oncerns with bio-security and bioterrorism for food and agriculture greatly increased in 2004. That prompted closer agency coordination and the NCC monitoring of regulatory requirements’ development.
The NCC prepared fact sheets for ginner and cottonseed sectors regarding the Food & Drug Administration (FDA) food/feed rule promulgated in response to the Bioterrorism Act of 2002 and for warehouse members to help them comply with the USDA security plan requirements caused by Department of Homeland Security (DHS) Presidential Directives. These directives also led to detailed DHS, FDA and USDA communication efforts affecting agriculture and feed/food handlers and processors. Chemical security legislation that would affect agricultural chemicals will be reintroduced in 2005.
In that vein, the NCC worked with USDA’s Animal & Plant Health Inspection Service (APHIS) on a proposed Environmental Impact Statement in connection with the potential changes to the regulation of the importation, movement and release of transgenic organisms. The NCC also sought to properly fund this effort in the 2005 fiscal year. Comments also were lodged in support of APHIS’ deregulation of Widestrike Insect Protection, which helped ensure its availability for the 2005 growing season.
The NCC’s Electronic Documents Task Force began the development and implementation of electronic phytosanitary documents. That need arose as recent shifts by USDA and Homeland Security prompted changes affecting APHIS’ phytosanitary inspections and certificates on U.S. raw cotton. The NCC Phytosanitary Accreditation Protocol Task Force, chaired by North Carolina warehouseman Coalter Paxton, III, was created to harmonize the accreditation processes throughout APHIS to ensure U.S. cotton’s continued timely flow into world markets.
A NCC priority is the re-registration process for the approval of current, reliable crop protection products. That included coordination with EPA’s Special Review and Re-registration Division on the re-registration of several insecticides, herbicides and fungicide seed treatments. NCC help was given in identifying use patterns and changes in cultivation practices that have occurred since the passage of the 1996 Food Quality Protection Act, which requires the re-registration of chemicals labeled before 1984. As the August 2006 deadline for re-registration approaches, the NCC is working to insure that several key crop protection products, including aldicarb and malathion, will continue to be available to cotton producers. Specific agency concerns, such as endangered species risks, also were addressed.
The NCC also communicated with EPA to: 1) ensure timely registration and availability to producers of biotechnology traits, and 2) help formulate a position for defending feasible Bt cotton refuge options, including urging the adoption of a resistance management component in EPA’s Section 18 change proposal.
All Cotton Belt regions are either under active eradication or have been eradicated of the boll weevil except for one Texas zone that was to vote in early 2005.
The Boll Weevil Action Committee’s (BWAC) post eradication transition subcommittee developed protocols for those activities. A Technical Advisory Committee also was appointed to provide technical expertise on post eradication related issues. The USDA reported that the Boll Weevil Farm Services Agency Loan Program was “an unsung success story” with an excellent loan repayment record.
The Pink Bollworm Action Committee (PBAC) remained committed to securing full funding for the program that was initiated in Trans Pecos/El Paso, South Central New Mexico and Chiahuahua in adjacent Mexico. The PBAC also agreed that if supplemental funding becomes available for 2005, the pink bollworm eradication program would implement the program’s sterile moth component. The BWAC voted to support the dual pink bollworm and boll weevil eradication programs along the U.S./Mexico border by setting aside funds for possible use in these programs.
Along with other agricultural interests, the NCC worked within the Pesticide Policy Coalition (PPC) to ensure EPA gave final guidance on whether clean water permits would be required for proper application of pesticides under the Federal Insecticide, Fungicide & Rodenticide Act. The PPC sent a letter to EPA encouraging the agency to respond formally to an Idaho county’s request for a National Pollutant Discharge Elimination System permit for mosquito control spraying. The Senate included report language in its 2005 appropriations process directing EPA to make their July 2003 interim guidance final.
Coordination with the American Farm Bureau Federation, CropLife America, regional cotton interest organizations and others resulted in a strong show of support for the joint counterpart regulations for the Endangered Species Act (ESA). The NCC continued to advocate the development of counterparts as a scientific means in which threats to endangered species can be determined. The NCC also communicated with Cotton Belt Congressional members in support of two separate “agriculture-friendly” bills that would amend the ESA.
Efforts were redoubled on cotton quality and flow.
The NCC re-emphasized its seed cotton/lint contamination prevention campaign. In coordination with the National Cotton Ginners Association, USDA and others, advisory stickers and updated brochures were sent to ginners with recommendations of ways to prevent lint contamination. The goal was to reach producers, custom harvesting crews and ginning crews about the importance of zero contamination tolerance and maintaining the industry’s reputation for delivering clean, pest free cotton.
