EPA seeks public comment on proposal restricting insecticide
December 30, 2016
Innocent until proven guilty; safe until proven unsafe. That is how Joe Newland, Neodesha, Kan., farmer and Kansas Farm Bureau's third district board member, said he and other farmers view chlorpyrifos, an insecticide used on more than 50 types of crops in the U.S. and worldwide.
Chlorpyrifos is the subject of a proposal by the Environmental Protection Agency, which is seeking to remove all tolerance levels of the insecticide both in and out of the agricultural industry.
The EPA is seeking public comment until Jan. 17, 2017 on a Notice of Data Availability, which concerns a proposal that would restrict the use of all chlorpyrifos. The court has ordered the EPA to take any final actions regarding the proposal by March 31, 2017.
Will Moreland of Moreland Farms LLC in Medford, Okla., said chlorpyrifos need to be regulated, but didn't need to be completely restricted.
"The insecticides in question do most definitely need regulation, as they can be harmful to humans if not used correctly," Moreland said. "But when and if consumers use them correctly, they are a very effective insecticide group."
Moreland Farms uses the insecticide on about half of their acres each year, as chlorpyrifos are one of the most effective insecticides on the market.
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"Our biggest use (of chlorpyrifos) currently is on our wheat acres, where these insecticides do a very good job of controlling the mites and very small pests that wheat typically has issues with," Moreland said. "The other main insecticide group that we use, called pyrethroids, doesn't do much of a job at all to tackle those mites and aphids in wheat."
According to the EPA, more than 40,000 crop-producing farms use chlorpyrifos to control pests.
Farmers rely on chlorpyrifos because of its low cost, ease of use and a lack of alternatives to kill pests.
The EPA said there are other cost-effective alternatives available to farmers that target many of the same pests as chlorpyrifos.
Newland said a ban of the insecticide will lead to extra costs and less efficiency for everyone involved.
"It's kind of a lose-lose situation when they start taking safe chemicals away from us," Newland said.
According to the EPA, chlorpyrifos has been used as a pesticide since 1965 and corn is its largest market in terms of total pounds of active ingredient.
Newland said his farm uses the insecticide on 2,000 acres of corn.
"When we use a product that has been proven safe for a number of years, until it is proven unsafe by science, the EPA shouldn't be allowed to take something away from us," Newland said.
According to Newland, the ban will result in an increase in costs, not just for farmers and consumers, but also chemical companies as they will be forced to "reinvent the wheel" with new chemical research. He said he does not see any cost-benefits in fully restricting chlorpyrifos.
The EPA already has safety restrictions on the chemical, requiring workers who handle and apply chlorpyrifos to wear personal protective equipment because occupational exposure is a concern. The EPA also prohibits entry into treated fields from 24 hours to five days.
THE CURRENT PROPOSAL
The EPA's proposal to ban the use of chlorpyrifos came after a petition by the Natural Resources Defense Council and Pesticide Action Network North America in 2007 calling on the agency to restrict all tolerances of chlorpyrifos and cancel all registrations of the chemical.
The "rigorous scientific reassessments" done in a registration review process, a program that re-evaluates pesticides every 15 years, was completed on chlorpyrifos just before the petition was created.
Due to the petition, in 2007, the EPA initiated another review, a decade ahead of the 15-year-cycle schedule.
In 2010, just three years after the petition, the NRDC and PANNA sought a court order for the EPA to "promptly act on the petition." The court in 2015, and before the EPA had completed its scientific registration review, ordered the EPA to make a final decision on the possible restriction by the end of March 2017.
On Oct. 30, 2015, the EPA proposed to revoke all tolerances of chlorpyrifos. Because at that time the EPA had not yet completed its review, the agency said they were unable to make a safety finding. However, in November 2016, the EPA revised its chlorpyrifos human health risk assessment and drinking water exposure assessment.
According to the EPA, the revised analysis showed risks from residue that exceeded the levels considered safe through dietary exposure, such as chlorpyrifos in food crops and drinking water.
EPA SEEKS COMMENTS
The analysis did not change the EPA's proposal from October 2015, but is available for a 60-day comment period. The EPA said it plans to respond to all comments on the proposal before making a final decision by March 31, 2017.
Should the proposal go through, the rule would revoke all permitted uses of chlorpyrifos.
Newland said he has confidence the chemical is safe after it has been tested and retested for years and encourages not just farmers, but everyone, to reach out to their legislators and the EPA.
"Everybody has to be notifying their legislator to help push the EPA," Newland said. "And write a letter to the EPA themselves — when numbers of their American people speak — they need to listen when we put them in that position to help and we need to ask them for their help on this." ❖