 news for the first two sets of chemicals. The final 13 BE for atrazine, simazine, propazine and glyphosate 14 is going to be ready in November. We've already done 15 good work on carbaryl and methomyl. And the rest of 16 those chemicals you can see when the draft BEs are 17 coming and when the final BEs are coming and those 18 graph BEs are out -- you know, they will be put out 19 for public review on the EPA docket so that 20 stakeholders will have the opportunity to provide 21 review and comment of those documents. 22 Next slide. 23 So the Fish and Wildlife Service just 24 recently released for public comment and review a 25 draft biological opinion related to malathion. This For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 133 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 has been a long time coming in terms of the Fish and 2 Wildlife Service working to prepare this document. 3 It's a complicated document. And so the document is 4 out for public review. The comment period ends in 5 June. And you can see also the docket number and the 6 docket, at www.regulations.gov. 7 If you are interested in spending time 8 reviewing this document, I would encourage you to do 9 it because -- I will say the following, we have a 10 unique relationship with EPA on this issue of draft 11 documents or draft biological opinions. It is not 12 normally the process of, at least the Fisheries 13 Service, to release documents at a draft stage for 14 public review and comment. This process has really 15 been envisioned as an interagency conversation 16 between, for example, the Fisheries Service and the 17 action agency in terms of what is going on with the 18 proposed action, and sometimes applicants are brought 19 in on a case-by-case basis. 20 What we have with the EPA, ESA, FIFRA 21 services process is really quite different about 22 putting draft documents like this out for public 23 review and getting feedback on those. So if you're 24 interested, I would invite you to take advantage of 25 what is being offered in terms of the opportunity to For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 134 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 provide review and comment. 2 3 Next slide, please. So what did Fish and Wildlife say about 4 malathion? They said that of the species they looked 5 at, and they looked at many species, that 78 of those 6 listed species could be jeopardized and there were 23 7 critical habitats that could be adversely modified. 9 interesting, is rather than presenting defined 10 reasonable and proven alternatives, which are 11 approaches to relieve the jeopardy, the BiOp has 12 included categories of different types of techniques 13 or ways that you can then adapt or adopt into an RPA 14 alternative, and then also it's going to include 15 reasonable and prudent measures to help minimize 16 incidental take. And then that it's Fish and 17 Wildlife Service's intention to work with EPA and the 18 appropriate registrants to craft those final 19 reasonable and prudent alternatives. 20 Next slide, please. 21 So we have two biological opinions that we 22 recently put out for public review, and that comment 23 period closed in April of 2021. And you can see the 24 chemicals there. We analyzed the impacts not 25 nationally -- the malathion BiOp was a national 8 And what the document does, which is For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 135 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 biological opinion. These particular biological 2 opinions, for the way that they were set up from 3 court orders, et cetera, really only covered 26 4 listed species, and those are salmon and steelhead in 5 Washington, Oregon, and California. 6 So we put those documents out for public 7 review. We got a lot of really good feedback on 8 those. The common period is closed on that. And now 9 we're projecting to complete those opinions in 2021. 10 And what I want to say -- next slide, 11 please -- is that we ended up with a no jeopardy 12 conclusion for the species that were involved and we 13 worked very closely on these two opinions with 14 stakeholders, meaning the registrants, as well as 15 EPA, to help craft those reasonable and prudent 16 measures in terms and conditions, which is also a 17 normal part of the EPA process with other federal 18 agencies, not just this one. 19 And what we have in terms of RPAs -- RPMs 20 and terms and conditions is that -- I call it a pick 21 list. There are a variety of different risk 22 reduction measures from a list of alternatives that 23 the grower can choose from to end up in a certain 24 place that's going to avoid and reduce the risk to 25 listed species. And you can see some of the examples For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 136 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 there in terms of filter strips, riparian buffers, et 2 cetera. 5 chlorpyrifos, diazinon and malathion back in 2017, 6 and that was a jeopardy conclusion biological opinion 7 for a number of species. And so as a result of a 8 request from EPA, with new information that they felt 9 they had, they reinitiated consultation in 2019 on 10 that biological opinion. We've been working with EPA 11 and the registrants in terms of providing -- 12 reviewing additional data that they've given us, and 13 we hope to complete that process per a court order 14 settlement in June of 2022. 15 And I'm saying court order in a couple of 16 places because I think some of you know, but maybe 17 not all of you know, that a lot of this is very 18 litigation-driven in terms of due dates for these 19 various documents. So there's a certain amount of 20 contents under pressure, so to speak, in terms of 21 reviewing and completing documents within a certain 22 time frame because many of the due dates are court- 23 ordered-driven due dates. 24 I've also included on the slide the EPA 25 website that you can go to to find out additional 4 3 Next slide, please. So we also issued a biological opinion on For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 information about reducing exposure to nontarget 2 plants and animals, where they focus on listed 3 species because as part of this re-initiation effort 4 and also part of implementing the biological opinion 5 while this is going on, EPA developed a website with 6 this information. And I would also invite you to go 7 to that website and take a look at what they're doing 8 regarding these issues. 9 Next slide. 10 So I'm going to close with the following -- 11 a couple following statements. You know, Mano 12 mentioned about maybe some difficulties or challenges 13 with the consultation process. I think Ed brought 14 that up as well in terms of maybe there are some 15 challenges going on. I don't disagree with that. 16 This is a very complicated process. 17 The consultations that we're preparing are 18 probably some of the most technically complicated 19 consultations that the Fisheries Service does across 20 the country. And with that comes a lot of back and 21 forth and a lot of information sharing, agreeing, 22 disagreeing, you know, talking it through about how 23 to do this in a way that's not only efficient but 24 protective in terms of species conservation and also 25 fulfills the mandates under FIFRA and ESA. For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 138 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 And we're really committed to enhancing -- 2 looking where we can to improve this consultation 3 process because just like anything, it can always be 4 made better. We can always be in a process of 5 continuous improvement as I like to say. 7 considering are, you know, where can you have 8 protections for listed species and move them earlier 9 into the consultation process, so that rather than 10 them coming later, they're included within the 11 proposed action. And in doing so, then that becomes 12 part of the consideration of what we're actually 13 consulting on in terms of looking at effects and 14 levels of effects. And this is not new to the 15 consultation process. This is something that we 16 would like to talk more about in terms of maybe 17 emphasizing it in this consultation process. 18 The other thing that we're thinking about 19 is the following, we need to look at all species, 20 especially when we're doing a national consultation, 21 right? We're looking at all of the listed species 22 under our purview in terms of the analyses that we're 23 doing in our biological opinions. But how can we 24 maybe think about especially sensitive species and 25 how we're doing that analysis and the way that we're 6 And so a couple of the ideas that we're For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 139 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 doing that compared to other species that might not 2 be as sensitive. 4 prioritization scheme, et cetera, et cetera. It 5 doesn't mean that we're not going to analyze all the 6 species or do a full-throated analysis, but where are 7 the places where we can really home in on a chemical 8 basis and think about those essentially especially 9 sensitive species and what we might be doing with 10 those? 11 With that, that is the end of my 12 presentation and thank you for the opportunity to 13 speak and I'd be happy to take any comments or 14 questions that you have later. Thanks. 15 MR. ANNINOS: Thanks very much, Cathy. And 16 I think given the time and the fact that the next 17 segment starts around 3:00, I'm going to turn this 18 immediately over to Lori Anne. 19 Hi, Lori Anne. And you can unmute yourself 20 and you can take it from here. 21 MS. BURD: Can someone advance to the next 22 slide, please? 