Subject: APHIS Regs

From: Charles Benbrook <[email-masked]>
Date: 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 [email-masked]   I 
must admit a certain degree of skepticism regarding these concerns, but 
if someone knows different, please let me know.