Dicamba, pollinators, pesticide reregistration, worker protection, glyphosate evaluation, endangered species and online pesticide labels are all issues that bear watching by farmers and consultants in coming months, according to a National Cotton Council spokesman.

Don Parker, NCC manager for integrated pest management, offered an update on regulatory issues during the Crop Consultant’s Conference, the opening session for the 2018 Beltwide Cotton Conferences held in early January in San Antonio, Texas.

He started with dicamba and a warning that product stewardship will be essential to maintain registration of the new formulations that are linked to auxin tolerant cotton varieties, labeled for use for the first time in 2017. The products have received both praise and criticism—praise for the exceptional control of hard-to-control and herbicide resistant weeds, criticism for crop damage from off-target movement and injury to sensitive plants.

Product misapplication was also reported in 2016.

“We have seen some improvement in 2017,” Parker says. “But EPA is not happy with the numbers, and it’s not just in the cotton belt but in the soybean belt as well. EPA is not happy with the publicity.” He adds that keeping the new dicamba formulations in the weed management tool box is not a sure thing. “If EPA sees the same thing (as they have in 2016 and 2017) we will not have it available for another year. Last year, we got a two-year registration, and I said then, ‘it’s yours to lose.’ We have to do a better job.”

Parker was one of a half-dozen or more specialists, consultants and industry representatives who discussed dicamba issues during the two-day conference, underlining the turmoil surrounding the technology in some states, including new state and federal restrictions on application timing and training.

POLLINATOR ISSUES

Parker says the pollinator issue also “is not going away,” and that NCC continues to monitor pollinator issues that include evaluation of products important to the cotton industry. “We (NCC) are encouraged with state efforts to develop plans,” he says. “Volunteer programs offer opportunities for growers, consultants, beekeepers, ag aviators and others to be involved in the process at both the local and state levels. It’s a process that allows you to regulate yourself instead of having the EPA regulate with a one size fits all policy. NCC encourages these plans.”

He says EPA will look at the state plans over the next few years and evaluate effectiveness.

Parker has been trying to figure out how to put metrics together that focus on a volunteer program that could vary from state to state. He says EPA has begun to look more favorably on the potential for such volunteer programs. “We want to minimize attention and problems,” he says.

The issue is important since EPA has been forced to move into pollinator risk assessments, including neonic assessments. Parker encourages growers, consultants and other cotton industry representatives to be aware of continued attacks on pesticides, especially neonicotinoids. He notes that recent risk assessment plans offered for public comment generated 400,000 comments. Other plans brought in 60, 000, 35,000, and 36,000 comments.

MANY DETRACTORS

 “We know that a large campaign group is out there flooding comments that indicate products (important to cotton) endanger pollinators and the health system,” Parker says. He mentions an ecological risk assessment for aquatic species in 2017 that generated 340,000 public comments. “We are not sure how many of these are pro and how many are con,” he says, “but we can assume that most are against reregistration.”

A revised benefit assessment for neonicotinoids for soybeans “looks more favorable than the previous assessment from the previous administration,” Parker says. The new assessment will “weigh benefits and risk. This has been released for public comment,” he adds, “and I encourage you to comment so EPA understands the benefit of neonics to cotton.”

He says the earlier assessment may have “miscalculated and left out valuable papers.” The assessment also included risk factors for citrus and cotton bloom and identified citrus and cotton as high risk crops. He adds that FIFRA requires a risk benefits analysis.

The process will include ecological risk assessments for several products to justify re-registering products. The assessment is out for public comment with a Feb. 20 deadline.

Organophosphates are also under the gun, but Parker comments on a possible re-evaluation of a 2017 assessment of safety risk factors that “seems to indicate that EPA is rethinking its position and considering the possibility that regulations overstep the bounds of science from 2017 study.”

WORKER PROTECTION

Worker protection standards are also being reassessed, Parker says, and several components need to be revisited. That process is expected to begin in late 2018. Issues of concern include minimum age restrictions, designated representatives, and application exclusion zones. “A notice of proposed revisions will be open for public comment at that time.”

Parker also notes that the “designated representative,” requirement makes little sense and should be addressed. He explains that the policy allows anyone who has a paper, signed by an employee, and names the bearer as a designated representative, the right to request all pesticide application records. “What does that have to do with worker protection? It doesn’t.”

Parker says EPA has changed the preliminary draft risk assessment for glyphosate that shows the product is “not likely a carcinogen.” The new assessment will be released for comment. He says EPA has reviewed data that found no evidence of glyphosate being carcinogenic.

ENDANGERED SPECIES ACT

Parker says a near impossible situation exists with the Endangered Species Act and the Federal Insecticide Fungicide and Rodenticide Act (FIFRA). “The policy of Endangered Species is to save the critters,” Parker explains. “FIFRA follows a risk/benefit policy based on science and data.” FIFRA conducts a number of risk assessments every year and reviews every 15 years. Endangered Species theory of save the critters, he says, is based on biological opinion.  He says EPA has the difficult task of working with Fish and Wildlife and FIFRA for a final opinion and come up with policy that’s science-based.

He says the conflict makes it hard for EPA to develop a consistent policy. “The system is still broken, and lawsuits continue,” he says. Several important cotton seed treatments are included in those lawsuits with. “Plaintiffs are asking the court to vacate some registrations.”

Parker concluded with a question on the advisability of smart label and web-distributed pesticide labels, designed to offer the most up-to-date labels. “How confusing will that be in the long run?”  He questioned the accessibility for producers without email accounts and the challenge to get users to go online and get a label.

Parker says NCC continues to follow these and other regulatory issues and to work for the industry to keep products available and to alert producers and consultants to regulatory changes.