The NCC’s Quality Task Force, chaired by Texas producer/ginner Larry Nelson, asked the NCC to issue an industry advisory cautioning ginners to exercise care in adding moisture because of still undetermined quality risks.
NCC, Cotton Incorporated, University of Georgia and industry specialists developed consensus recommendations regarding agronomic, harvesting and processing decisions that ensure optimum fiber quality is produced and preserved. They focused on a multitude of factors alleged to cause increase in short fiber, especially in prior years’ southern Georgia and Florida growths.
The Joint Cotton Industry Bale Packaging Committee’s specifications for the 2004 crop included a USDA requirement that bagging manufacturers discontinue manufacturing strip-coated and randomly-coated woven polyolefin bagging in favor of fully coated bagging. Use of existing inventories of strip-coated bagging was allowed as long as those bags were manufactured prior to May 11, 2004, the date the revised packaging specifications went into effect.
Working with its Cotton Flow Committee and industry trade organizations, the NCC submitted comments to the Commodity Credit Corporation’s (CCC) proposal on warehouse standards. The NCC conveyed the industry’s belief that outside storage is inconsistent with safe and effective storage of CCC interest commodities.
A NCC Rack Sample Study Committee survey examined the usage and handling of bale (rack) samples in order to evaluate the costs/benefits of current practices and their effect on marketing and flow. The Committee recommended to the NCC Board that economic benefits of samples to the merchant and mill be investigated and sample handling practices and uses continue to be monitored.
Cotton is well represented on the recently reappointed USDA Agricultural Air Quality Task Force (AAQTF). That panel advises USDA to help insure that the best available science is used by EPA in all air regulations that affect agriculture. Particulate matter (PM) and ozone (volatile chemicals from pesticides are precursors) are key issues which potentially could lead to “permit to farm” type regulations. AAQTF members include: Dr. Calvin Parnell and Dr. Brian Shaw, Texas A&M University; Kevin Rogers, Arizona producer; Robert Avant, Jr., Texas Food & Fiber Commission; Roger Isom, California Cotton Growers & Ginners Association; and NCC Senior Scientist Dr. Phillip Wakelyn.
NCC also is working with several coalitions on the revision of the PM national ambient air quality standards to make them more appropriate for agriculture.
In other key 2004 activities, the NCC:
- coordinated a Cotton Belt tour for Egyptian officials on a Cotton Belt tour, in conjunction with CCI and USDA-APHIS, that demonstrated: 1) how U.S. cotton production and ginning practices eliminate the risk of U.S. baled cotton exports transporting live boll weevils or other cotton pests and 2) why costly fumigation of densely-packed baled cotton is not necessary.
- joined with several coalitions to help farms, gins and oil mills that are affected by the EPA oil spill prevention and response Spill Prevention Control and Countermeasure (SPCC) plan regulations. EPA extended the compliance dates deadlines for amendments to the SPCC by 18 months and is considering potential rulemakings for oil filled process equipment and facility threshold, which could be important for gins and cotton production.
- worked to ensure that the potential flammability standards do not unfairly affect cotton products. Such standards, which could affect more than 4 million bales of cotton, are being developed by the Consumer Products Safety Commission and California Bureau of Home Furnishings for upholstered furniture, mattresses and bedclothes, and general wearing apparel.
- assisted in Occupational Safety & Health Administration-related issues, particularly with cotton dust and hazard communication.
- monitored EPA and FDA actions on dioxin in food and feed that could severely affect cottonseed products.
- communicated positive science-based information on biotech cotton’s benefits by presenting a paper at an international conference, helping prepare a book chapter and participating on the “Report of the Second Expert Panel on Biotechnology of Cotton.”
- led reviews of USDA Agricultural Research Service post-harvest cotton and fiber bioscience research, which exceeds $12 million.
- changed the 2005 Beltwide Cotton Conferences to a concise, three-day format.
- followed the hours-of-service lawsuit and the DC Circuit Court of Appeals stay on further action that ensured trucking operations, including cotton module trucks, were not hampered during the 2004 season.
- succeeded in getting several amendments to rules controlling air pollutant emissions from vegetable oil processing, including exempting users of extraction solvents, other than hexane, from detailed air quality recordkeeping and reporting requirements.
- initiated revisions of fire, building and other codes that apply to densely-packed cotton bales. This was a necessary step as both the National Fire Protection Association and International Code Council had adopted codes that erroneously classified densely-packed baled cotton as a highly combustible material and therefore, a hazardous material. This would have affected storage of baled cotton and could have prevented the building of new warehouses.