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Tell EPA To Deny Request for Unregistered Use of Bird-Killing Pesticide
(Beyond Pesticides, Jun 6, 2003)
EPA is extending the public comment period through next week on the request made by Texas, Oklahoma and Louisiana to the use of the flowable formulation of the pesticide carbofuran (Furadan 4F Insecticide/ Nematicide) to treat up to 2.7 million acres of cotton to control cotton aphid. Flowable carbofuran is not registered for this use, however, a loophole in the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA), allows EPA permit an exemption under "emergency circumstances" such as a risk to human health or in cases of possible "significant economic loss." Beyond Pesticides questions the legitimacy of the "emergency," considering that organic techniques have been used successfully throughout the southern U.S.

The granular formulation of carbofuran was the subject of a Special Review between the years of 1986-1991, which resulted in a negotiated settlement whereby most of the registered uses of granular carbofuran were phased out due to its deadly effects on birds. Scientists at the U.S. Fish and Wildlife Service (FWS) stated that "there are no known conditions under which [granular] carbofuran can be used without killing migratory birds. Many of these die-off incidents followed applications of carbofuran that were made with extraordinary care." While the flowable formulation of carbofuran has not been phased out to the same degree as granular carbofuran, EPA and environmentalists believe that the proposed use on cotton could pose a similar risk.

The toxicity and the exposure routes between the granular and flowable formulations are very similar. The granular formualtion often kills seed-eating birds that mistake the pesticide for food. Predators and scanvengers are then poisoned when the eat contaminated birds and other small prey. With the flowable formulation, birds can be exposed via ingestion (insects, grit and vegetation that has been sprayed), via inhalation, via preening and via contaminated water (drinking and bathing). One documented kill in 1980's lists 1000's of waterfowl killed when they were exposed to irrigated water that was contaminated with flowable carbofuran. Again, secondary poisoning occurs when predators and scavengers eat contaminated prey.

In June 2002, the granular formulation was approved for use under a FIFRA section 18 emergency exemption for an initial 2,500-acre application on Louisiana rice, then denied for broader use weeks later. This exemption was denied after Beyond Pesticides and a coalition of environmental groups led by American Bird Conservancy (ABC) protested and sent comments to EPA voicing strong opposition to the state's request. Over 6,000 comments were sent to EPA on the issue.

EPA is soliciting public comments for the recent requests before making the decision whether or not to grant the exemption. Written comments, should be identified by docket ID number OPP-2003-0167. Comments may be sent by e-mail to opp-docket@epa.gov, or by mail to Public Information and Records Integrity Branch (PIRIB) (7502C), Office of Pesticide Programs (OPP), Environmental Protection Agency, 1200 Pennsylvania Ave., NW, Washington, DC 20460-0001.