Chlorpyrifos Protects

Growers of agricultural crops across the nation rely on chlorpyrifos’ benefits to protect food and fruit crops from damaging pests. Farmers, technical advisors, agronomists and agricultural pest control professionals favor chlorpyrifos products because they are effective, relatively inexpensive, and have a broad spectrum of activity against many insect pests when compared to alternative products.

The Environmental Protection Agency’s process for pesticide reevaluation includes opportunities for submission of comment by growers and members of the general public. When EPA has asked for public comments on chlorpyrifos, growers and grower organizations have responded with information to help the Agency understand how it is used and its importance for growing various crops.

Comments by Farming Region

Click on the map below to read excerpts from growers, grower organizations and university specialists in your region who have responded to one of EPA’s requests for input by explaining why they considered chlorpyrifos essential for protecting crops.

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Appalachian

North Carolina

“Chlorpyrifos is a major insecticide for quarantine control of Japanese beetle and imported fire ants in the nursery industry and is the only affordable quarantine treatment option available for commercial turf growers to control imported fire ants… If chlorpyrifos usage were eliminated, it would prevent all field nursery plant sales from areas of the southern U.S. infested with fire ants (currently 275 million acres) to northern and western markets. It is vital for shipping many field grown nursery trees and plants to other parts of the country that do not already have Japanese beetles as well.” – North Carolina Nursery and Landscape Association. (Nursery)

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Tennessee

“I have two major concerns about the impact of a chlorpyrifos ban on the U.S. nursery industry. First, chlorpyrifos is relied on heavily by the nursery industry for management of wood-boring insects. At the present time, there are no suitable chlorpyrifos substitutes for the preventative management of many wood-boring insects… Secondly, chlorpyrifos is a major insecticide for quarantine control of Japanese beetle and imported fire ants in the nursery industry and is the only affordable quarantine treatment option available for commercial turf growers to control imported fire ants… At the present time, we do not have any non-chlorpyrifos alternatives for treatment of field nursery plants that are approved in the Federal Fire Ant Quarantine… I feel the nursery industry is very dependent on the continued availability of chlorpyrifos until suitable substitutes can be identified. In the case of imported fire ants, the loss of chlorpyrifos would eliminate world markets for the southern field nursery industry and have a serious impact on their profitability.” – Entomologist, Tennessee State University Nursery Research Center. (Nursery)

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Corn Belt

Ohio

“I strongly urge that the use of chlorpyrifos not be cancelled in soybean. It has become 1) the most widely used and effective insecticide against soybean aphid that is not a pyrethroid, 2) one of only two materials that growers can use against two spotted spidermite, and 3) the only insecticide that can be used effectively in a field if both of these serious pests are causing a problem at the same time.” – Ronald B. Hammond, Entomologist, Ohio State University. (Soybeans)

“Chlorpyrifos is the only labeled insecticide for maggot control in radishes. Without chlorpyrifos, it will be impossible to raise radishes. Buurma Farms Inc. raises approximately 1500 acres of radishes each year. Without a labeled and effective insecticide for cabbage/radish maggot control, we would lose our ability to product our highest volume crop. If anything, we would like to see the label of chlorpyrifos expanded to include green onions.” – Ohio Grower. (Radishes)

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Lake States

Michigan

“Tart and sweet cherries are important crops in Michigan. The state grows 75 percent of the nation’s tart cherries, and we have 7,500 acres of sweet cherries in production. Although these two cherries are different species, they have an indistinguishable pest complex… Borers feed on tree cambium, and an infested four-to-six-inch limb will become unproductive within two years. A severe borer infestation can result in outright tree mortality, especially in young trees… The primary means for borer control in cherry is chlorpyrifos… Growers use borer insecticide sprays in conjunction with orchard monitoring techniques that utilize pheromone-based traps… [B]ased on chemical trials…we can safely say that [chlorpyrifos] is currently the only registered insecticide that provides reliable control of the borer complex… Without chlorpyrifos, the Michigan cherry industry would suffer tremendous losses in production, yield and orchard acreage.” – Dr. Nikki Rothwell, Northwest Michigan Horticultural Research Station. (Cherries)

