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July 06, 2020

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BRAG Biobased Products Blog - EPA Small Manufacturer Rule and Biopesticide Ingredient Comment Period

On May 22, 2020, the Environmental Protection Agency's Office of Pesticide Programs (OPP) announced the opening of a 15-day comment period on its proposal to register a new active ingredient and biopesticide product. The biopesticide product, PHC-91398, would contain Ea peptide 91398, the new active ingredient that was derived from naturally occurring bacterium and induces natural plant defenses. The plant’s reaction to the peptide “activates a hypersensitive response in treated plants, which enables resistance to bacterial and fungal infection, as well as suppression of nematode egg production.” PHC-91398, the biopesticide product, is intended for use on a wide range of agricultural crops and home and garden uses. There will be three product applications:

  • Pre-plant foliar or root dip;

  • Foliar application in greenhouses and fields through a conventional spray, drip, or aerial equipment; and

  • Seed treatment.

Upon review of the data submitted in support of Ea peptide 91398, EPA states that toxicity, allergenicity to humans, and/or adverse effects on non-target organisms is not expected.

EPA is seeking comments, particularly from pesticide users, registrants, public interest organizations, and state, tribal, and local governments. Comments are due on or prior to June 5, 2020.

EPA Issues Small Manufacturer Definition Update Rule In Final

Additionally, on May 28, 2020, the EPA  announced the issuance of the final rule amending the definition of small manufacturer, including a new definition for small government in accordance with the Toxic Substances Control Act (TSCA). Effective June 29, 2020, these amendments affect certain reporting and recordkeeping requirements in the Chemical Data Reporting (CDR) rule under TSCA.

©2020 Bergeson & Campbell, P.C.National Law Review, Volume X, Number 150

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About this Author

Lynn Bergeson, Campbell PC, Toxic Substances Control Act Attorney, federal insecticide lawyer, industrial biotechnology legal counsel, Food Drug Administration law
Managing Partner

Lynn L. Bergeson has earned an international reputation for her deep and expansive understanding of the Toxic Substances Control Act (TSCA), the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), European Union Registration, Evaluation, Authorization and Restriction of Chemicals (REACH), and especially how these regulatory programs pertain to nanotechnology, industrial biotechnology, synthetic biology, and other emerging transformative technologies. Her knowledge of and involvement in the policy process allows her to develop client-focused strategies whether...

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