The proposed changes to rule 205 helps decrease already existing conflicts. The current rule is
more restrictive than the standards of nearby states (Ohio, Indiana, and Illinois) as well as the
Federal Seed Act. The proposed rule brings Michigan closer to their less-restrictive standards. It
also brings Michigan directly in line with South Dakota, a large producer of small grains. The
proposed changes do not conflict with AOSCA standards.
The proposed changes to rules 214 and 215 present no conflicts. The Michigan Crop Improvement
Association (MCIA) brought the need for the proposed changes to the attention of the Pesticide
and Plan Pest Management Division. The standards have already been adopted by the national
Association of Official Seed Certification Agencies (AOSCA) and the Federal Seed Act, as well as
by Iowa Crop Improvement, a close cooperator of MCIA and of the companies growing
foundation inbred corn in Michigan. Some seed companies, including those operating in
Michigan, have produced locations in multiple states and sometimes countries. With multi-state
and international domains, it is beneficial to have consistent standards to facilitate marketing.
10. Is the subject matter of the rules currently contained in any guideline, handbook, manual,
instructional bulletin, form with instructions, or operational memoranda?
The subject matter of these rules is contained in several internal documents possessed by the
Michigan Crop Improvement Association (MCIA), the official seed certification agency in
Michigan, per MCL 286.73 and Rule 101. These include the MCIA Grower Handbook, Lab
Quality Manual, and MCIA Inspector Training Handbook. No MDARD documents reference the
subject matter of these rules.
11. Are the rules listed on the department’s annual regulatory plan as rules to be processed
for the current year?
12. Will the proposed rules be promulgated under Section 44 of the Administrative Procedures
Act, 1969 PA 306, MCL 24.244, or under the full rulemaking process?
13. Please describe the extent to which the rules exceed similar regulations, compliance
requirements, or other standards adopted at the state, regional, or federal level.
The proposed changes to rule 205 bring Michigan closer to other state’s less restrictive standard.
The current rule is more restrictive than the standards of nearby states (Ohio, Indiana, and Illinois)
as well as the Federal Seed Act. It also brings Michigan directly in line with South Dakota, a large
producer of small grains.
The proposed changes to rules 214 and 215 align with similar regulations and standards across the
country and at the federal level. The proposed changes are more restrictive than the standards of
nearby states (Ohio, Indiana, and Illinois) and the Federal Seed Act, but they are less restrictive
than the existing rule.
14. Do the rules incorporate the recommendations received from the public regarding any
complaints or comments regarding the rules? If yes, please explain.
15. If amending an existing rule set, please provide the date of the last evaluation of the rules
and the degree, if any, to which technology, economic conditions, or other factors have changed
the regulatory activity covered by the rules since the last evaluation.