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Minnesota

“Chlorpyrifos is an extremely important insecticide for soybean production in Minnesota, as well as most of the upper Midwest. Chlorpyrifos effectively controls two very significant pests in soybean production — spidermites and soybean aphids. Infestations of spidermites can be sporadic [and when they] do occur, yield reductions of greater than 50 percent can result. Based on University of Minnesota research, chlorpyrifos is the product of choice for controlling spidermites in soybeans… Chlorpyrifos is one of only two types of products that have proven to provide effective control of soybean aphids. The other products are synthetic pyrethroids…and their use has sometimes resulted in the need to make supplemental applications of chlorpyrifos to control spidermites.” – Minnesota Soybean Growers Association. (Soybeans)

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Mountain

Idaho

“Chlorpyrifos is an important tool in pest management for sugarbeet production in [Southern Idaho]. It provides a much-needed change in chemical formulation to help prevent sugarbeet root maggot resistance… It helps ensure that good quality products are produced to meet market demands and consumer preference. When used properly, chlorpyrifos only improves the quality that we work so hard to provide.” – Jentzsch-Kearl Farms. (Sugarbeets)

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Northeast

Maine

“The directors of the Maine Vegetable and Small Fruit Growers Association support the continued use of the active ingredient chlorpyrifos for agricultural production. In Maine, the [principal or [sic]] agricultural uses of chlorpyrifos are in field corn, sweet corn, broccoli, cabbage and other cole crops, and strawberries. For broccoli and other cole crops, it is the only active ingredient available that effectively controls…root maggot. For our other crops, this is an important active ingredient to maintain in order to be able to provide a rotation to effectively manage insect resistance development.” – Maine Vegetable and Small Fruit Growers Association. (Field crops)

“Maine is currently the third-largest broccoli producing state in the nation, behind California and Arizona. I anticipate our production to continue to increase at its current pace, about ten- to 15-percent per year, as transportation costs continue to encourage broccoli users to source their needs on a regional basis. The portion of the delivered cost charged to transportation is less out of Maine than the West for a majority of east coast customers. Maine’s cool, wet spring is conducive to the propagation of the cabbage root maggot. The continued use of this material [i.e., chlorpyrifos] would allow us to competitively produce these types of vegetables in Maine closer to eastern markets, pass on transportation savings to consumers, and as a direct result reduce the amount of diesel fuel burned and the pollution and greenhouse gases discharged into the environment.” – Emerald Valley Ranches, LLC. (Broccoli)

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New York

“[O]nions are one of the most important vegetable crops in New York in terms of crop value… New York growers plant well over 12,000 acres of onion, with a cash value of over $39 million and an overall economic development impact of $100 million… According to [the Cornell cooperative Extension] 95 percent of the onions produced in New York have been treated with chlorpyrifos… The restriction of this product, with no viable alternatives, would put many, if not all, onion growers out of business… [O]nion growers do not see the logic or wisdom of restricting the product’s use and effectively terminating commercial onion production in New York at this current time.” – New York Farm Bureau. (Onions)

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Northern Plains

North Dakota

“On wheat, chlorpyrifos at low rates provides a reasonable control method for an outbreak of Russian wheat aphid. Aphids can cause significant damage to wheat on our farm by reducing both yield and quality. Our sugarbeet acres occasionally require treatment for the control of cutworm and sugarbeet root maggot. Both of these pests have a major impact on yield. The American sugarbeet growers have very few options when these pests reach beyond economic thresholds… We will be among the first to adapt to better control methods when they become available… Until then, please maintain one of the few tools we have to control the serious pest problems that confront us.” – North Dakota grower. (Wheat, Sugarbeets)

“Chlorpyrifos is an important tool for managing many insect pests of the major field crops grown in North Dakota…”