23 Good afternoon, everyone. So we've spent a 24 lot of time here talking about the Endangered Species 25 Act, but you'll notice a few things never really come 3 This is sort of thinking about what is a For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 140 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 up in the conversation. The first is, what's at 2 stake? And the second is, how do we actually 3 implement protections to stop extinction? Because, 4 ultimately, the ESA is not about the process. The 5 ESA is not about working hard. The ESA is not about 6 stakeholder extinction. The ESA is about stopping 7 extinction and the stakes could not be higher. 8 I hate to say this again. I've said this 9 at many meetings, but extinction is forever. And 10 after years and years of hard work, we still don't 11 have ESA consultations that have been completed and 12 implemented on the ground. We don't have measures to 13 benefit our most imperiled plants and animals, even 14 the most narrow endemics or the most sensitive 15 species. And I'm really glad that Cathy brought that 16 up, the need to look at a path forward for them. So 17 I'm going to talk about what's at stake and I'm going 18 to talk about a path forward. 19 The American bald eagle is a great 20 conservation success story. The symbol of our 21 nation, bald eagles almost went extinct. One of the 22 key factors driving them towards extinction was DDT. 23 Action was taken to stop that extinction. DDT was 24 banned. Bald eagles were listed under the Endangered 25 Species Act. EPA was created in response to all For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 141 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 this. 2 Fast forward a few decades, bald eagles are 3 once again imperiled by pesticides. A new study that 4 just came out has shown that 82 percent of bald 5 eagles have anticoagulant rodenticides in their 6 blood, 82 percent. Poisoning and death by 7 anticoagulant rodenticides is an awful, awful way to 8 go, and that's the fate that we are giving to bald 9 eagles. 10 And this is the results of our choices. 11 This is the result of the actions of this office. 12 This office plays a significant role in driving our 13 current heartbreaking extinction crisis. What are 14 casually called off-target impacts around these parts 15 are not a de minimis issue. I'll say it again. The 16 actions taken by these people in this office play a 17 major role in driving extinction. And we've too long 18 pretended that this is a side issue to deal with. 19 Study after study shows this is not true. We have to 20 face this fact. 21 Next slide. 22 It's not just bald eagles. It's countless 23 species that are being impacted by pesticides. A new 24 study released just a few weeks ago found 55.8 25 percent of Florida manatees sampled have glyphosate For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 142 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 in their plasma, 55.8. The level of glyphosate 2 exposure in these manatees is enough to cause both 3 kidney and liver damage. This is not an 4 insignificant off-target impact. This is not 5 something to look at with endless refinements. This 6 is real harm, real suffering to real endangered 7 species right now. 8 Next slide, please. 9 The insect apocalypse is here. Study after 10 study shows the populations of insects, birds, 11 amphibians, and mammals are decreasing. For many of 12 them, pesticides play a significant role in their 13 population level declines. I'm going to highlight 14 insects in my presentation because, of course, a 15 significant portion of crop protection efforts target 16 insects. 17 Next slide, please. 18 Monarch butterflies. Monarch butterflies 19 are right now on a freefall towards extinction. In 20 the upper left corner, you can see blue is the total 21 number of monarchs we have; green is the increasing 22 glyphosate use that corresponds with the time of 23 their population level decline. You can see about 2 4 the same amount of corn and soy has been grown, but 25 the big thing that has changed is the widespread For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 143 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 adoption of RoundUp Ready or glyphosate-tolerant 2 crops. 4 milkweed. A few decades ago milkweed was considered 5 a pesky weed. Now, people are desperately planting 6 milkweed in their gardens. I won't even tell you all 7 what I just paid for a packet of native milkweed 8 seeds for my garden. But all of our gardens planted 9 can't be enough to replace the milkweed that has been 10 destroyed in the Heartland. 11 The amazing migration of monarchs could end 12 right now. We have more Starbucks locations in 13 California than Western monarchs, 1,900 Western 14 monarchs total. Of course, there are other factors 15 impacting monarchs. I will not say that, you know, 16 pesticides are the only thing impacting them, but 17 they play a significant role. 18 Next slide, please. 19 Monarchs aren't the only insects we're 20 tracking. As many of you know, populations of native 21 pollinators are in severe decline nationwide, not all 22 of them, but many of them. A few months ago, we 23 petitioned the U.S. Fish and Wildlife service to list 24 the American bumblebee as endangered. It was once 25 found in 47 of the lower 48 States, every state 3 Glyphosate is really good at killing For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 144 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 except Washington. It's now experienced an 89 2 percent population level decline. And pesticides are 3 playing a major role in this. 4 And, you know, often we talk about how 5 pesticides are getting more sophisticated, more 6 targeted, we have all these new technologies, but the 7 fact of the matter is that study after study shows 8 that U.S. agriculture is getting more toxic. 9 Next slide, please. 10 On Monday, the U.S. Fish and Wildlife 11 Service took a big step in proceeding with our 2020 12 petition to list the Suckley's Cuckoo bumblebee, an 13 amazing bumblebee. It issued a 90-day finding, the 14 first step towards being listed. 15 If you look at this map, you'll see that 16 this bee has basically disappeared from all areas 17 with heavy pesticide use, and the blue -- the green 18 dots, I'm sorry, are the dots that show where it 19 remains. The yellow dots or historic occurrences, 20 not many left. 21 So next slide, please. 22 The Endangered Species Act is both a legal 23 and a moral imperative. I show this picture of 24 Aleutian geese because they're an amazing ESA success 25 story, and there are so many of them. The Endangered For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 145 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 Species Act is 99 percent effective at stopping 2 extinction, but we have to actually implement it for 3 it to work. And success stories cannot happen when 4 agencies do not carry out their duties under the ESA. 5 And the ESA asks for more than hard work; the ESA 6 asks for completion of consultations and their 7 implementation. The ESA doesn't ask for refinements 8 or multi-led stakeholder processes. The ESA asks 9 agencies to use the best available science. 10 I also included this picture of geese 11 because the actual use -- the chase for actual use 12 data of the past four years has been a wild goose 13 chase. Career staff in OPP have long considered 14 actual use data in their ESA consultation processes. 15 It's a very small part of the data that's required in 16 this process. It's a very incomplete subset. Any of 17 you look who look at the malathion BiOp will read the 18 part where they talk about how they reached out to 19 all the states and most states didn't get back to 20 them, and even the ones that did didn't get back to 21 them after that. The data just doesn't exist. 22 But, luckily, that's not what the ESA asks 23 for. The ESA asks for data -- asks for consultation 24 to happen on the agency action, not some 25 extrapolation of how the action might play out but For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 146 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 what the agency authorized. 2 This all has been a huge distraction, this 3 actual use data and the 2017 Bernhardt intervention 4 that axed the almost completed biological opinions on 5 malathion, diazinon and chlorpyrifos, and has really 6 set this work back. The time lost is sad. The 7 wheels spun are sad. But the real issue is that this 8 has precluded actual progress and it's species that 9 bear the brunt of the suffering. Zero on-the-ground 10 protections have been implemented, even after 11 biological opinions, draft or final, have shown 12 jeopardy. 13 There's no real work plan. EPA has taken 14 no proactive steps on consultation without 15 litigation. None. There's no plan for moving 16 forward. There's just adhering to the deadlines that 17 are coming down. 18 So I'll say, you know, we can continue 19 litigating, we can continue bringing cases, or we can 20 find a path forward that makes sense and gets species 21 the protections they need to dodge extinction. 22 Next slide, please. 23 I think one myth that is successfully 24 circulated around these parts is that ESA 25 consultation is extraordinarily hard. And I will For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 147 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 acknowledge that pesticide consultations, nationwide 2 consultations are not the easiest consultations by a 3 long shot. However, consultations happen every 4 single day. Between 2008 and 2015, there were almost 5 -- there were over 88,000 consultations. None of 6 them stopped projects. However, they did result in 7 important conservation measures. And that's not 8 what's happening here. 9 Every other agency routinely consults on 10 their actions. They don't have to be sued every 11 single time. There's no other agency that has 12 consistently flouted the law like this. I'll just 13 say complying with the ESA is like paying taxes. 