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Stakeholder action- emergency petition to suspend clothianidin
Story Date: 8/29/2012
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Source: Allen Scarborough, Ph.D., Stakeholder Relations Manager, BAYER CROP SCIENCE, 8/23/12
I am sending this request to you as again there is an opportunity for agriculture to provide meaningful comments to EPA in support of the registration for the insecticide clothianidin. This product is the active ingredient in Bayer’s important seed treatments Poncho, Poncho Beta, and Poncho VOTiVO. Comments should be submitted by September 25.
The comments are being sought by the EPA in response to a petition filed with the agency by activists and a few beekeepers to cancel the product. The EPA has denied the petition as it did in response to one filed previously; however, it is important for the end user, agribusiness community, and others to provide the Agency information on the importance and benefits of these seed treatment products while the process continues.
The formal request from Bayer to the stakeholder community includes background information and instructions, and is included in this message (below.) Please also pass to other colleagues/members who can submit comments. Well-informed original comments are very important and will contrast with the large number of negative and inaccurate comments the agency receives from those opposed to the neonicotinoid family of chemistry including these specific products.
Emergency Petition to Suspend: Clothianidin
Dear Stakeholder:
This note is to request help from experts, commodity organizations and other stakeholders who are:
· Familiar with the benefits clothianidin offers growers in the United States;
· And/or understand the benefits of a regulatory process built on sound science;
· Willing to speak up by September 25th, 2012
BACKGROUND
The EPA received a petition filed by several non-governmental organizations and beekeepers on March 20th, 2012, to immediately suspend clothianidin and to take other actions affecting its registration. On July 19th, 2012, the EPA announced their decision to deny the suspension request, and invited the public to comment on the petition, including their decision.
ACTION REQUESTED:
In order to assist EPA in drawing a balanced opinion regarding the petition, it is important for them to receive credible feedback from those in agriculture who understand the role that pesticides, in particular clothianidin, play in agriculture and to your business. So far, most of over 500 comments already posted to EPA’s docket, although providing little substantive information, are urging the suspension of clothianidin and related neonicotinoid pesticides. Therefore, it is imperative that stakeholders who know the benefits of products based upon this chemistry[1] provide feedback to the docket in order that your voice is also heard.PROCESS FOR STAKEHOLDER COMMENTS
· To access the docket where comments are filed, connect via the Federal eRulemaking Portal: http://www.regulations.gov/. Enter in the following Docket ID number: EPA-HQ-OPP-2012-0344, then follow the on-line instructions for submitting comments[2].
· Clothianidin has many use patterns, and the benefits of its use vary by crop. Comments that are made based on the writer’s own experience, and in his/her own words, are important to the EPA. Some thought stimulators are outlined below to aid you in capturing your messages; however, please feel free to construct your own messages as you see fit.
General topics
* The EPA has a Registration Review process, which is designed to address potential human health and environmental risks. This process is already underway for clothianidin and other neonicotinoid insecticides.
* Growers need these tools to control pests in their crops.
* Encourage continued focus on developing best management practices, practical labeling and continued bee research for managing pollinator safety.
Specific to clothianidin
* Clothianidin registration is an important tool for controlling [crop/pest]
* There are insufficient alternative registered insecticides that are effective and registered for the crop/pest(s)
* Clothianidin plays a significant part in managing pest resistance,
* Important Integrated Pest Management tool – e.g., softer on beneficial insects than many alternatives,
* As a seed treatment, its use reduces the total number of insecticide sprays in the crop - decreases number of passes over the field, reducing fossil fuel use and emissions
* Improves growers’ return, and prevents crop/financial losses through increasing and protecting yield
· By way of example, this link takes you to an example letter in the docket from the Florida Department of Agriculture & Consumer Services:
http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OPP-2012-0334-0056
IMPORTANT: Comments on the petition to suspend Clothianidin registration must be posted to the docket, or mailed to the EPA, by September 25th, 2012!
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