White House Pollinator Plan: The Industry Responds
September 7, 2015
September 7, 2015
Pest Management Professional (PMP) magazine asked three industry associations for their takes on the White House Pollinator Plan and its potential impact on professional pest management. Here’s what they had to say.
Association of Structural Pest Control Regulatory Officials
ASPCRO is a national professional organization, comprised of state regulatory officials, that works to address and resolve issues related to the regulation of pest management and pesticide use. Its focus is on structural and urban pest management issues.
We have a successful track record working closely with our member states, the U.S. Environmental Protection Agency (EPA) and the pest management industry to address pollinator protection issues. In 2014, we sponsored training for EPA staff to discuss and provide real-world perspective of the regulatory challenges and stewardship opportunities related to protection of bees as it pertains to structural pest management and related non-agricultural pesticide uses.
ASPCRO’s letter to the EPA on Aug. 15, 2013, and the EPA’s subsequent response, provided clarification and supported development of the ASPCRO Guidance Document for Bee Language for Neonicotinoid Products in Outdoor Structural and Turf and Ornamental Settings. This document provides interpretation of the pollinator protection and nonagricultural directions-for-use language as a resource for pesticide state lead agencies (SLAs) in verifying compliance with neonicotinoid bee language.
We support the EPA’s goal to protect managed bees through label restrictions, as well as flexible and locally directed measures developed by states. We applaud its initiative to create clear, enforceable pollinator protection language, and fully support its direction and efforts to encourage and support development of state-based Managed Pollinator Protection Plans (MP3s). We believe the MP3 approach enhances communication, builds relationships, increases understanding and establishes clear expectations among all stakeholders, including the regulatory authority, beekeepers, landowners, applicators and the public. This is why we’ve requested the EPA’s support to encourage pollinator plans to include nonagricultural use sites and consideration of urban pest management in development of the general plans, which should involve pest management and landscape professionals as stakeholders, as well as those from the SLA with regulatory expertise in structural pest management. Such plans should address nonagricultural applicator use by encouraging the development of best management practices (BMPs) and adoption of resources such as the National Pest Management Association’s (NPMA’s) Pollinator Protection Best Management Practices.
If further label language restrictions are considered, the EPA should provide guidance and work with states to develop clear, enforceable language to additional sites, including nonagricultural sites that remain in bloom throughout the application season. There are times when bees are the target pest, and insecticide applications for their management are warranted. Applications to control bees when they’ve become a public health risk, a danger to people, pets or other animals, or are damaging property — should be expressed clearly on labels.
It’s important for the EPA to understand and acknowledge the limitations some states might have to the MP3 implementation process. Many states do not have the funding, authority or stakeholder support to initiate even a voluntary MP3. It might be difficult for some states without funds to support plan development and stakeholder involvement. Other agencies within a state might need to take the lead; this could create situations in which other groups within a state recommend legislative action that could impose unfunded mandates on SLAs and lead to inconsistent regulation nationally.
Last, but not least, we support additional science-based research and risk-assessment improvements to increase certainties related to pollinators and pesticide impacts, including those in the stated areas from the policy. As more knowledge and information are gained, we encourage the EPA to work with us to develop additional language (if needed) related to nonagricultural uses.
— John Scott, President
United Producers, Formulators & Distributors Association
UPFDA’s mission is to bring a standard of excellence and enhanced professionalism to the structural pest management industry. It strives to recognize the requirements and needs of its customers and promote better cooperation and communication with government authorities.
The Pollinator Health Task Force co-chaired by the U.S. Department of Agriculture (USDA) and the EPA released the Pollinator Protection Plan in late May. With respect to pesticides, the proposal seeks to adopt mandatory pesticide label restrictions to protect managed bees under contract pollination services. The restrictions would apply to foliar applications of certain products on a contact exposure basis and would prohibit the application of these products during bloom when bees are known to be present under contract. These situations apply primarily to agricultural uses of pesticides and would not specifically affect those of us in the structural pest control industry.
However, the EPA is proposing that it rely on state and tribal agencies to develop plans to protect pollinators from pesticide exposure when not under contract. Such plans could certainly impact those of us in the structural pest control field. UPFDA members have been working with the EPA and will continue to work with state lead agencies and their organizations, including ASPCRO and the Association of American Pesticide Control Officials (AAPCO)/State FIFRA Issues Research and Evaluation Group (SFIREG), to develop workable plans to reduce potential exposure while still protecting structures and public health and safety.
In addition, UPFDA members continue to help educate our PMP customers about these mitigation plans. We will also continue to serve as a conduit for information from ASPCRO to producers, formulators and distributors.
We strongly encourage PMPs to work with their state lead agencies to help develop their state mitigation plans. As affected stakeholders, PMPs should help create pollinator protection plans that are workable for the professional pest management industry.
— Dr. Cisse Spragins, Secretary-Treasurer
Responsible Industry for a Sound Environment
RISE is a national trade association representing manufacturers, formulators, distributors and other industry leaders involved with specialty pesticides. Based in Washington, D.C., it promotes the safe use of pesticides to control pests and invasive species.
As we learn how the White House Pollinator Plan might impact certain pesticide active ingredients and uses we represent, we know there is no imminent threat to pest control or other specialty uses. However, we also know the plan provides opportunities to threaten access to chemistries that are essential to protecting public health, safety and infrastructure.
We are working with regulators every day to protect pesticide active ingredients and use patterns on which pest management professionals (PMPs) rely. While the White House Pollinator Plan does not directly impact pest management, it has not changed our outlook on the issue. The pollinator issue has increased antipesticide activism and attacks on our industry, so our work is on two fronts:
1. maintaining industry unity to ensure important chemistry remains available for all the use patterns we represent; and
2. taking proactive steps to ensure pollinator-focused antipesticide activism does not erode federal and state pesticide preemption, which would have an impact on PMPs’ access to the solutions they need.
— Aaron Hobbs, President
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