AHPA works with EPA and IR-4 Project to improve pesticide policy

Member feedback sought on herbal crop group pesticide priorities, inadvertent residue data

December 10, 2021

The U.S. Environmental Protection Agency (EPA) issued a final rule on November 6, 2020, revising its regulations by adding new Crop Groups 25 (“Herbs”) and 26 (“Spices”). A quantitative tolerance must now be established for any individual pesticide to be applied to commodities in either of these new crop groups, which will also affect regulatory control of pesticide residues, including those present due to inadvertent environmental exposures. At present, EPA has received petitions for only three pesticides, picarbutrazox, trifloxystrobin and fluopyram, that include the new crop groups.

Tolerance priorities input requested for CGs 25 and 26
Working to expedite the tolerance-setting process, AHPA plans to collaborate with the IR-4 Project, a research group created by the United States Department of Agriculture that is the primary organization developing new crop group tolerance petitions. IR-4 staff work with stakeholders and researchers to develop and conduct residue studies with the representative commodities for each crop group, using the resulting data to petition EPA for the approval of new pesticide-specific tolerances.

An essential step in this process is to identify pesticides that are priorities for establishing tolerances for the two new crop groups. Please contact Robert Marriott, AHPA's Director of Regulatory Affairs, at with information about specific pesticides that may be applied to or found on any of the commodities included in new Crop Groups 25 and 26.

Data needed to support broader EPA discussions
In a related matter, AHPA also continues its discussions with EPA to address the need for pragmatic policies for regulating pesticide residues present due to inadvertent environmental factors (and not intentional, direct application), including policies that account for the limited human exposure that occurs in low-intake consumer products such as herbal teas and supplements. If you would like to provide specific data or information on inadvertent pesticide residues found in herbal samples inspected during pre-purchase due diligence procedures, please contact AHPA General Counsel Will Woodlee at to discuss providing such data in strict confidentiality.




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