WASHINGTON, Nov. 10, 2016 – Dow AgroSciences says U.S. farmers may soon have their last opportunity to respond to EPA’s proposal to revoke all food tolerances for the insecticide chlorpyrifos, which Dow called a “critical tool for U.S. agriculture.”

The company was responding to EPA’s release today of a notice that it had updated its human health risk analysis for chlorpyrifos, which American farmers use on more than 50 different types of crops. EPA said the revised analyses indicate that expected residues of chlorpyrifos on food crops “exceed the safety standard under the Federal Food, Drug, and Cosmetic Act. In addition, the majority of estimated drinking water exposures from currently registered uses, including water exposures from non-food uses, continue to exceed safe levels even taking into account more refined drinking water exposures. “ 

EPA said the revised analyses haven’t changed its mind about the plan to revoke all tolerances. But, it says that having considered the advice of a Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) Scientific Advisory Panel, it is proposing to modify the scientific analysis that supports that finding. EPA says the analysis will be published in the Federal Register in a Notice of Data Availability (NODA), and that will trigger a 60-day comment period. A final decision on the proposal will be made by March 31, 2017.

Phil Jost, Dow AgroSciences’ portfolio marketing leader, U.S. Crop Protection Insecticides, rejected EPA’s revised analysis.

“We disagree with the chlorpyrifos NODA and with key aspects of the underlying assessment,” Jost said in a release. “The assessment lacks scientific rigor, is contrary to EPA and administration policies of data access and transparency in scientific decision-making, and falls short of the FIFRA requirement that decisions be based on valid, complete and reliable scientific data.”

EPA announced its proposal to revoke U.S. food tolerances for chlorpryifos on Oct. 30, 2015, following a U.S. Ninth Circuit Court of Appeals decision ordering the agency to respond to allegations about chlorpyrifos made in a 2007 petition. Dow notes that the EPA’s proposal to revoke tolerances was made before the agency had finished its formal health and safety evaluations of chlorpyrifos.

Furthermore, the company said it is concerned that the NODA “cannot be reconciled with the requirements of the FIFRA and the agency’s own guidelines, policies and procedures.”

“For many important pests, growers face limited or no viable alternatives to chlorpyrifos,” Dow said in its release, adding: “When an outbreak of a new pest occurs, growers look to chlorpyrifos as a proven first-line of defense.”

Dow said the upcoming 60-day public comment period may be the last opportunity for stakeholders to express their need for chlorpyrifos and to call for EPA to rely on sound and transparent science and regulatory process.

The company also noted that the EPA can still deny the original petition and retain all tolerances for the insecticide. It says that “would be consistent with the science and allow the agency to complete its registration review and address their remaining concerns in an orderly manner.” Dow AgroSciences stated that “it remains confident that authorized uses of chlorpyrifos products, as directed, offer wide margins of protection for human health and safety.”


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