As part of the ongoing reregistration process for all pesticide products in the United States, and in this case for the herbicide glyphosate specifically, NALP submitted comments on EPA’s recently released draft biological evaluation report. In our comments, we articulated our concern that the assumptions used by EPA in deriving their conclusions do not comport to how this herbicide is actually used in practice. For instance, EPA assumes that whenever glyphosate is used, it is applied as a blanket application to all possible acreage and at the highest possible label rate. NALP countered that glyphosate is rarely applied as a banket spray and is most often used to selectively remove unwanted vegetation from a site. Absent our commentary on uses, EPA would have no way of knowing how these products are utilized by professional applicators.
