Without crop protectants, up to 40 percent of the world’s food production would be lost to pests and diseases. So why is the government constantly trying to take away our crop protection tools?
Western Growers has a long history of advocating for the registration and safe use of pesticides that are critical in the production of healthy crops. In the past several years, regulations around the use of pesticides, herbicides and insecticides have significantly increased. For example, the California Department of Pesticide Regulation (DPR) recently announced that it intends to further restrict the use of pesticides near schools. This regulation would likely become effective in 2017. Not long after, the U.S. Environmental Protection Agency (EPA) flexed its regulatory muscle and issued a notice of intent to ban commercial insecticides made with flubendiamide, or Belt, in the United States. The cancelation would be a significant loss for growers as Belt is currently registered for use on more than 200 crops including almonds, pistachios, lettuce, strawberries, tomatoes and bell peppers.
There is no doubt that the battle to keep our critical tools is heating up. Crop protection is at the forefront of Western Growers’ core policy concerns, and the association is continually educating decision makers on the unique challenges that face the agricultural industry. With plants competing with 30,000 species of weeds, 3,000 species of nematodes and 10,000 species of plant-eating insects, crop protection products are crucial for an abundant and reliable food supply.
Considering that California already has the most restrictive crop protection regulations in the country, WG’s priority is to advocate that any future restrictions need to be based on scientific evidence.
All pesticides that are registered in California must also first be registered with the EPA. EPA requires all pesticides to undergo up to 120 health, safety and environmental tests before a product is registered for sale and use. In fact, the use and development of these products are regulated by the EPA primarily under two federal laws: the Federal Insecticide, Fungicide and Rodenticide Act and the Federal Food, Drug and Cosmetic Act. This pesticide registration process takes an average of nine years and costs pesticide manufacturers $150-$250 million for each crop protection product. In fact, only 1 in 139,000 chemicals make it from the laboratory to the farmers’ fields.
Once federally registered, pesticides must be cleared through DPR’s stringent approval process before use in California. To start, DPR requires that each product registration must be accompanied by the following:
• Cover letter detailing in-depth data and reasoning for submission.
• California Application for Pesticide Registration with information about active and inert ingredients.
• Proposed marketing/production/container labels with copies of different sizes and various languages.
• Scientific data (e.g., residue data, exposure information) to support registration.
• U.S. EPA stamped-accepted label and accompanying letter of acceptance.
• Up to $6,350 in application fees.
After all the information is received and indexed by DPR, only then does the actual pesticide registration process begin. This includes a submission evaluation process to ensure that no additional data is needed, a formal scientific evaluation where the request is routed to a number of different departments for even more assessment, and a 30-day period for public comment prior to approval or denial.
Compared to EPA, DPR’s process for pesticide registration requires far more data and steps. For example, EPA does not generally require product performance data to be submitted to support registration of non-public health products. DPR requires data to be submitted for each and every product. DPR may also require supplemental data to support the registration or amendment of a pesticide product (e.g., hazards to bees, indoor exposure).
Thousands of pages of test data are rigorously reviewed and scrutinized by scientific and administrative branches of the EPA and DPR before crop protection products gain approval. Because the process to deem a pesticide safe for use is extremely extensive, any type of additional restrictions should be scientifically justified. There needs to be hard data to support new rules requiring growers to implement larger buffer zones or limit their use of certain application methods.
Anti-pesticide groups that push for more regulation in our state fail to understand (or, more likely, don’t care about) the multi-level process that governs the manufacture, sale, distribution and use of pesticide products. They also ignore the fact that the decision to develop pesticides is carefully based on current and potential crop threats and the increasing consumer demand for fresh, safe food.
The world population has doubled in the past 40 years and the land devoted to crop production has remained nearly constant. The crop protection toolbox has enabled growers to produce higher yields on the same amount of land. With so many people to feed, farmers will need to continue relying on crop protection tools and technologies to sustain a reliable global food production. Western Growers is committed to preventing regulators to arbitrarily take them away.
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