The following was released by Phil Jost of Dow AgroSciences this week. Thanks Phil,
Blayne
Dow
AgroSciences LLC dowagro.com
9330 Zionsville Road Indianapolis,
IN 46268 USA
Tel 317 337 0000
Fax 317
337 0000
May 19, 2016
Transform®, Closer® and Sequoia® with Isoclast® Active (sulfoxaflor) proposed labels posted for public comment
On May
17,
2016, the U.S. Environmental
Protection Agency (EPA) posted the proposed label for Transform®,
Closer® and Sequoia® with Isoclast® Active (sulfoxaflor) for a 30
day public
comment period that ends on
June 17. (https://www.regulations.gov/#!docketDetail;D=EPA-HQ-OPP-2010-0889). This is
a significant milestone for obtaining
a reestablished registration
for these products.
We anticipate that at
least 30 additional days will
be required
for EPA to review
the public comments, resulting in federal registration no earlier than late June, 2016.
This regulatory action has no impact on the Section 18 Emergency Exemptions granted or submitted. Therefore, you may continue to purchase and use product according to the Section 18 label. Product in the possession of growers may be used according to existing package labels.
While
Dow
AgroSciences (DAS)
is excited
about this step forward, there are a number of
issues of concern raised
in the proposal document:
1. EPA is specifically requesting comments concerning tank mixing. (Page 10 of proposal document)
2.
EPA is specifically
requesting comments concerning
a proposed 12 foot on-field
buffer zone restriction. (Page 9)
3.
Other than a few crop groups, applications are only permitted post-bloom. (Page 3)
4.
Cotton, citrus, strawberries, cucurbits and soybeans have
been removed from the proposed
label. (Page 3)
Tank mixes are under significant
scrutiny from the US EPA. All products being
registered or undergoing registration
review will face the
same level of scrutiny. In fact,
the recently posted label for Monsanto’s dicamba,
for use in its dicamba-tolerant cropping
system, prohibits
tank mixing. DAS believes tank
mixes with other active
ingredients are vital to American
agriculture as they provide
broad spectrum control
and reduce the time
required by multiple applications. Prohibiting or limiting such tank mixes would severely inhibit
the
ability of growers to
manage pests effectively,
while greatly increasing application costs and
the resulting carbon footprint created
by multiple
applications. To that
end, DAS is asking all relevant industry
groups to comment
so
that agriculture’s voice
is heard by the EPA.
The EPA
is also soliciting comment on a
proposed downwind 12-foot
on-field buffer when blooming vegetation
is bordering the field. DAS believes
this proposed buffer zone
is unmanageable
in production agriculture, is based on
overly conservative assumptions (such as 100% of bees’
diet coming from areas immediately
adjacent to fields), is unnecessary to provide
protection to pollinators, and ultimately
will lead to more
applications of insecticides to crops as
this basically establishes a nursery serving as a source for subsequent infestations.
DAS and the industry
urgently need
your help. The public
comment period provides a window of opportunity
for EPA to hear
from the agriculture industry about the importance of regaining
Isoclast products as insect management tools
as well as the importance of being
able to tank mix. DAS is asking
for your help to address the following points during
the comment period:
·
The benefits provided
by Isoclast,
which have been amply demonstrated over 4+
years of these products
use
and include:
o
Outstanding efficacy against
key pests such as
aphids, plant bugs and
psyllids
o
Lack of cross-resistance with other insecticides
o
Lack of effects
on beneficial insects
o
Lack of any reported effects
on pollinators
·
The need to
re-establish a registration for
cotton, citrus, strawberries,
cucurbits and soybeans.
·
The need to
apply these products
during the bloom period
of many crops consistent with
the previously
cancelled registration.
·
The criticality of tank mixing
as a mechanism to:
o
Broaden spectrum of insect control
o
Management to prevent insecticide resistance
o
Provide for efficient insect management
and reduced the carbon footprint
o
Ensure higher productivity to feed the
worlds growing population
·
The impracticality of the proposed buffer
zone restriction; it is unmanageable in production agriculture
and
will only lead to more applications of insecticides.
If you have questions
or would like further information
on steps you can take to comment on the proposed label,
please contact your local DAS Account Manager.
Sincerely,
Phil Jost
Phil
Jost
