EPA is now re-evaluating its approach to reviewing 24(c) registrations and the circumstances under which it will exercise its authority to disapprove those registrations.
Some of the current differences of opinion between EPA and many SLAs centers around the concept of “new uses” and what constitutes a “new use”; this issue was illuminated with the dicamba Section 24(c)s that provided risk reduction restrictions. However, it is important to remember that there are other Section 24(c)s which are unrelated to the dicamba issue that have been approved by states for the exclusive purpose of providing restrictions which protect the environment.
The letters below address state concerns regarding this new approach by EPA:
- EPA’s Response to AAPCO
- EPA’s Response to Alabama
This proposed guidance document was developed in coordination with SFIREG’s Pesticide Operations and Management Working Committee, and submitted to EPA for review in May 2019. Please contact Rose Kachadoorian, AAPCO President, at firstname.lastname@example.org with any questions or comments.
Photo of Hazelnuts courtesy of the Oregon Department of Agriculture