January 24, 2017
All pyrethroid insecticides (bifenthrin, Warrior/Karate, Mustang Max, Baythroid, Asana, Permethrin, etc.) are currently undergoing registration review at EPA. Nine are specifically being evaluated, but serve as surrogates for all 19 active ingredients.
The preliminary evaluation shows that all pyrethroids exceed “Levels of Concern” for exposure to aquatic invertebrates. THIS IS MAJOR. If LOCs are exceeded, the exposure must be mitigated. This can be done in a variety of ways, but generally means loss of uses, reduced rates, reduced number of applications, or other use restrictions.
IF PYRETHOIDS ARE IMPORTANT IN PRODUCTION OF YOUR CROPS, YOU ARE ENCOURAGED TO SUBMIT COMMENTS TO EPA ON THIS EVALUATION.
The current deadline is Jan. 30 at 11:59 p.m. (ET). An extension has been requested but has not been granted as yet. Please comment now if possible. EPA particularly needs to know why and specifically how you use pyrethroid insecticides.
Your comments should include:
Who you are and why you are commenting (grower, consultant, etc.; acres grown and other pertinent information as to your qualifications).
Why pyrethroids are important to you (why you use them over other products; why alternatives are not adequate or preferred; etc.)
YOUR USE PATTERNS (be very specific if at all possible): For EACH crop (and possibly season) indicate which pyrethroid(s) you use, the pest(s) targeted, the use rate, number of applications, re-treatment interval, and preharvest interval (particularly if a short PHI is necessary).
The general importance of pyrethroids is important (about the only broad spectrum products we have left), but the specific use information is needed to adjust the exposure estimates.
To comment, click on the following link:
https://www.regulations.gov/document?D=EPA-HQ-OPP-2010-0480-0019 (Regulations.gov webpage); the summary does not mention pyrethoids, but this is the place (pyrethroids are in the table at the bottom of this document); click the “Comment Now!” button on the upper right of page and follow the instruction.
A user friendly option is the Pyrethroid Working Group site:|
Go to https://www.votervoice.net/PWG/campaigns/48706/respond and follow their instructions. This site includes a template and suggestions for the information submitted.
It is a very good idea to compose and review your comments in a WORD document (or other program) before submitting them to EPA.
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