Archived August 23, 2022
The Office of the Inspector General’s Audit of EPA’s Special Local Need program
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
Georgia Department of Agriculture
North Carolina Department of Agriculture and Consumer Services
Alabama Department of Agriculture
- EPA’s Response to Alabama
Region 5 States (Illinois, Indiana, Michigan, Minnesota, Ohio, Wisconsin)
South Dakota Department of Agriculture
AAPCO’s Proposed 24(c) Guidance
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 at rkachadoorian@oda.state.or.us with any questions or comments.