ISA formally objects to EPA chlorpyrifos rule

October 21, 2021 | Bethany Baratta

The Iowa Soybean Association joined 81 other agricultural organizations in a letter objecting to the Environmental Protection Agency’s rule to revoke all tolerances of chlorpyrifos.

Stakeholders can object to pesticide tolerance changes or cancellations, and the EPA Administrator must then respond.

The EPA on Aug. 18 announced the ban on the use of the pesticide chlorpyrifos on all food.

In a final rule, EPA rescinded all “tolerances” for chlorpyrifos, which establish an amount of a pesticide that is allowed on food. In addition, the agency will issue a Notice of Intent to Cancel under the Federal Insecticide, Fungicide, and Rodenticide Act to cancel registered food uses of chlorpyrifos associated with the revoked tolerances.

In the letter sent to the EPA on Oct. 19, the groups, including ISA, cited several concerns with EPA’s revocation decision, including the processes used to reach its decision to revoke use of the pesticide.

Chlorpyrifos has more than 50 registered agricultural uses on numerous crops, many of which are high-benefit uses to protect against economically-significant pests, according to the letter.

The groups said revoking use of the pesticide will leave thousands of growers across the country “defenseless to devastating pests.”

Soybean growers use chlorpyrifos to control both two-spotted spider mites (TSM) and soybean aphid populations that have developed resistance to other insecticides, such as pyrethroids. These pests can inflict yield losses as high as 60% if left unchecked.

“For growers who face these pests, there is no one-to-one replacement for chlorpyrifos – it is the only option that will control both pests,” ISA and others noted in the letter to the EPA. The groups said this could have an adverse effect on the environment.

“Should this rule take effect, soybean growers who face TSM and pyrethroid resistant aphids will now have to choose between applying twice as much pesticide active ingredient (which will also significantly increase their operational costs) or face serious crop damage. This results in an increase in pesticides used in the environment and additional sprays which unnecessarily increase the use of water and fuel,” they said.

In addition, the rule’s February 2022 implementation date means that millions of gallons of chlorpyrifos remain in storage—very few growers are using the product this late into the 2021 growing season. Most users will be effectively prohibited from using the product even if the registration has not been formally cancelled at that point, placing the financial and logistical burden on users and retailers to determine how to responsibly dispose of product.

“Without additional clarification from EPA on what to do with these existing stocks, it could inadvertently lead to inappropriate or mass disposal of product which would have significant environmental consequences,” the groups said in the letter.

The groups requested that EPA stay implementation of this rule until the Agency can thoroughly consider and respond to objections.

“To lose the ability to use chlorpyrifos, as would occur through implementation of the rule, would unnecessarily result in significant and immediate economic and environmental damage.”

 

Read the letter: 10-19-2021_Coalition-Chlorpyrifos-Tolerance-Revocation-Objections-1.pdf (soygrowers.com)

 

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