Commentary

Mark March 28, 2017, on your calendar. The USDA and the U.S. EPA have been engaged in an epic dispute regarding the use of chlorpyrifos. The insecticide is used on at least 40,000 farms in the U.S. and on 50 different types of crops. If you read The New York Times story on the insecticide you would conclude that EPA scientists were merely protecting the health of young children and farm workers. The New York Times suggested EPA’s science had been rejected. The news article made no effort to review the powerful arguments made by USDA against EPA banning the use of chlorpyrifos.

Powerful new forces at USDA brought agriculture’s arguments to Mr. Pruitt’s attention and based on USDA arguments, the new EPA Administrator rejected the views from EPA staff. Mr. Pruitt last Wednesday evening declared “We need to provide regulatory certainty to the thousands of American farms that rely on chlorpyrifos, while protecting human health and the environment." He said, “By reversing the previous administration’s steps to ban one of the most widely used pesticides in the world, we are returning to using sound science in decision-making – rather than predetermined results.”    

All of agriculture owes an enormous debt of gratitude to Dr. Sheryl Kunickis, director of the USDA Office of Pest Management Policy. She summed up the importance of the March 28 decision saying, “it means that this important pest management tool will remain available to growers, helping to ensure an abundant and affordable food supply for this nation.” Kunickis and her team, in comments filed by USDA, obliterated EPA’s arguments to ban chlorpyrifos.

A few examples:
EPA proposed to revoke all tolerances for the insecticide chlorpyrifos. Kunickis and USDA declared EPA used overly conservative assumptions to calculate exposure to chlorpyrifos. USDA said EPA’s population adjusted dose led to higher exposure to chlorpyrifos “…which leads to the mistaken conclusion that chlorpyrifos as it is currently used, is unsafe.” USDA argued that the drinking water risk assessment used by EPA overestimated exposure because of removal of the insecticide at a treatment facility. EPA apparently made the assumption that chlorpyrifos would always be used at the highest application rate and on all possible crop acres. USDA said this approach was “…overly conservative and could be refined.” I would suggest the information shouldn’t be refined but it should be declared false because it does not represent fact.

Another devastating fact apparently ignored by EPA and The New York Times “[T]he USDA Pesticide Data Program (PDP) has sampled groundwater and drinking water for chlorpyrifos, including at school and daycare wells, for the past 15 years. No chlorpyrifos was detected in hundreds of water samples in 2010-13 at the parts per trillion level. USDA suggests that PDP water data be used in the chlorpyrifos analysis instead of the overly conservative modeling estimates.”

On top of using models, EPA said it did not have enough data and it used what is known as a default 10X FQPA safety factor which means you have a number and you lower it by ten times. The purpose of the safety factor is to account for uncertainties. USDA pointed out the enormous amount of data available and such a safety factor is simply inappropriate for chlorpyrifos.

EPA and its experts used epidemiological data. USDA claimed EPA’s studies were federally funded and the data should be made available. At the time USDA commented EPA had not nor would not release the data. Several pages of the USDA January 5, 2016, comments obliterate EPA’s science arguments. USDA outlines for EPA what a valuable tool chlorpyrifos is for farmers and the loss of the product would have major negative impacts on our production capacity and the economic stability of farms. Not an issue EPA concerns itself with. Several crops were highlighted. EPA was advised that chlorpyrifos is the only insecticide for cotton which has an adequate efficacy to prevent boll damage and damage from cotton aphids. For non-citrus tree fruit chlorpyrifos is critical to control tree-boring insects. Without chlorpyrifos there would be a 100% loss of the plantings. Other tree-boring insects must be controlled in stone fruit such as peaches. For some of these insects chlorpyrifos “…is the only effective option for control of borers in cherry and peach. There are no alternatives.” In citrus, chlorpyrifos is the only effective control for ants. USDA’s comments rely on science.

Result: Win for USDA and farmers.