The National Association of State Departments of Agriculture (NASDA) submits the following comments on the U.S. Environmental Protection Agency’s (EPA) proposed Draft Ecological Risk Assessments: Pyrethroid Registration Review (docket number EPA-HQ-OPP-2010-0384).
- About NASDA
NASDA represents the Commissioners, Secretaries, and Directors of the state departments of agriculture in all fifty states and four U.S. territories. State departments of agriculture are responsible for a wide range of programs including food safety, combating the spread of disease, and fostering the economic vitality of our rural communities. Conservation and environmental protection are also among our chief responsibilities.
In forty-three states and Puerto Rico, the state department of agriculture is a co-regulator with EPA and responsible for administering, implementing and enforcing the production, labeling, distribution, sale, use and disposal of pesticides under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA).
- General Comments
Crop protection tools are an important component within many agricultural production systems, and FIFRA establishes a rigorous, scientific evaluation and risk-benefit review process for these tools. NASDA supports the scientifically-sound development, review, registration, and re-registration of crop protection technologies, such as Pyrethroid products.
Pyrethroid pesticides are an effective tool in controlling a wide range of insects, from mosquitos and ticks, to numerous other pests that threaten public health and agricultural production. Farmers across the U.S. rely on pyrethroid products for the protection of over 120 different crops that benefit all Americans. It is estimated that Pyrethroids provide an economic benefit of $1.6 billion to U.S. consumers in the form of lower food prices while protecting a wide range of commodities and specialty crops that would otherwise be vulnerable to harmful pests.
Pyrethroids play a critical role in integrated pest management (IPM) and insecticide resistant management programs. Pyrethroid products have a strong worker safety record, and EPA has continually determined Pyrethroids do not pose health risks for applicators when used as directed. The importance of Pyrethroids in pest management is underscored by the fact there are very few if any alternatives currently available.
Considering all of the benefits Pyrethroids provide to American agricultural producers, consumers, and public health activities, NASDA is concerned with EPA’s preliminary ecological risk assessment (PRA). Under FIFRA, EPA is required to undertake a risk-benefit analysis in its registration of pesticides, and the ecological risk assessments ensure EPA’s approved uses are not likely to cause harmful effects to terrestrial and aquatic life. This complex process must account for pesticide use patterns, the chemical properties and behavior that influence environmental fate and transport, and a thorough and holistic approach that relies on sound science and robust data to support risk conclusions tied as closely to real-world conditions as practicably possible. NASDA is concerned that EPA’s PRA does not reflect the risk-benefit balancing required under FIFRA and overstates the potential risks of Pyrethroids due to EPA’s failure to account for these complexities, real world conditions supported by numerous scientific studies, and risk mitigated via IPM practices and label restrictions.
NASDA cannot support EPA’s ecological risk assessment for Pyrethroids absent further refinement to address the issues and limitations highlighted in these comments. Without further refinement, EPA risks limiting the availability of pyrethroid products and leaving farmers, mosquito control authorities, and pest control industries without effective and safe alternatives and critical resistance management tools, based on a risk assessment that grossly overstates the potential risk Pyrethroids pose to the environment and fails to meet the risk-benefit balancing required by FIFRA.
NASDA requests EPA utilize all available data and practices when further evaluating Pyrethroids in keeping with the Agency’s responsibility to incorporate the best available scientific information when evaluating environmental risks. Specifically, EPA should consider the complexities of actual use of Pyrethroids in the field as well as the impacts of mitigation measures being utilized on farms. Furthermore, EPA should include in its assessment studies and model refinements assembled by Pyrethroid insecticide registrants, and EPA’s modeling should capture the positive effects of the current label requirements as they were not previously considered. Finally, the model should be refined to more accurately match real work application conditions and requirements.
EPA’s risk-benefit balancing should also consider the vital role of Pyrethroid products in mitigating resistance and ensuring safe and effective use of pesticides in crop protection and public health. Effective and sustainable resistance management rests on the availability of a menu of pest control options and pesticide products. Regulatory decisions that would remove an entire class of products from the market or further restrict their use would weaken resistance management efforts and could lead to increased resistance and/or use of pesticides that have a greater risk profile for humans and the environment.
Growers face constant pressures ranging from weather conditions, pest stressors, resistance issues, and myriad of other challenges. It is essential that EPA execute its authorities and responsibilities in a timely manner consistent with the Agency’s robust science-based registration and review process to ensure farmers have access to a broad range of technologies and crop protection tools, such as Pyrethroids.
NASDA encourages EPA to undertake further refinements to the Agency’s ecological risk assessment for Pyrethroids to address the issues and limitations highlighted in these comments and in keeping with the Agency’s dedication to the well-established review process under FIFRA.
As regulatory partners with EPA, NADSA appreciates the opportunity to comment on this important issue. Please contact Dudley Hoskins (firstname.lastname@example.org) if you have any questions or would like any additional information.
Director, Public Policy