Endosulfan: Updated Risk Assessments, Notice of Availability, and Solicitation of Usage Information

National Potato Council Review of EPA BEAD Report "Assessment of the Impacts of Extending the Restricted Entry Intervals for Endosulfan on Potato" The Environmental Protection Agency (EPA or Agency) has suggested the Restricted Entry Interval (REI) for endosulfan be extended to 18 days for potatoes. A restriction of this magnitude would be tantamount to cancelling the products on this crop. Since the Agency has not indicated that there is significant dietary risk, the discussion involving endosulfan should focus on balancing risk versus benefits. The National Potato Council (NPC) believes that due to the benefits associated with endosulfan use on potatoes, the Agency should direct its attention toward risk mitigation as opposed to proposing restrictions that would functionally cancel the product. The NPC represents more than 95 percent of the potato growers in the 34 states in the United States that produce commercial quantities of potatoes. The value of potato production in the United States exceeds $3.5 billion annually and that economic value is greatly increased as a result of further processing, packing, handling and retailing. Potatoes are an expensive crop to grow and the economic risk to growers for damage to crops from various pests can be significant. For an efficient producer, the cost of producing an acre of potatoes can easily exceed $3,000. Therefore, the economic losses from a crop that is compromised by pests or disease can be devastating. For this reason managing pests of concern in potatoes is even more critical than for crops with significantly lower costs of production. The National Potato Council (NPC) has reviewed the report by Chiri and Donaldson and has the following comments. •The fourth sentence of the EPA review says that endosulfan has a relatively minor role in potato pest management. If one looks at the most recent National Agricultural Statistics Service (NASS) data, it shows of the 23 most commonly used insecticides on potatoes, 14 are more widely used than endosulfan and 8 are less widely used. This volume of use makes endosulfan a product of medium importance in terms of usage. The use data clearly indicates that endosulfan is not a minor use product on potatoes. More importantly, even if a product is used less than many other products it does not mean the chemical is not locally important. The recent NPC report (attached to this submission) on endosulfan, demonstrates that the product is locally important in diverse potato growing regions. •In sentence 5 , EPA mentions that potato tuberworm (PTW) is a pest in Washington but overlooks the information that PTW has been a huge problem in Oregon as well, and is of great concern in Idaho. There is no reason to believe that PTW will not be spread to Idaho from Washington and Oregon. Two more times in the document EPA references their belief that PTW is only a problem in Washington. •The first sentence of the second paragraph of the EPA report states that they are proposing to change the REI from 1 day to 18 days. It is hard to reconcile that endosulfan would need an REI of 18 days when products such as methamidophos, carbofuran, oxamyl, ethoprop, phosmet, phorate and methomyl have substantially shorter REI. •Later in this paragraph EPA states that growers and workers have no training and no access to personal protection equipment. First, all growers and custom applicators understand the requirement to comply with pesticide labels. Growers and custom applicators regularly provide appropriate PPE to their workers. •When EPA mentions endosulfan use it relies on NASS and on proprietary data which usually means Doane data. These sources are based on surveys in the larger potato growing state. The NPC believes that endosulfan use is concentrated not only in the Pacific Northwest, but also in smaller potato growing states where usage data is not collected. Because of thi…

NATIONAL POTATO COUNCIL 1300 L Street, NW, Suite 910 Washington, DC 20005 202.682.9456 ? 202.682.0333 fax www.nationalpotatocouncil.org spudinfo@nationalpotatocouncil.org February 14, 2008 Office of Pesticide Programs (OPP) Regulatory Public Docket (7502P) Environmental Protection Agency 1200 Pennsylvania Ave., NW Washington, DC 20460?0001. RE: Docket Identification (ID) number EPA?HQ?OPP?2002?0262 To Whom It May Concern: This letter is being provided to the U.S. Environmental Protection Agency?s (EPA) announcement on the availability of updated human health and ecological effects risk assessments and subsequent opening of the comment period for endosulfan, as outlined in the November 16, 2007 Federal Register Notice. The National Potato Council (NPC) is the only trade association representing commercial potato growers in 50 states. Our growers produce both seed potatoes and potatoes for consumption in a variety of forms. Annual production is estimated at 437,888,000 cwt. with a farm value of $3.2 billion. Total value is substantially increased through processing. The potato crop clearly has a positive impact on the U.S. economy. The NPC appreciates and welcomes the opportunity to supply the EPA with input on this important topic. Endosulfan has a long history of use in the U.S. potato industry. It is used against an unusually wide spectrum of pests including a number of problem insects not commonly thought of as pest management challenges in potatoes. It is one of only two products that are effective against the silverleaf whitefly in California and the Gemini virus transmitting whiteflies in Florida. It has an unusually important role in resistance management. It is specifically identified in resistance management programs in the Pacific Northwest, the South East, Texas and California. It is repeatedly recommended as a product that can control a mixture of pest species that other insecticides cannot control. The combination of its spectrum of control, resistance management role, short pre harvest interval, flexibility in methods of application and low relative toxicity to beneficial organisms make it an important tool for potato growers in all regions of the United States. In the Pacific Northwest, endosulfan is primarily used to control Colorado potato beetle (CPB). CPB has developed resistance to pyrethroid insecticides in Idaho and Oregon. The development of resistance has been documented by Dr. Juan Alvarez, entomologist, University of Idaho. Endosulfan has been proven to be effective against pyrethroid resistant CPB populations in this region. Endosulfan is also used to a lesser extent against beet leafhopper and the false chinch bug. In Michigan and Wisconsin, endosulfan is used to control potato leafhopper. It is most commonly applied once per season, usually in rotation with products belonging to other classes of chemistry. In Maine, endosulfan is applied by ground when growers have a mixed assemblage of pests that do not often occur and it is one of the products of choice against armyworms. Endosulfan is one of two products recommended for control of silverleaf whitefly in potatoes in California (http://www.ipm.ucdavis.edu/PMG/ selectnewpest.potatoes.html). More than one application is needed per season, and due to severe concerns with resistance, endosulfan should be rotated with dinotefuran. It is one of three products recommended for control of aphids in California potatoes. It is one of five products recommended for control of flea beetle. Endosulfan is an important product for potato production in the Mid-Atlantic states. Following is an excerpt from the Pennsylvania potato crop profile: ?During late June or Early July, aphids begin the destructive portion of their life cycle.At this time, endosulfan is rotated with the Organophosphates to manage Colorado potatobeetle, potato leafhoppers and aphids. At this time of the season, the pyrethroidinsecticide…

Filed on regulations.gov — full text not in the inline record.