14 It's something everyone has to do. You might not 15 like it, but you've got to do it. You can't just opt 16 out of taxes or ESA compliance. We are, after all, a 17 nation of laws. 18 Next slide, please. 19 I recognize we're running low on time, so 20 this is just a slide that shows some admissions of 21 noncompliance. It's not an open question. EPA is 22 not even pretending even to the court that it is 23 complying with the ESA aside from instances where 24 litigation deadlines are set -- or work deadlines are 25 set by litigation. And there has been no attempt to For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 148 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 explain how OPP will achieve compliance with the 2 mandates of ESA. 5 minutes, because this isn't just a backlog issue, 6 this is an issue of OPP making an affirmative 7 decision to ignore the ESA every single day. For 8 example, just in January, it approved the use of 9 Aldicarb for Florida citrus. This decision affects a 10 small number of species, a very small number of 11 species, and many of them are narrow endemics. 12 Consulting on this decision would have been 13 relatively simple. It would have been an opportunity 14 for OPP to demonstrate a willingness to consult to 15 get started, to find a path forward where it does not 16 continue to add to the backlog. But, once again, it 17 affirmatively chose to violate the ESA. 18 And you'll hear a lot from OPP about how 19 they're not consulting on new decisions because 20 they're working on getting these new pesticides 21 online that will replace the bad old ones, but I'm 22 not sure how that logic actually would apply to 23 something like Aldicarb. And Florida also didn't buy 24 it. Florida said because OPP failed to comply with 25 federal law, under their state law, they could not 4 3 Next slide, please. I want to talk about Aldicarb for a few For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 149 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 abide by that decision and will not allow Aldicarb to 2 be used for the uses that EPA authorized. 6 good indication of what a path forward might look 7 like. And it's simple. It's really extraordinarily 8 simple, because at the end of the day, all we're 9 looking for is common sense actions to protect our 10 nation's most vulnerable species, and by extension, 11 many of our most vulnerable people. 12 The path forward that atrazine shows could 13 happen provides certainty. It reduces workload. And 14 what does it involve? It involves registrants 15 proactively working with the agency to modify labels 16 to minimize the effects on endangered species. The 17 picture of the bird here is an ^i'iwi. It's a 18 Hawaiian species that now is not going to have to 19 have endangered species consultation completed on it 20 because atrazine will no longer be used in Hawaii per 21 in agreement with the registrant and OPP. These are 22 the kinds of common sense actions that provide a way 23 forward that doesn't continue to have us mired in 24 litigation and endless delay. 25 I'm asking registrants to get proactive. 3 Next slide, please. And this is my final 4 one. 5 Atrazine I think really provides us with a For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 If you want certainty, then sit down and figure out a 2 path to certainty that reduces the scope of pesticide 3 use in endangered species habitat. Once you do that, 4 the process will be faster. The expert agencies can 5 do their jobs. EPA can implement the consultations. 6 Species can get protections. We can stop suing. 7 Everyone is happy. 8 And in the meantime, we ask OPP to get 9 serious about on-the-ground protections, especially 10 for the most sensitive species, especially for the 11 narrow endemics. These actions will protect 12 communities and they'll stop extinction. Endangered 13 species are the canary in the coal mine. When we 14 protect them, we protect everyone. 15 So, you know, in closing, I'll say we're 16 not going away. The attempts to exempt pesticides 17 from the ESA in the last Farm Bill failed. We ask 18 you to set a schedule. We ask you to set an 19 ambitious schedule. Categorize it as you like. You 20 know we will sit down with you and work with you. If 21 you want to do all the neonics at once, insecticides 22 at once, broad spectrum herbicides, whatever it is, 23 set a schedule, come up with a plan, stick with it. 24 Enough refinements, enough process. We 25 want to see protections implemented. We want to see For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 151 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 20 consultations completed and implemented each year 2 while you get the hang of this process and get a grip 3 on what catching up with the backlog is going to look 4 like. We will support you. We hope industry will 5 support you as well. This era of lawlessness and 6 endless delay has to end and we have to get serious 7 about ending this office's role in driving 8 extinctions and finding a path forward to spare 9 species this terrible fate. 10 Thank you. 11 MR. ANNINOS: Thank you very much, Lori 12 Anne. 13 I see we have about five or six minutes 14 before the next segment. Let's take some questions, 15 comments from the audience. They could be for either 16 Lori Anne or Cathy. 17 MR. MESSINA: Yeah, please don't be shy 18 about this important issue. And thank you to our 19 presenters for those presentations. 20 Surely someone must have a comment. 21 MR. ANNINOS: So it looks like Mano would 22 like to chime in. Mano, you're up. 2 3 MR. BASU: Thank you very much, Paul. 24 Again, a great presentation from Cathy and 25 Lori Anne. I just want to reiterate what I mentioned For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 152 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 in my presentation, that we, as industry, are willing 2 to sit and have conversation on moving the process 3 forward and looking for a path forward on the 4 extremely important, complex ESA-FIFRA issue, where, 5 you know, as I mentioned in my presentation, at the 6 end of the day, it's what are we doing to benefit the 7 species. Let's focus on the benefit of species and 8 the legal certainties. Again, any future opportunity 9 that may exist for all of us to come together, sit 10 down and explore opportunities, we are looking 11 forward to those opportunities. 12 Thank you. 13 MR. ANNINOS: Thank you, Mano. 14 The mic is open, folks. 15 MR. MESSINA: About maybe examples of good 16 mitigation, I think Lori Anne had an easy one that's 17 right on the slide here and thanks for highlighting 18 that one, Lori Anne. Are there other examples or 19 things the agency should consider with regard to 20 early mitigation that could be some quick wins that 21 folks want to suggest or talk about? 22 MR. ANNINOS: Mano, did you -- it looks 23 like you popped up again. Let's go. 2 4 MR. BASU: Yes, I did. Thanks, Paul. Not 25 necessarily around mitigation, but one comment that For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 we have made through our public comments to the BEs, 2 as well as the revised method, we have suggested the 3 extremely complex tools that have been used for the 4 BEs, the MAGtool and the plant assessment tool, tools 5 like these should be reviewed by a scientific 6 advisory panel as a normal practice. So I just want 7 to reiterate that at the PPDC here. Thank you. 8 MR. MESSINA: Thanks, Mano. 9 Who's going to be brave to talk about this 10 topic? Come on, this is like the topic we need to 11 talk about, right? So let's hear some talk. 12 MR. ANNINOS: Joe Grzywacz, go ahead. You 13 might want to go off mute. Take yourself off mute. 14 We still don't hear you, Joe. Maybe -- Sarah, is Joe 15 on mute? 16 MS. CHADWICK: No, he is unmuted, so we 17 should be able to hear him. I would just recommend 18 to make sure that your mic isn't off on your 19 computer. 20 MR. MESSINA: And, Joe, are you dialed in 21 by your phone or is it possible you're double muted 22 on the phone? Give me a thumbs up. Are you dialed 23 in from the computer? Give me a thumbs up if you're 24 dialed in by computer. Okay. He's on by computer, 2 5 yeah. So... For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 154 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 MR. ANNINOS: Okay. Well, while Joe is 2 figuring that out, Jasmine has popped into the chat. 3 So Jasmine Brown and then we'll come back to Joe. 5 path forward, not just for atrazine, but its 6 breakdown products are sometimes more toxic than the 7 parent compound and so that should be a 8 consideration. Simazine, triazine, and atrazine seem 9 to all have same effects. And this is something I'll 10 bring back to the Tribal Pesticide Program Council 11 for discussion and then, hopefully, they can provide 12 their collective comments back to the group. 13 MR. ANNINOS: Excellent. Thanks, Jasmine. 14 And, Joe, how about now, can you say 15 something and see if we hear you? 16 MR. GRZYWACZ: Can you hear me now? 17 MR. ANNINOS: You bet. 18 MR. MESSINA: Yes, we can hear you now. 19 MR. GRZYWACZ: All right. Sorry about 20 that. And I have to admit, I am totally dumb about 21 all of this stuff. So this question is probably not 22 wisely raised and it may throw oil on fire, but I'm 23 really compelled by Lori Anne's presentation. And it 24 seems as though part of the presentation is sort of 25 the notion of all the litigation that's at play. And 4 MS. BROWN: I just wanted to add that a For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 155 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 so one of the questions that I have is clearly doing 2 away with litigation would be a nice thing, but 3 that's a hard thing to do. 5 what are the different points of view on why the 6 litigation is coming? Because it seems as though 7 industry is happy to play, but yet, you know, who is 8 rendering or who is putting forward the litigation, 9 which groups is it coming from and how is that 10 bogging down the system I guess, is my question. 