Message
From:
Sent: To: CC: Subject:
Schwab, Justin [/0=EXCHANGELABS/OU=EXCHANGE ADMINISTRATIVE GROUP (FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=EED0F609C0944CC2BBDB05DF3A10AADB-SCHWAB, JUS] 5/26/2017 7:45:46 PM Joe Bischoff [JBischoff@cgagroup.com] Tim Lust [tim@sorghumgrowers.com] Re: Impact of recent changes to risk assessment
Thank you for this. I will make sure it gets to the right policy people here.
Sent from my iPhone
> On May 26, 2017, at 3:20 PM, Joe Bischoff <JBischoff@cgagroup.com> wr ot e:
>
>
>
> Justin,
>
> My apologi es for taki ng so 1ong to get back to you with examples of how thi ngs have signi fi cantly
changed in the regi strati on and re-regi strati on of pesti ci des in recent years. I am sti11 gatheri ng
examples, as they are a more di ffi cult to tease out than I initially anti ci pated but they remai n very
much real and impactful to growers.
>
> We know that there have been si gni fi cant changes to risk assessment, not through stakehol der engagement
or noti ce and comment but through fi a t . These changes were fi rst si gnaled by D r . Thomas Burke (Former
D e p . Assi stant Admi ni strator at EPA) in 2009 when he presented, "New Di recti ons for Risk Assessmenti n the
Incomi ng Admi ni strati on and Beyond" to the Wharton School of Busi ness. Whi1e the changes were done
through poli cy and model shi fts wi thi n the agency the impacts have been profound.
>
> HERBICIDE
> The fi rst example is in regards to Atrazi n e , whi ch is the second most wi dely used herbi ci de in the
Uni ted States, pri mari ly on corn, sorghum, soybean and sugarcane producti o n . Atrazi ne has been around for
more than 50 years and few chemi cals have been studi ed more closely. Atrazi ne is currentl y goi ng through
re-regi strati on at EPA, as it di d in 2003, but thi s ti me through si gni fi cant poli cy changes appear to
have been made and the goal posts moved. Below I have provi ded a list of some of the major concerns.
Attached, y o u '11 fi nd two documents that provi de addi ti onal detai1s about these concerns. One document
(ATZ summary) was produced by folks at Syngenta. The other document (ATZ EPA Review Memo) was produced
through the T ri azi ne Network whi ch is a coali ti on of grower organi zati o n s , includi ng the Nati onal Sorghum
Producers).
>
> * EPA ignored the recommendations of thei r own Science Advisory Panel s (2007, 2009, 2012) in setting
aquati c 1evel of concern (LOCs).
> * Preli mi nary assessment focuses on models that cl early overestimate potential envi ronmental
concentrations of atrazi ne in water and ignores real-world and robust data taken over a 10 year period
that completely contradi cts the imaginative models used by EPA.
> * Di fferent outcomes despi te the same informati on
>
* In 2003 EPA concluded "atrazine is practical 1y non-toxic to siightly toxic to bi rds and
mammals" . But in 20016, despi te the thresholds remai ni ng unchanged EPA concluded that atrazi ne posted a
chroni c ri sk to mammals.
>
* In 2003 EPA concluded "atrazi ne is practi cal ly non-toxi c to sii ghtl y toxi c to bi rds." But in
2016 EPA concluded that there was acute ri sk for piant-eati n g , insect-eati ng and omni vorous bi rds for
nearly al1 use patterns.
>
> PESTICIDES AND POLLINATORS: Decisions based on hazards and not on ri sk assessment
> I have attached the Nati onal Sorghum Producers' comments on the regi strati on of sulfoxaflor (EPA-HQ-
OPP-2010-0889) and a 2015 1etter from EPA to the regi strants instructi ng them not to pursue further
neoni coti noi d uses. I provi ded these two documents to help illustrate how OPP has made regi strati on
deci si ons that were influenced by the NGO outcry about honeybees and other pol1inators wi thout
documenti ng ri sk (e.g ., exposure). These are hazard-based deci si ons that have been repeated over and over
and are not in keeping with a ri sk-benefit evaluation as requi red under FIFRA. Below I have highlighted
some of the specific concerns captured and further explained in the attached documents.
>
> * EPA identi fi ed the hazard and assumed a harmful exposure wi thout data to support thei r
assumptions.
>
* Crops 1ike sorghum, soybean and ci trus were prevented from bei ng regi stered uses, keepi ng a
useful tool out of producers hands.
> * E P A 's letter prohi bi ti ng new neoni c regi strati ons has kept cost effective tools out of growers
hands do to thei r "no ri sk" approach to bees.
>
* Sorghum faces a new and devastating pest (sugarcane aphid). Studies have shown that an
imi daclopri d in-furrow treatment would be effecti ve and inexpensive for thi s 1ow-i nput cost crop.
Sierra Club v. EPA 18cv3472 NDCA
Tier 1
ED 002061 00165349-00001
Unfortunately, EPA has told the registrants not to apply for the use due to their presumed concerns about
bees.
>
* The 1etter ci rcumvents the ri sk/benefi t evaluati on process required under FIFRA and blocks
regi strati ons wi thout evi dence.
>
* A 1etter from OPP instructi ng regi strants that the moratori urn no-1 onger applies would be a
strong message and encourage innovation and new uses.
> * Honeybees are non-nati ve livestock in the Uni ted States. Beekeepi ng is a form of agriculture.
However, EPA has chosen that form of agriculture over al1 others.
> * While beekeepers do have signifi cant pest and pathogen chal1enges, wehave more honeybeecolonies
in the U.S. than we have had in 20 years.
> * The abundance of cauti on and concern that EPA is exhi bi ti ng to be es, and honeybees in parti cular,
is keeping important crop protection tools out of the hands of producers and ignoring thei r needs to
control pests.
>
> I am worki ng to gather speci fi c examples of how the model s have changed and the resulti ngimpacts on
regi strati o n s . Hope to have that to you in the next week or t w o .
>
> On a di fferent topi c, can you tel 1 us if there has been any progress on the sorghum oi1 pathway? We are
sti11 wai ti ng to hear from EPA regardi ng next steps, whi ch we hope is a letter provi di ng the approval.
>
> Thank you for your conti nued attenti on to our issues and pi ease 1et me know if you have any questi o n s .
Hope you enjoy the hoiiday weekend.
>
> - Joe
> ______________________________
>
> Joe Bischoff, PhD | Senior Vice President
> Cornerstone Government Affai rs
>
> Annapoli s | Atlanta | Austi n | Baton Rouge | Chi cago | Des Moi nes
> Houston | Jackson | Ri chmond | Springfield| Washington
>
.
_E_x_. _ 6
mobile | [
x!"
direct
> wwwTcggfpTcom<http ://vi^Tcggr'pTc'om/>
> OCGAgroup
<ATZ EPA Revi ew Memo_5.16.2017[2].docx> <Atz summary - llmayl7[2].docx> cneonicotinoi d-new-use.pdf> <2016_06_17_Sulfoxaflor_EPA-HQ-OPP-2010-0889-Final.docx>
Sierra Club v. EPA 18cv3472 NDCA
Tier 1
ED 002061 00165349-00002