CPDA and other members of the PRIA Industry Coalition attended the EPA PRIA Quarterly Stakeholder Meeting held at the Agency’s Office of Pesticide Programs headquarters in Arlington, Virginia on March 13, 2019. The meeting included OPP leadership from all three registering divisions (RD, AD and BPPD). EPA personnel gave a brief summary of the events leading up to the March 8, 2019 enactment of PRIA 4, highlighted some of the new provisions in the reauthorized statute, and discussed the Agency’s plans to implement PRIA 4 and eliminate the backlog of actions awaiting review that was created by the federal government shutdown earlier this year.

In an effort to reduce the backlog of submissions mentioned above, EPA has been reaching out to companies that had multiple actions in the queue and is asking those companies to identify which of those registration actions that remain pending are deemed priority actions. EPA is also requesting that companies agree to a 90-day extension for the review of their product applications. EPA staff signaled they will likely continue to seek additional extensions moving forward but that the additional time sought will be 60 rather than 90 days.

EPA personnel also addressed product applications that were received from February 15, 2019 through March 7, 2019, the period during which PRIA 3 had lapsed and fees were reduced by 70% and the statutory timelines were no longer in effect. Those applications may be withdrawn and then resubmitted with the new PRIA 4 fee. The application packages will receive a PRIA 4 timeline for review as established under the current law. EPA, however, will keep 25% of the fee that was submitted with the original product application during the time period in which PRIA had lapsed.

OPP staff also discussed efforts to reduce the backlog of non-PRIA fast track amendments and notifications and indicated that non-PRIA actions could be bundled together as one submission rather than being submitted as separate label amendments. In addition, OPP representatives suggested that companies could include a PRIA label and a non-PRIA notification in one submission. EPA is considering possible ways to do a quicker review of notifications that might include providing product managers increased authority to sign off on these actions. OPP representatives signaled that they are preparing an update on PR Notice 98-10 on Notifications, Non-notifications, and Minor Formulation Amendments that will address the comments received by the Agency in response to changes proposed previously. In related developments, on April 2, 2019 CPDA and its allied industry partners will be meeting with management from OPP registering divisions to discuss the issue regarding the current backlog of notifications awaiting action.

In other discussion, EPA staff reported that the Agency is considering how best to use the maintenance fees that have accumulated over the years as a result of the previous appropriations constraint that limited the Agency’s ability to spend those funds. Staff noted that the Agency’s Office of Inspector General has recommended the development of a spending plan for maintenance fees under which no more than four months of maintenance fees could be carried over from year to year.

EPA has updated its web site to include PRIA 4 fee tables, revised decision trees, and the interpretations associated with each PRIA 4 fee category. Agency staff are also developing a table that will compare PRIA 4 to PRIA 3 and will make that available on the Agency’s web site very shortly. A summary of the March 13th stakeholder meeting developed by DC Legislative & Regulatory Services on behalf of the PRIA Industry Coalition of which CPDA is a member is available by clicking here. In addition, a presentation made by EPA on what’s new in PRIA 4 may be accessed by clicking here and an overview of the Agency’s PRIA implementation activities including a compilation of product actions completed to date is available here.