The National Cotton Council works to ensure cotton producers can operate in a regulatory environment based on sound science and common sense — and one that includes the availability of safe and effective crop protection products.
Are there chemicals facing scrutiny?
The NCC recently submitted comments on the Environmental Protection Agency’s registration review of specific sulfonylurea chemicals in herbicides important to cotton production. Thifensulfuron-methyl, tribenuron-methyl and rimsulfuron are used in pre-plant burndown herbicides, and trifloxysulfuron-sodium is a post-emergent. The NCC urged EPA to consider in its review these chemicals’ weed resistance management benefits. We emphasized producers’ need for multiple herbicides with different modes of action so they can continue rotating or combining MOAs. Late last year, the NCC and producer interest organizations also provided comments to USDA in support of a deregulation decision regarding Dow AgroSciences’ genetically engineered cotton that is resistant to 2,4-D and glufosinate.
There are several organophosphate pesticides under EPA review. NCC-submitted comments urged the agency to recognize the benefits of the insecticides dicrotophos (Bidrin) and dimethoate. These provide producers with an alternate chemistry to incorporate into their integrated pest management and resistance management programs targeting such pests as cotton fleahoppers, fleabeetles, stinkbugs and thrips. Comments also were submitted on tribufos, the active ingredient in DEF/Folex, a defoliation tool that has been critical in protecting lint from staining and excess trash.
The NCC also submitted comments on EPA’s proposal to revoke the tolerances for chlorpyrifos after EPA was ordered by the Ninth Circuit Court of Appeals to decide whether to place an effective ban on its agricultural uses by the end of 2016. We explained how chlorpyrifos is used to prevent yield and quality losses by controlling aphids, lygus and whiteflies, which can contaminate lint with a sticky secretion that interferes with textile processing. We urged EPA to consider all studies submitted on this insecticide and to continue on its historic path of reliance on credible data.
Any other products threatened?
n The Ninth Circuit Court of Appeals also issued a verdict to vacate EPA’s unconditional registration of sulfoxaflor, used to control aphids and other insects, and remanded the registration to the EPA to obtain further studies and data regarding that insecticide’s effects on bees. Among NCC-conveyed concerns was that the court’s judgment potentially set a precedent jeopardizing crop protection products’ overall availability. The NCC also reviewed EPA’s preliminary pollinator risk assessment for imidacloprid and provided comments in support of this neonicotinoid insecticide that is being studied this year for its impact on honey beehive health.
Last year, the NCC asked EPA to consider scientific evidence for retaining flubendiamide’s registration — as it (Belt) provides highly effective control of such pests as bollworms and armyworms without flaring mite outbreaks. Last month, though, EPA announced its intention to cancel all remaining flubendiamide products resulting in Bayer CropScience seeking an administrative hearing to review the product’s safety data.
These are just a few examples of ongoing cancellation threats and why the NCC will continue to intercede when necessary so product availability is not compromised.
Gary Adams is president/chief executive officer of the National Cotton Council of America. He and other NCC leaders contribute columns on this Cotton Farming magazine page.