In related activities surrounding the shortage of BIT, CPDA has been engaged with the Washington State Department of Agriculture (WSDA) in calling for guidance that would set forth a streamlined process allowing registrants of spray adjuvants to substitute alternative preservatives in their products. In a request sent to WSDA’s Registration and Licensing Services Program on September 18th, CPDA Interim President Gary Halvorson emphasized that the BIT shortage is not likely to abate any time soon and he requested that the Department move quickly in providing instructions for the modification of adjuvant registrations of existing formulations.

WSDA in response has specified three steps that registrants are required to take if they choose to revise their adjuvant formulations:

1. Determine the appropriate revisions to the adjuvant CSF, based on the preservative use limits in 40 CFR 180.910 or .920 (assuming the adjuvant is intended for use on food or feed crops).
2. Submit a revised adjuvant CSF to WSDA using the secure pesticide registration portal (https://agr.wa.gov/PestFert/Pesticides/ProductRegistration.aspx#Secure), and mention in the “Notes” box that the only change is the preservative. Do not submit a CSF by email, since this method is not secure.
3. Contact the assigned Registration Specialist (https://agr.wa.gov/PestFert/Pesticides/ProductRegistration.aspx#RegContacts) and let them know that the registrant is submitting a revised adjuvant CSF.

WSDA has instructed that in lieu of these actions, a revised CSF can be submitted by ground mail or fax. The registrant should include a cover letter explaining that the only change is the preservative in such cases.