March 15, 2018
Office of Pesticide Programs
Regulatory Public Docket (7502P)
U.S. Environmental Protection Agency
1200 Pennsylvania Ave., NW Washington, DC 20460
RE: Docket ID Number EPA-HQ-OPP-2012-0373
Dear Ms. Biggio:
The National Cotton Council (NCC) appreciates the opportunity to comment on the Environmental Protection Agency’s (EPA) Human Health Draft Risk Assessment for Registration Review and Preliminary Ecological Risk Assessment for the Registration Review of Buprofezin. The NCC urges EPA to recognize the unique mode of action (MOA) buprofezin offers for resistance management scenarios. As EPA urges producer to recognize the values of rotating chemical MOA’s for resistance management purposes, EPA must recognize rotation is not possible unless there are multiple MOA’s available. This product especially serves critical whitefly resistance management objectives.
The NCC is the central organization of the United States cotton industry. Its members include producers, ginners, cottonseed processors and merchandizers, merchants, cooperatives, warehousers and textile manufacturers. A majority of the industry is concentrated in 17 cotton-producing states stretching from California to Virginia. U.S. cotton producers cultivate between 9 and 12 million acres of cotton with production averaging 12 to 18 million 480-lb bales annually. The downstream manufacturers of cotton apparel and home furnishings are located in virtually every state. Farms and businesses directly involved in the production, distribution and processing of cotton employ more than 125,000 workers and produce direct business revenue of more than $21 billion. Annual cotton production is valued at more than $5.5 billion at the farm gate, the point at which the producer markets the crop. Accounting for the ripple effect of cotton through the broader economy, direct and indirect employment surpasses 280,000 workers with economic activity of almost $100 billion. In addition to the cotton fiber, cottonseed products are used for livestock feed and cottonseed oil is used as an ingredient in food products as well as being a premium cooking oil.
First, the NCC appreciates the EPA’s thorough review of merited science that demonstrates the safety of this product with regards to human health. The unique MOA (inhibitor of chitin biosynthesis Group 16, Insecticide Resistance Action Committee (IRAC), IRAC Mode of Action Classification Scheme, July 2017, Version 8.3), provides producers with an insect management tool targeting specific processes chitin biosynthesis, and greatly reduces risk concerns for humans and many other taxa of the environment.
The draft Human Health Risk Assessment demonstrates no scientific evidence for carcinogenicity to humans; sufficient scientific evidence to reduce FQPA safety factors; aggregate risk assessment of no concern; and no dietary risk of concerns. Even with the remaining uncertainty factors, it is clearly a product of low, if any, human health concerns. The NCC notes that, even though the majority of the Occupational Handler Exposure and Risk Assessments were not of concern, EPA did identify certain scenarios that indicated a concern. The NCC would encourage EPA to refine those risk assessments with stakeholder input as to the PPE and technological advancements used to mitigate those concerns.
The Preliminary Ecological Risk Assessment reports the Level of Concerns (LOCs) are not exceeded for terrestrial plants, freshwater invertebrates, benthic invertebrates, or aquatic plants. This determination represents numerous taxa with no risk concerns. EPA did identify exceedance of LOC for some chronic risk assessments. The NCC would encourage EPA to refine those assessments for field relevant use.
The NCC recognizes that buprofezin is not used annually on most U.S. cotton acreage, but buprofezin is a very critical product for control of whitefly outbreaks. There are many papers discussing the challenges to the control of whitefly outbreaks and the extreme need for multiple MOA in rotation to avoid uncontrollable populations (Hequet et al., 2007, Sticky Cotton: Causes, Effects, and Prevention, USDA ARS Tech. Bull. No. 1915, 210pp; Nichols et. al. Management of White Fly Resistance to Key Insecticide in Arizona, http://www.cottoninc.com/fiber/AgriculturalDisciplines/Entomology/Whitefly/WhiteFlyResistance/ ;
Whiteflies: Cotton Insect Management Guide, https://cottonbugs.tamu.edu/foliage-feeding-pests/whiteflies/). Buprofezin is a critical Insect Resistance Management (IRM) tool for managing whiteflies, and its loss could force additional applications of other materials that would not provide the benefits of buprofezin. Elsworth et al. (1999, The University of Arizona, Cooperative Extension IPM Series No. 13, Stick Cotton Sources & Solutions) reported “insecticide treatment to specifically prevent stickiness has cost Southwestern cotton growers $47 million for aphids and $154 million for whiteflies from 1994-1998.” The development and implementation of a new integrated system of whitefly management greatly reduced costs, but optional management tools must remain available to comply with IRM recommendations.
The whitefly is more than just a pest that may reduce yield. The sugars secreted by whitefliesy can result in heavy deposits resulting in sticky cotton. Sticky cotton impacts the entire cotton chain – reducing producer returns, slowing ginning process by up to 25 % (Ellsworth et al, 1999), lowering grade and value by $0.03/lb – $0.05/lb (Ellsworth et al. 1999), causing textile losses by requiring extra efforts to spin fibers. Sugar deposits in textile processing can require frequent shutdown for cleaning of processing equipment, and potential reduction in final product due to staining and fiber grade. The seriousness of sticky cotton can impact entire regions as mills attempt to avoid the purchase of sticky cotton.
The NCC urges EPA to refine the Ecological Risk Assessment with field relevant data while moving forward with this registration review. The NCC additionally urges EPA to carefully examine the benefits of this material and the potential impact on the entire cotton industry with inadequate products for control of whiteflies.
Thank you for allowing the NCC to comment on EPA Human Health Draft Risk Assessment for Registration Review and Preliminary Ecological Risk Assessment for the Registration Review of Buprofezin.
Senior Scientist, Regulatory and Environmental Issues
National Cotton Council