February 27, 2014

**MEMORANDUM UNITED**  **ST AT**  **ES ENVIRONMENTAL**  **PROTECTION AGENCY**  WASHINGTON D

. C

. , 20 4 6 0

O FFICE OF CHEMICAL SAFETY AND POLLUTION

PREVENTION

**SUBJECT:** FIFRA Scientific Advisory Panel (SAP) Wa iver Request for the Direct Final

Rule and the Notice of Proposed Rulemaking - "Labeling of Pesticide Products and Devices for Export" **FROM:** Laura 

### E. Bailey, Manager/Executive Secretary

FIFRA Scientific Advisory Panel (720 1 M) **TO :**  Steven Bradbury, Director

Office of Pesticide Program s (750 1 P )
The FIFRA SAP waives scientific review and comment on the proposed rulemaking entitled, "Regulation to Clarify Labeling of Pesticides Export", and the final rule entitled, "Labeling of Pesticide Products and Devices for Export; Clarification of Requirements." The revisions are adm inistrative in nature and do not contain scientific issues that require the SAP's consideration.
Attachment
cc: Brian Frazer/FEAD ( 7506P ) Martha Shim k i n/FEA D ( 7506P ) Kathryn Boyle/FEAD ( 7506P )UNITED S T ATES E N VI R O N M ENTAL P R OTECTION AGENCY WA S H INGTON, D.C. 20460

OFFICE OF CHEMICAL SAFETY AND POLLU T ION PREVENTION February 4, 2014 ME MO RAND UM SUBJECT: Requ e st to Waive the F IF RA Scientific Advisory Panel's Review of the Direct

Final Ru l e an d the Noti c e o f Proposed R u l emaking, both Entitled "L abeling of Pesti c ide Pro d u

cts and D ev ices for Export" FROM: Laura E
. Bailey , Execut i ve Secretary

FIFRA S c ient i fic Advis o ry Panel TO: Dani e l S c hlenk, Ph.D., C h a ir

FIFRA S c ientific Advis o ry Panel Attached is th e p r

oposed rulem aki ng e ntitled, " Regulatio n to Cl ari fy Labeling of Pesticides Export" an

d th e final rule entit l e d , " Labelin g of Pestici d e Products and Devi ces for Export; Clarification of Requirement s ." E PA is taking direct 

### f i nal rule action to r e

vise the regulations that pertain t

o labeling of p e

sti cide products and devices intended solely f or export. This action will allow p l acement of the re q uired inf ormation on collateral lab e ling attached to a shipping container of su c h products rat her than on the label of e a ch individual pro d uct in such a shipment. The FIFRA SAP p reviously waived its review of both rules because the rules are administrative in natu

re an d do not contain an y scientific issues that warrant review by the Panel. The purpose of the at

tac hed revised final rul e is to restore the eliminated " supplemental labeling" provision which was in a

d v ertently eliminated from the final rul e . The Agency requ

e s ts the FIFRA S A P wai v e re view of th e f i nal rule since it is administrative in nat ure an d does not conta i n scientific issues th a t r e quire the SAP's consideration. Please in di c ate your concurre n ce or non - concurr e n c e with this request and I will notify the Agency a c cord i n gl y. RECOMMEN DATIO N : The FI FRA Scientific Advisory Panel waives scientific review and comment on the final rule , "L abe · of estici e Products and Devices for Export ; Clarification o f Requirement s . "

Non
- Concur



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