Crop Protection Use Policy

Date: 7/07
Position Number: V-C
Expires: 3/08

Background: The Environmental Protection Agency (EPA) should recognize the importance of crop protection products as effective and economical corn production tools, and should recognize that, over the past few years, manufacturers of these products and corn growers have voluntarily initiated and adopted changes in use rates, application practices and additional best management practices (BMP) that have resulted in significant decreases in total volumes applied and significant increases in soil and water protection measures. We urge EPA to objectively evaluate the risks and benefits of these crop protection products using the best available science.

Resolution/Position:

1. Farmers should not be held liable if they use products according to label directions and generally accepted agronomic practices.
2. Encourage all producers to become certified applicators of restricted-use crop protection products.
3. Support efforts to increase the testing, research and adoption of science-based, environmentally safe methods and products for the control of pests and diseases. Encourage the use of these methods by agriculture.
4. Mandatory record keeping of crop protection products should be limited to restricted-use crop protection products. Confidentiality of the individual’s records should be maintained.
5. Support the FQPA to take precedence over local crop protection product regulation.
6. Oppose efforts by EPA to require implementation of pesticide management plans. Support individual state water quality plans.
7. In its review of the registration of the triazines, EPA should recognize the importance of these products as effective and economical corn production tools that work well with conservation tillage.
8. Encourage and support the labeling of all crop protection product containers to clearly state the trade names and the amount of each chemical in a premix product, as well as the disclosure of this information in print advertising and promotional materials.
9. Require a cost risk/benefit analysis for the registration and re-registration of crop protection products.
10. When addressing risks of crop protection product residues in food, the most scientifically reliable
    estimates of risk and exposure should be used.
11. Require that any new environmental regulations show a positive cost and risk benefit analysis before implementation.
12. Oppose EPA efforts to implement zero tolerance or unrealistic spray drift policies or otherwise attempt to implement drift policy on a case by case basis.
13. With the passage of the FQPA, we recommend that the EPA move expeditiously to:
    1. Make decisions based on sound science instead of based on default assumptions.
    2. Register new crop protection products.
    3. Release regulations and tolerances for products that have completed data.
14. Support the use of counterpart regulations to clarify the process of pesticide reviews under FIFRA and endangered species reviews under the Endangered Species Act.