Council of Producers & Distributors of Agrotechnology

Terry Kippley, CPDA

August 28, 2023

Dear CPDA Supporter,

It has been another busy few days since our last News and Notes. Thanks to Dr. Ray McAllister, CPDA’s Regulatory & Technical Advisor, we are actively engaged on two pressing Pesticide Registration Improvement Act issues.

Pesticide Registration Improvement Act (PRIA) – Commodity Inerts

With Ray’s leadership, CPDA has been involved in discussions between the PRIA Coalition and EPA’s Office of Pesticide Programs (OPP) regarding the interpretation of the new PRIA category (I018), which was created for a submission requesting the addition of a single inert ingredient to the Commodity Inert Ingredient List.

A major point of controversy is the commodity inert status of certain registered active ingredients (AIs). In the early days of the commodity inert program (at the start of the COVID pandemic), EPA approved more than 50 registered AIs as commodity inerts. (Contact Ray for the list.) Most of these have long had primary use as inerts and only incidental use as AIs, such as vinegar, carbon dioxide, ethanol, sucrose, etc. OPP now intends to cut off all future approvals of AIs as commodity inerts, citing concerns over impurity profiles, and is reconsidering those AIs already on the commodity list. CPDA and the PRIA Coalition would like to see the current list maintained and future approvals continued, with reasonable limitations.

In 2020 when OPP was inundated with sanitizer product applications related to COVID, the Agency allowed commodity use of inerts that had compensable data supporting only tolerance exemptions, so long as that commodity use was in non-food-use products only. CPDA has recently been told this policy will continue, though clarification of EPA’s recent Guidance for PRIA Category I018 will be needed in this respect.

The commodity inert program can be an important tool in reducing the burden and backlog of non-coded PRIA actions. We hope to maintain a robust commodity inerts program without unnecessary bureaucratic restrictions.

Non-PRIA Backlog

(Submissions that do not have PRIA code)

For the last 14 months, CPDA has been having monthly meetings with OPP staff to identify ways we can work together to help reduce the non-PRIA backlog. One of the first actions CPDA members undertook was to identify, with OPP’s help, any non-PRIA submissions that were no longer relevant. These submissions, which accounted for 10% of the backlog, were then withdrawn. This reduced OPP’s workload while creating goodwill for CPDA.

These monthly meetings have created other efficiencies. This includes identifying other best practices, such as changes to the notification, fast track labeling and CSF amendment process to streamline and standardize the approval process. Also on the table is a discussion of situations where OPP would accept notifications instead of amendments. Our next one-on-one with OPP is September 11th. Please reach out to Ray McAllister if you have suggestions.

Nearly 800 attendees at Agribusiness Global Trade Summit in Miami. Great to catchup with Meister Media’s Eric Sfiligoj and Eric Davis along with speakers Allister Phillips and Derek Oliphant co-founders of Agbioinvestor who presented “Future Outlook of the Crop Protection Market.”

Market Intelligence

The 2023 season has been described as “challenging” as crop protection inventories have been destocked and global market intelligence is at a premium. I recently attended the Agribusiness Global Trade Summit in Miami put on by our media partner Meister Media who publishes CropLife Magazine and Agribusiness Global Magazine. With over eight hundred attendees from China, India, Latin America, Europe along with U.S. distribution and crop protection companies, it was a great opportunity to understand current market conditions and what to expect in 2024.

CPDA member Bob Trogele with AMVAC was on hand and provided the attendees with an insightful recap of our current market conditions along with an overview for how our current situation will present opportunities in the future.

Meister Media’s Editor Eric Sfiligoj and Bob Trogele, COO at Amvac.

It was great to see so many CPDA members in person and understand how CPDA can continue to be their voice and represent their interests.

It was great to catch-up with CPDA member Steve Greenfield, President of Consus Chemicals at the start of the summit bringing together crop protection suppliers from India and China to share market intel.

Great crew of CPDA members at Global Agribusiness Trade Summit: Jim Kank, Albaugh; Antoine Puegh, MEY and incoming CPDA Chairman, Brad Swillen, Ethox Chemicals.

Enjoyed learning more about CPDA member Atlantic-Pacific’s export business with President Darrin Quern and National Sales Manager, Jamie Roundabush.

Visited with CPDA member Dave Schumacher, President of Helm and Nick Mylonakis, Supply Chain Leader.

Fun to catch-up with Dave Van Dam of Winfield United—Canada.

CPDA Annual Meeting is Almost Here!

If you have not made plans to attend the CPDA Annual Meeting in Nashville, please do so now. The dates are September 12-14 where attendees will learn more about PRIA V implementation from Laurie Flanagan, the PRIA Coalition Coordinator and Nathan Ehresman, Director of Regulatory Affairs for Albaugh.

Until next time...