NCC Seeks Malathion Comment Extension

The National Cotton Council, along with a number of cotton producer interest organizations and boll weevil eradication foundations, submitted comments to EPA on its “Draft Malathion Human Health Assessment” requesting the agency to extend the comment period an additional 60 days from the announced deadline of November 21, 2016.

Published: November 11, 2016
Updated: November 11, 2016

November 10, 2016

Office of Pesticide Programs
Regulatory Public Docket (7502P)
U.S. Environmental Protection Agency
1200 Pennsylvania Ave., NW Washington, DC 20460

RE:  Docket No. EPA-HQ-OPP-2009-0317

The National Cotton Council (NCC) and the undersigned cotton producer interest organizations appreciate the opportunity to review EPA’s “Draft Malathion Human Health Assessment” but respectfully requests a 60-day extension beyond the announced November 21, 2016 comment deadline.  Malathion has been and continues to be of vital interest to the cotton industry and more specifically the Federal public/private partnership that created the National Boll Weevil Eradication Program.  This 30/70 cost-share partnership has nearly completed the eradication of one of the most destructive, costly, invasive cotton pest known to the U.S. cotton industry.  An Ultra-low volume (ULV) formulation of malathion is the sole pesticide that has been used to eradicate the boll weevil across most of the cotton belt, and it is the only product that can be used to effectively complete the eradication in the remaining active zones.  Any action limiting the current labeled availability of ULV malathion does not simply jeopardize the completion of the program, but eliminates effective treatment for the boll weevil.  Such action will allow the second march of the weevil from Mexico across the cotton belt with massive destruction and few remaining suppression products.  The 37-year investment (mostly paid by producer assessments, but including federal investments appropriated by Congress and through USDA APHIS PPQ) will be rendered a loss with any action altering or limiting malathion use.  For this reason, we believe it is critical to carefully evaluate the EPA’s draft material to ensure sound science guides any decisions.

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.

It is our understanding that EPA is proposing to use a study based on chlorpyrifos chemistry to assert equal risk for malathion and all other organophosphates, and that this assertion is based on a questionable epidemiology study.  The NCC is concerned about how EPA has demonstrated equivalency in risk, and recognizes the need for more in depth study of EPA’s draft human health risk assessment before we can adequately provide our membership clear representation of the draft.  Additionally, EPA should provide the epidemiology study in the malathion docket, thus allowing stakeholders to understand the basis of the draft decision.  EPA should also provide the minutes of the SAP review of the study to provide understanding of how EPA applies the study to all organophosphates.

We urge EPA to recognize the enormous investment to date in eradicating the boll weevil from the U.S., and this progress has removed the boll weevil from 98 percent of the cotton production areas.  Similarly, the removal of the weevil has resulted in unforeseen reductions in required insecticide use, particularly early season applications.  The undersigned organizations respectfully request EPA to grant a 60-day comment period extension beyond the current November 21, 2016 comment deadline in order to allow careful evaluation of EPA’s draft assessment, prepare meaningful comments, and to allow EPA to post other highly relevant documents to the malathion docket.  Additionally, we ask EPA to ensure all relevant documents are provided in the docket related to the draft assessment of malathion.

Thank you for your consideration of this important request.




National Cotton Council

Agricultural Council of Arkansas

Arizona Cotton Growers Association

Arizona Research and Protection Council

Arkansas Boll Weevil Foundation

Arkansas Farm Bureau

Cotton and Grain Producers of the Lower Rio Grande Valley

Delta Council

Georgia Boll Weevil Foundation

Georgia Cotton Commission

Georgia Farm Bureau

LA. Department of Agriculture and Forestry

Mississippi Boll Weevil Management

North Carolina Cotton Producers Association

North Carolina Boll Weevil Foundation

New Mexico Boll Weevil Foundation

Plains Cotton Growers Inc.

Oklahoma Boll Weevil Foundation

Oklahoma Cotton Council

Rolling Plains Cotton Growers Association

Southern Rolling Plains Cotton Growers Association

South Texas Cotton and Grain Association

Southern Cotton Growers Inc.

Southeast Boll Weevil Foundation Board of Directors

Tennessee Boll Weevil Foundation

Texas Boll Weevil Foundation

Texas Farm Bureau