08
Jun
Take Action: EPA Considers “Emergency” Pesticide Use with Bee-Toxic Pesticide for 10th Year in a Row
(Beyond Pesticides, June 9, 2020) EPA has received applications from the states of Maryland, Pennsylvania, and Virginia for the “emergency” use of the bee-toxic neonicotinoid insecticide dinotefuran to control brown marmorated stinkbugs in pome and stone fruits. These three states (and others) have received emergency exemptions for this use for the nine previous years and it must not be allowed for a tenth year. Rather than skirt the regulatory process of review, this use pattern must be subject to EPA registration review in combination with all other neonicotinoid uses.
As a neocotinoid insecticide, dinotefuran presents an alarming hazard to bees and other pollinators. Like other neonicotinoids, it is systemic and can indiscriminately poison any insects feeding on nectar, pollen, or exudates. It is also highly toxic to aquatic invertebrates and soil organisms, as well as being highly persistent. In addition to the serious ecological impacts, dinotefuran is toxic to the immune system. This is, of course, an effect that should avoided during the coronavirus pandemic—when the immune system is under attack.
Section 18 of the federal pesticide law (FIFRA—Federal Insecticide, Fungicide, and Rodenticide Act) is designed to allow the use of an unregistered pesticide in emergency situations when there is not time to go through the registration process. Although the Section 18 regulations make reference to alternative practices, there is an underlying assumption that “pests” must be controlled with pesticides, so the lack of a registered pesticide for a given purpose is considered to be an “emergency.” The continual, repeated allowance of emergency pesticide uses disincentivizes the transition to safer and sustainable practices and products—as is found in organic management systems.
With the growth of the organic sector, that assumption is increasingly shown to be false. Although there are a few registered pesticides allowed in organic production, pests are mostly controlled by management of the agroecosystem. In fact, an organic systems plan must not allow the use of synthetic pesticides unless the use of management techniques—including crop rotation, crop nutrient management, sanitation, “selection of plant species and varieties with regard to suitability to site-specific conditions and resistance to prevalent pests, weeds, and diseases,” management of predators and parasites, and use of lures, traps, and repellents—are shown to be insufficient. In addition, the synthetic chemicals they use must meet stringent requirements prohibiting harm to human health and the environment. Organic producers can now grow anything that is grown by chemical-intensive methods, so it is reasonable to apply those same requirements to those applicants seeking an emergency exemption.
In 2006, EPA promulgated regulations making it easier to issue repeat emergency exemptions, despite the fact that the definition of an emergency condition requires an “urgent, non-routine situation.” In the case of dinotefuran, EPA has approved 125 emergency exemptions in eight states from 2011 through 2019 to kill brown marmolated stinkbugs in pome and stone fruits. The emergency exemptions were approved for all nine years in five states, eight years in two states, and four years in one state.
EPA must stop approving emergency exemptions in routine cases. In particular, EPA must not approve these repeat exemptions for the bee-toxic dinotefuran and must instead comply with the law, while supporting farmers with information on alternative practices and materials. Emergency exemptions are not subject to the determination that the pesticide does not pose unreasonable adverse effects on humans and the environment, as is required by a full registration. After nine years of use in eight states, EPA should have enough data to determine whether to grant a full registration.
If EPA decides to grant dinotefuran a full registration for this use, it must include label restrictions that will protect bees, other pollinators, and aquatic invertebrates. It must require monitoring to ensure that the label restrictions are working.
Please sign the petition by June 10.
It will be delivered to EPA before the end of the comment period on June 11. A copy will be delivered to your congressional Representative and Senators.
Please also consider adding to your impact by submitting your own comments to Regulations.gov.
Thank you,
The Beyond Pesticides Team
PETITION TO EPA:
To EPA Docket EPA-HQ-OPP-2020-0264:
Beyond Pesticides and the undersigned oppose granting emergency exemptions for dinotefuran to control brown marmorated stinkbugs in pome and stone fruits.
EPA’s allowance of an emergency pesticide application of a pesticide every year for nine years is not justifiable and it must not be allowed for a tenth year. EPA has received applications from the states of Maryland, Pennsylvania, and Virginia for the “emergency” use of the bee-toxic neonicotinoid insecticide dinotefuran to control brown marmorated stinkbugs in pome and stone fruits. The three states (along with others) have received emergency exemptions for this use for the nine previous years. Rather than skirt the regulatory process of review, this use pattern must be subject to EPA registration review in combination with all other neonicotinoid uses.
Dinotefuran, as a neonicotinoid insecticide, presents an alarming hazard to bees and other pollinators. Like other neonicotinoids, it is systemic and can indiscriminately poison any insects feeding on nectar, pollen, or exudates. It is also highly toxic to aquatic invertebrates and soil organisms, as well as being highly persistent. In addition to the serious ecological impacts, dinotefuran is toxic to the immune system. This is, of course, an effect that should avoided during the coronavirus pandemic—when the immune system is under attack.