11 MS. BURD: Ed, do you want to answer that 12 or do you want me to? 13 MR. MESSINA: It's such a great question. 14 Why don't you take a stab? And it's sort of a 30- 15 year history, that you've asked that great question 16 and maybe Lori Anne can talk and then I can fill in 17 some of the gaps. But, please, yeah, Lori Anne, that 18 would be great. 19 MS. BURD: So there has been zero USA 20 compliance except for with litigation. It's the only 21 thing that's gotten any action under the ESA. So 22 we'd be happy not to bring it if there was ESA 23 compliance. But without it, endangered species would 24 be completely ignored. And there is nothing on the 25 schedule that has not been because of litigation. 4 So what is the source -- why -- you know, For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 156 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 And, again, you know, I'll reiterate, we're happy to 2 talk about a schedule any time so we don't have to 3 continue bringing litigation. 5 about the challenges, right? Because you want to 6 talk about sort of past administrations on both sides 7 of the aisle have struggled with this issue, ESA, and 8 this is a 30-year, sort of how do you show that a -- 9 let's take an herbicide, for example, that is 10 designed to kill plants won't land on an endangered 11 plant. That's sort of the scientific questions that 12 we're trying to answer in the thousands of pages that 13 are written about that, right? 14 And there's a number of mitigation and 15 approaches you can take. And now we're talking about 16 thousands of species, we're talking about plants and 17 animals and insects, right? So now we have an 18 insecticide that is designed to kill things. It's 19 not an insecticide if it's not killing things. I 20 mean, that doesn't work. So how do you then do that 21 scientific review? That's been the struggle for the 22 last 30 years with multiple administrations. 23 Go ahead, Joe. 24 MR. GRZYWACZ: I'm sorry, but, I mean, 25 again, now we're in a space where I actually know 4 MR. MESSINA: Yeah, so I think I'll talk For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 157 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 something about it and that is this is not unlike the 2 challenges of those of us who do public health 3 research with humans, you know, are kind of grappling 4 with the same question. And it usually comes down to 5 which hegemonic science really has the advantage. 6 You know, is it the basic biology or chemistry or 7 whatever else it is? And what models are those sort 8 of set up upon and the assumptions that we're willing 9 to make or not make? 10 So it seems as though that's the issue at 11 play and it's a matter of not being able to come to 12 consensus on, well, which one is the right one or 13 should there even be a right one. 14 MR. MESSINA: Well, and then so take your 15 point and extrapolate it. It's even developing those 16 methodologies and having scientific consensus around 17 those methodologies for this area where these two 18 things sort of got mashed together, right? And it's 19 an important legal obligation for the agency to 20 satisfy, Endangered Species Act, because as Lori Anne 21 points out, once you're extinct, you're extinct. So 22 we want to make sure we're not contributing to that 23 and we're meeting our ESA obligation. 24 I'll say, you know, I'm hopeful. You know, 25 the fact that we put this on the agenda and the fact For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 that we've invited Lori Anne, we've invited 2 government, we've invited industry to talk about 3 these issues. This is going to take a collaborative 4 effort. We can keep litigating around it, but that 5 is -- I think everyone's in agreement, that's not 6 going to help solve the problem. And we're not doing 7 a -- we're doing a disservice to those species that 8 need us to focus on this. 9 So I think, you know, going into the next 10 session, which is sort of next steps, we will start 11 seeing some things would come out from the agency on 12 this. There is a willingness to work with industry 13 and the NGOs on this topic, to develop a plan going 14 forward. And let's try to [audio issue] and keep 15 talking about this and maybe that's one of the new 16 workgroups we form for PPDC, right, which is a 17 workgroup that deals with ESA. So it's an important 18 topic. 19 MR. ANNINOS: If you'll note, Gina Hilton 20 has put -- entered something in the chat, a link to 21 EPA cross-species toxicity assessment that might be 22 of interest to folks. 23 MR. MESSINA: Thanks, Gina. 24 MR. ANNINOS: Lori Anne, you put some 25 stakes in the ground in your presentation. No doubt For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 159 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 about it. And you've had a chance to hear Joe's 2 question and Ed's remarks. Anything you'd like to 3 respond with? 4 MS. BURD: Yeah, thank you. I'll just note 5 that the ESA doesn't ask for perfect science. It 6 asks for the best available science. And endless 7 refinements towards perfection are not getting us 8 anywhere. And so we submitted a notice of intent to 9 sue over the revised methods. You'll notice we 10 haven't sued yet because what we want is action and 11 implementation. Obviously, that action still exists, 12 but, again, like, this pursuit of perfection is 13 getting in the way of anything. And so, you know, 14 more stakeholder process, more conversation, I don't 15 think is the solution. I think the solution is a 16 work plan going forward. 17 And, like I said, you know, atrazine shows 18 us that we can eliminate a lot of species from 19 consideration by taking some common sense measures to 20 take them out of play. And I think that there needs 21 to be a lot more consideration of that, because at 22 the end of the day all consultation will result in, 23 you know, it's not going to bring the whole house 24 down, all consultation will result in are some common 25 sense measures, some increased buffers, maybe some For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 160 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 areas where a pesticides can't get used where there's 2 a very narrow endemic, really, you know, steps that 3 protect species and that's it. 5 following what the ESA says, which is consulting on 6 the action, not every possible way the action might 7 play out or has played out, following the best 8 available science that we already have in front of 9 us, rather than continuing to look for more, that's 10 how we find a path forward that will protect species 11 and provide certainty. 12 MS. TORTORICI: So, Paul, I would like to 13 make one comment, which is, you know, I believe that 14 those opinions that we just released, for example, 15 the ones that we just completed in April and now 16 we're putting out in June, are achieving the concept 17 of what we're talking about here in terms of reaching 18 a level of species conservation that makes sense, 19 allowing for flexibility on the part of growers to be 20 able to manage the process that they are going to be 21 using to implement that work, the kind of items that 22 Lori has on this slide about a path forward. 23 These are the kind of conversations that we 24 need to be engaging further in, not only EPA but also 25 with the registrants, because some of this might 4 So getting to that point is the goal and For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 involve label changes. And so that's the kind of 2 conversation that we're hoping to have with EPA and 3 registrants about not only mitigation measures, 4 conservation measures, but also appropriate label 5 changes that can be brought forward into the process. 6 And then at the end of the day, what you're 7 consulting on is already have a level of protection, 8 because those items have been already built into the 9 action on which we're looking at. 10 And so I think part of the litigation issue 11 has been, yeah, it's like we don't all agree on the 12 science, whoever's suing us, there's a process, we 13 don't all agree on that either. But I think that 14 we're making progress in certain areas. And it's 15 really not about trying to get to a perfect thing. 16 It's about trying to continue to get to a practical 17 workable thing that makes sense in terms of 18 implementing on-the-ground protections to conserve 19 species, and we really are trying hard to do that. 2 0 MR. ANNINOS: Thank you, Cathy. 21 And with Ed's permission -- and I know we 22 originally had a one-hour block for this topic and 23 then we had to kind of shift that a little bit with 24 Dr. Freedhoff joining us after lunch, so what I'm -- 25 Lauren -- sorry, how come I'm thinking -- yeah, For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 162 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 Lauren Lurkins and Mano had a couple of comments. Do 2 we have -- can we go ahead and take those? 3 MR. MESSINA: Yes, please. 4 MR. ANNINOS: And then we can close this 5 out. 6 MR. MESSINA: Yeah, I'm not going to cut 7 this conversation short. 