Thus far, EPA has shown an unusual amount of deference to pesticide opponents who have been pressuring the Agency to speed up its established schedule for review of chlorpyrifos and make decisions based on incomplete information. This is affecting the entire review process and has created the potential for flawed regulatory policy as a result of hasty decision making.

Pressures from Pesticide Opposition

You Can Help!

Go to the regulatory review schedule for chlorpyrifos to see dates for open comment periods.

For example, in response to issues raised in a 2007 petition and subsequent lawsuit filed by the Pesticide Action Network of North America (PANNA) and the Natural Resources Defense Council (NRDC), EPA has shortened the amount of time the Agency will devote to producing a final chlorpyrifos human health assessment. This raises legitimate concerns among many stakeholders that EPA’s review schedules are now being driven by pesticide opponents, to the detriment of other interests.

A more recent example: During July of 2012, EPA responded to 6 of 10 issues of human health concern raised against chlorpyrifos by pesticide opponents in 2007 as a basis for cancelling all registrations. The Agency rejected the validity of these concerns and has committed to responding to the remaining complaints by the end of 2012. Dow&AgroSciences applauds EPA’s clear action in dismissing these unfounded allegations and expects the Agency to continue to show courage in sticking to a science-based, regulatory path and not to be distracted and derailed by the actions of pesticide opponents.

Moving Forward – Slowly and Carefully

Due to the complexity of the chlorpyrifos assessment, the precedent-setting application of new EPA policies, and the importance of chlorpyrifos to U.S. agriculture, Dow AgroSciences and grower organizations have encouraged EPA to take the right amount of time to do the best job possible with their assessments and not be pressured to take any shortcuts. Dow AgroSciences also believes it is important that EPA not compromise its science-based, transparent registration review process based on interference and pressures by pesticide opponents. Pesticide opponents are working hard to circumvent EPA’s established registration review process for chlorpyrifos and obtain special privileges and influence with EPA through bullying tactics and legal actions. This makes it all the more important that growers and other stakeholders who rely on chlorpyrifos and other products undergoing EPA registration review also provide their inputs and views as invited by EPA during the public comment periods.