Section 18 of the federal pesticide law (FIFRA—Federal Insecticide, Fungicide, and Rodenticide Act) is designed to allow the use of an unregistered pesticide in emergency situations when there is not time to go through the registration process. Although the Section 18 regulations make reference to alternative practices, there is an underlying assumption that “pests” must be controlled with pesticides, so the lack of a registered pesticide for a given purpose is considered to be an “emergency.” The continual, repeated allowance of emergency pesticide uses disincentivizes the transition to safer and sustainable practices and products—as is found in organic management systems.
With the growth of the organic sector, that assumption is increasingly shown to be false. Although there are a few registered pesticides allowed in organic production, pests are mostly controlled by management of the agroecosystem. In fact, an organic system plan must not allow the use of synthetic pesticides unless the use of management techniques—including crop rotation, crop nutrient management, sanitation, “selection of plant species and varieties with regard to suitability to site-specific conditions and resistance to prevalent pests, weeds, and diseases,” management of predators and parasites, and use of lures, traps, and repellents—are shown to be insufficient. In addition, the synthetic chemicals they use must meet stringent requirements prohibiting harm to human health and the environment. Organic producers can now grow anything that is grown by chemical-intensive methods, so it is reasonable to apply those same requirements to those applicants seeking an emergency exemption.
In 2006, EPA promulgated regulations making it easier to issue repeat emergency exemptions, despite the fact that the definition of an emergency condition requires an “urgent, non-routine situation.” In the case of dinotefuran, EPA has approved 125 emergency exemptions in eight states from 2011 through 2019 to kill brown marmolated stinkbugs in pome and stone fruits. The emergency exemptions were approved for all nine years in five states, eight years in two states, and four years in one state.
EPA must stop approving emergency exemptions in routine cases. In particular, EPA must not approve these repeat exemptions for the bee-toxic dinotefuran and must instead comply with the law, while supporting farmers with information on alternative practices and materials. Emergency exemptions are not subject to the determination that the pesticide does not pose unreasonable adverse effects on humans and the environment, as is required by a full registration. After nine years of use in eight states, EPA should have enough data to determine whether to grant a full registration.
If EPA decides to grant dinotefuran a full registration for this use, it must include label restrictions that will protect bees, other pollinators, and aquatic invertebrates. It must require monitoring to ensure that the label restrictions are working.
Thank you.
Letter to Congress
Please tell EPA not to grant emergency exemptions for the bee-toxic insecticide dinotefuran to control brown marmorated stinkbugs in pome and stone fruits.
EPA’s allowance of an emergency pesticide application of a pesticide every year for nine years is not justifiable and it must not be allowed for a tenth year. EPA has received applications from the states of Maryland, Pennsylvania, and Virginia for the “emergency” use of the bee-toxic neonicotinoid insecticide dinotefuran to control brown marmorated stinkbugs in pome and stone fruits. The three states (along with others) have received emergency exemptions for this use for the nine previous years. Rather than skirt the regulatory process of review, this use pattern must be subject to EPA registration review in combination with all other neonicotinoid uses.
Dinotefuran, as a neonicotinoid insecticide, presents an alarming hazard to bees and other pollinators. Like other neonicotinoids, it is systemic and can indiscriminately poison any insects feeding on nectar, pollen, or exudates. It is also highly toxic to aquatic invertebrates and soil organisms, as well as being highly persistent. In addition to the serious ecological impacts, dinotefuran is toxic to the immune system. This is, of course, an effect that should avoided during the coronavirus pandemic—when the immune system is under attack.
Section 18 of the federal pesticide law (FIFRA—Federal Insecticide, Fungicide, and Rodenticide Act) is designed to allow the use of an unregistered pesticide in emergency situations when there is not time to go through the registration process. Although the Section 18 regulations make reference to alternative practices, there is an underlying assumption that “pests” must be controlled with pesticides, so the lack of a registered pesticide for a given purpose is considered to be an “emergency.” The continual, repeated allowance of emergency pesticide uses disincentivizes the transition to safer and sustainable practices and products—as is found in organic management systems.
With the growth of the organic sector, that assumption is increasingly shown to be false. Although there are a few registered pesticides allowed in organic production, pests are mostly controlled by management of the agroecosystem. Organic producers can now grow anything that is grown by chemical-intensive methods, so it is reasonable to apply those same requirements to those applicants seeking an emergency exemption.
EPA must stop approving emergency exemptions in routine cases. In particular, EPA must not approve these repeat exemptions for the bee-toxic dinotefuran and must instead comply with the law, while supporting farmers with information on alternative practices and materials.. Emergency exemptions are not subject to the determination that the pesticide does not pose unreasonable adverse effects on humans and the environment, as is required by a full registration. After nine years of use in eight states, EPA should have enough data to determine whether to grant a full registration.
If EPA decides to grant dinotefuran a full registration for this use, it must include label restrictions that will protect bees, other pollinators, and aquatic invertebrates. It must require monitoring to ensure that the label restrictions are working.
Thank you.
Please don’t allow a quick and easy decision and action create long term devastation!!!
June 11th, 2020 at 12:01 pmPLEASE DO NOT GRANT ANY EXCEPTIONS TO THIS LAW!
June 17th, 2020 at 9:10 am