← National Agricultural Aviation Association
EPANonrulemakingEPA-HQ-OPP-2005-0162

Reregistration of Carbofuran

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Last modified
Sep 10, 2025
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closed 6398d ago
National Agricultural Aviation Association filings
2

Activity

National Agricultural Aviation Association filed 2 comments on this docket between May 4, 2006 and May 11, 2006. 60 other organizations filed here. The comment window closed 6398d ago.

What National Agricultural Aviation Association filed (2)

May 11, 2006· DUPLICATE ENTRY: Comment submitted by A.D. Moore, National Agricultural Aviation Association· EPA-HQ-OPP-2005-0162-0161

May 2, 2006 Public Information and Records Integrity Branch (7502C) Office of Pesticide Programs Environmental Protection Agency 1200 Pennsylvania Avenue, NW Washington, DC 20460-0001 Re: EPA-HQ-OPP-2005-0162 Carbofuran Revised Risk Assessment To Whom It May Concern: The National Agricultural Aviation Association (NAAA) appreciates the opportunity to comment on the EPA?s revised risk assessment for carbofuran (EPA-HQ-OPP- 2005-0162). NAAA represents more than 1,300 members in 46 states. NAAA member operator/pilots are licensed as commercial applicator-operators that use aircraft to enhance food and fiber production, protect forestry, and control health-threatening pests. Furthermore, through its affiliation with the National Agricultural Aviation Research & Education Foundation (NAAREF), the NAAA contributes to research and educational programs focused on enhancing the efficacy and safety of aerial application. The active ingredient carbofuran is an important tool for farmers to use to combat insects pernicious to crops in the United States, particularly corn, alfalfa, sweet corn, potatoes, sugarcane, sugar beets, soybeans, wheat and a variety of fruits and vegetables. It is important for the production of these crops that carbofuran be available in the event that a pest infestation occurs and carbofuran is the only effective crop protection product available. It is also important that carbofuran be available for aerial use. It is important to ensure aerial use remain available because aerial application accounts for almost 25% of crop protection applications in the United States. Aircraft help in treating wet fields and spraying when crop foliage is too thick for ground rigs. An airplane or helicopter can accomplish more in one hour than ground equipment can in one day. This means less fuel used, less air pollution and no soil compaction. To produce future food and fiber and leave room for wildlife we must increase production on the land we are now using. High-yield agriculture benefits the environment by producing maximum crop yields from fewer acres. Aerial application is a critical component of high-yield agriculture. Aerial application is used extensively in soybeans to control the emerging soybean aphid pest. Soybean aphids can be a devastating pest causing extensive damage of up to 10-20 bushels per acre or more. Aphids have shown an ability to develop resistance quickly to treatments due to multiple generations each season. Pyrethroids are used extensively now to control this pest and these products are prone to resistance developing if overused. Maintaining alternate classes of chemistry is important for this pest because of both efficacy and insect resistance management (IRM). The carbamate chemistry offers an important alternative. In addition, aerial application is used in many crops like alfalfa where ground application may cause crop damage. Pilots have relied on carbofuran for many years to provide quick and effective control of alfalfa weevils. It is especially effective on alfalfa weevil larvae in the spring when the weather is cool. If this carbamate insecticide were not available, multiple applications of other pyrethroid products may be required. Grasshopper epidemics occur sporadically in many crops and especially in wheat. Aerial application of carbofuran has proven to be the most effective treatment on this pest -especially for large hoppers. High rates of other products would be necessary if carbofuran was not available. In regards to determining the occupational effects of using pesticides via aerial application, FMC?a manufacturer of Furadan which includes the active ingredient carbofuran?has initiated many mitigation steps for Furadan to help limit environmental and worker risks that are important to aerial applicators. These include 100% of the product being provided in closed containers, returnable containers limiting the need for disposal and…

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May 4, 2006· Comment submitted by A. D. Moore, National Agricultural Aviation Association· EPA-HQ-OPP-2005-0162-0142

Attached Comments on Carbofuran from the National Agricultural Aviation Association

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Abstract

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Co-filers (60)

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