
1
Call
with
CA
Stakeholders
on
Procedural
Regulations
for
Registration
Review
October
7,
2005
(
1
pm)
Draft
Agenda
and
Water
Quality
Agency
Key
Points
1.
Establish
teleconference
and
make
introductions
(
10
min)

2.
Overview
of
proposed
registration
review
process
&
Q/
A
on
proposed
process
Vivian
Prunier
/
Carol
Stangel
(
60
min)

3.
Overview
of
issues
identified
by
water
quality
agencies
relative
to
registration
review
&
Q/
A
Representatives
of
the
California
Water
Board,
Tri­
TAC
(
wastewater),
California
Stormwater
Quality
Association
(
stormwater),
and
the
UP3
Project
(
Bill
Johnson,
Ann
Heil,
Geoff
Brosseau,
and
Kelly
Moran)
(
45
min)
Note:
Please
see
below
­
Water
Quality
Agency
Key
Points
4.
Next
Steps
(
5
min)
2
Procedural
Regulations
for
Pesticide
Registration
Review
Water
Quality
Agency
Key
Points
Notes
for
Teleconference
10/
7/
05
Data
for
Registration
Review
 
U.
S.
EPA
data
gathering
for
initial
docket
should
include
a
literature
search
&
assembly
of
relevant
data
from
all
sources,
including
government
sources
(
i.
e.,
monitoring
data).
 
U.
S.
EPA
must
require
that
necessary
data
be
provided
to
complete
environmental
risk
assessments
addressing
surface
water
quality,
municipal
wastewater
discharge
compliance,
&
urban
runoff
compliance.
U.
S.
EPA
&
registrants
should
fund
surface
water
monitoring.

Schedule
 
Prioritize
pesticides
known
to
impair
or
threaten
water
quality
for
registration
review.
 
Support
grouping
of
pesticides
into
classes.
 
Oppose
review
scheduling
based
only
on
chronological
criteria.
 
Would
like
"
use
cluster"
assessments
for
urban
uses
 
would
help
prevent
problems
with
substitutes
for
cancelled
uses.
 
Pyrethroids
should
be
a
top
priority
for
review.

Public
Participation
 
Support
U.
S.
EPA
efforts
to
create
meaningful
opportunities
for
involvement
of
all
parties
in
registration
review.
 
Support
U.
S.
EPA
plan
for
early
stakeholder
involvement
and
use
of
electronic
dockets.
 
U.
S.
EPA
should
modify
the
proposed
procedures
to
ensure
that
public
participation
occurs
at
all
key
decision
points
in
the
process,
including
the
decision
as
to
whether
to
complete
an
environmental
risk
assessment,
the
draft
risk
assessment,
and
selection
of
risk
mitigation
options.
 
The
public
participation
process
needs
to
be
adjusted
to
provide
for
minimum
comment
periods
of
at
least
60
days
and
to
ensure
that
all
major
public
consultation
points
are
announced
in
the
Federal
Register.
 
U.
S.
EPA
should
provide
thoughtful
responses
to
public
comments.

Incorporating
Water
Quality
into
Risk
Assessments
 
All
pesticides
with
urban
uses
need
to
be
reviewed
for
surface
water
quality
impacts
from
urban
uses.
 
Entire
pesticide
products
need
to
be
evaluated
together
 
individual
ingredients
should
not
be
evaluated
separately.
 
Develop
water
quality
criteria
(
or
equivalent
non­
regulatory
values)
and
sediment
targets
during
registration/
re­
registration.
Use
these
values
to
determine
if
estimated
surface
water
concentrations
are
safe
 
Evaluate
sewer
discharges,
including
effects
on
sewage
sludge
(
which
may
be
reused).
3
Risk
Management
 
Procedures
to
address
alternatives
are
needed.
U.
S.
EPA
needs
a
process
to
address
alternatives
when
risk
management
measures
make
a
transition
to
another
pesticide
likely.
U.
S.
EPA
needs
to
ensure
that
alternatives
implemented
are
indeed
safer
for
human
health
and
the
environment.
For
example,
we
experienced
a
failure
with
diazinon
&
chlorpyrifos
 
the
market
transitioned
to
pyrethroids,
which
are
causing
new
water
quality
problems.
The
transition
to
pyrethroids
was
readily
foreseeable.
U.
S.
EPA
should
prevent
 
and
not
cause
 
such
environmental
and
compliance
problems.
 
