By Dave Puglia, Senior Vice President, State Government Affairs & Communications
and Hank Giclas, Senior Vice President, Strategic Planning, Science & Technology
There is a sense of urgency today at Western Growers as we begin to understand the scale of several attacks on proven and effective crop protection tools of the utmost importance to specialty crop agriculture. New legislation at the federal, state and even local levels, increased media coverage fueled by activists, and precautionary approaches at key regulatory junctures and decision points threaten both the short and long term viability of fumigants and neo-nicotinoids.
The key foils of the activist and regulatory communities are the possibility of a fumigant connection with cancer and the health of pollinating insects (bees) as relating to the neo-nicotinoids. Hostile activist groups and some legislators are working relentlessly to severely restrict or even completely block the use of these key categories, alleging that they negatively impact the health of humans and bees.
Let’s look briefly at their arguments.
Research indicates that multiple factors are at work in the “colony collapse disorder” associated with decline of the bee population, and that the impact of these few insecticide products is minimal. Yet we continue to hear strong and persistent voices targeting crop protection products (some specific, others very general) and the farmers that rely on those products. On the international level we have witnessed suspension of the use of these products and those suspensions are now being contemplated in other countries including the United States. This action would have sweeping consequences for farmers across the country. Not only would such a move change the face of agriculture in the United States by severely hampering productivity, but it would negatively impact competitiveness of U.S. agriculture in international markets.
Are these actions based on science?
The increasingly shrill and brazen activist voices in the public debate continue to blame crop protection products entirely for the woes of bees, while trampling and ignoring the overwhelming scientific evidence to the contrary. When honeybee colonies appear to suffer, it is easy to blame pesticides, because the evidence is made murky and investigation is inconsistent or entirely lacking. Inexplicably, there exists no robust program to investigate, determine and enforce compliance with validated Best Management Practices in beekeeping that would quantify the real, top causes of poor bee health: rampant parasite infestations in the hives, serious bee disease problems, “overworking” of some bees, monolithic bee genetics, and difficulties with nutrition of the bees.
It is important to understand and address all the pressures on pollinators and not to simply ban or suspend crop protection tools because it is the easy thing to do. (Interestingly, we see activist environmental groups take a similar tack in their push to cut water pumped to San Joaquin Valley farmers from the Sacramento-San Joaquin Delta; despite mountains of evidence pointing to multiple factors for the decline of the delta smelt and other protected fish species, they point only to the pumps.)
Likewise, fumigants are under attack.
At the federal level, a review of registration for all fumigants has been initiated and through that review much new data will be generated and brought forward to inform the U.S. Environmental Protection Agency (EPA) as the agency considers modifications in labels, uses and mitigation strategies.
In California, however, there is an ongoing pressure by activists to eliminate this category of compounds despite the fact that there are no efficacious alternatives available to producers. Chloropicrin, a compound that has been used safely in California for more than 60 years, is the most urgent example. Since 2001, a unit within Cal/EPA — the California Department of Pesticide Regulation (DPR) — has been reviewing the use of this compound. Data submitted to regulators found that it has the potential to cause adverse health effects at low doses and the National Institute for Occupational Safety & Health (NIOSH) set an eight-hour time weighted average of 0.1 parts per million (ppm) as the reference exposure limit for workers exposed to chloropicrin, primarily for the prevention of eye irritation in humans. This data set the parameters for California-specific regulation while DPR continued for the next several years gathering information on worker exposure, air quality monitoring data and dietary information.
In May 2013, DPR proposed mitigation measures designed to protect bystanders and residents from acute (short-term) exposures to chloropicrin and requested comments. The measures include additional restrictions beyond labeling and regulation to protect residents and bystanders including: buffer zones; buffer zone credits; acreage limits; time periods between applications with overlapping buffer zones; emergency preparedness and response; and notice of intent requirements.
Western Growers has commented on these proposed measures and DPR will defer concluding the reevaluation until an occupational, seasonal, and chronic Risk Mitigation Decision is completed. That reevaluation might trigger additional mitigation measures.
In the meantime, a separate regulatory unit of Cal/EPA, in concert with several environmental groups, is claiming that chloropicrin is carcinogenic in spite of the fact that no agency outside the state of California has ever reached that conclusion. Like yelling “Fire!” in a crowded theater, their claim that chloropicrin is cancer-causing is designed to cause a regulatory panic, with the intended outcome being the banishment of chloropicrin.
The stakes are enormous; should the activists succeed here, the few remaining fumigants available to California growers would likely come under fire as well.
Western Growers is engaged in the defense of these critical tools and will remain active at the federal, state and local levels. We work with the discrete chemical owners (registrants) to support efforts to maintain the broadest access and fewest restrictions on use. When restrictions are necessary we work with regulators to ensure they are based on science and that they protect public health without diminishing efficacy in the field. This marriage of science and policy is where the Government Affairs and Science & Technology units at Western Growers come together for the benefit of our members.
Most importantly, we recognize that this is not simply a matter of good science and sound policy-making. It is a political fight being waged by activist organizations that thrive on the fear they spread among consumers by twisting science to paint all pesticide use as fundamentally toxic to human health, the environment or both.
Every agriculture association in the country needs to recognize this reality and work together to educate consumers, elected officials and regulators and to protect the integrity of our federal and state pesticide regulatory systems.
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