EPN Comments on EPA and FDA’s Proposal to Modernize the Approach to the EPA and FDA Oversight of Certain Products

On March 22, 2023, EPN submitted oral comments regarding EPA and FDA’s proposal to modernize the approach to the oversight of certain pesticides or new animal drugs. We suggest that both agencies draw a jurisdictional line (using administrative tools including MOUs, public guidance, and/or rule-making) between which agency would better regulate a particular product based on expertise, resources, and scope of legal authority. With this in mind, we recommended the agencies think about how to manage the transition for products that move to a new regulator, as the proposal did not address this. We also suggested creating a portal where the regulated community can get timely answers to questions.

Read the oral comments