The National Association of State Departments of Agriculture (NASDA) submits the following comments on the U.S. Environmental Protection Agency’s (EPA) proposed registration decision for sulfoxaflor (docket number EPA-HQ-OPP-2010-0889).
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, 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).
As the pesticide regulatory partner with EPA in forty-three states and Puerto Rico, NASDA is intimately familiar with EPA’s statutory obligations under FIFRA to conduct a scientifically-sound risk-benefit analysis for crop protection tools, including sulfoxaflor. Crop protection tools are an important component within many agricultural crop production systems. NASDA supports the development, scientific-review, and approval of new technologies necessary to combat the constant pest stressors weed-resistance challenges and enable growers to produce our nation’s food, fiber, and fuel.
NASDA has several concerns with a number of elements under EPA’s proposed registration, which does not comply with its obligations under FIFRA’s risk-benefit analysis. NASDA notes EPA did not provide an appropriate benefits analysis for soybean, grain sorghum, cotton, strawberries, cucurbits, and citrus. NASDA requests EPA amend its proposed registration to include these uses as supported by the exposure data.
NASDA is concerned with provisions that would restrict tank mixing of different pesticides. Tank mixing is a critical tool used to inhibit the development of future resistance issues. Often times, multiple pest species occur simultaneously, and tank mixing affords growers the ability to mitigate the constant pest stressors without the need for multiple applications. Any restrictions on tank mixing will unnecessarily limit and compromise our growers' ability to implement scientifically-sound integrated pest management (IPM) practices.
In addition to allowing for the critical use of tank mixing, it is also necessary to remove any requirements for in-field buffer zones within the production area. Such buffers provide no enhanced regulatory protections, which are thoroughly addressed through training, industry collaboration, and responsible stewardship practices, but these buffers will provide unnecessary refuges for pest and weed stressors and enable reproduction of enhanced resistant weeds.
Growers face constant pressures ranging from weather conditions, pest stressors, resistance issues, and myriad other challenges. It is essential to American agriculture that EPA execute its authorities and responsibilities in a timely manner consistent with the Agency’s robust science-based registration process to ensure farmers have access to a broad range of new technologies and modern crop protection tools to continue to produce our nation’s food, fiber, and fuel.
NASDA appreciates the opportunity to comment on this important issue, and NASDA requests EPA amend its proposed registration decision for sulfoxaflor to include for soybean, grain sorghum, cotton, strawberries, cucurbits, and citrus consistent with the Agency’s risk-benefit analysis requirements under FIFRA. NASDA further requests EPA allow for the appropriate use of tank mixing and remove the proposed in-field buffer zones.
As regulatory partners with EPA, NASDA stands ready to assist EPA in ensuring our growers have access to a broad range of technologies and crop protection tools, reviewed and approved in a scientifically-sound and transparent manner, needed to continue to produce our nation’s food, fiber, and fuel.
Please contact Dudley Hoskins (email@example.com) if you have any questions or would like any additional information.
Director, Public Policy