AMVAC Environmental Products is addressing concerns and confusion that now exists due to the recent updates from EPA and resulting “proposed recommendations” regarding the aerial application of Naled formulations (e.g., Dibrom® Concentrate and Trumpet® EC).

The United States Environmental Protection Agency (EPA) released several Preliminary Risk Assessments for Naled in accordance with the Agency’s routine re-evaluation process, or ‘Registration Review’.

• This Registration Review program is required for all active ingredients by the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) and is designed to periodically evaluate registered chemicals to ensure they continue to meet current testing standards and do not pose unreasonable adverse effects to humans or the environment.
• Registration Review is a multi-step process that takes many years to fully complete, culminating with EPA’s Registration Review Final Decision.
• All pesticides registered before October 2007 must complete Registration Review by October 01, 2022.
• As the basic registrant of Naled, AMVAC Chemical Corporation will be fully supporting the Naled reregistration and has engaged experts in several scientific fields to prepare responses to the draft risk assessment.

AMVAC and AMCA have requested a meeting with EPA to address the publication of proposed recommendations prior to review of final comments on the risk assessment.

• AMVAC is working with AMCA and other stakeholders to submit comments on EPA’s assessments. The comment period closes November 24, 2020.
• EPA must consider all stakeholder comments posted to the docket during the comments period before publishing a Proposed Registration Review Decision (expected in 2021).
• AMVAC and stakeholders will then also have an opportunity to comment on the Proposed Decision before EPA renders its final Registration Review Decision (expected in 2022).
• During this evaluation process, products containing Naled (e.g., DIBROM® Concentrate, Trumpet® EC) remain in good standing with EPA and the commercial labels should be followed until any updates are published from EPA.

If you have any questions regarding this memo, please contact: Derek Wright, National Sales Manager – Public Health, 941-737-9883 DerekW@amvac.com.