In its release of a pre-publication copy of the Notice of Data Availability (NODA) related to its assessment of the human health risks associated with the insecticide chlorpyrifos, the U.S. EPA took another step toward finalizing its proposal to revoke all food tolerances for this critical tool for U.S. agriculture.
“We disagree with the chlorpyrifos NODA and with key aspects of the underlying assessment,” said Phil Jost, Dow AgroSciences Portfolio Marketing Leader, U.S. Crop Protection Insecticides. “The assessment lacks scientific rigor, is contrary to EPA and Administration policies of data access and transparency in scientific decision-making, and falls short of the FIFRA requirement that decisions be based on valid, complete and reliable scientific data. However, it is important to note this NODA is not a final decision.”
Prior to the announcement, on October 30, 2015, EPA announced a proposal to revoke U.S. food tolerances for chlorpyrifos. This proposal was an outcome of a U.S. Ninth Circuit Court of Appeals decision ordering the EPA to respond to allegations about chlorpyrifos made in a 2007 petition. The EPA’s proposal to revoke tolerances was made before the Agency had finished its formal health and safety evaluations of chlorpyrifos. Dow AgroSciences stated that it remains confident that authorized uses of chlorpyrifos products, as directed, offer wide margins of protection for human health and safety.
Dow AgroSciences is concerned that the NODA cannot be reconciled with the requirements of the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) and the Agency’s own guidelines, policies and procedures.
According to Dow AgroSciences, chlorpyrifos is a critical tool for growers of more than 50 different types of crops in the U.S. For many important pests, growers face limited or no viable alternatives to chlorpyrifos. When an outbreak of a new pest occurs, growers look to chlorpyrifos as a proven first-line of defense.
The EPA will be opening a 60-day public comment period for the NODA and indicated this to be the last opportunity for stakeholders to express their need for chlorpyrifos and call for EPA to rely on sound and transparent science and regulatory process.
The court ordered EPA to make a final decision on the petition by March 31, 2017, but did not specify what that decision should be. The EPA can deny the petition and retain all tolerances, which would be consistent with the science and allow the Agency to complete its registration review and address their remaining concerns in an orderly manner.