The following was released by Phil Jost of Dow AgroSciences this week. Thanks Phil,
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.
U.S. Insecticides Marketing Leader 317.337.5045 firstname.lastname@example.org