Source: DOW AGROSCIENCES, 10/30/15

(EDITOR'S NOTE: Scroll down for additional background information on chlorpyrifos)

Today, the U.S. Environmental Protection Agency (EPA) announced it will open a public comment period on an proposal to revoke U.S. tolerances for the insecticide chlorpyrifos.  (See attachment or http://www2.epa.gov/ingredients-used-pesticide-products/proposal-revoke-chlorpyrifos-food-residue-tolerances, which also includes a pre-publication of the proposed rule.)  EPA will soon be seeking specific input from stakeholders.  We would be happy to visit with you about your submitting your position during the comment process.

This proposal is an outcome of a recent U.S. Ninth Circuit Court of Appeals order requiring EPA to respond, by October 31, 2015, to allegations about chlorpyrifos in a 2007 activist petition before the Agency has finished its formal health and safety evaluations of the product.  That is, EPA proposed to revoke the tolerances outside of the registration review process only after being ordered by the U.S. Court of Appeals for the Ninth Circuit to take final action on the petition by October 31.

Dow AgroSciences’ perspectives on this action is:
•         This EPA proposal to revoke U.S. chlorpyrifos tolerances is just that: a proposal, not a final regulatory action.  It has no current impact on existing uses of the product.
•         Dow AgroSciences disagrees with EPA’s proposal and remains confident that all U.S. tolerance issues relating to the continued use of chlorpyrifos can be readily resolved with a more refined analysis of data.
•         EPA has said that it will not decide whether or not to act on its proposal to revoke tolerances until it has received and responded to input from interested stakeholders, including growers who rely on chlorpyrifos-containing products to protect their crops and livelihood from destructive insect pests.  As written, EPA’s proposal would not affect the 2016 growing season.
•         Dow AgroSciences is committed to addressing the needs of its U.S. customers for continued access to chlorpyrifos by providing EPA with high quality scientific and regulatory support on a timely basis, as needed to resolve this situation.

I’ve included some additional background information on chlorpyrifos below.  Please don’t hesitate to let me know if you have any questions or need any additional information.  Thank you for your continued support.

Thanks again,
Megan

Megan J. Provost
State Government Affairs
Dow AgroSciences, LLC

Additional information on chlorpyrifos can be found at:  http://www.chlorpyrifos.com/news-and-resources/news/

Q&A on chlorpyrifos:
What is chlorpyrifos?
Chlorpyrifos is one of the most widely used pest control products in the world.  It is authorized for use in about 100 nations – including the U.S., Canada, the United Kingdom, Spain, France, Italy, Japan, Australia and New Zealand – where it is registered for protection of essentially every crop now under cultivation.  No other pesticide has been more thoroughly tested.

Has chlorpyrifos been tested in terms of health and safety?
Yes.  Labeled uses of chlorpyrifos rest on five decades of experience in use, health surveillance of manufacturing workers and applicators, and more than 4,000 studies and reports examining the product in terms of health, safety and the environment.  No pest control product has been more thoroughly evaluated.

Can chlorpyrifos products still be used in the U.S.?
Yes.  Products containing chlorpyrifos may still be sold and used in the U.S. according to the current labels. U.S. food tolerances for chlorpyrifos are still in effect, and no currently authorized uses are affected by this EPA proposal.

Why is EPA proposing to revoke U.S. chlorpyrifos tolerances?
In August 2015, the U.S. Ninth Circuit Court of Appeals ordered EPA to respond, by October 31, 2015, to a 2007 activist petition calling for regulatory action against chlorpyrifos based on alleged health concerns.  Since the petition was filed, EPA has issued periodic updates denying most of the elements of the petition and, as late as March 2015, the Agency indicated that, once it had completed its formal health and safety evaluations of chlorpyrifos for product reregistration, it expected to deny the activist petition in its entirety.  Because EPA has now been ordered by the Court to respond to the petition before the Agency’s evaluations of chlorpyrifos have been completed, however, the Agency has not yet refined certain hypothetical modeling-based projections of residues in drinking water that are driving this regulatory proposal to revoke tolerances. Dow AgroSciences remains confident that all U.S. tolerance issues relating to the continued use of chlorpyrifos can be readily resolved with a more refined analysis.

Why are projections of chlorpyrifos residues in drinking water driving EPA’s current proposal to revoke the product’s U.S. tolerances?
EPA’s projections of chlorpyrifos residues in drinking water are based on highly conservative unrefined, screening-level mathematical modeling inconsistent with extensive real-world monitoring  demonstrating that residues in water are well below highly conservative regulatory standards for the protection of health and safety.  Dow AgroSciences remains confident that all U.S. tolerance issues relating to the continued use of chlorpyrifos can be readily resolved with a more refined analysis of data.

When will EPA decide whether or not to revoke chlorpyrifos tolerances?
EPA has said that it will decide whether or not to act on its proposal to revoke tolerances only after soliciting, evaluating and responding to input from interested stakeholders, including growers who rely on chlorpyrifos-containing products to protect their crops and livelihood from destructive insect pests.  As written, EPA’s proposal and the regulatory process that follows would not affect the 2016 growing season.

Why Growers Need Chlorpyrifos
Growers and grower group representatives willing to discuss why they need continued access to chlorpyrifos in their operations are available for interview by arrangement.

“Along with other crops, I farm about 600 acres of cotton each year. Year to year, I don’t know which bug is going to pop up, and for some of those bugs chlorpyrifos is the best choice – and, under some conditions, the only choice for truly effective control. Last year, we had a huge aphid infestation, and chlorpyrifos was an important part of the solution. Aphids excrete sugars that make cotton fibers sticky so that when the lint goes to the yarn mill it gums up the machines. Buyers don’t want sticky cotton. Some might accept it, at a significant discount. But next year when the prime cotton buyers are buying, they may not be coming back to you. White fly is another problem, one we have every year, and we sometimes need to use chlorpyrifos with other products to get control of the situation quickly. Without chlorpyrifos, I would be using less effective materials and risking having to spray more often. I’ve used chlorpyrifos for years, and I need it in my toolbox.” – Mark Watte, California grower.

"I've been farming since the mid-1970's, and one thing I know for sure is that there's a mealybug for almost everything.  With grapes, mealybugs leave a sticky residue that can make them unsellable.  They're not good for table grapes because the residue won't come off. And they're not good for juice or wine,  because the residue will turn the juice rancid. And if you pick those grapes, the mealybugs get on your clothes and shoes, and you'll spread those insects to other grapes and you may even get them around your home infesting your plants.  Chlorpyrifos is one of the few materials left to us that we rely on for effective control.  We know chlorpyrifos is restricted and we treat it with respect. If we didn't have chlorpyrifos , we'd be using more frequent sprays of less-effective material, and more fuel and other farm inputs, none of which would be good for the environment." – Dennis McFarlin, California grower.