Agricultural Retailers Association filed 4 comments on this docket between May 4, 2018 and Jun 9, 2020. 87 other organizations filed here. The comment window closed 642d ago.
The attached comments are being submitted on behalf of the Agricultural Retailers Association.
Neonics are a modern class of insecticides that have been widely adopted to manage some of the most destructive insect pests on crops. These products are being used in place of older insecticides because of their effectiveness against pest management programs and favorable environmental profile and mammalian safety. Neonics are used on many crops such as soybeans, wheat, cotton, sorghum, and canola. They are also used on many smaller-acreage horticultural crops, ornamental plants, lawns and even on pets for flea control. These pesticide products are extremely valuable for America's agricultural industry because of their use in integrated pest management (IPM) programs. Neonic insecticides help ensure beneficial insects remain available to keep other potential pests in check due to their selective control of target pests. If farmers were potentially forced to rely on older classes of chemistry it could result in reduced yields, more frequent sprays, higher costs, and less selective on types of pests impacted. Pesticides are highly regulated products in commercial use, with over 120 different baseline studies required for new EPA registrations. These studies assess safety to humans, wildlife, and the environment. On average it takes around 11 years for a new product to be registered, sold and used in the U.S. marketplace. All pesticides, including neonics, are required to undergo periodic evaluation to ensure they continue to meet the highest standards of safety necessary to protect human health and the environment. One of the most common uses for neonics is part of seed treatment technologies to protect vulnerable seeds from threats of insects and diseases that exist in the soil during early developmental stages. Agricultural retailers provide seed treatment services for their farmer customers to deliver a very precise pesticide application that ensures the plant has a greater opportunity to grow a strong root system which is the foundation of a healthy, productive plant. Seed treatments also reduce the environmental impact on the crop production process by decreasing the necessary number of pesticide applications during the planting season and lessening potential exposures to non-target species, including humans and pollinators. Agricultural retailers, their farmer customers and other key segments of the industry are constantly evolving to improve seed treatment processes. Due to these technological advances, only milligrams of active ingredient are now used per individual seed. ARA's main concerns are regarding additional PPE requirements, reductions in seasonal application rates, crop growth stage restrictions, and proposed spray drift and runoff mitigations. EPA has proposed that applicators wear a respirator and gloves for certain uses of clothianidin and thiamethoxam including for treating corn and seed. While safety is of the highest importance for ARA and its members, we want to ensure that any additional PPE requirements are based on confirmed risks so to maximize employee compliance and not overburden our members with unnecessary costs. ARA is concerned that the proposed reduced application rates will result in fewer total soil and foliar application availability for all neonics. For some crops, these reductions would have minimal impact but for others it would be more significant. Since these restrictions are based on maximum pounds of active ingredient per acre per year, they may harm industries where multiple crops are grown per year on the same site. In this case, the restriction would not account for the need of applications across multiple crop growing seasons. Compared to other insecticides, neonotinoids are more selective, allowing for the preservation of beneficial insects, which are a key element of IPM programs. Neonicotinoid products are very effective against certain types of insects and would be replaced with older, less selective products that would negatively affect beneficial insects, reduce yie…
Attached are comments submitted on behalf of the Agricultural Retailers Association.
Attached are comments submitted on behalf of the Agricultural Retailers Association.
For further information contact: Garland Waleko at waleko.garland@epa.gov or neonicotinoidinquiries@epa.gov
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