Public Comment on Pyrethroid Insecticides Requested Jan 24, 2017 | Written by Ash Sial Dear Blueberry Growers: ALL pyrethroid insecticides (bifenthrin, Warrior/Karate, Mustang Max, Baythroid, Asana, Permethrin, etc.) are currently undergoing registration review at EPA. Nine are specifically being evaluated, but serve as surrogates for all 19 active ingredients. The preliminary evaluation shows that all pyrethroids exceed “Levels of Concern” for exposure to aquatic invertebrates. THIS IS MAJOR. If LOCs are exceeded, the exposure must be mitigated. This can be done in a variety of ways, but generally means loss of uses, reduced rates, reduced number of applications, or other use restrictions. IF PYRETHOIDS ARE IMPORTANT IN PRODUCTION OF YOUR CROPS, YOU ARE ENCOURAGED TO SUBMIT COMMENTS TO EPA ON THIS EVALUATION. The current deadline is January 31. An extension has been requested but has not been granted as yet. Please comment now if possible. EPA particularly needs to know why and specifically how you use pyrethroid insecticides. Your comments should include: Who you are and why you are commenting (grower, consultant, etc.; acres grown and other pertinent information as to your qualifications). Why pyrethroids are important to you (why you use them over other products; why alternatives are not adequate or preferred; etc.) YOUR USE PATTERNS (be very specific if at all possible): For EACH crop (and possibly season) indicate which pyrethroid(s) you use, the pest(s) targeted, the use rate, number of applications, re-treatment interval, and pre-harvest interval (particularly if a short PHI is necessary). The general importance of pyrethroids is important (about the only broad spectrum products we have left), but the specific use information is needed to adjust the exposure estimates. Submitting comments: This is more difficult than it should be. Several options are included below. Note: While comments can be made under docket numbers for any of the pyrethroids, EPA has agreed that comments for all pyrethroids are to be submitted in the lamda-cyhalothrin docket. Go to https://www.regulations.gov/document?D=EPA-HQ-OPP-2010-0480-0019 (Regulations.gov webpage); the summary does not mention pyrethoids, but this is the place (pyrethroids are in the table at the bottom of this document); click the “Comment Now!” button on the upper right of page and follow the instruction. At EPA I will present two options: On the EPA web site search for “pyrethrins and pyrethroids”; open this link and you will see what appear to be a basic fact sheet; scroll down and you will see a section on the Registration Review; click any of the Docket Numbers and you will go to a site that allows for comment (“Comment Now!” button). Go to https://www.epa.gov/pesticides/open-comment-pesticide-actions-and-documents; this site lists all the documents open for comment; scroll down to any pyrethroid and click the “Document Available for Comment” or “Comment Now” link and you should end up where you can submit comments. A user friendly option is the Pyrethroid Working Group site: Go to https://www.votervoice.net/PWG/campaigns/48706/respond and follow their instructions. This site includes a template and suggestions for the information submitted. It is a very good idea to compose and review your comments in a WORD document (or other program) before submitting them to EPA. Ranting and raving accomplishes nothing in this situation. Please provide constructive criticism and useful information that will allow EPA to conduct a more accurate (and hopefully friendly) evaluation of the pyrethroids.