Cyfluthrin Registration Review

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

RE: Pyrethroids Ecological Risk Assessment, Cyfluthrins; Docket ID No. EPA-HQ-OPP-2010-0684 The Northwest Horticultural Council, a regional trade association representing tree-fruit growers, packers, and shippers in the states of Idaho, Oregon, and Washington, submits the following comments on the use of pyrethroids, their importance to the Pacific Northwest tree fruit industry, and our concern regarding the impact an adverse risk assessment might have on our industry. Pacific Northwest states produce approximately 66 percent of the U.S. apple crop and supply 77 percent of the U.S. fresh apple market. 74 percent of the total U.S. pear crop is produced in the Northwest. 78 percent (by volume) of cherries (fresh consumption) are also produced in these states. Approximately a third of the crop is exported each year which amounts to more than 90 percent of U.S. apple and pear exports and 65-75 percent of U.S. cherry exports. The Council supports the long-established, rigorous, and science-based pesticide registration review process established under the Federal Insecticide Fungicide, and Rodenticide Act (FIFRA). FIFRA requires EPA to engage in a risk-benefit analysis in its regulation of pesticides. Ecological risk assessments to ensure that approved uses of pesticides are not likely to cause harmful effects to terrestrial and aquatic life are an important component of the review process. This is a complex process that must account for pesticide use patterns, the chemical properties and behavior that influence environmental fate and transport. A thorough and holistic approach that relies on sound science and robust data ensures that risk conclusions are as closely tied to real-world conditions as practicably possible. Water, soil, air, and the beneficial orchard biota must remain healthy for our industry to produce the high quality tree-fruit our region is known for. Pyrethroids are vitally important to the production of tree-fruit, particularly orchards that are under the threat of brown marmorated stink bug (Halyomorpha halys) (BMSB) which has devastated many crops in the eastern and central United States and is marching across the continent toward our region. Maintaining the option to treat tree-fruit with pyrethroids to control BMSB when it becomes necessary is of extreme importance. In a publication posted to the stopbmsb.org website , the national BMSB Specialty Crop Research Initiative Coordinated Agricultural Project Orchard Crop Commodity Team has indicated that of sixteen pest products identified to effectively control BMSB, twelve of these beneficial products are pyrethroids. Listed alternatives include neonicotinoids and carbamates. Restrictive use of pyrethroids as a result of a constraining ecological risk assessment could greatly affect the ability of commercial tree-fruit producers to safeguard their orchards from this invasive pest. In addition to controlling BMSB, pyrethroids are utilized in pear production to combat pear psylla and in cherry production as a rotation product alternative to spinosyn, applied to control the invasive species (and quarantine pest) spotted wing drosophila. Most industries have moved to the use of "softer" chemicals, but overuse and potential resistance is a looming concern. Pyrethroids are used in this application to reduce that risk. Cyfluthrin, the pyrethroid specifically listed in this docket, is currently used on less than one tenth of one percent of tree-fruit produced in the Pacific Northwest. While use may increase in the future should BMSB become as significant of an issue for our growers as it is for our eastern and Midwestern counterparts, this low usage rate shows that our growers only utilize this product when necessary. The family farmers we represent are committed to using crop protection tools in ways that are protective of orchards, people, and the environment. It is critically important that EPA maintain the registration and use of these pyrethroid products…