U.S. cotton and its agribusiness allies are partnering with EPA to address risk and policy-based issues.
To ensure continued availability of proven plant protection products, the National Cotton Council closely monitors EPA’s pesticide review process and provides input to the agency.
What is the status of EPA’s review procedures?
The safe protection of U.S. agricultural commodities from pests is dependent upon EPA regulation and registration procedures under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA). In the past, EPA’s Office of Pesticide Programs registered safe products for helping U.S. agriculture remain competitive. That office used a risk-benefit analysis process in compliance with FIFRA.
However, in the last several years, its regulatory process seems to have shifted toward a precautionary principle approach. By requiring additional needs justification, this approach has delayed, and in some cases, prevented new products from coming to the market. The result is a systematic elimination of access to proven chemistries. If cotton is kept on a pesticide label but with such onerous use restrictions that the product is impractical to use, then that product is lost as surely as if cotton had been removed from the label.
How is the NCC addressing this concern?
U.S. cotton and its agribusiness allies are partnering with EPA to address risk and policy-based issues as they arise. This requires the EPA to act in a transparent and cooperative manner and to adhere to FIFRA risk-benefit requirements. We believe this cooperative approach means U.S. cotton producers will continue to have access to many safe and environmentally friendly products.
What are some recent NCC actions in this arena?
Ahead of a July 24 deadline, the NCC submitted to EPA six sets of comments covering seven pesticides. Those comments can be accessed on the NCC’s website at www.cotton.org/issues/2017/pesrev.cfm. Filed under the EPA’s registration/review process were comments for aldicarb, ethephon and methoxyfenozide. The NCC pointed out issues with EPA’s analyses of the pesticides. For example, we emphasized the lack of alternatives for aldicarb — especially in fields with high nematode populations — but conveyed our appreciation to EPA for its proposed continued registration of that important product. Regarding ethephon, we stated there was no need to conduct pollinator studies because by the time this harvest aid is applied, few if any flowers remain on the plant as it shuts down and begins maturing its fruit load.
The other three sets of comments were filed for the neonicotinoids (neonics): clothianidin, imidacloprid, thiamethoxam and dinotefuran. The imidacloprid comments primarily addressed concerns with the water models that NCC believes EPA uses incorrectly to assess aquatic risk. Comments on the other three neonics focused on errors in EPA’s study of risks to bees and on providing the agency with the benefits that these products provide for efficient cotton production.
Specific to clothianidin and thiamethoxam, we pointed out 1) entomologists’ consensus that there are no acceptable alternatives to replace neonic use in the IPM and resistance management strategies for their states and 2) the loss of access to neonics will lead to additional reliance on older chemistries, multiple applications, and risks to flare up other pest populations. These scenarios could result in additional, costly control measures.
Gary Adams is president/CEO of the National Cotton Council of America. He and other NCC leaders contribute columns on this Cotton Farming page.