ARA submits comments on atrazine for FIFRA SAP
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.