Extension Sought On Pesticides Registration Review
The NCC submitted a 60-day extension request for more time to review EPA’s pesticide registration review of draft human health and ecological risk assessments for sulfonylureas and other pesticides -- including organophosphates. The request highlighted seven specific chemicals used in crop protection products that are of significant importance to the cotton industry.
November 10, 2015
Environmental Protection Agency Docket Center (EPA/DC), (28221T)
1200 Pennsylvania Ave. NW
Washington, DC 20460-0001
Mr. Richard Dumas, Pesticide Re-Evaluation Division (7508P)
Office of Pesticide Programs
Environmental Protection Agency
1200 Pennsylvania Ave. NW,
Washington, DC 20460–0001
Re: Docket ID No. EPA–HQ–OPP–2015–0386. Pesticide Registration Review; Draft Human Health and Ecological Risk Assessments for Sulfonylureas and Certain Other Pesticides; Notice of Availability and Request for Comment, September 25, 2015
Dear Mr. Dumas:
In response to the Environmental Protection Agency's September 25, 2015 Federal Register notice opening a public comment period on EPA's draft human health and ecological risk assessments for the registration review of a group of pesticides known as sulfonylureas and other identified chemicals, the National Cotton Council (NCC) is requesting a 60-day extension of the comment period.
The NCC is the central organization of the United States cotton industry. Its members include producers, ginners, cottonseed processors and merchandizers, merchants, cooperatives, warehousers and textile manufacturers. A majority of the industry is concentrated in 17 cotton-producing states stretching from Virginia to California. The NCC represents producers who cultivate between 10 and 14 million acres of cotton. Annual cotton production, averaging approximately 16 to 20 million 480-lb bales, is valued at more than $5 billion at the farm gate. The downstream manufacturers of cotton apparel and home furnishings are located in virtually every state. Farms and businesses directly involved in the production, distribution and processing of cotton employ more than 230,000 workers and produce direct business revenue of more than $27 billion. Accounting for the ripple effect of cotton through the broader economy, direct and indirect employment surpasses 420,000 workers with economic activity well in excess of $120 billion. In addition to the cotton fiber, cottonseed products are used for livestock feed, and cottonseed oil is used as an ingredient in food products as well as being a premium cooking oil.
While NCC appreciates the 60-day comment period provided to review and comment on these risk assessments, we respectfully request an additional 60-days to further review the notice, analyze the potential impacts, and development the necessary comments.
The following chemicals, which are referenced in this notice, are used in products that have a significant impact on the cotton industry:
Chlorpyrifos-methyl – Some formulations of Chlorpyrifos are used in cotton and are critical to California and Arizona for the control of aphids (aphids secrete honey dew that causes sticky cotton). Although the chlorpyrifos-methyl may not be specific for cotton, it may set precedent for other chlorpyrifos formulations.
Dicrotophs – This active ingredient is critical to cotton production for protection against damaging pests such as stinkbugs and plant bugs.
Dimethoate – This chemical is an insecticide that provides an alternate mode of action for control of thrips.
Tribufos – This chemical is critical to cotton defoliation, which is necessary for proper harvest preparation and management.
Trifensulfuron-methyl – Some use to prepare weed-free planting conditions.
Tribenuron-methyl and Trifloxysulfuron-sodium – Recent years have shown an elevated importance of these products for weed control making them of critical importance to weed management programs for cotton.
Methoxyfenozide – This active ingredient is an extremely important tool for the management of some caterpillar pests of cotton.
As you can see from the above, this notice contains a considerable number of chemicals undergoing risk assessment with each requiring the evaluation of a substantial amount of information in order to best prepare thorough and thoughtful comments.
NCC appreciates the opportunity to provide comments concerning these chemicals so important to the U.S. cotton industry and looks forward to providing additional comments at a later date. Thank you for your consideration of this request for a comment period extension. Please do not hesitate to contact us with any questions or concerns.
VP – Washington Operations
National Cotton Council of America