Dear Misters Bongard and Savage,
Thank you for the opportunity to comment on the U.S. Environmental Protection Agency (hereafter the EPA) White Paper Describing Benefits of Structured and Digital Content Labels for Pesticide Products (EPA-HQ-OPP-2023-0562).
The Weed Science Society of America (WSSA), along with the Aquatic Plant Management Society (APMS), North Central Weed Science Society (NCWSS), Northeastern Weed Science Society (NEWSS), Southern Weed Science Society (SWSS) and Western Society of Weed Science (WSWS) (hereafter “Weed Science Societies”) represent over 3000 weed scientists from around the world. Members include academic, governmental, and private industry research scientists, university, extension professionals, educators, land managers, and crop consultants.
The Weed Science Societies respect the challenges the agency faces under the current registration and re-registration environment. Ample non-scientific court decisions coupled with the loss of personnel is a monumental task to overcome, but one that can be addressed through partnering with science-based organizations such as the WSSA. The Weed Science Societies are committed to working with EPA to 1) generate dependable, accurate, and usable science-based data, thereby improving the regulatory process and 2) provide a direct connection to research and extension experts working with herbicides across environments in real-world situations. Furthermore, the WSSA is requesting the agency consider the many benefits of developing WSSA-EPA working groups to cooperatively and more effectively address the Endangered Species Act.