As part of the registration review process, the public is invited to submit comments on a public forum, associated with what is called a “docket,” or case.
Effectively Focusing Your Comments
Public comment periods coincide with registration decision points related to specific scientific assessments (human health, environmental, etc.) that may contain proposals for new restrictions on use. When provided these opportunities, you, as growers, should be prepared to focus your responses on:
You Can Help!
Go to the regulatory review schedule for chlorpyrifos to see dates for open comment periods.
- why you use the product
- why you need it
- what you would do in its absence
- what effect its absence would have on your operations in terms of overall productivity and sustainability
This kind of information is not reflected in the scientific reports provided to EPA, which makes it all the more important to bring to light. It’s also important to leave comments about:
- any major errors in assumptions about product use EPA may have made
- potential impacts of the new restrictions on your ability to manage pests, including economic impacts
- alternate practices already in place or restrictions that could be more readily adopted with reduced impacts to agriculture (e.g. using low-drift spray nozzles vs. implementing a proposed new, infeasible no-spray zone)
The most important thing to remember is to draw from what you know: agriculture. By the time comment periods are opened to the public, EPA has waded through mountains of scientific evidence and commentary. What they are missing is your story.
Find out when the next public comment period is scheduled or go to the EPA docket for chlorpyrifos .
Examples of Comments from Previous Comment Periods*
The following examples show effective information provided to EPA during an open comment period:
“[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.”
“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.”
“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 Management] 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.”
“[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.”
* 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.