In another development, EPA has updated its benefits assessments of endosulfan for potato, cotton, apples, tomatoes, cucumber, melons, pumpkin and squash and said it finds that the loss of the pesticide will be minimal to cotton. The agency is requesting public comments on the finding by July 6.
This action is in response to a Feb. 19, 2008, petition filed by the National Resources Defense Council and the Pesticide Action Network North America. The petition requested EPA cancel all registrations and revoke all tolerances for endosulfan, claiming endosulfan “harms the hormone system, and low levels of exposure in the womb have been linked to male reproductive harm, other birth defects and possibly autism.”
EPA’s Biological and Economic Analysis Division considered two strategies to mitigate worker exposure to endosulfan — elimination of aerial applications and extension of the Restricted Entry Interval to address, respectively, concerns for workers: (1) who mix, load and apply endosulfan and (2) who conduct various field activities following an application of endosulfan.
According to BEAD, both strategies could make the use of endosulfan impracticable for growers. As a result, growers are likely to switch to alternatives.
According to the National Cotton Council, endosulfan currently has a relatively minor overall role in cotton pest management nationwide but is used on about 25 percent of the cotton acreage in Arizona and 9 percent in California, where high-value long staple cotton is produced. Effective alternatives from several chemical classes exist for control of the lygus bug and whitefly on cotton in Arizona and California. Endosulfan’s most important niche is in Arizona where it is used in rotation with acephate, oxamyl, and flonicamid for Lygus bug resistance management.
BEAD believes that endosulfan’s current role in resistance management is minimal and that the loss of endosulfan will not result in adverse resistance management outcomes. Given endosulfan use patterns, its target pests, effectiveness of its alternatives and the cost of its alternatives, BEAD concludes that there will be minimal impact on cotton producers that are not likely to exceed 1 percent of net operating revenue if endosulfan is not available.
Comments on EPA Impact Assessments on Endosulfan; Request for Comments and Additional Information on Importance of Use should be identified by Docket No. EPA-HQ-OPP-2002-0262 and submitted by July 6 to http://www.regulations.gov.