Note To Reader:

Attached is a recounting of activities designed to begin making the occupational risk assessment development process more transparent, and increase public and Land Grant University involvement early on. EPA, USDA, and the Land Grant Universities will continue discussions to further define the process for participation.

OCCUPATIONAL RISK ASSESSMENT

EXPANDED PUBLIC PARTICIPATION

EPA / USDA / LAND GRANT UNIVERSITY COOPERATION

The TRAC process has highlighted the increased need for transparency in the regulatory process and for productive stakeholder involvement in the process. In particular, stakeholders need to better understand the occupational risk assessment process in order to productively comment on Agency analyses, occupational risk assessments and risk mitigation measures. During the last TRAC meeting, the Agency outlined its occupational risk assessment process. TRAC's response to this briefing, as well as the USDA comments on the preliminary risk assessments for organophosphates, made it apparent that the Agency needs to engage in more explanation of the risk assessment methods and needs to solicit more participation earlier in the assessment process. During the past few months, EPA has been involved in a number of activities to meet these needs.

Active, Early Involvement of Land Grant Expertise

USDA and the land-grant universities can assist the EPA with its development of occupational risk assessments by providing information about pesticide use and cultural practices. Recently, USDA staff and land-grant faculty have served as reviewers of EPA risk assessments, which include occupational risks for several organophosphate pesticides. This has led to an opportunity to discuss engaging the USDA and land-grant universities throughout the risk assessment process, as well as in the planning and implementation of risk mitigation measures.

Presentation to the Pesticide Program Dialogue Committee

At the last Pesticide Program Dialogue Committee meeting, the Agency presented a short briefing on the occupational risk assessment methodology, including a case example.

Meeting with USDA Headquarters and Land Grant Reviewers

In July, the Agency met with a small group of USDA and Land Grant University staff to again present the occupational risk assessment methodology and discuss improvements.

Meeting with USDA Southern Region Pesticide Applicator Training Program Coordinators and Land Grant University Researchers

In late September, the Agency met in Baton Rouge with a number of land grant university and USDA staff to discuss the risk assessment and risk mitigation methodology employed by the Agency. The public and TRAC members were broadly invited to this meeting. Detailed presentations were made on the Worker Protection Standard, Reregistration and Tolerance Reassessment, Risk Mitigation in Reregistration Eligibility Documents, Human Health Risk Assessment, Occupational Exposure Analyses, Use and Usage Data Needs, and the Public Participation Process (pilot).

During the discussion phase of the meeting, it was apparent that USDA and land grant staff would like to contribute to risk assessment and mitigation earlier in the process, with improved data that better reflects field reality.

Meeting with USDA North Central Region State Pesticide Impact Assessment Program Coordinators

In October, the Agency met with the north central states Pesticide Impact Assessment Program Coordinators to again present the occupational risk assessment methodology and discuss possible improvements and expanded participation in the process.

Possible Future Presentations

EPA / USDA / Land Grant University focused multi-day workshop - winter date possible.

Northeast Pesticide Applicator Training Program Coordinators annual meeting - spring.

North Central Pesticide Applicator Training Program Coordinators annual meeting - spring.

Western States Annual Pesticide Meeting - spring.