The U.S. EPA took another step toward finalizing its proposal to revoke all food tolerances for chlorpyrifos with its November 10 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.
The NODA release drew quick response from Dow AgroSciences, on behalf of U.S. farmers.
“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.”
Chlorpyrifos is a long-standing, critical tool for growers of more than 50 different types of crops in the United States. According to the Dow AgroSciences statement, growers face limited or no viable alternatives to chlorpyrifos for control of many important pests or for outbreaks of new pests.
On October 30, 2015, EPA announced a proposal to revoke U.S. food tolerances for chlorpyrifos, based on 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 remains confident that authorized uses of chlorpyrifos products, as directed, offer wide margins of protection for human health and safety. The company 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.
The EPA will be opening a 60-day public comment period for the NODA, noting that this will be the last opportunity for stakeholders to express their need for chlorpyrifos and to 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 any remaining concerns in an orderly manner.
Source – Dow AgroSciences