As you probably know, on October 30, 2015, U.S. EPA announced a proposal to revoke US crop tolerances for the insecticide chlorpyrifos. This proposal is an outcome of a recent U.S. Ninth Circuit Court of Appeals decision ordering EPA to respond to allegations about chlorpyrifos in a 2007 activist petition, even before the Agency has finished its formal health and safety evaluations of the product currently underway in registration review. If this revocation of crop tolerances occurs, U.S. Growers will not be able to apply chlorpyrifos to their crops.

EPA said it will not act on its proposal to revoke crop tolerances until it has received and responded to input from interested stakeholders, including growers who rely on chlorpyrifos containing products to protect their crops and livelihood from destructive insect pests. EPA’s proposal would not affect the 2016 growing season.

EPA needs to hear from you about why chlorpyrifos is an important pesticide tool for your customers! “Specialty Crops” like hazelnuts and cranberries are especially at risk for cancellation, leaving growers with few alternatives to combat certain pests.

>> Comments are due by January 5, 2016. << Products containing chlorpyrifos include: Cobalt Cobalt Advanced Lorsban Lock-On Nufos 4E Vulcan Warhawk and others, check your labels! More details about the proposal from EPA can be found HERE.

In addition to the letter we have provided, feel free to craft the letter as it pertains to your customers and please share the link to our Action Alert so they may submit comments as well. Important items they should include in their comments are:

– The need for chlorpyrifos for the success of your operation.
– Why chlorpyrifos is critical for production?
– Impact if the product is no longer available?

Why chlorpyrifos is important for you. Consider such aspects as:
– Broad spectrum control
– Effectiveness
– Cost effectiveness
– History of use and knowledge of how it works
– How it fits into insect resistance management programs
– Advantages over alternatives. Not just for production, but also things such as if it is more favorable on beneficials

Other aspects of the use of the product that will help the Agency’s evaluation:
– Application timing relative to the seasons, especially if the applications occur in the dry season when runoff would not be a concern (EPA is focused on drinking water concerns).
– Are all application methods used in your area or is your situation specialized?

In the summary below, we outline concerns in each of the three areas. We have also provided the following suggested template for comments to be filed file with EPA (EPA-HQ-OPP-2015-0653-0001) before the deadline of January 5, 2016.
The more you can customize comments based on specific crops, experiences, and situations, the greater impact you will have on EPA’s direction and decisions.

It is critical that the EPA hears from the agriculture community to better understand the true consequences of this proposed action. If implemented “as is” it will set precedents with far-reaching consequences which could severely limit crop production and Ag industry’s ability to manage pests.