Support
U.
S.
EPA's
stated
intent
to
phase
out
uses
in
a
more
timely
manner.
 
Procedures
to
address
phase­
outs
are
needed
(
particularly
to
prevent
dumping
of
unwanted
pesticides).
Procedures
should
be
developed
in
consultation
with
states
&
municipalities,
including
water
quality
agencies.
 
U.
S.
EPA
should
maximize
the
ability
of
the
pesticide
registration
review
process
to
prevent
potential
water
quality
problems
associated
with
pesticide
use.
The
risk
benefit
standards
of
FIFRA
require
U.
S.
EPA
to
ensure
that
a
pesticide
is
used
in
such
a
manner
that
mitigation
under
the
Clean
Water
Act
is
minimal
or
unnecessary.
Risk
management
should
be
implemented
for
all
exceedances
of
water
quality
criteria
(
or
equivalent
values
calculated
for
purpose
of
the
risk
assessment)
and
all
expected
incidents
of
non­
compliance
by
NPDES
permit
holders.

Costs
 
U.
S.
EPA
should
consider
costs
for
non­
compliance
with
Clean
Water
Act
requirements.
4
Procedural
Regulations
for
Registration
Review
October
7,
2005
EPA
Region
/
Other
Stakeholder
Participant
List
Agency/
Organization
Name
email
California
Association
of
Stormwater
Quality
Agencies
(
CASQA)
Geoff
Brosseau
geoff@
brosseau.
us
UP3
Project/
CASQA
Kelly
Moran
kmoran@
tdcenvironmental.
com
UP3
Project/
Association
of
Bay
Area
Governments
Laura
Speare
lspeare@
waterboards.
ca.
gov
City
of
San
Jose
Jim
Ervin
James.
ervin@
sanjoseca.
gov
Los
Angeles
County
Sanitation
District/
Tri­
TAC
Ann
Heil
Preeti
Ghuman
aheil@
lacsd.
org
PGhuman@
lacsd.
org
California
Department
of
Pesticide
Regulation
Nan
Singhasemanon
Marshall
Lee
nsinghasemanon@
cdpr.
ca.
gov
mlee@
cdpr.
ca.
gov
City
and
County
of
San
Francisco
Debbie
Raphael
debbie.
raphael@
sfgov.
org
California
Water
Resources
Control
Board
Patricia
Gouveia
pgouveia@
waterboards.
ca.
gov
California
Association
of
Sanitation
Agencies
Bobbie
Larson
blarson@
lawssd.
com
City
of
Sacramento/
CASQA
Bill
Busath
bbusath@
cityofsacramento.
org
EPA
Region
9
Ray
Chavira
Chavira.
raymond@
epa.
gov
5
Procedural
Regulations
for
Registration
Review
October
7,
2005
OPP
Participant
List
Name
Division
Email
Vivian
Prunier
Field
and
External
Affairs
Prunier.
Vivian@
epa.
gov
Jean
Frane
Field
and
External
Affairs
Frane.
Jean@
epa.
gov
Nathanael
Martin
Field
and
External
Affairs
Martin.
Nathanael@
epa.
gov
Kennan
Garvey
Special
Review
and
Reregistration
Garvey.
Kennan@
epa.
gov
Carol
Stangel
Special
Review
and
Reregistration
Stangel.
Carol@
epa.
gov
Kendra
Tyler
Special
Review
and
Reregistration
Tyler.
Kendra@
epa.
gov
Dana
Spatz
Environmental
Fate
and
Effects
Spatz.
Dana@
epa.
gov
Sid
Abel
Environmental
Fate
and
Effects
Abel.
Sid@
epa.
gov
Jennifer
Slotnick
Antimicrobials
Slotnick.
Jennifer@
epa.
gov
