An EPA official challenged the agriculture industry to take advantage of public comment periods to make their cases for retaining products they need to protect crops.
"It is vital that we get comments from you on how a product is used," said Rick Keigwin, director, EPA Pesticide Programs, during the Cotton Consultant's Conference, the lead-in to the annual Beltwide Cotton Conferences, held this year in Austin, Texas, Jan. 8-10.
Keigwin said EPA needs to hear more than anecdotal reports about how important a product is, though that information is helpful, when EPA considers reregistration and registration reviews.
He said EPA wants to know "how vital a product is, what the impact of the product is compared to what losing it would mean. Did we assess the use rates correctly? Did we assess how many applications you need in a season?"
He added that data showing the economic loss from crop damage as well as the additional costs to substitute other products and potential environmental changes provide information that allows EPA to make informed decisions.
He said the agency needs information that "provides something tangible that can support what you're saying so EPA can justify modifying the risk assessment to reflect how you all are actually using the product. The more data you provide, the more helpful it is in our review."
He added that EPA needs to know how geography affects product use. Data might show a product in a certain part of the Cotton Belt is used a certain way and then in a different part of the Cotton Belt the product is used a different way.
"At EPA we are trying to find out what's the value of a product," Keigwin said. "We want to quantify the value economically and biologically. Why is it important to the crop?"
Keigwin said the timing of consumer comments make a difference.
The 60-day comment period following the draft risk assessment offers an opportunity to weigh in on how important a product is to agriculture.
"And then we evaluate those comments. We revise the risk assessments if we think it's warranted. And then we come up with a proposed interim decision or proposed regulatory decision and this is where we're doing our cost-benefit analysis. Then we pause to consider the feedback from stakeholders. And then we look at an interim or a final decision."
He said comments on the interim risk assessment are important.
"We are largely in these two phases right now; the bulk of the chemicals [under review] are either in the draft risk assessment stage or in the proposed decision phase."
A public comment period is currently in progress. "So, if this is an issue that impacts you specifically, it would be good to hear from you."
Keigwin explained that EPA conducted a reregistration program back in 2008.
Then Congress added a registration review. "Congress said, 'well, you know, maybe we shouldn't just be looking at chemicals one time and be done because we know that science evolves, information changes, new things become available.' So, when they passed the Food Quality Protection Act amendments in the late 1990s and then through some changes in legislation, they created what's called the registration review program. Rather than a one-time reregistration process, now it is a process that every 15 years we reevaluate every active ingredient. We're currently in that first round or first cycle of registration review."
In 2019, EPA reviewed 14 new active ingredients and 9 biopesticides. They also looked at 212 new uses of existing chemicals and three new uses of existing biopesticides.
EPA currently has 1,100 active ingredients and 700 cases under review. Deadline to finish is Oct. 1., 2022.
Keigwin said the agricultural industry should take the opportunity for public review seriously but explained that the reregistration decisions are not based on the "number of votes," pro or con, a product receives. He said a recent review included more than a million product comments, the vast majority negative. The final decision, he said, is based on science.
"We scope out what we think we know about the active ingredients, what its registered uses are, how it's used, and what additional data we think we're going to need, primarily from the registrar. We conduct that evaluation and then we put the plan out for public comment."
He said the process is moving into "the harder chemicals for risk assessment in 2020," including neonicotinoids, pyrethroids, organophosphates, acephate, chlorpyrifos and others. They are also looking at dicamba.
He said EPA's opinion on glyphosate remains that "it poses no public health risk and it is not a carcinogen. We will release our final decision early in the year."
He said neonics provide a challenge but said risk with seed treatments appears lower than other application methods.
Acephate is a challenge because of food risk. "We need a better understanding of how it is used, when it is used and the residue on food," he said.
Keigwin said the recent declaration by Secretary of Agriculture Sonny Perdue that the pink bollworm has been eradicated will activate a review of Bt cotton products.
He said dicamba incidents have resulted in label changes, including required training, application by a certified pesticide applicator, revised application timing regulations and additional buffers to limit volatility drift.
"Off-site movement studies are under way. Also, some counties have different restrictions and some states have different application timing regulations."
Keigwin said the agriculture industry should provide as much use and impact information as possible to preserve needed chemistry.
"What will influence how we do the assessment is if you have better data than we do and data on how it's been used or the different use patterns across cotton production areas that can lead us to changing the risk assessment. It's important to you, and it is vitally important to comment at the proposed decision phase."