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Special Local Need Registration
Requesting Special Local Need Registration
Special Local Need (SLN) requests may only be submitted by a pesticide’s registrant or manufacturer. However, registrants rely on the requestor to provide much of the required information. Therefore, the requestor should review and understand this information and incorporate as much data as possible in their request to the registrant. Doing so will increase the chances of the request being supported by the registrant and decrease the amount of time it takes to review and prepare the request.
Submit a cover letter that discusses, in detail, the events which brought about the “special local need” request. The discussion must include:
- A description of the pest problem.
- A list of the available pesticides (or active ingredients) currently registered for the use in question and the reasons why they will not adequately control the pest problem and/or they are not sufficiently available. In general, a price differential between products is not considered as justification to grant an SLN registration.
- Whether the pest problem is nationwide or localized (indicate if the proposed use has been requested or granted in other states).
- The estimated annual value of the SLN registration to users in Michigan should be included. The estimated annual value should include the expected cost savings and/or yield increase, and should be rounded to the nearest thousand dollars.
Letter of Support
A letter of support from at least one of the following sources is required:
- A Michigan State University (MSU) researcher, extension specialist or other unaffiliated expert who is capable of verifying the special local need, and has worked with (or is familiar with) the proposed use and the registered alternatives.
- An individual representing the commodity group, commission or association for the crop/site. In the absence of a commodity or user organization, individual letters of support from growers/applicators will suffice.
Federal SLN Application
All SLN request must include a signed and dated federal SLN application form (EPA form 8570-25). You can obtain this form electronically from EPA’s website.
An SLN registration must be accompanied by supporting data. Submit one (1) copy of field data, published articles, and other documents which support the request.
1) Residue Data
- If the request is for use on a food or feed crop, a federal tolerance or exemption from the requirement of a tolerance must exist. Cite the specific section in the Code of Federal Regulations (CFR) where the tolerance or exemption from tolerance can be found.
- Data showing that the proposed use will not result in crop residues exceeding the established tolerances must be submitted if the proposal involves any of the following:
- Increased application rate.
- Increased number of applications.
- Decreased interval between applications.
- Decreased pre-harvest interval.
- Certain changes in use pattern (i.e. a change from soil application to foliar application).
- Certain changes in formulation (i.e. addition of a sticker or extender to the formulation, or conversion to a slow-release formulation). Any SLN request involving a change in formulation that is submitted without supporting residue data must be accompanied with a detailed explanation of why residues would not be increased with the change.
- Residue data submitted in support of an SLN registration must be in conformance with applicable requirements in EPA’s Residue Chemistry Test Guidelines OPPTS 860.1000 Background and 860.1500 Crop Field Tests (http://www.epa.gov/opptsfrs/home/guidelin.htm). Note that the latter publication contains a section specifically devoted to SLN registrations.
- Residue data should always be generated under Good Laboratory Practices (GLP) as established under 40 CFR 160. A signed statement must accompany the data (1) indicating the study was performed under GLP, or (2) describing in detail all differences between the practices used in the study and those required under GLP with an explanation as to why this will not invalidate the data, or (3) indicating the requester did not conduct the study and does not know whether the study was conducted in accordance with GLP.
Residue data must be accompanied by the field and laboratory protocols and the procedures used to carry them out. If the data is also on file at the EPA, provide the appropriate reference number, such as the Master Record Identification (MRID) number.
2) Efficacy Data
The SLN registration request must be supported by efficacy data (comparative data when other registered pesticides are available for use). Efficacy data must be accompanied by the study protocol and the procedures used to carry it out.
SLN Label Requirements
1. Submit one copy of the current federally registered product labeling.
2. Submit one copy of the proposed SLN label.
Maintaining a Special Local Need Registration
A registrant may contact MDARD within three months of a 24(c) label expiration to request an extension of the label expiration date. In order to request an extension of the label expiration date, the registrant will need to submit new letters supporting the need for the registration and a label reflecting the updated expiration date.