Comments from "Decision Tree" Proposal - Received at 12/5/08 PPDC Workgroup Meeting
- As part of this initiative, new DfE categories/sectors being proposed? (Yes) What is the process within DfE for new sectors? Answer (from Clive Davies): stakeholder input needed; public process to discern benefits
- Requirement of efficacy- what about 25(b) products? Not required to come in for registration, EPA does not review their labels. Who would review these data? A real headache for the states, and should be excluded from “green” initiatives (state perspective).
- Does putting this through DfE criteria ignore that there are already existing OPP criteria (e.g., Tox Category 4, signal words on the label currently)? Information to make comparative decisions currently resides within OPP, not with DfE- how does the Agency see the evaluation working? OPP role?
- Factual statements vs. logo/comparative claims: concern from industry that comparative claims may not be the way to go- from their perspective, they are focused on their products, not on others (don’t want to make comparative claims). One commenter opined that mixing factual and comparative statements is problematic. From a state perspective, they prefer to see an individual logo which has gone through a standardized process, not a list of allowed factual statements that could go on a label. This would be much easier for consumers to understand.
- Distinction between professional buyers and consumer buyers was made- I & I purchasers are professional buyers. In commenter’s experience, purchasers have initially preferred the logo, but as they get more experienced, they demand more information. Logo/seal may be workable, but many complex issues must be resolved to get there- commenter felt that factual statements would be a good first step in the meanwhile.
- Discussion from industry on what their drivers for “green” labeling are: Comment that retail stores (e.g., Wal-Mart) are one of the drivers of this process. They have scorecards/standards for packaging, for formulation. In addition, the chemical companies have environmental goals- consumers may not be aware of the registrants’ efforts to be good stewards- allowing logos or factual statements allows companies to make this information available to consumers. Environmentally Preferable Product (EPP) programs such as Green Buildings/LEED are drivers- LEED uses existing standards- Green Seal is the default. Also has to meet standards in California VOC regulations. Side comment made that it would be helpful to have the Wal-Mart PPDC member present for these discussions.
- Cleo passed along his and Michael’s conversation with the regional folks. Are they hearing that access for non-green products is a problem? Response from some region folks was that industry is not unable to get these products into the market, but that from a regional perspective, some sort of “less toxic” ID might be helpful. Industry response that their government affairs folks are active in making sure pesticide products are carved out of “green” preferences in the state procurement regulations.
Would 25(b) products need to go through the registration process/be subject to Agency review if engaged in this initiative?
It was countered that consumer understanding of a logo on a label would require enormous public education effort, but there was disagreement with that conclusion- DfE education effort on their website was held out as an example of success in the non-FIFRA realm.
- Johnson Diversey- what about concentrated products? It is felt these products should be considered for environmental preference. Moves manufacturing process to the end user, less packaging, less weight, less transport- better value to the buyer, end user.
- PMRA- just starting down this path- they look forward to future participation and to our sharing our materials with them.