The Environmental Protection Network (EPN) has submitted formal comments to the EPA, strongly requesting that the agency not finalize the proposed unconditional registration of epyrifenacil, a new systemic PPO inhibitor herbicide. EPN asserts that the agency has exhibited a “rush to judgment” and that the current administrative record is insufficient to meet the statutory standards required for registration under FIFRA and FFDCA.
EPN’s Key Deficiencies and Concerns
EPN’s opposition centers on the failure to conduct a complete risk review and issues with the proposed product labeling:
- Failure to Assess Cumulative Risk: Because of the fluorine bonds it contains,epyrifenacil is a PFAS, which the agency did not address in this proposed action. EPA also failed to explain why it did not conduct a cumulative risk assessment for epyrifenacil and related substances in the same chemical class.
EPA’s plan to only address cumulative effects at a later date is insufficient for an unconditional registration of a food-use chemical.
- Misbranded and Unworkable Labeling: The proposed labeling is legally “misbranded” because the directions are not likely to be read and understood; users are required to go through multiple steps to obtain accurate and useful information for application. EPN recommends the replacement of this process with a more user-friendly system, such as a QR code, on the label.
- The labeling also lacks a critical performance-based restriction, such as a “no harm” standard for spray drift, to ensure proper application that limits off-target damage and critical species protection.
EPN concludes that the EPA must conduct a more comprehensive risk analysis and fully reevaluate the labeling to ensure it meets all required FIFRA standards before the registration can be finalized.