«

»

Sep
24

CRE Files Comments with OMB on the Requested ICR for EPA’s Proposed Rules for the Certification of Pesticide Applicators

On September 23, 2015, the Center for Regulatory Effectiveness filed comments with EPA and with the Office of Management and Budget on EPA’s requested Information Collection Request for EPA’s proposed Pesticide Applicator Certification rules. OMB has to approve the ICR before EPA can require information to be submitted under the rules.

“I. Executive Summary

CRE does not object to EPA’s requested ICR for the Certification Rules so long as

  • the record for the Certification Rules and their ICR continues to clearly state,“When used in accordance with label restrictions, RUPs [restricted use pesticides] can be safely applied”; and
  • before clearance, OIRA requires EPA to produce a public record that demonstrates the ICR’s compliance with IQA Guidelines. Hypothetically, this requirement might be demonstrated by a written EPA statement pointing to parts of the current record that demonstrate compliance with IQA Guidelines.

The proposed Certification Rules and ICR are related to EPA’s WPS Rules and ICR. The
WPS Rules and ICR are now being reviewed by OIRA. OIRA should not clear them
unless and until

  • their record clearly states, “When used in accordance with label restrictions, all pesticides subject to the WPS Rules and their ICR can be safely applied”; and
  • EPA has produced a public record that demonstrates that the WPS Rules and their ICR comply with IQA Guidelines.”

Click here to read the CRE’s entire comments.

 

Leave a Reply

Please Answer: *