Statement of CropLife America

Presented by Dee Ann Staats, Ph.D. Environmental Policy Leader

Before the EPA FIFRA Scientific Advisory Panel on atrazine to consider
and review the interpretation of the ecological significance of atrazine
stream-water concentrations using a statistically-designed monitoring
program

December 4, 2007

 

I am commenting today on behalf of CropLife America (CLA), which is a
not-for-profit trade organization representing the nation’s
developers, manufacturers, formulators and distributors of plant science
solutions for agriculture and pest management in the U.S. Our member
companies produce, sell and distribute virtually all the crop protection
technology products used by American farmers. CLA comments on issues
that can have broad regulatory implications, which sometimes occur in
the context of chemical-specific or product-specific regulatory reviews,
decisions, and actions.

	

In its October 2003 Atrazine Interim Reregistration Eligibility Decision
(IRED), EPA required the registrants to conduct a watershed monitoring
program to confirm the Agency's conclusion that use of atrazine is not
likely to result in unreasonable adverse effects to freshwater aquatic
ecosystems. CLA commends EPA for achieving this goal and on the design
of this innovative, extensive and intensive watershed monitoring
program. Because this program may serve as a template for future studies
on other crop protection products, CLA encourages the Agency to
carefully consider not only triggers for monitoring but milestones or
triggers to reduce, suspend or end monitoring once a conclusion is
reached.

This extensive program shows that atrazine has little to no effect on
these watersheds, which were chosen to represent those that are
potentially most vulnerable, i.e., a worst-case scenario.  Therefore,
additional monitoring is unnecessary and would set a precedent of undue
burden on the registrants for future such studies.

Furthermore, the data generated in this study has allowed for the
magnitude and duration of exposure to aquatic plants to be determined
and used to develop a Level of Concern.  These monitoring data,
generated under Good Laboratory Practice Standards, used in conjunction
with other extensive monitoring data and surveys, should now be utilized
by the OPP and OW to develop triggers for aquatic life criteria based on
rolling averages.  CLA encourages EPA to move forward with this effort
and to consider this methodology in the future for the development of
aquatic life criteria for other crop protection products.

