SECTION: IN THE NEWS

LENGTH: 1142 words

HEADLINE: PREPARED STATEMENT OF
WILLIAM LOVELADY
NATIONAL COTTON COUNCIL
BEFORE THE HOUSE AGRICULTURE COMMITTEE
DEPARTMENT OPERATIONS, OVERSIGHT,
NUTRITION, AND FORESTRY SUBCOMMITTEE

BODY:

 
Thank you, Mr. Chairman, for your interest and leadership in this issue and for the opportunity for me to speak on behalf of the National Cotton Council (NCC). My name is Bill Lovelady. I am a cotton and pecan farmer from Tomillo, Texas near El Paso. I am also a former President of the NCC and the NCC representative on the Tolerance Reassessment Advisory Committee (TRAC).
As a farmer, I am proud that American agriculture produces the most abundant, the highest quality, and the safest food and fiber supplies in the world. As farmers, we also take seriously our role as stewards of our land and natural resources. At the same time, there are tools that we need to protect our crops from the ravages of insects, diseases, and weeds. Analyses indicate that, if cotton farmers lost the uses of organophosphate compounds, economic losses would total approximately $7.2 billion per year. And, this estimate does not include the use of other necessary compounds. Mr. Chairman, I testified before this subcommittee last year during a heating on this same subject. At that time, there was a high level of anxiety among the agricultural community that Environmental Protection Agency's (EPA) implementation of FQPA would unnecessarily result in the loss of some of our most valuable pest management tools. There have been some positive developments over the past ten months but there are still quite a few concerns. I would like to briefly mention those developments and concerns.
It is absolutely critical that FQPA be implemented with the use of sound science. In fact, the statutory language of FQPA requires EPA to use solid reliable data in its tolerance reassessments. However, in the absence of good date, EPA often relies on conservative default assumptions, such as assuming 100% of the crop is treated at maximum rates. These assumptions grossly exaggerate risk.
An example of the problems involved with such assumptions and one which I suppose you will hear a lot about today, is the case of azinphosmethyl or Guthion. This compound was first registered in 1959 and is now used on more than 50 food crops. Guthion is an important product used on cotton particularly in the southwest-growing region. At the TRAC Working Group meetings of April 8 and 9, EPA reviewed its tolerance reassessment of this product. At the initial phase of its, EPA's default assumptions led it to overestimate the risk involved with the use of Guthion by 95 times. Such a discrepancy in risk estimates clearly illustrates why it is critical that EPA uses data which reflect real life situations. The need for accurate assessments becomes even more critical when other sources of aggregate risk and cumulative risk are considered.
EPA can only use sound scientific data if it has such data in hand. The agency must inform the ag community and the registrants of data it is lacking. The agricultural community is very willing to provide necessary data. The NCC is currently working with EPA on data regarding the feeding of waste products from ginning operations. We discovered that EPA's initial assumptions overestimated the amount of gin trash that is in the diets of beef and dairy cattle by 7 to 20 times.
The TRAC has been a useful means for producers to participate in FQPA implementation and to voice their concerns. The TRAC has met on five different occasions. Its sixth meeting is scheduled for the end of this month. I encourage that this committee or a similar forum be continued at least until the time that EPA has established a well- defined methodology for reassessing existing tolerances and establishing tolerances for new products.
During the TRAC meetings, EPA decided upon nine science issues which it believes are important for FQPA implementation. The position of the agency on these issues is being published in the Federal Register for public comment over a period of time. We support this type of public participation. On the other hand, the final completion of these science issues is not scheduled until the first part of next year. In the meantime, EPA will be making tolerance decisions for the August 3rd deadline before it has all the science issues resolved.
The TRAC meetings have also resulted in an increased role for USDA in FQPA implementation. We fully support a higher level of USDA participation especially with the planning for transition strategies. USDA is currently reviewing EPA's revised risk assessments for the organophosphates. The department is utilizing the expertise of the land grant universities for further review and input. We support this approach providing that USDA is using land grant faculty who are familiar with the respective crop and protectant. We are concerned, however, that, over time, the use of university resources could place a burden on the system. We realize that this committee is not responsible for funding these programs but we would encourage you to discuss with the appropriators a means to compensate the land grants for their services. We also support USDA's Pesticide Data Program and National Agricultural Statistics Service for the data they are generating.
EPA has funneled much of its time and resources into the reassessments of existing tolerances under FQPA standards. I have already stated the need to do such reassessment accurately. At the same time, we would not want EPA's other responsibilities, such as Section 18's and registrations of new active ingredients, to suffer.
Section 18 of FIFRA authorizes EPA to exempt a state or federal agency from the provisions of FIFRA if EPA determines that emergency pest conditions exist. The fact that an emergency exits suggests that time is of the essence. However, EPA is interpreting FQPA to say that a full blown FQPA tolerance must be determined to issue a Section 18. This is a time consuming process. There needs to be a better system to meet these emergency needs while still maintaining adequate safety standards. EPA should adopt an incremental risk approach to evaluating and approving Section 18 requests. This approach will take into account the limited time and area of usage.
The NCC is also concerned that the implementation of FQPA has detracted from the registration of new crop protection products. The number of new product registrations in Fiscal 95 shows that EPA has a greater capacity to register new products. Growers need these newer tools. They are looking for safer products. They need a variety of products for resistance management, for specific pest problems, and, potentially, to replace organophosphate uses.Mr. Chairman, as I have said, there have been some positive developments in FQPA implementation. But, there are still quite a few concerns. The NCC looks forward to working with your subcommittee on these issues.
Thank you, again, for this opportunity to speak.
END

LOAD-DATE: April 24, 1999