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SMART Meetings
A significant focus of the public participation process is for EPA and stakeholders to begin communicating as early as possible to ensure the accuracy of information about pesticide use. Current pesticide use and usage information is vital to the Agency in developing accurate pesticide exposure and risk assessments.
In Pre-Phase 1, before the public participation process formally begins, EPA may host a meeting known as a SMART meeting with USDA, pesticide registrants, and other key stakeholders. The meeting provides stakeholders an opportunity to improve the Agency's understanding of actual, current pesticide use practices. While responses are not required, EPA's SMART Meeting Questions indicate the types of information that the Agency is most interested in refining at this stage.
After verifying and analyzing the information received, EPA prepares a Use Closure Memo summarizing its current understanding of the pesticide's use, and posts this information in the docket and/or on the pesticide's page on the reregistration status website. EPA welcomes input from the public to further refine this summary of a pesticide's current use.
SMART Meeting Questions
While responses are not required, these questions guide registrants and others in updating EPA's pesticide use and usage information.
Current Labeling
- Verify the label information shown in tables provided by EPA.
- Are there any feeding/grazing restrictions on product labels not described on these tables?
- Are there any rotational crop restrictions?
- Please describe all registered formulations.
Additional State or Federal Labels or Restrictions
- Are there federal or state imposed buffer zones for aerial or ground application?
- Are there any other existing restrictions? Please describe specific uses and areas/sites to which the restriction applies.
Anticipated Changes in Labeling
- Have labels been recently changed or do you plan on making any label changes in the near future? If so, what are these changes?
Supported Uses
- Which uses will be supported?
- Are there any uses that are currently registered, but not marketed?
- If there are any uses that you are not supporting for reregistration, are you aware of anyone who will be supporting these uses?
- What use rates are supported with residue data?
- Are there any crop uses that will not be supported for U.S. registration, but will be supported as a tolerance for imported commodities?
- Will supported uses be at the current maximum label rates, number of applications, and the application intervals as currently stated on the labels?
- Will you be supporting any special local needs (SLN) registrations? If so, provide a list of supported SLNs.
Actual Use
- Do you agree with the Agency's use estimates outlined in the Screening Level Usage Analysis? If not, please explain the specific disagreement and provide rationale and data sources. In the past three years, how many pounds of active ingredient were used nationally for each use site? Please provide regional information as well. What are the typical application rates for each use site? Please provide regional information as well. Do you have any additional information? If your estimates are from a single source, how do they compare with publicly available sources, such as from USDA and California DPR?
- By use site, how many total acres are treated per day and per season for each method of application?
- What are the typical and maximum use rates? What information do you have on the distribution of rates; particularly for products that are often used in combination with other pesticides?
- What is the percent crop harvested at various PHIs?
- What is the frequency and timing of application (typical and maximum)? How often is the pesticide applied? What is the typical and minimum interval between applications? Describe seasonal variations in use. Provide information on typical and maximum areas of application.
Use Practices
- Describe the typical personal protective equipment (PPE) used for mixing, loading and applying.
- Describe the various pet treatments - shampoos, dips, direct sprays, wipes, soap, pet collars, application tubes - in detail.
- What other pesticides are used in combination with these products?
- What is the market niche? What are the key pests or other conditions that drive the use? Please discuss on both a regional and national basis.
- Describe all methods of application (air, ground, chemigation, soil injection, etc.). By site, how much active ingredient is applied by each method of application? Explain why. Provide information/data concerning the amount and percentage of active ingredient applied pre-plant, at-plant and post-plant, sorted by crop site, application method and application season.
- Do you know of any emerging equipment or cultural practices that could reduce exposure to your product in food, to workers, or in the environment?
Incidents
- Are there any reported incidents of drinking water contamination? Please provide specific details.
- Are there any reported spray drift or volatilization incidents? Please provide specific details.
- What are the ecological incidents (nontarget plant damage and avian, fish, reptilian, amphibian and mammalian mortalities) that have been reported while the current use practices have been in place?
- Are there any air or water monitoring data available from public sources, such as CARB, USGS, and states?
Benefits
- What is unique about products containing this active ingredient?
- What alternatives are available?
- Are there any constraints to the use of alternatives such as cost or efficacy?
- Is there any geographic area where there are no alternatives?
- What is the largest droplet size that is efficacious?
Additional Data/Information
- Are you aware of any sub-populations who may have higher exposure than the general population?
- Are there any additional new toxicology, chemical-specific exposure, biomonitoring or epidemiological data available? Are there any plant toxicity data using typical end-use products?
- Are you aware of metabolites, degradates or contaminants in the end-use or technical grade products? What information do you have regarding the metabolism/toxicology of these metabolites, degradates or contaminants?
- Are there studies being conducted to support tolerances in rotational crops?
- What additional data do you plan to submit in the next two years?