8 MR. ANNINOS: Okay, thank you. 9 Go ahead. Lauren, go ahead and go off -- 10 Lauren Lurkins, go ahead and go off of mute, followed 11 by Mano. 12 There you are. 13 DR. KUNICKIS: I've not figured out how to 14 get off of mute. 15 MR. ANNINOS: Oh, we can hear you. 16 MR. MESSINA: Sheryl, we can hear you, 17 Sheryl, Dr. Kunickis. 18 DR. KUNICKIS: Oh, did you call me? 19 MR. ANNINOS: Oh, no, no, no. 20 DR. KUNICKIS: Or did you call Lauren? 21 MR. MESSINA: We called Lauren. 22 MR. ANNINOS: Lauren Lurkins. Is Lauren 23 Lurkins in the house? 24 (No response.) 2 5 MR. ANNINOS: Probably on mute or having For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 163 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 trouble unmuting. 2 Let's move to Mano and then maybe, Sarah, 3 you could help Lauren get unmuted. 4 MR. BASU: And I just want to check since 5 Dr. Kunickis is on the line, if she had a comment or 6 not, given Dr. Kunickis' involvement with the ESA 7 process for such a long time. 9 a different computer today, and I don't have any way 10 to raise my hand. So that's why I'm kind of waving. 11 So thank you very much, if you don't mind. 13 acknowledge that over the 11 years I've been working 14 working with -- working with your staff has been 15 incredible. They're very dedicated to making sure 16 that the work they do is very thorough, very well 17 done, and they are credible scientists. 18 The other thing I want to note, too, is 19 that many of us working in this space over the years 20 have looked at the recovery plans on the species, and 21 it's very interesting to note -- and I've talked 22 about this in a previous public meeting and we have 23 noted that pesticides are not generally even listed 24 as one of the stressors for some of the endangered or 25 listed species. As a matter of fact, what we've 8 DR. KUNICKIS: Actually, I did, and I'm on 12 This is mainly for Ed. Ed, I just want to For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 164 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 learned, and we're very much aware of, is that the 2 fact -- and I think every -- Lori Anne and Cathy 3 would agree that the fragmentation of habitat is a 4 huge effort. 6 trying to work on taking care of the species -- and I 7 assure you that I am not aware of anybody who isn't 8 interested in doing that -- that we really should put 9 our efforts toward improving habitat in the areas 10 where species need to be or that they need to thrive. 11 I don't know what problem it is we're trying to solve 12 with going after and spending millions and millions 13 of dollars and hours working on the issue of 14 pesticides and not getting anywhere, where those 15 dollars could be invested on habitat improvements. 16 And then there was one other thing I wanted 17 to mention, also, the question that you asked about 18 measures that that could be done or mitigations that 19 could be done. It's absolutely essential that 20 America's farmers have to be included in looking at 21 what those mitigations are. We've been really 22 challenged with some of what we've seen. What works 23 in the EU does not work for farmers in America. Our 24 farming systems are so very different. 2 5 And so I would hope that everybody would 5 So I would think often that if we're truly For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 look and make sure that farmers, representatives for 2 growers, are included in any mitigations that are put 3 forward or required to be implemented. 4 That's all I have to say. Thank you for 5 the time. Thanks, Mano, for seeing my hand up. 6 MR. ANNINOS: Thank you, Sheryl. 7 And, Mano, go ahead. We're still working 8 with Lauren on how to release her voice. 9 MR. BASU: Thanks, Paul. And I'll make it 10 quick. 11 Again, it's great to see so many 12 questions/comments coming up. I mean, this is an 13 issue there -- you know, everyone has had challenges 14 with resolving this, making progress. A great 15 presentation from Lori Anne, suggestion on the path 16 forward. Cathy as well. You know, the question is, 17 how could we continue with the discussion on 18 prioritization? How do we start the conversation? 19 I mean, certainly, we have to bring all 20 stakeholders and that's what I mean when, from my 21 presentation, I said broader stakeholder engagement, 22 federal family, growers, registrants, NGOs, 23 mitigation bank, conservation groups and who 24 (inaudible), and how can all of these folks come 25 together focusing on conserving the species, For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 166 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 protecting the species. Because, you know, none of 2 us want extinction of a species. So the focus should 3 certainly be on the species here. Thanks once again, 4 Paul. 5 MR. ANNINOS: Thank you, Mano. Thanks very 6 much. 7 Lauren, let's try you once more, then we're 8 going to go to Iris. 9 MR. ANNINOS: Okay, I think what Lauren's 10 going to try to do now is maybe get her comment or 11 question into the chat window. 12 In the meantime, Iris, you have the mic. 13 MS. FIGUEROA: Thanks. And I'm really 14 heartened to hear that it seems like this is an area 15 where there might be space for collaboration. 16 Admittedly, endangered species is not my area of 17 expertise, but to Sheryl's earlier comment, I think 18 from Lori's presentation and other presentations, 19 it's clear pesticides are not the only factor, but, 20 of course, we're having this meeting under the 21 auspices of OPP. So I think it's absolutely relevant 22 and important and a concern for this group. Whatever 23 those other factors may be, this agency and this 24 office doesn't have authority over many of those 25 other factors. For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 So we need to really be focused on making 2 sure that the responsibility and the ability and the 3 capacity that we do have within the auspices of OPP 4 and of EPA are really maximized to be able to 5 mitigate some of that damage, again, even though it 6 might not be the sole cause of the damage that is 7 what's within our purview. 8 MR. ANNINOS: Thank you, Iris. Thanks for 9 that comment. 10 Let me give Lauren one more shot of this. 11 We're trying to troubleshoot it behind the scenes, 12 but we are having trouble with that. So let me just 13 pause and see if Lauren is there. 14 Well, here we go. What she's done is she's 15 put her thoughts or a comment into the chat box. Let 16 me read it, if that would help. 17 I would like to offer the perspective of 18 someone who works alongside growers in the middle of 19 the country. FIFRA is complicated. ESA is 20 complicated. Farmers are a bit perplexed by the 21 intersection of the two and particularly the court 22 challenges. At the end of the day, the pesticide 23 products are needed in ag, even as we look to address 24 climate change. 25 Lauren, thanks for contributing that. She For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 168 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 goes on to say, there's also a significant amount of 2 species conservation that occurs due to the action by 3 farmers on their private lands. 4 MS. TORTORICI: So, Paul, maybe Ed wants to 5 say something about this as well but I don't agree -- 6 I don't disagree with what Lauren is saying. I mean, 7 part of the dilemma that we're struggling with here 8 is trying to integrate two pieces of legislation that 9 weren't necessarily lined up, per se, when they were 10 developed. Do you know what I mean? So that 11 integration of those two things is simply complex. 12 And, yes, I can certainly appreciate that, 13 you know, from the grower perspective, this might 14 this might look like just a -- I don't even know what 15 it would look like, you know. And so that's why 16 we're trying to figure out ways, not only to 17 understand through EPA, for example, and USDA through 18 Sheryl, you know, what are growers thinking about all 19 of this, but try to pull that information into how 20 we're talking about implementing our work in a way to 21 make it implementable, right? So that it's easier to 22 implement on the ground and then you're going to get 23 the result that you want, because people understand 2 4 it and can embrace it and implement it in a way that 25 makes sense for them. For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 169 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 So there is a role in terms of bringing in 2 individuals like that and groups like that to get 3 that practical approach in the same way that we work, 4 for example, in the Fisheries Service with the 5 fishing industry, right? As we're regulating them on 6 commercial fishing, so we're not doing that in a 7 vacuum, there are fishery management councils that we 8 work with and we work very closely with them in terms 9 of implementation of regulations. So it's an 10 analogous kind of activity that we're trying to do 11 here with all the bumps and the warts and trying to 12 make progress as we move along. 13 But I want to say thank you, Lauren, for 14 that comment because it's right in the bailiwick of 15 what we need to be thinking about to balance out the 16 species conservation aspect with the implementability 17 aspect. 18 MR. ANNINOS: Great point, Cathy, 19 especially this analogy with the fishing industry. 20 It's a harvesting-related industry. There's economic 21 value associated with the take of commercial fish and 22 recreational fishing for that matter. 23 MS. TORTORICI: Yes. 24 MR. ANNINOS: And so constant balance 25 between the economic considerations and the species For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 170 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 protection consideration. So great point. 