  • Alfalfa — grasshoppers, leafhoppers, armyworms, cutworms, pea aphid, plant bugs
  • Field corn — cutworms, grubs, seed corn maggot, wireworm, grasshoppers, armyworms
  • Soybean — grasshoppers, Lepidoptera foliage feeders, armyworms, bean leaf beetle, cutworm, soybean aphid, spider mites
  • Sugarbeet — grasshoppers, spidermites, lygus bugs, sugarbeet root maggot, aphids
  • Sunflower — cutworms, grasshoppers, banded sunflower moth, seed weevil, stem weevil, sunflower beetle, sunflower moth, lygus bugs
  • Wheat — aphids, grasshoppers, army cutworm, cutworms, wheat midge, cereal leaf beetle

“Chlorpyrifos has…been important to growers of North Dakota because it is the only insecticide that can effectively kill some of the insect pests. In wheat, for example, chlorpyrifos is the most efficacious and cost effective insecticide for control of wheat midge… In addition, chlorpyrifos is the insecticide of choice for control of aphids and spidermites in many field crops, because of the ability of spidermites, for example, to develop insect resistance and to ‘flare up’ (rapid population density increases) when other insecticides….are used for control.” – Dr. Janet Knodel, Department of Entomology, North Dakota State University. (Field crops)

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Kansas

“I am writing as an entomologist involved in advising producers on how to manage various insect pests in field crops in Kansas. While I realize we must do everything we can to protect our food supply from unnecessary chemical residues, I also know that the loss of chlorpyrifos would greatly limit the choices available to manage several major insect pests in the United States. Chlorpyrifos is one of the last remaining organophosphate insecticides still used in the production of many field crops. While its use has greatly declined over the years with the introduction of newer chemicals and the development of transgenic crops to control lepidopterous insects and the corn rootworm, there remain several pests such as the Russian wheat aphid, pea aphid and soybean aphid where chlorpyrifos is still a very important management option.” – Phil Sloderbeck, Southwest Research and Extension Center. (Field crops)

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Pacific

California

“Alfalfa is not a high insecticide-use crop, but that could change dramatically without chlorpyrifos and cause adjacent crops to also require more pesticide applications… Alfalfa fields are managed as IPM [Integrated Pest Management] tools because they host extremely high numbers of beneficial insects that migrate to adjacent crops… [C]hlorpyrifos has a moderate effect on beneficial insects. It is well documented that pyrethroids, the chemical class used most often as a substitute, is much more disruptive to beneficial insects. Therefore banning chlorpyrifos would harm IPM programs and increase the need for insecticide use. Additionally, banning the chemical would greatly increase the potential for insect resistance due to the small number of alternative chemicals registered for alfalfa.” – California Alfalfa and Forage Association. (Alfalfa)

“[There are a number of crops] that are critical to improving the health and nutrition of our nation’s people…that rely upon the protection of chlorpyrifos against destruction by leaf maggots. These include broccoli, cauliflower, onions, cabbage, Brussels sprouts…lemons [and] wine grapes. Products such as chlorpyrifos are used by growers in our region in combination with cultural practices and other nonchemical measures as an integrated pest management scheme… There is no comparable product available to farmers as a substitute for chlorpyrifos. If this product is not available, crop losses would be up to 50 percent from reduced yields. Specific example: A local grower submitted results of his attempt not to use the product on onions in the spring of this year. ‘Out of 1,500 acres planted,’ [he wrote], 'I lost 215.3 acres to bulb mite or soil maggots — I can’t stay in business with losses like that.’ Replanting the lost acres cost this grower an additional $60,929.00… Less effective substitutes for chlorpyrifos would result in an increase in overall pesticide use. So we would have potentially greater environmental impacts as growers scramble to achieve similar crop protection using less effective products. Farmers would continue to experience losses and more pesticides would be applied.” – Monterey County Farm Bureau, Salinas, California. (Vegetables)

“For California wine grapes, chlorpyrifos predominantly is used for managing the recently introduced vine mealybug, a significant problem in some regions and threat across the state. Approximately 39,000 wine grape acres were treated in 2005, as published by the California Department of Pesticide Regulation. Chlorpyrifos is one of the few registered products and most efficacious for controlling vine mealybug, particularly its spread to noninfested areas. When used, the material is carefully applied at delayed dormancy or post harvest for direct kill or to suppress ants that impede biological control of mealybugs… It is important…to maintain all safe and effective uses of chlorpyrifos in California wine grapes, at least until other efficacious alternatives become available.” – California Association of Wine Grape Growers. (Wine grapes)

