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Comments from “I & I” Proposal - Received at 12/5/08 PPDC Workgroup Meeting
Clarification- scope of pilot limited to I & I, but serves as a useful model for broader scope.
- Metrics included in pilot: If going forward with pilot, there should be some metrics for success/failure, as well as a timeline. Suggestions for metric included success at claiming market share w/logo.
- Inclusion/exclusion of a.i.: Most seemed to agree that excluding the active ingredient from consideration did not make sense; one comment was that this proposal was a non-starter with the environmental community without the a.i. included. The subgroup acknowledged that new criteria might need to be developed for evaluation of a.i. and that this could delay implementation of pilot in the short term.
- 3rd party certification: Surprise that 3rd party certification was back on the table- previous near unanimous agreement that it should be government role and that multiple sources leads to confusion; response was that there are programs currently recognized/used, and that this allows multiple avenues to achieve a good decision (consensus was not reached within the subgroup on this issue). One commenter suggested that maybe multiple certifying entities could be allowed, as long as a single standard used. Organics program could serve as a model for multiple certifiers.
- Resources: What resources are available for this effort? From industry? From EPA?
- Objective of program should be to 1) help consumers and 2) move the market to safer products. Use Agency scientific background to make sure program is doing what we want it to. Guiding questions- What do we want to do? What are we going to test? What are our resources?
- Pre-emption: Industry perspective: all of these preferred purchasing programs in the states could lead to confusion for industry. EPA owns the label, states should accept Federal label (but process that allows state inclusion in consultation leading up to the final label very important). From industry and user perspective, uniformity through all 50 states is preferred. State Lead Agency perspective: the reality is that states serve valuable function, often finding errors/discrepancies in Federal labels, or language confusing to end user. They consider themselves co-regulators with the EPA, often identifying problems with the label, and are problem-solving on the ground. They serve a quality control role. States are naturally conservative, as to them the label is primarily a compliance vehicle- for this reason they have reservations about the marketing. Allowing these claims introduces greater complexity in their review, presents opportunity for small distributors to “go wild”.
- 25(b) ingredients- issue raised by states that if these ingredients are included, they are exempt from Federal registration (and Federal label), so responsibility falls to the states to look at these. How would 25(b) products be handled under the I & I proposal?
- Scope of the pilot- is a fungicide used in house paint a “hard surface sanitizer? This is coming from a CLA perspective of NOT wanting agricultural products to be included. It was noted that I & I products are often also sold to consumers- it may be difficult to delineate products which are being considered under a pilot from other consumer products.
- Sense of urgency- the I & I sector has already bought into “green”, and the marketplace isn’t waiting for EPA, it is moving ahead. Thought was that if the timeline for this effort isn’t to move quickly forward, may not be practical to move forward at all.
- Discussion of static standard that all products in market might eventually achieve vs. standard that is revisited/reset based on % of market. Research suggests that a static standard results in most in the marketplace eventually complying, but with little innovation. In contrast, a standard based on the top percentage excludes most products, but fosters innovation amongst those few vying for the top spot.
Concern that some certifiers have criteria that are too restrictive and not many products were qualifying; counterpoint was that not many companying were applying in the disinfectant sector b/c of current stance re: FIFRA.