CPDA and other members of the PRIA Industry Coalition participated in the PRIA quarterly stakeholder meeting that was held with EPA on Wednesday, April 29, 2020. The meeting was conducted online due to the ongoing COVID-19 pandemic. The meeting included OPP managers from all three registering divisions (RD, AD and BPPD) who provided updates and detailed metrics on the Agency’s implementation of PRIA.

Office of Pesticide Programs Director Rick Keigwin opened the meeting by reporting that Agency staff have been working remotely since mid-March. In his remarks, Keigwin noted that the ability to access electronic records remotely has allowed Agency staff to keep up with the somewhat increased pace of FOIA requests that OPP has experienced recently. He added that OPP is “gearing up” for what is soon expected to be a significant onslaught of FOIA requests related to the Agency’s COVID-19 activities.

In his other comments, Keigwin told Coalition members that OPP continues to hire staff and that personnel level are now at levels greater than previous levels which were inadequate. The Agency has long maintained that with the round of retirements and rate of attrition of existing staff that has occurred over the last several years, additional personnel were needed for EPA to meet its PRIA obligations. As reported previously, the language in PRIA 4 which removes the previous constraint limiting EPA’s ability to spend maintenance fees that had accumulated over the years as a result of appropriations falling short of PRIA baseline levels, provides some relief enabling the Agency to hire new staff.

EPA officials stated that since the start of the federal government’s 2020 fiscal year which began October 1, 2019, the Registration Division has hired 9 new employees. However, during this same time period three employees left RD and two more are expected to leave in the coming weeks. EPA representatives note that despite these employee departures, RD staffing levels remain in the “positive” range. (Please note that at the recent Joint Inerts Steering Committee meeting held April 22nd, Kerry Leifer, Branch Chief of EPA’s Chemistry, Inerts and Toxicology Assessment Branch, indicated that he has received approval to hire up to three – possibly as many as four additional staff for CITAB and he is actively recruiting).

OPP management reported that applications submitted digitally through the electronic Pesticide Submission Portal are being processed by Agency staff remotely. However, the processing of actions requiring some type of hard copy or paper review has been delayed because personnel do not have access to paper documentation sent to EPA’s offices. Throughout FY 2020, EPA has been working to implement IT improvements that will make it easier to submit PRIA applications electronically through the portal.

During the meeting, EPA officials presented a slide showing the number of PRIA submissions across all three registering divisions that were made electronically through the portal compared with the number of submissions that were made on paper or CD/DVD for the first half of FY 2020. The number of antimicrobial and biopesticide product actions submitted electronically through the portal exceeded the number of paper or CD/DVD submissions. However, for conventional PRIA actions, the number of paper submissions was roughly equal to the number of electronic portal submissions. Registration Division Director Mike Goodis questioned the “50/50 split” noting that there was a general sense among RD staff that the number of portal submissions seemed to significantly outweigh the number of paper submissions coming into the Agency. Goodis suggested that the submission of Gold Seal letters for EPA processing could be affecting the numbers.

EPA representatives also presented slides providing a summary of the percentage of completed PRIA decisions with renegotiated due dates across all product types (antimicrobials, biopesticides, conventional actions, and inerts) as well as the rate of on-time product completions for the first half of FY 2020.  EPA officials acknowledged that while resources and staffing levels are underlying factors for some of the late completions and renegotiations of product submissions, the Agency cites greater frequency of deficiencies found in application packages and supporting documentation.

In other updates, plans continue for the relocation of the Office of Pesticide Programs from Arlington, Virginia to Washington, D.C. Agency representatives emphasize that disruption in operations will be kept to a minimum and that telework on PRIA actions will continue during the move. OPP will have a new telephone number and will update its web site accordingly. In addition, the Agency will revise its procedures for delivery of registration and reregistration packages at its new Federal Triangle headquarters office. The Agency does not yet have a firm date for the move. The EPA slides presented at the PRIA Quarterly Stakeholder Meeting may be accessed by clicking here.