9.4 State-Federal Partnerships & Funding
States play an important role in the regulation of pesticides. They work cooperatively with EPA to regulate pesticide licensing and certification programs, and protect water resources, endangered species and agricultural workers. States conduct inspections in producer establishments, on farms, at pesticide dealerships, and in the marketplace; respond to complaints from a variety of individuals related to alleged pesticide misuses and work closely with the Cooperative Extension Service in educating the public about the use of pesticides; assist in the disposal of canceled and suspended and unusable pesticides; facilitate "Clean Sweep" pesticide disposal and container recycling programs; and sample pesticides as well as commodities. EPA should expedite approval of state equivalency applications under the federal container/containment regulations, supporting the implementation with sufficient inspector training and additional funding to support implementation.
Where states are given new mandates under the FQPA, and other federal programs, efforts to maintain and increase funding are essential for implementation of these programs. Increased regulations delegated to states without adequate companion funding are unacceptable and unproductive. Steps should be taken by EPA to ease reporting burdens and reduce paperwork, wherever possible. Ongoing efforts made by EPA to be as inclusive as possible with their state partners in developing regulations and making decisions should be continued. EPA should set certain basic minimum standards in cooperation with their state partners and avoid costly and labor intensive reviews of state-delegated management plans, thereby allowing sufficient flexibility in pesticide program activities to accommodate the great variety of resources and needs which exist in individual states. To ensure the safety of the American food supply, however, when implementing Performance Partnership Grants, the agency must ensure that all pesticide enforcement and program monies continue to be provided to the state lead pesticide agency responsible for pesticide enforcement. These resources must not be used for other environmental purposes.
EPA should move quickly to implement a program recognizing electronic labels for a variety of uses to include label amendments to products in the channels of trade, allow for filtering lengthy labels for crop specific use directions, enhance label accessibility, and provide version controls.
EPA should take action to assure that pesticide registration programs comply with the Office of Pesticide Programs’ (OPP) Label Review Manual by providing sufficient training to EPA staff, addressing referrals from states on problematic labels and label language and implement recommendations made by the Label Accountability Workgroup.
EPA has not yet managed to review and approve the majority of state generic pesticide and surface water management plans and will soon be faced with reviews of numerous pesticide-specific management plans. EPA should develop a common effects assessments methodology to support identification of endpoints for FIFRA risk assessments as well as develop aquatic life criteria under the Clean Water Act.
NASDA supports a uniform federal pesticide container recycling system that relies on partnerships between state departments of agriculture, local communities, extension, industry associations, grower groups and other interested parties. These programs should be supported by pesticide registrants, remain voluntary for farmers and retailers and should continue to recognize triple rinsed pesticide containers as non hazardous waste that can be legally landfilled.