The IWG is a coalition of farmers, farm and food groups, pest management and manufacturing organizations. Yes, the IWG fully supports the fundamental goals of the law, particularly the special emphasis on protecting children and the establishment of a uniform public health standard. The law should be implemented in a balanced way to avoid serious negative effects on pest management and production of food and fiber in the United States, with subsequent adverse impacts on the health and well-being of the American public. In this way, EPA can achieve the FQPA goals and avoid serious negative effects on pest management and agricultural production in the United States. However, based on decisions EPA has made to date under FQPA, many safe pest management products essential to the protection of public health and agricultural production may be in unnecessary jeopardy.
Sound science means the use of reliable data produced by studies using validated methods.
Transparency describes a regulatory process and policy development that are open to public scrutiny, invite and encourage participation by interested stakeholders and the informed public, and follow due process. Balance means appropriate concern for both risks and benefits, and proper allocation of government resources among competing priorities in the EPA Office of Pesticide Programs. Workability means administering the FQPA in a practical, realistic way from scientific, political, regulatory, agricultural, environmental and public health perspectives. The IWG urges that, after thorough review, analysis and full public discussion, EPA and USDA adopt the recommendations proposed in the Framework. Use sound science and reliable information, as intended by Congress, in fulfilling the FQPA mandate to protect public health from unacceptable risk of exposure to pesticides.