Comments Submitted on Oxamyl
NCC's comments submitted to EPA on the agency’s preliminary ecological risk assessments for oxamyl noted that it has a long history of safe use in cotton, is recognized as a broad-spectrum insecticide, miticide, and nematicide and is beneficial to a number of states for a variety of uses.
November 13, 2017
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-2010-0028
Dear Maria Piansay:
The National Cotton Council (NCC) appreciates the opportunity to comment on the Environmental Protection Agency’s (EPA) “Oxamyl: Preliminary Ecological Risk Assessment for Registration Review.” The NCC urges EPA to recognize the long-term registration of this crop protection product and to recognize the unique mode of action (MOA) it offers for resistance management scenarios. As EPA urges producers to recognize the values of rotating chemical MOA’s for resistance management purposes, EPA should recognize rotation is not possible unless there are multiple MOA’s available.
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.
Oxamyl is a carbamate insecticide that has a long history of safe use in cotton. EPA notes that cotton uses approximately 200,000 lbs of oxamyl per year. Given the acreage of cotton (approximate 5-year average) is 10.5 million acres, it is clear the product is not overly used. EPA additionally notes that of those acres that are treated with oxamyl, 83% only receive one application. Although the market share is not enormous, it should be recognized that its use is critical to certain pest situations. However, EPA’s model assessments should be revised to reflect real world use rather than exaggerated assumptions of maximum use.
Oxamyl is recognized as a broad-spectrum insecticide, miticide, and nematicide. Use of oxamyl is highly varied based on the geographic production location. For example, portions of Texas rely highly on oxamyl as a post emergent nematicide. They have no alternative post emergent nematicide. Oxamyl may not be the first product of choice for tarnished plant bugs and nematodes in Arkansas, but is a very important component of a system rotation of MOAs for producers in Arkansas. Arizona has noted little use, however an infestation of cotton leaf perforator (particularly in Pima cotton) could quickly change the scenario due to challenges of that particular insect.
As we continue to face control challenges to multiple, other piercing and sucking insect pests, it seems EPA should not identify a product as an alternative when internally EPA knows of challenges for registration review of the alternative. Piercing and sucking pests such as thrips, aphids, plantbugs, and stinkbugs are an increasing challenge for the cotton industry, and fewer products are available each year for control of these pests. In the ongoing fight against resistance, cotton producers need more control choices rather than fewer.
The NCC thanks the EPA for the opportunity to provide comment, and encourages EPA to make no changes to the current label of this safe product.
Senior Scientist, Regulatory and Environmental Issues
National Cotton Council