APHIS Regs
Charles Benbrook (benbrook@hillnet.com)
Wed, 8 Mar 1995 23:14:23 -0800 (PST)
I had a chance to discuss tyhe APHIS regs with a senior USDA official
tonight who has not been directly involved but is aware of the growing
concern about them. Apparently the regs evolved within USDA/APHIS as
many do -- without a lot of discussion with people outside the dept. with
a sense of what the needs are and actual implications of the proposals
being made. His sense is that the regs need to be slowed down and fixed
during the public comment period, so people who are concerned should get
a copy, via ftp as directed by a post the other day, read them, ask your
supplier or any local suppliers how they think the regs might affect
their ability to make beneficial insects available to local farmers. The
rulemaking process is very regimented. USDA is bound by law to respond
to comments received, problems noted. The key challenge is to offer
constructive, practical suggestions re how the regs can be changed to
avoid onerous and costly burdens on a small, growing and important
industry, while still serving the vital public interest which motivated
them. Any ideas on this front? Who is going to do comments?
Some people have raised concerns/allegations that the regs are a
result of pesticide industry efforts to shut down competitors. This is a
serious charge and if true, would cast a pale over the process. I am
working on a report on pest management policy for the Consumers Union
which, among other things, assesses a range of USDA policies and their
impact on pest management options. The APHIS regs will be addressed. If
anyone has any evidence or examples of how undue influence has been
brought to bear on the process I would like to hear about it or be told
how I might find out about it. E-mail me at benbrook@hillnet.com I
must admit a certain degree of skepticism regarding these concerns, but
if someone knows different, please let me know.