FYI

Hershberger, Wilbur (WHershbe@afrs.ars.usda.gov)
Tue, 9 Feb 1999 15:03:58 -0500


> ----------
> From: 	panupdates@igc.apc.org[SMTP:panupdates@igc.apc.org]
> Sent: 	Monday, February 08, 1999 3:34 PM
> To: 	panups@igc.apc.org
> Subject: 	PANUPS: Action alert: Risks to birds
> 
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> P A N U P S
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> Pesticide Action Network 
> North America
> Updates Service
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> 
> February 8, 1999
> 
> Action Alert: Cotton Pesticide Poses Reproductive Risks to Birds
> 
> The American Bird Conservancy's Pesticides and Birds Campaign urges 
> the scientific, conservation and advocacy communities to call on the 
> U.S. Environmental Protection Agency (EPA) to deny registration of 
> the insecticide chlorfenapyr because of reproductive risks to birds. 
> Chlorfenapyr has been characterized by EPA as "one of the most 
> reproductively toxic pesticides to avian species that Environmental 
> Fate and Effects Division has evaluated." Because of the agency's 
> concerns regarding ecological risks, EPA's Office of Pesticide 
> Programs has opened a public comment period through February 19.
> 
> American Cyanamid has proposed use of chlorfenapyr (brand names 
> Pirate and Alert) as an insecticide and miticide on cotton. It is 
> touted as one of the most effective controls available for beet 
> armyworm in chemically intensive cotton agriculture. Applications 
> for use on citrus and vegetables and for termites and ants are also 
> pending. Chlorfenapyr belongs to a new class of chemical called 
> "pyrrole" -- never before registered by EPA. When metabolized, it 
> acts on the mitochondria and disrupts production of ATP (adenosine 
> triphosphate), leading to cell death and, ultimately, mortality.
> 
> The following ecological concerns are detailed in the EPA risk 
> assessment:
> ** In a chronic reproductive study of mallards, declines were seen 
> in number of eggs laid (-41%), number of viable embryos (-44%), and 
> number of normal hatchlings (-56%). A decrease in body weight of 
> adult males and females (males: -14%; females -15%) was also evident 
> and in females appeared in the first few weeks of exposure. 
> 
> ** American Cyanamid's testing shows chlorfenapyr to be persistent 
> in soils, with a half-life of one or more years. Applications made 
> to the same fields in consecutive years can result in a build-up in 
> the soil to as much 2.5 times the annual application rate. Such 
> persisting residues could contribute to levels of dietary exposure 
> higher than those suggested by a single year of application. 
> 
> ** Chlorfenapyr residues are found in avian food items including 
> weed seeds, insects and foliage. Levels of chlorfenapyr in avian 
> diets may be as much as 68 times higher than the EPA threshold for 
> reproductive effects, and EPA states that these toxicological 
> thresholds may be exceeded for up to five weeks after initial 
> application to cotton crops.
> 
> ** The timing of chlorfenapyr applications coincides with critical 
> reproductive events for most, if not all, of the more than 50 avian 
> species that, according to American Cyanamid, are associated with 
> cotton fields. Many of the tested species are showing downward 
> population trends in cotton growing states.
> 
> American Cyanamid has proposed numerous mitigation measures and 
> restrictions for use of chlorfenapyr; however, EPA believes that 
> such measures "still yield dietary exposure estimates that exceed 
> chronic toxicity thresholds for birds." In addition, EPA's risk 
> assessment does not include effects of ingestion of the chemical 
> through preening or via drinking water, dermal exposures or 
> inhalation of suspended particles. American Cyanamid also has not 
> provided a field study of chlorfenapyr that specifically addresses 
> avian reproductive effects.
> 
> At least 13 pesticides documented as causing die-offs in migratory 
> birds are currently registered for use on cotton. The American Bird 
> Conservancy is concerned that the addition of another chemical with 
> evidence of reproductive risks for avian species is imprudent.  
> 
> Send comments to the EPA by February 19 asking EPA to deny 
> registration status for chlorfenapyr under Section 3 of the Federal 
> Insecticide, Fungicide, and Rodenticide Act (FIFRA) given its 
> reproductive toxicity for birds. In addition, call for EPA to 
> discontinue the registration process for all other applications of 
> chlorfenapyr. Comments that add scientific information on 
> chlorfenapyr and its particular effects on avian species are 
> extremely valuable, as are comments on the scientific soundness of 
> EPAUs ecological risk and/or economic benefit characterizations.
> 
> Include docket number OPP-34162 and send to: 
> Public Information and Records Integrity Branch, Information 
> Resources and Services Division (7502C), Office of Pesticides 
> Programs, Environmental Protection Agency, 401 M St. SW, Washington 
> DC 20460. Email can be sent to opp-docket@epamail.epa.gov as an 
> ASCII attachment without special characters or encryption codes.
> 
> Full text of the chlorfenapyr risk benefit assessment can be found 
> at: www.epa.gov/pesticides/reg_assessment. Additional information 
> can be found at the American Bird Conservancy web site: 
> www.abcbirds.org
> 
> Source/contact: Kelley R. Tucker, Director, Pesticides and Birds 
> Campaign, American Bird Conservancy, 1250 24th St. NW, Washington, 
> DC 20037; phone (202) 778-9666; fax (202) 778-9778; email 
> ktucker@abcbirds.org.
> 
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> 
Wilbur Hershberger
WHershbe@afrs.ars.usda.gov