“Chlorpyrifos is needed for control of a wide variety of pests. In California there are 17 counties infested with vine mealybug and once established, vine mealybug is difficult to eradicate. Black widow spider has become a serious issue due to quarantine requirements on U.S. table grape exports, and for stone fruit growers there are similar demands for zero tolerance of Oriental fruit moth on exports destined to Mexico. Chlorpyrifos continues to provide a significant benefit in managing these pests.” – California Grape and Tree Fruit League. (Table grapes, Stone fruit)

“Chlorpyrifos in cotton is used primarily against cotton aphids, and particularly late-season infestations. These infestations are potentially very damaging in terms of sticky cotton. Chlorpyrifos is a highly effective chemical and one we can ill afford to lose.” – California Cotton Ginners and Growers Association. (Cotton)

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Oregon

“Chlorpyrifos is widely used in Oregon as a seed treatment to control pests that feed on snap bean and sweet corn and young seedlings. In addition Oregon growers use it quite regularly to control insects such as cabbage maggot on broccoli and cauliflower. Producers also use it on sweet corn at planting, to help control corn rootworm larvae, cutworms and symphylans. Growers have not found alternative products that offer the control of chlorpyrifos. Elimination of chlorpyrifos would have significant negative impacts on Oregon growers’ ability to competitively produce processed vegetable crops and consequently would severely hamper the entire processed vegetable industry in the state.” – Oregon Processed Vegetable Commission. (Vegetables)

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Washington

“As hay growers, we are advised strongly to rotate insecticide families (i.e., organophosphates, carbamates and synthetic pyrethroids) in our lygus control program to help prevent the development of insect resistance. Removing [chlorpyrifos] as one of these options increases the likelihood of development of insect resistance. Lygus is one of our most persistent and serious threats. It is essential that we keep [chlorpyrifos] in this rotation program.” – Washington State Hay Growers Association. (Hay)

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Southeast

Alabama

“I am a nurseryman who relies very much on chlorpyrifos for the control of fire ants in my nursery. If I lose that chemical, it will be very expensive to replace it, if I can. Please consider not banning the use of chlorpyrifos.” – Greene Hill Nursery. (Nursery)

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Georgia

“Chlorpyrifos is an absolutely key material for southeastern peach growers. Policy-driven incentives to either eliminate or restrict its use in peaches would further degrade grower options for successfully managing lesser peachtree borer. It would almost certainly further increase pyrethroid use. Any restrictions on the availability of chlorpyrifos to southeastern peach growers would be ill advised.” – Dan Horton, Professor of Entomology, University of Georgia; and Ted Cottrell, research scientist, U.S. Department of Agriculture. (Peaches)

“Peachtree borer has historically been regarded as the southeastern U.S.’s key borer species, as uncontrolled peachtree borer infestations will debilitate and kill trees more rapidly that the lesser peachtree borer. Control of peachtree borer in southeastern peach production has been, and remains, almost entirely dependent on post-harvest application of chlorpyrifos… Pheromone mating disruption, or substitution of either endosulfan or pyrethroids are dramatically inferior to the current use of chlorpyrifos.” – Dan L. Horton, University of Georgia, Entomology. (Peaches)

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Southern Plains

Texas

“My major concerns regarding the withdrawal of chlorpyrifos from the management options currently available to pecan growers in Texas are 1) that the risk of resistance to remaining materials will increase; 2) that some producers may adopt materials that are more disruptive of the IPM [Integrated Pest Mangement] program (i.e., pyrethroids) than those currently being used; and 3) that outbreaks of secondary pests like aphids, mites and leafminers may result and trigger more insecticide use than is currently needed to produce large crops of good quality.” – Texas Entomologist. (Pecans)

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* Dow AgroSciences has not independently verified the assertions made in the comments or the identities of the individuals or organizations purporting to have submitted the comments.

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