Defend American Farmers Against Frivolous Lawsuits

This petition was published by Croplife America on Feb 01, 2010

We urge the EPA Office of Pesticide Programs to:

1. NOT impose unnecessary buffers that would reduce cropland available for American agriculture.

2. Develop a bystander exposure scenario for the risk assessment in the pesticide registration process;

3. Develop risk-based tolerances for non-target property.

4. Maintain the FIFRA risk-based standard of “no unreasonable adverse effects”.

5. Acknowledge that some small level of pesticide drift is unavoidable (in some cases) and does not pose an “unreasonable adverse effect”;

6. Acknowledge that the mere detection of a pesticide off-target does not pose an unreasonable adverse effect and is not a violation of FIFRA that requires an enforcement action.

7. Remove the new hazard-based standard of “harm” from the Drift Pesticide Registration Notice.

8. Remove the vague, unenforceable, and unmanageable concepts of “could cause” or “may cause” adverse effects or “harm” from the Drift PRN.

9. NOT apply an additional unnecessary factor of 10 in the occupational exposure scenario.

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