HCPA and Allied Groups Submit Joint Comments to Cal EPA
July 17, 2018
On July 5, HCPA, RISE, CropLife America and the Council of Producers & Distributors of Agrotechnology (CDPA) submitted joint comments to California’s Office of Environmental Health Hazard Assessment (OEHHA) on their proposal to create a safe harbor for pesticide ingredients within Prop 65 (view comments here). We made a strong case that EPA’s registration process, which evaluates carcinogenicity and reproductive toxicity, is the functional equivalent of the safe harbor level. We also pointed out that Cal EPA’s proposal for safe harbor through a label warning conflicts with EPA’s regulatory requirements for warning statements. In effect, it is possible, if not likely, that the EPA would not approve the California warning language to be eligible for safe harbor status. Finally, we argued that if Cal EPA does not provide the same safe harbor for pesticides, then the Cal EPA should get the U.S. EPA’s buy-in for a warning statement before proceeding.
On July 5, HCPA, RISE, CropLife America and the Council of Producers & Distributors of Agrotechnology (CDPA) submitted joint comments to California’s Office of Environmental Health Hazard Assessment (OEHHA) on their proposal to create a safe harbor for pesticide ingredients within Prop 65 (view comments here). We made a strong case that EPA’s registration process, which evaluates carcinogenicity and reproductive toxicity, is the functional equivalent of the safe harbor level. We also pointed out that Cal EPA’s proposal for safe harbor through a label warning conflicts with EPA’s regulatory requirements for warning statements. In effect, it is possible, if not likely, that the EPA would not approve the California warning language to be eligible for safe harbor status. Finally, we argued that if Cal EPA does not provide the same safe harbor for pesticides, then the Cal EPA should get the U.S. EPA’s buy-in for a warning statement before proceeding.