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.