NCC Submits Thidiazuron Comments

The NCC submitted comments to EPA on June 20, '16 on the agency's proposed interim decision for registration of the defoliant Thidiazuron and urged EPA to ensure the risk assessment reflects real world scenarios rather than overstating the presence of pollinators in a precautionary manner.

Published: June 24, 2016
Updated: June 24, 2016

June 20, 2016

Office of Pesticide Programs
Regulatory Public Docket (7502P)
U.S. Environmental Protection Agency
One Potomac Yard (South Building)
2777 S. Crystal Drive
Arlington, VA 22202

RE: Thidiazuron; Registration Review Proposed Interim Decision; EPA-HQ-OPP-2015-0381

The National Cotton Council (NCC) appreciates the opportunity to comment on EPA’s Proposed Interim Decision for registration of thidiazuron.  The NCC supports the registration of this important cotton harvest aid product, and believes the EPA’s overly conservative review demonstrates that this product used according to label instructions poses no human health or environmental risks.  The NCC recognizes EPA is proposing this interim decision with stipulations for additional studies, particularly pollinator studies.  The NCC is concerned that the EPA continues to erroneously assume pollinator presence in cotton, even at this plant stage of harvest preparation.  The NCC respectfully urges EPA to insure the risk assessment reflects real world scenarios rather than overstating the presence of pollinators in a precautionary manner.

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 9 and 12 million acres of cotton.  Annual cotton production, averaging approximately 12 to 18 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 125,000 workers and produce direct business revenue of more than $21 billion.  Accounting for the ripple effect of cotton through the broader economy, direct and indirect employment surpasses 375,000 workers with economic activity well in excess of $75 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.

Thidiazuron continues to be an important harvest aid product for the defoliation of cotton plants.  Most university cotton defoliation experts claim thidiazuron to be a foundational product in their state defoliation recommendations. Harvest aid program are complex and one product alone generally will not provide the desired results.  Effective harvest aid programs often are designed to defoliate leaves, open bolls, and inhibit regrowth.  Proper leaf defoliation reduces staining of lint as well as reducing potential leaf trash/debris that reduces quality and grade.  Harvest aid programs are not designed to kill the plant.  To be effective they require the plant to be active.  Plant activity at the time harvest aid programs are implemented can vary greatly from year to year and field to field in the same year.  Having a good feel for the status of the plant is critical toward developing a successful program.  The bottom line in a harvest aid program is to enhance and synchronize the natural process of leaves falling from the plant and the bolls opening to facilitate a one-time harvest thus preserving yield and fiber quality.

Thidiazuron possesses strengths that set it apart from other products.  For example, leaves drop green – one part of a program to preserve fiber quality without leaf trash or stain in lint.  Additionally, thidiazuron is very effective in removing juvenile leaves.  Thidiazuron inhibits both terminal and basal regrowth.  This is particularly important when weather events or other factors delay harvest beyond expectation.  Without the regrowth inhibition, producers are forced to make subsequent applications of other products in order to address regrowth prior to harvesting.  Most harvest management programs require a combination of products.  The strengths of thidiazuron make it a great tank mix partner with other products that excel in areas where thidiazuron is weak. 

The NCC concurs with EPA’s thorough review showing no human health risk and mitigation of any potential ecological risks.  The NCC appreciates the EPA’s comments and encouragement for enhanced attention to drift reduction advancements.  The NCC believes the EPA’s drift models do not appropriately reflect current drift reduction technology.  However, the NCC does and will continue to seek research and educational means to minimize drift concerns.  The NCC urges EPA to consider engaging in dialog with the agricultural aerial application industry in an effort to appropriately represent current drift reduction technologies.

The NCC additionally urges EPA to rely on biological data for plants and pollinators rather than requiring costly studies with little biological relevance.  The NCC does not agree with EPA’s assertion that pollinator studies are justified when the cotton plants have reached the harvest preparation stage.

The NCC recognizes the challenges EPA faces regarding Endangered Species Act (ESA) compliance and consultation with the Services.  The NCC appreciates the extensive efforts being made to jointly develop interim approaches addressing ESA, but NCC remains concerned the approach lacks scientific credibility in favor of overly protective measures that jeopardize agriculture.  The NCC supports the continued efforts of EPA and the Services to identify procedures that will result in measurable, scientifically credible risk assessments for threatened or endangered species.

The NCC appreciates the opportunity to provide these comments in support of the registration of thidiazuron.  The NCC appreciates EPA’s recognition of the benefits and importance of this cotton defoliant product.  The NCC believes the historical use of this product speaks clearly to its safety for human health and environmental safety.

Respectfully submitted,
Reece Langley
VP – Washington Operations