The Agricultural Retailers Association has submitted written comments on atrazine that were submitted to EPA on Tuesday, May 29. From June 12-15, 2012, the EPA’s Federal Insecticide, Fungicide, and Rodenticide Act Scientific Advisory Panel (FIFRA SAP) will consider and review Problem Formulation for the Reassessment of Ecological Risks from the Use of Atrazine. ARA has submitted similar written comments during previous SAP meetings for this product.
Here is a copy of the letter ARA submitted.
Office of Pesticide Programs
Regulatory Public Docket (7502P)
U.S. Environmental Protection Agency
1200 Pennsylvania Avenue, NW
Washington, D.C. 20460-0001
On behalf of the Agricultural Retailers Association (ARA), I submit the following comments regarding the EPA’s Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) Scientific Advisory Panel to consider and review alleged problem formulation for the reassessment of ecological risks from the use of atrazine.
Statement of Interest
ARA is a not-for-profit trade association that represents America's agricultural retailers and distributors. ARA members provide goods and services to farmers and ranchers which include: fertilizer, crop protection chemicals, seed, crop scouting, soil testing, custom application of pesticides and fertilizers, and development of comprehensive nutrient management plans. Retail and distribution facilities are scattered throughout all 50 states and range in size from small family-held businesses or farmer cooperatives to large companies with multiple outlets.
Critical Crop Protection Tool
Atrazine is a critical crop protection tool widely used by agricultural retailers and commercial applicators. According to data from GfK Kynetic, in 2009 atrazine was applied to more than 53 million base acres. Atrazine is annually applied on well over half of all U.S. corn acres, two-thirds of U.S. sorghum acres, and as much as 90 percent of U.S. sugar cane acres. It is also an important tank mix partner that adds another mode of action to improve effectiveness and performance of other herbicides. A report released by Professor of Agronomy Michael Owen of Iowa State University in November 2011 called “The importance of atrazine in the integrated management of herbicide-resistant weeds” highlights atrazine’s unique mechanism of action that complements the use of other herbicides with other mechanisms of action. According to Professor Owen’s study, “without atrazine, it is anticipated that a number of weeds could not be effectively managed in corn, sweet corn, sorghum and sugarcane…It is likely these weeds would escalate more rapidly in economic importance if atrazine were not available.” EPA previously estimated that farming without atrazine would cost $28 per acre in alternative herbicides and reduced yields, which would result in costing American farmers more than $2 billion.
Reduces Soil Erosion
The use of atrazine products has allowed American farmers to utilize more conservation tillage and no-till systems that help protect topsoil and reduce erosion. According to the Conservation Tillage Information Center, conservation tillage can reduce soil erosion by as much as 90 percent. It is estimated that 64 percent of atrazine used in corn allowed for no-till or conservation farming (Source – GfK Kynetec).
The environmental benefits of conservation tillage include:
• Improves soil and water quality by adding organic matter as crop residue decomposes; this creates an open soil structure that lets water in more easily, reducing runoff
• Conserves water by reducing evaporation at the soil surface
• Conserves energy due to fewer tractor trips across the field
• Reduces potential air pollution from dust and diesel emissions
• Crop residue provides food and cover for wildlife
Source: Minnesota Department of Agriculture
Over Fifty Years of Proven Safety
Atrazine has been on the market for over 50 years and is the most heavily studied and tested crop production product for safety with over 6,000 studies from around the world. Previous EPA officials and FIFRA Scientific Advisory Panels have found the herbicide “not likely to be carcinogenic.” These EPA findings are consistent with findings of the World Health Organization (WHO) and other government agencies such the United Kingdom (UK), Canada, and Australia. In addition, recent findings from a U.S. Geological Survey entitled “Regression Models for Estimating Concentrations of Atrazine plus Deethylatrazine in Shallow Groundwater in Agricultural Areas of the United States” point out that even in untreated groundwater in agricultural areas where atrazine is used, if any residues occur at all the concentrations are low and would assure large safety margins in drinking water. In 2010, the WHO raised its recommended safe level of atrazine in drinking water from 2 parts per billion (ppb) to 100 ppb. EPA’s drinking water standard of 3 ppb is highly protective with a larger margin of safety, larger than even the WHO standard.
In determining whether to cancel or change a classification of a registered pesticide such as atrazine, the EPA needs to take into account the impact of the action proposed on production and prices of agricultural commodities, retail food prices, and otherwise on the agricultural economy. Atrazine is a cost-effective, reliable, and essential tool for no-till and conservation tillage systems as well as integrated pest management programs. It is also proven safe to humans and the environment and it is essential that the agricultural community continue to have it available.
ARA members and their farmer customers have safety used atrazine for decades and we support the continued use of this product. With proper monitoring and the use of agronomic and science-based decisions, atrazine will continue to provide significant benefits for agricultural retailers, farmers, and consumers. EPA needs to make decisions about pesticides based solely on science and respond to scientifically based justified petitions and requests (i.e. those with data citations with referenced sources). In determining whether to issue Petitions based on hypothetical allegations and research that has not been properly peered reviewed should be rejected by EPA as they take away from limited agency resources that could be used on fact based scientific analyses and judgments. Thank you for your review and consideration of our written comments.
Sr. Vice President, Public Policy & Counsel