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Source: GROWINGMATTERS.ORG
Neonicotinoids are currently undergoing registration review, an extensive scientific process that the EPA conducts on all registered pesticides every 15 years, to ensure they meet the latest scientific standards. EPA is now seeking public comments on the current neonicotinoid risk assessments. Introduced in the mid-1990s, neonicotinoid insecticides have become one of the most important tools used in agriculture and the largest selling insecticide class in the world.
A comprehensive, 16-report study by AgInfomatics, released in 2014 and 2015, showed neonicotinoid insecticides increase crop yields, add billions of dollars to the economy and benefit entire communities, not just farmers. Because EPA receives many comments from environmental groups about restricting neonics, it’s important for the Agency to hear from people who actually use these products Some key facts about benefits of neonicotinoids: Scientific evidence clearly shows that bees and other pollinators can coexist with commercial applications of neonicotinoid insecticides, when used according to label. If neonicotinoids were not available, growers would incur a projected net-cost increase of nearly $850 million per year. The loss of neonics would result in higher costs, reduced yields and more frequent sprays – all a serious setback to IPM and resistance-management programs. Neonicotinoid insecticide use leads to average yield increases, ranging from 3.6 percent to 71.3 percent in eight major crops in North America.
Some key facts about risk assessments: Human Health – No issues or concerns identified.
• Environmental – EPA conducted screening-level (highly conservative) assessments that are worst-case and not representative of real-world risks. No real-world negative impacts observed over many years of widespread use of neonics.
• Unreasonable assumptions, such as 100% of diet is a single feed item contaminated with highest residues: e.g., a bird/mammal eats treated seed, with maximum neonicotinoid loading, every day over its entire lifetime.
• High exposure is assumed, despite the fact that modern planter equipment minimizes seeds remaining above ground that could be available for feeding.
• No issues for fish/amphibians, and aquatic and terrestrial plants.
• While the EPA has indicated there are potential risks to aquatic insects, this is based on theoretical water concentrations derived from highly conservative models, which do not reflect real-world water concentrations or the protective effects of current label use restrictions. Risk decisions should not be based on highly conservative risk assessments. Further refinement is necessary to better represent the real-world situations and benefits of these products. Sensible mitigation can then be applied, where needed.
As an association leader, consultant and/or grower, you have valuable information that will help EPA understand the importance of neonicotinoids to your operation.
= How many acres do you farm? Where is the farm located? What kinds of crops do you grow?
= How do you use these products: seed treatment, foliar application and/or soil application?
= Why do you use these insecticides? How do they benefit your farming operation?
= If these products were no longer available for use, what effect would that have on how you farm: What other products would you need to use? Would you need to change from seed treatment/soil applications to foliar sprays? Would you need to spray more often, etc.?
= Consider closing with: “We know these are preliminary risk assessments. We trust EPA will refine, as necessary, based on sound science and field data and think through IPM and resistance management requirements.”
The research reports, along with news releases, fact sheets, infographics and videos, are available at GrowingMatters.org.
To post a public comment, respond by February 20.
Active Ingredient (a.i.) & Docket Number
Imidacloprid EPA-HQ-OPP-2008-0844
Planned Completion -2018
Open Dockets for Comment (Closing on February 20, 2018) Transmittal of the Preliminary Terrestrial Risk Assessment to Support the Registration Review Benefits of Neonicotinoid Insecticide Use in the Pre-Bloom and Bloom Periods of Cotton (All Neonics) Benefits of Neonicotinoid Insecticide Use in the Pre-Bloom and Bloom Periods of Citrus (All Neonics)
Active Ingredient (a.i.) & Docket Number
Clothianidin EPA-HQ-OPP-2011-0865
Thiamethoxam EPA-HQ-OPP-2011-0581
Dinotefuran EPA-HQ-OPP-2011-0920
Planned Completion -2018
Open Dockets for Comment (Closing on February 20, 2018) Occupational and Residential Exposure Assessment for Registration Review.Drinking Water Exposure Assessment for Registration Review of All Registered Uses Draft Human Health Risk Assessment in Support of Registration Review. Acute and Chronic Aggregate Dietary (Food and Drinking Water) Exposure and Risk Assessments for Registration ReviewTransmittal of the Preliminary Aquatic and Non-Pollinator Terrestrial Risk Assessment to Support Registration Review
Registration review includes the following neonic brands:
= Imidacloprid – Bayer’s Admire® Pro, Gaucho® (600, XT), Leverage360, Velum® Total.
= Clothianidin – Bayer’s Poncho®, Poncho®/VOTiVO, Poncho® Beta, Prosper® EverGol®, Sepresto 75WS, Emesto Quantum. Valent’s NipsIt INSIDE®, NipsIt® Suite, INOVATE®, INTEGO®, Belay® Insecticide.
= Thiamethoxam – Syngenta’s Actara®, Platinum®, Cruiser® FS, CruiserMaxx®.
= Dinotefuran – Valent’s Venom® Insecticide.
Comment Instructions:
1. Please post comments on each a.i. (can be the same comments) by clicking on the correlating docket number in the chart above, i.e. EPA-HQ-OPP-20__-____.
2. This takes you to the individual a.i. registration review page (shown below). Then click on the dark-blue box, “Comment Now!”
3. The next screen shows: “You are commenting on.” Enter comments in box – 5,000 character limit. You have the option of uploading files. When finished, press “Continue” button on bottom right.
4. Next, you can preview and edit comments. You must check the box, “I read and understand the statement above,” before you can click “Submit comment.”
5. The next page provides a receipt number to verify your comments have been received by EPA.
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