NCGA files formal comment on EPA’s proposed carbofuran ruling (10/08/08)
The National Corn Growers Association today submitted a formal response to the U.S. Environmental Protection Agency's proposed decision to revoke food tolerances for carbofuran, the only reliably effective post-plant rootworm rescue treatment available.
“The corn rootworm presents a very serious problem to the nation’s corn crop and is one of the most aggressive and serious pests infesting corn today,” NCGA President Ron Litterer wrote on behalf of the association. “Rootworm larvae feed on a corn plant’s roots, which results in extensive root damage and leaves corn plants vulnerable to falling over because their root system is no longer capable of providing support or nutrients and water to the plants. Once plants are toppled due to root loss, harvesting corn becomes extremely difficult because modern combines are not designed to collect corn from fallen plants. This results in significant yield reductions, and in some cases, total yield loss.”
In its public comments, NCGA explained that the dietary risk assessment for carbofuran developed by EPA is based on flawed analysis and is overly conservative. “NCGA believes that the carbofuran tolerances for corn necessary to support carbofuran’s continued use on field corn as a rescue treatment should be retained because these potential residues do not pose an unacceptable risk to human health from either dietary or water exposure,” the letter stated.
Earlier in September, NCGA joined National Cotton Council and National Potato Council in seeking an extension of the comment period, due to the significant amount of technical information that would be necessary to provide effective feedback to the Agency. “As we have stated repeatedly, carbofuran continues to provide important benefits to our growers in specific use patterns and geographic areas, and its use in those scenarios should be maintained,” the organization leaders stated in their Sept. 11 letter. “We also remain willing to discuss additional risk mitigation measures to maintain these uses.”
Representatives of the three organizations met with the EPA on Sept. 19 to outline their concerns; however, the agency denied the request for an extension to the comment deadline.
Visit http://www.ncga.com/news/notd/pdfs/CommentEPACarbofuran9-29-08.pdf to download NCGA’s complete comment to the EPA.