2 And so we've got to -- boy, I tell you, we 3 definitely didn't reserve enough time on the agenda 4 for this. We got everybody all energized here at the 5 end of the day. I did notice the Jasmine Brown 6 popped into the chat. 9 comment. So we have sampled for atrazine and while a 10 farmer may follow a label and do the application 11 perfectly legally, during rain, we see spikes of it 12 in wells and drinking water. And in our streams, 13 when there's a storm, so there's a lot of rain -- a 14 rain event, we'll see spikes of it. And so these 15 products are very easily displaced from the site of 16 application downstream. 17 And then in drier climates, if we're 18 thinking ahead for climate change -- and just for any 19 registrants on the call, drier areas, there's higher 20 pesticide carryover in drier areas, because there's 21 just not the soil microbes, insects, and rain and 22 things to start breaking those down. Same as Alaska. 23 They have higher persistence because of their cold 24 weather and snow pack. So there's different 25 persistence and different things happening regionally 8 7 Jasmine, a brief comment from you. MS. BROWN: Yeah, I just wanted to briefly For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 and just to keep that in mind. 2 The buffers are great. We don't allow 3 picloram or atrazine in any wetlands, period. But, 4 like I said, even if they applied to up to 15 feet 5 away, doesn't mean that's actually protective on the 6 ground for that species. Chances are it will still 7 be displaced in the environment 15 feet away. I'm 8 not saying taking off the market. I'm just saying 9 consider that when you're thinking of how you're 10 going to mitigate it. Thank you. 11 MR. ANNINOS: Thank you very much, Jasmine. 12 So I think one thing I wanted to ask maybe 13 Shannon and Carla, we've got quite a little bit of a 14 conversation going in the chat window. Maybe we 15 could -- I don't think the chat windows are preserved 16 in the recordings. I could be wrong about that, but 17 maybe just grab this chat, copy it and paste it 18 somewhere so -- just in case a workgroup does emerge 19 on this topic, which sounds like there might be some 20 energy behind that based on a question I see from 21 Mano in the latest entry in the chat window. And 22 maybe this also leads into the next segment when we 23 talk about next steps, moving forward, et cetera. 24 Maybe this topic is part of that. 25 But what I think we'll do is because I For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 think if we just left it open, we could probably 2 stick around for another hour or two talking about 3 this topic. And so I want to suggest unless there is 4 an objection, which is perfectly legit, I'm going to 5 maybe ask Ed if it makes sense for us to move to the 6 next segment of the agenda now and -- 7 MR. MESSINA: Yeah, I'll close this out 8 with a couple of comments -- 9 MR. ANNINOS: Okay. 10 MR. MESSINA: -- and then we'll move to the 11 next session. 12 And so certainly, you can see why we put 13 this on the agenda. I agree with Sheryl's, Dr. 14 Kunickis', views that the scientists at EPA that are 15 working on this issue are just some of the smartest 16 minds we have in the world. They are dedicated. 17 They've done some incredible work these last couple 18 of years, considering these issues, and they deserve 19 our credit and respect. And so I could not agree 20 with Sheryl more on that issue. 21 I think grower concerns really need to be 22 taken into account in terms of the implementability 23 of mitigation. I know and I've met a number of 24 growers who have ESA pollinator gardens and 25 pollinator strips and areas where they've set aside For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 173 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 to protect species where they need to. So we need to 2 definitely consult with the growers on any aspect of 3 this. 5 stakeholders, which is why I think this is a great 6 venue for us to have this conversation. But there's 7 probably going to be a need for other venues as the 8 agency puts out more policies around this. And I 9 think I -- and hopefully this came through -- I think 10 one of -- rather than, you know, more workgroups and 11 more conversation and -- you know, I'm not implying 12 that that's all we need to do. I think the 13 conversation around what are some early mitigation 14 that we can put in place while we continue to refine 15 the science, which we need to, and while we continue 16 to refine the procedures here is an important aspect 17 of this as well. 18 I think we need to try to find some quick 19 wins here and focus on what we're trying to protect, 20 which is the endangered species, while also 21 preserving tools for growers who desperately need 22 these tools to provide safe food for the citizens of 23 this great country. So it's been a great topic, 24 multiple perspectives that need to be taken into 25 account, and so I appreciate everyone for taking 4 As Mano mentioned, there's multiple For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 174 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 their time to listen to this and also to our speakers 2 for taking the time to prepare remarks and provide 3 your important perspectives on this. 4 So with that, I think we will move on to 5 sort of next steps. I know we've captured aspects of 6 things that we'd like to move forward, but I really 7 wanted to -- a couple of things, to remind folks for 8 the PPDC next meeting, we'll have a similar format. 9 We're going to have the workgroups present. Maybe it 10 will be shorter, but it will be this is what -- the 11 work product that was developed by the workgroup. 12 Suggest that it go to the full PPDC where the full 13 PPDC will recommend yea or nay as to whether those 14 work products should be moved to EPA for 15 consideration, representing the full PPDC consensus 16 on any products that are going to go forward to EPA 17 for consideration on the various workgroups that 18 you've heard from today. So that's going to be one 19 of the main objectives for the next meeting. 20 The other thing is there are certainly some 21 new topics that came up today that we can sort of 22 highlight and talk about whether we add to the next 23 agenda. I think, you know, for example, on the 24 emerging technologies workgroup, we heard that 25 possibly a future topic is hearing from the non-ag For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 175 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 space for emerging technologies. And so maybe if 2 somebody wanted to take the baton to volunteer to 3 take that on and present or find some speakers that 4 could present on those non-ag technologies, we could 5 make that a potential agenda topic. 6 I think we're automatically going to put 7 ESA on just as a topic and then our -- so to the 8 group, are there any tasks, deliverables that you 9 heard, and topics for the next meeting that we want 10 to put on the agenda? And so with that, Shannon's 11 going to take some notes. Feel free to just type it 12 in the chat, too, and we can copy and paste that chat 13 into the document and sort of collect where we want 14 to go moving forward. 15 So with that, I'll stop talking and let 16 others sort of chime in. 17 MR. ANNINOS: I can sense the wheels 18 turning so feel free to keep thinking about this. 19 It's a chance to help shape the agenda for the 20 next -- 21 MR. MESSINA: Yes, I think non-ag would 22 include specialty crops. Yes. Sorry. Non-ag is not 23 the best term to use for that. So we could say non- 24 ag and specialty crops. And, Mark, if you're 25 volunteering to present, feel free to indicate in the For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 comments. 2 All right. So we have from now until the 3 fall. I know there's more topics that folks want to 4 talk about. I don't want to be the only one to 5 suggest them. Maybe there's a presentation from the 6 worker community on what it's like to be -- you know, 7 the challenges that are in the field. Maybe it's a 8 grower who wants to provide information on the 9 challenges for how to comply with labels. Maybe it's 10 a state organization that wants to present on some of 11 the issues on the enforceability of language in the 12 labels. 13 There's lots of expertise out there that I, 14 hopefully, would encourage you to discuss. How does 15 EPA interface with RNAI technology. So I think -- 16 let's add a session on biotechnology. I think that 17 we heard from BPIA today, but I think maybe -- I 18 think we could do a presentation on some new 19 activities for biotechnology. That might be a good 20 time in the fall. 21 MR. ANNINOS: Ruben, I see you're lighting 2 2 up. 23 MR. ARROYO: Yeah, Ed, I just wanted to 24 mention, you know, when we talk about label changes 25 and languages, you know, as far as an enforcement For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 177 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 agency, you know, we run into a lot of Spanish- 2 speaking people and, yeah, that would be great. Or I 3 think Mily had maybe mentioned it before about, you 4 know, having our manufacturers or registrants having 5 a link to having it translated in another language. 