SECTION: IN THE NEWS

LENGTH: 1125 words

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

BODY:


My name is Bill Lovelady. I am a cotton farmer from Tomillo, Texas near El Paso. As a farmer, I take seriously my role as a steward of our land and natural resources. I am also a father. And I want you to know that my kids eat lots of safe and nutritious American grown fruits and vegetables.
Thank you, Mr. Chairman, for your leadership and interest in this important issue of the Food Quality Protection Act (FQPA) implementation. Thank you also for the opportunity to speak, once again, on behalf of the National Cotton Council (NCC) before your subcommittee. I have testified before this subcommittee in the past. This time I do so with a great deal of concern and disappointment in the recent actions taken by the U.S. Environmental Protection Agency (EPA). I must be honest, Mr. Chairman, the NCC normally tries to be courteous and diplomatic in these types of issues. However, considering the haste and timing of these decisions, it is blatantly obvious that EPA has abandoned sound science and has replaced it with political science. It is clear that, with a presidential election upon us next year, EPA is bending to the demands of the environmental activists.
I am a former President of the NCC and the NCC representative on the Tolerance Reassessment Advisory Committee (TRAC). FQPA passed unanimously through both chambers of Congress and was signed into law three years ago to this date. For almost two years, there was a deafening silence from both the EPA and the agricultural community on this issue. In early 1998, an internal EPA memo was leaked. This memo suggested that, as one of several options, EPA might cancel all organophosphates (OP's) by May 15th. The prospect of such a cancellation and the importance of the OP's to agricultural production were enough to energize the ag community to organize and become vocal. The agricultural community knew that EPA did not have the data or the methodologies needed to implement the new safety standards of FQPA particularly the aggregate and cumulative risk assessments. They feared that, in the absence of such science, EPA would proceed with implementation using conservative default assumptions and that crop protection tools would be unnecessarily eliminated. Responding to this outcry, Mr. Stenholm and Berry consulted with Vice President Gore. The Vice President issued a memo in April directing EPA and USDA to work together on FQPA implementation and that they were to be guided by four principles: sound science, transparency, stakeholder input, and transition.
The outcome of that memo was the formation of the TRAC process. The TRAC has met on six different occasions. Its final meeting is tentatively scheduled for some time in October. Although there has been some criticism of the process, my personal opinion is that TRAC has been very useful and has made significant progress for several reasons. First, the TRAC has been a useful means for producers and other interested parties to participate in FQPA implementation and to voice their concerns. Second, 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 of mitigation and transition strategies. The department is utilizing the expertise of the land grant universities for further review and input regarding practical solutions. Third, as a result of the TRAC meetings, EPA has decided upon nine science issues that it believes are important for FQPA implementation. Draft positions of the agency on these issues are being published in the Federal Register for public comment over a period of time. We support this type of public participation.Finally, through TRAC, EPA had developed a six phase pilot program for reassessing the tolerances of the OP's. This program involves refining preliminary assessments, review and input by USDA, and risk mitigation discussions involving user groups as well as registrants.
Mr. Chairman, again, allow me to be candid. The recent decisions by the EPA Administrator have literally destroyed any progress that has been made over the last year through the TRAC process. Any credibility or trust which may have developed regarding a cooperative and consensus building process for implementing FQPA has been demolished.
EPA has decided to target methyl parathion and azinphosmethyl and to cancel and mitigate some of its uses. Fruits and vegetables are going to be most severely impacted. EPA has made these decisions despite the fact that science issues identified in the TRAC discussions and pertinent to these compounds have not been completed. The final determination on the 10X children's safety factor is not expected until March, 2000; yet, EPA is applying a full 10X on methyl parathion and, that is, in spite of new neurotox studies submitted by the registrant. Other pertinent science issues which have not been resolved are the use of human data and the 99.9 percentile. Furthermore, as I said earlier, a six phase pilot process was established for the OP's. In the case of methyl parathion, phases five and six were totally disregarded. EPA has made final decisions on this product and the USDA has not even completed its review. Ms. Browner made a public announcement yesterday even before the technical briefing was convened. The affected users were not consulted as these decisions were being made.
We have already seen what results from the use of more reliable and refined data. The preliminary reassessment of azinphosmethyl showed a dietary risk to infants under one year old that was 10,000% of the risk cup. The use of better data brought that risk down close to 100% in the refined assessments. This example illustrates that it is absolutely critical that FQPA be implemented with the use of sound science and reliable data.
Mr. Chairman, as I have said, any hopes of cooperation and progress with EPA concerning FQPA implementation have been shattered. The last year's efforts by the TRAC have been wasted. It is apparent that the current Administrator will ignore the entire consensus building process if it suits her political aspirations. The concern of the NCC is, however, in regards to the precedent that will be established. It is critical that FQPA be implemented using sound science and reliable data. As important is the need for a well-defined and publicly understood process. The need for crop protection products is too vital to production agriculture for the whims of politics.
Mr. Chairman, I thank you again for this opportunity to provide comments on these issues. The NCC looks forward to working with you and your subcommittee to prevent such poor decisions from being made in the future.
END


LOAD-DATE: August 5, 1999