CPDA and other members of the PRIA Industry Coalition participated in the PRIA Quarterly Stakeholder meeting held by Office of Pesticide Program (OPP) representatives on November 12, 2020. The virtual meeting included managers from all three registering divisions (AD, BPPD, and RD) who provided updates and metrics on the Agency’s implementation of PRIA and efforts to improve process efficiencies.
Agency Reorganization Changes
OPP officials began the meeting with an overview of last September’s reorganization of the Office of Chemical Safety and Pollution Prevention (OCSPP). Under the new structure, OCSPP is divided into three offices including the Office of Pesticide Programs, the Office of Pollution Prevention and Toxics, and the Office of Program Support. As a result of the reorganization, the number of OPP divisions has been reduced from nine to seven.
Update on Relocation of OPP Offices to Downtown Washington, D.C.
An update was provided on OPP’s plans to move from its Arlington, Virginia Potomac Yards location to EPA’s Federal Triangle headquarters in downtown Washington, D.C. The lease for the Potomac Yards space has been extended to September 30, 2021. As soon as conditions allow employees to physically return to the office, OPP will resume preparations for the move.
OPP Continues to Hire Aggressively
OPP staffing levels stood at 594 at the start of FY 2021 and are projected to reach 632 by the end of the fiscal year as EPA continues to hire aggressively.
Within the Registration Division, 16 new employees were on-boarded during FY 2020. However, during that same time, RD lost 7 staff members due to retirements and resignations and is working to fill those vacancies. With a significant number of junior employees who have been in place for less than two and a half years, RD is placing significant emphasis on training.
Pesticide Submission Portal (PSP) Improvements
The meeting included an update on EPA’s progress in making improvements to its Pesticide Submission Portal (PSP). The Agency’s goal is to have 100% electronic submission capability for all actions reviewed by OPP. Among the recent features added to the portal is the Company Number Generator which will enable companies seeking a registration number from OPP to receive one within 24 hours. EPA is also examining the possible integration of PRIA fee payment capability into the portal at the time of product submission so that registrants do not have to go to a separate site such as www.pay.gov to make a PRIA fee payment. In other IT improvements, EPA is looking at how to make the authorized agent registration process less cumbersome and is developing interactive training tutorials that will be available on the portal in 2021.
EPA Transitions to Digital Gold Seal Letters
OPP staff announced a new process for issuing Gold Seal letters electronically with the insertion of a seal that is digitally rendered rather than embossed. The electronic process for issuing Gold Seal letters was developed by OPP staff in response to the challenges of working remotely during the ongoing COVID-19 pandemic. OPP staff continue to work internally with the Office of Enforcement and Compliance Assurance to address security concerns related to electronically signed letters and are engaged with the U.S. Department of State in addressing procedures for the authentication of Gold Seal letters.
FY 2021 Maintenance Fee Invoices to be Sent Electronically
OPP is updating its web site in preparation for electronically sending letters to registrants invoicing them for FY 2021 maintenance fees. Previously, maintenance fee invoices and the required forms and instructions were mailed in hard copy. However, because EPA staff are working remotely due to COVID-19, maintenance fee invoices will be sent electronically and the forms and instructions will be posted on EPA’s web site for downloading. The FY 2021 maintenance fee is set at $4000. Payment of maintenance fees is due by January 15, 2021 and invoices will be emailed shortly. Registrants are advised to update their company profile on file with EPA to ensure that the Agency has the correct email address of the individual who should receive the maintenance fee invoice. The EPA web site for doing so may be accessed by clicking here. Registrants are also advised to acknowledge receipt of the maintenance fee email by responding to the mailbox address that will be included on the letter. Questions may be directed to EPA’s Kimberly Smith at email@example.com.
PRIA Performance Metrics
EPA representatives presented a detailed set of metrics on PRIA submissions received and completed during FY 2020. The high rate of renegotiations across the registering divisions continues to be of concern and the Agency is considering possible changes to the front-end processing screen and the 45/90 day technical screen to remedy this situation. The following are copies of several slides excerpted from EPA’s presentation showing a summary of the total number of PRIA submissions, completions, and renegotiations for FY 2020; the percent of on-time product completions for FY 2020 across all product types; and, the percent of completed PRIA decisions with renegotiated due dates going back historically to FY 2012. During FY 2020, out of a total of 54 inert ingredient submissions received by EPA, 23 were completed. Of those, 16 or 69.5% had renegotiated due dates.
To access the full set of slides presented by EPA at the PRIA Quarterly Stakeholder meeting please click here.