6 The only question that comes up to me as an 7 enforcement person is the enforcement end of it. So 8 we can have all the label changes we want, it's just, 9 you know, in some states I know there's one state 10 agent or a few for -- that actually do the 11 enforcement versus California where we have close to 12 3- to 400 inspectors out in the field doing pesticide 13 use enforcement. And so that's the big challenge I 14 see in some of these states and districts is who's 15 enforcing it. And, you know, we can make all the 16 label changes we want, but it's the enforcement end 17 of it that we have to deal with. 18 And granted, like I said, California, yeah, 19 you can make the changes and it will happen the next 20 day once we see it on the label, but how do we know 21 who's enforcing it in these other states? And what's 22 the, I guess, the goal and how do we get that 23 outreach out to those enforcement agencies and the 24 state agencies? And how do we know if it's being 25 effective or not, I guess? Because I don't know For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 178 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 about the other states; I just know about California. 2 And maybe you can shed some light as to if 3 we make label changes, how does that occur in the 4 other states, as far as the enforcement end of it. 5 MR. MESSINA: Yeah, and I see Liza chiming 6 in. So maybe there's an AAPCO presentation in the 7 works, Liza. That might be helpful to refresh. 8 MS. FLEESON TROSSBACH: Sure, Ed. I mean, 9 I'm certainly happy to provide that information. I 10 mean, I can speak to it now, but I can certainly 11 provide a broader presentation to the group about the 12 regulatory activities in states and territories. 13 MR. MESSINA: Yeah, why don't we put that 14 on for the fall agenda as a topic for consideration. 15 MS. FLESSON TROSSBACH: Okay. 16 MR. ARROYO: And, Ed, I'd be more than 17 happy to help in giving, you know, at least the 18 California perspective and what we see in our 19 enforcement end of it, along with the California 20 Department of Pesticide Regulation. 21 MR. MESSINA: That would be phenomenal. 22 Thank you, Ruben. 23 MS. BROWN: And, Liza, I'd be happy to give 24 you the updates for the tribes and territories 25 enforcement actions. For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 179 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 MS. FLEESON TROSSBACH: Fantastic. Happy 2 to help there, Jasmine. 3 MR. MESSINA: Shannon, I think another 4 topic we -- I mentioned, just seeing if the group is 5 interested, if there were maybe just 30 minutes on 6 the technological improvements that the agency was 7 trying to undertake in-house to address the 8 registration workflow and workload issues. I had a 9 couple of slides just on the workload issue, but we 10 could expand a little bit on that and maybe even do a 11 demo of the tool if folks are interested. You could 12 say yea or nay in the chat if you don't mind. 13 Okay. Well, I think this was a good start. 14 I want to be sensitive to the fact that we preserved 15 this time for public comments and allow folks to 16 provide that. And we can kind of wrap this up. Any 17 closing comments from anybody? And certainly feel 18 free -- GLP inspection update from OPP. Okay, great, 19 we'll add that and see if our OECA friends are 20 interested in providing an update on that. I think 21 we had had them potentially -- they weren't ready to 22 speak at this session, but I think in the fall, we'll 23 get them geared up and we can have a GLP inspection 24 update from OECA. Yep, thank you, Charlotte. 25 So why don't we close this out. Keep your For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 180 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 ideas coming in the chat and then Shannon will record 2 them and -- risk communication, yep. Thanks. We 3 definitely -- we're going to try to get Casey Buell 4 to present in the fall. 5 And then, of course, as part of the normal 6 procedure we'll send out to this group the list of 7 topics and then have the group decide sort of what 8 are the best issues for the agency to hear about 9 collectively. 10 So with that, we'11 open it up for the 11 public comment period, Paul. 12 MR. ANNINOS: Great. Thank you, Ed, and 13 thank you, everybody. That was a rapid fire set of 14 fodder for the next meeting. So that's excellent. 15 Great job. 16 So we're now prepared to, in this segment 17 of the agenda, which is our final segment -- and 18 after this segment, I certainly will ask Ed to come 19 back and, you know, close out the day or the two days 20 really. But we're in the process now of kind of 21 receiving comments from the public. Earlier today, I 22 checked in with Sarah, with Sarah Chadwick, and she 23 indicated that we had five individuals that had -- 24 that are on our list, so to speak, for speaking 25 today. For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 So just a couple of things. One, I just 2 want to confirm verbally with Sarah while we're 3 online here, is that still the number, Sarah, about 4 five people? 5 MS. CHADWICK: Yes. Last time I checked, 6 there were about five of our preregistered speakers 7 on. 8 MR. ANNINOS: Okay. So if we give each of 9 those people, let's say, three minutes -- three or 10 four minutes apiece that still leaves a little bit of 11 time for anybody that wants to provide "last-minute" 12 public comments. So with no objections, I think 13 that, Sarah, I'd like you to just kind of walk 14 through the instructions for the public comment 15 period. We'll then throw the slide up that shows the 16 five names and then we'll work our way through that 17 list. 18 MS. CHADWICK: Great. Thanks, Paul. So as 19 Paul mentioned, everyone will have three minutes to 20 speak and provide their public comment. I'll give 21 kind of a warning slide when you have about 30 22 seconds left and then once your time is up. 23 We'll start with the names of those who 24 have preregistered to speak and, as Paul said, we'll 25 be showing those on the next slide in a moment. And For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 182 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 we'll be going in alphabetical order by first name. 2 And then if there's additional time, at the end, 3 we'll open the public comment period to those who 4 have not preregistered. And you can identify your 5 interest to speak in two ways. One is by sending a 6 chat message to the host or Sarah Chadwick, and you 7 can use the chat box to do that and let us know that 8 you're interested in making a comment, or you can 9 email Shannon Jewell, and her email address is there 10 on this slide. And if you're interested in speaking, 11 you can also email her and she'll let us know. So I 12 think that covers all the instructions. 13 So I'll pass it back to you, Paul. 14 MR. ANNINOS: Thank you, Sarah. 15 16 17 18 19 20 21 22 23 24 25 For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 183 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 2 PUBLIC COMMENT PERIOD 3 MR. ANNINOS: And these are the folks that 4 are preregistered, and I'm not sure if you can -- if 5 you can help me. Yesterday, I went down the list and 6 we didn't -- we went pretty far down the list before 7 I got to somebody that was ready to speak. So we can 8 do that again. And we'll just make sure that we get 9 everybody a chance. 10 So Abdeljalil Mekkaaoui (phonetic), are you 11 present and want to speak? 12 (No response.) 13 MS. CHADWICK: I don't see him in the 14 meeting. The first person on our list that I see is 15 Laura Campbell. 16 MR. ANNINOS: Okay. 17 MS. CHADWICK: So I can go ahead and unmute 18 you and you can provide your comment. 19 MS. CAMPBELL: Thank you very much. I 20 appreciate the chance to be able to comment on this 21 process and I also appreciate the commentary and the 22 dialogue that's been going on, especially this 23 afternoon as we've been kind of talking about how to 24 move forward with combining Endangered Species Act 25 regulations with FIFRA pesticide labels and how do For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 184 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 you review registrations. 2 I think Lauren Lurkins said it very well, 3 that, you know, farmers really want clear guidance, 4 and I think we also want a process that we can look 5 back to to say, okay, this isn't just based on 6 estimations, it's not models, it's not something that 7 someone could interpret differently, you know. That 8 we want to be able to look back at evidence and 9 results and know that if we're going to require 10 someone to do something that it's for a reason and 11 not just, you know, because we're taking a 12 precautionary principle to it, you know, but that 13 there's science behind the decisions that we make. 14 So I really -- I have been glad to see that 15 this is a topic that the group wants to continue to 16 work on and wants to continue to have more 17 discussions about to figure out how do we get to that 18 place where these two statutes that don't really fit 19 together very well can hopefully find a process to 20 make not only label restrictions but also the 21 registration review process a little bit more 22 straightforward and a little bit better for farmers 23 trying to use them out in the field. Thanks. 2 4 MR. ANNINOS: Thank you very much, Laura. 25 Sarah, is Olga speaking today? For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 185 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 MS. CHADWICK: I do not see Olga on our 2 list. 3 MR. ANNINOS: Okay. How about — 4 MS. CHADWICK: I also — Ray is on the 5 line, however, he indicated that he will not be 6 making a comment today. Therefore, the next person 7 on our list is Sydney Morgan. Sydney, I'll go ahead 8 and unmute you and you can make a comment. 9 And it looks like Sydney actually just 10 signed off. So I will move down the list to Todd. 11 Todd, you're unmuted, so you may make your 12 comment. 13 MR. SCHOLZ: Well, good -- for me, it's 14 afternoon, I guess it's afternoon for you, too. 15 Thank you for giving me the opportunity to comment. 16 I really learned a lot attending this two- 17 day session. I appreciate all the presentations. 18 They were great. And I just want to remind everybody 19 that, you know, as we use pesticides, there is an 20 economic disincentive to use too much or to use it 21 incorrectly. And so I'm really excited about the 22 upcoming technologies that are available to my 23 producers. And the other thing I -- to be able to be 24 more targeted and be able to only spray where we need 25 to spray. For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 186 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 The other comment that I'd like to say is, 2 you know, one of my farmers reminded me that 3 sustainability isn't just about the environment, it's 4 also about him. So part of what we're trying to do 5 here is keep farmers sustainable. And so sometimes 6 pesticides are necessary, they're needed tools to be 7 able to to do that. And so we appreciate your work 8 and I really appreciate the presentations and the 9 earnestness of everybody involved. Thanks. 10 MR. ANNINOS: Thank you very much. Thank 11 you very much. Mr. Morton. 12 MR. SCHOLZ: I'm Mr. Schultz. 13 MR. ANNINOS: Sorry, Mr. Schultz. Sorry 14 about that. I thought we were -- okay, I messed up. 15 I'm very sorry. 16 MR. SCHULTZ: It's okay. You've done a 17 great job, Paul. 18 MR. ANNINOS: Okay. I'm finishing on a low 19 note, I guess. I'm sorry about that. All right, Mr. 20 Schultz, thank you. 21 Sarah? 22 MS. CHADWICK: We also have William Jordan 23 in the meeting, so I will go ahead and unmute you and 2 4 you can make your comment. 2 5 MR. JORDAN: Thank you for the opportunity For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 to comment again. I'll be speaking on behalf of the 2 Environmental Protection Network about the ESA path 3 forward. 4 I want to say that I think Lori Anne Burd 5 nailed the problem that's facing EPA and all of the 6 rest of the stakeholders, and that is that pesticides 7 may be harming endangered species and there has 8 simply been, over the last 30 years, no effective way 9 of identifying those problems and putting in place 10 measures to protect the species. And that is 11 something that really has to change. 12 For the first time, although I worked on 13 this for 30 years and really made no progress, I'm 14 encouraged. And I'm encouraged because I've heard 15 today interest on the part of the pesticide 16 registrant community, on the part of NGOs, on the 17 part of agriculture, on the part of EPA and the 18 services to get together and figure out a new way. 19 And I think that new way has to start with setting 20 priorities. 21 Currently priorities are based on 22 litigation and that is, at best, a very poor way of 23 doing it. There should be, I think, a better 24 scientifically based way of setting priorities. And 25 I want to suggest that there are three elements that For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 188 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 should be considered in this. First of all, what 2 chemicals do you look at? You probably want to focus 3 on the chemicals that pose the biggest risk because 4 of their inherent toxicity and their widespread use. 5 Second, you want to focus on the species that are 6 probably at biggest risk, the ones that are most 7 sensitive, the ones that have the least -- the 8 poorest chances of survival. And third, and this is 9 a new idea that I understand from both things that 10 Cathy Tortorici and Lori Anne Burd said, you want to 11 focus on the risks that are the biggest. 12 One of the problems that has affected the 13 scope of the biological evaluations is that EPA is 14 chasing after not only direct effects, but also 15 indirect effects that vastly complicates the analysis 16 and means more and more work needs to be done. If 17 you zero in on direct effects, using information that 18 EPA already has you will identify, I think, the most 19 risky chemicals to the most sensitive species, 20 certainly obvious things, as Ed Messina said, like an 21 insecticide that's used in the areas where endangered 22 insects are found and that in turn, I think, can lead 23 to the kind of ideas that Cathy Tortorici was talking 24 about for identifying protective measures earlier in 25 the process. For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 189 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 I want to end by one more note on this kind 2 of approach. This is a fairly big approach and I'm 3 not sure everybody will agree. That's why everybody 4 needs to talk about this and work through this and 5 exchange ideas. So some sort of collaborative 6 process, I would say that based on my experience, the 7 FIFRA 88, the FQPA amendments and the PRIA amendments 8 all were successful because of that collaborative 9 process, but all of them were mediated through 10 external stakeholder collaborative processes. And 11 that's probably what's needed here. A PPDC 12 workgroup, for all that I respect the PPDC process, 13 seems to me to be not the right kind of vehicle for 14 that. And so I encourage people to pursue a 15 collaborative mediated public dialogue kind of 16 process that involves a broad range of stakeholders. 17 Last thing I want to talk about is the 18 point raised by Mr. Arroyo and Ms. Trossbach, and 19 that has to do with compliance. I think one of the 20 assumptions that EPA makes about its label changes is 21 that people will comply. And EPA should know, from 22 its experience with resistance management's programs, 23 as well as state reports on enforcement activities, 24 is that not everybody does. And I think EPA lacks 25 information, critical information about the extent of For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 190 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 compliance. And so understanding the effectiveness 2 of enforcement programs and then bringing that 3 information back to the risk assessment process will 4 be essential to understanding whether the measures 5 that EPA decides are necessary to address pesticide 6 risks are actually going to be effective. Thank you. 7 MR. ANNINOS: Jordan, thank you very much. 8 That's the entire list we have in front of 9 us, but I should pause just in case, Shannon, if 10 you've gotten any emails or, Sarah, if you've gotten 11 any private messages from anybody else who would like 12 to speak. 13 MS. CHADWICK: I have not received anything 14 in the chat so far. 15 MS. JEWELL: No, not for me, Paul. Sydney 16 Morton did email me just to say that he had no 17 comment, but wanted to say that he was really 18 appreciative of the presentations today. 19 MR. ANNINOS: Okay, very good. 2 0 MS. JEWELL: She. I think Sydney was a 21 female. 22 MR. ANNINOS: Okay, got it. Thank you. 23 All right. So, Ed, before I hand it over 24 to you to close out, I just wanted to thank you and 25 your office, of course, for sponsoring the PPDC, For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 191 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 sponsoring this two-day meeting and all the 2 transparency of the work performed by the committee, 3 by the workgroup members, by your professional staff, 4 et cetera. So thank you very much for that. 5 And a special thanks, of course, to Shannon 6 and Clara behind the scenes for their kind of expert 7 work in designing not only a realistic agenda, but an 8 engaging agenda. 9 And thank you Sarah Chadwick for a great 10 job kind of managing this engagement platform for the 11 meeting today. 12 And to all the workgroup co-chairs and 13 their leadership in making these days very 14 productive. 15 So thanks to everybody. And I'll turn it 16 over to Ed for a final closeout. 17 18 19 20 21 22 23 24 25 For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 192 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 CLOSEOUT/REMARKS 2 MR. MESSINA: Well, thanks, and back at 3 you, Paul for the thank yous coming your way for 4 facilitating. I think it was a really a great 5 addition to have you and your team here. Shannon and 6 Carla, for all the technological wonders you've done. 7 I know COVID sometimes feels like one endless Zoom 8 meeting or, you know, teleconference meeting and, you 9 know, kudos to you guys, for everyone on this call 10 for hanging on for two days while we did have a great 11 discussion. So the technology worked and held up in 12 many cases and I think that's a testament to the 13 great behind-the-scenes work that's been going on. 14 So I want to thank each and every PPDC 15 member for attending. I want to really thank the 16 workgroup leads. I know how much work goes into 17 that, watching Mano manage that group for me, who's 18 been doing a lot of work there on the emerging 19 technology group, and there's lots of folks who are 20 pitching in. So thank you for really being a sort of 21 contributing member to those groups and particularly 22 to the heads of those. 23 Members of the public, all the different 24 stakeholder communities that came here today to 25 discuss and debate these important issues, your For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- 193 Committee Meeting EPA Pesticide Program Dialogue 5/13/2021 1 engagement here will really help EPA make sound 2 decisions in the future and help us tackle some of 3 the toughest issues that we have to. And I so really 4 appreciate you hanging on here for the whole 5 presentation and in both days. 6 Looking forward to doing this at some point 7 in person where we can not have to do the virtual 8 hands going across the screen to clap for everyone. 9 But thanks again, everyone. And hopefully have a 10 safe and healthy summer and we will see you guys in 11 the fall. So thanks. Take care. 12 (Day 2 adjourned.) 13 14 15 16 17 18 19 20 21 22 23 24 25 For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555 ------- |