Trifluralin Request for Information
Date sent: Mon, 25 Jan 2010 14:57:59 -1000
From: Mike Kawate
To: Cathy Tarutani
Subject: Fwd: Potential Threat to Trifluralin Production and Use - Your Input
is Needed
-------- Original Message --------
Subject: Potential Threat to Trifluralin Production and Use - Your
Input is Needed
Date: Mon, 25 Jan 2010 15:44:40 -0800
From: Rebecca Sisco
Please see the email below, if you wish to provide input to the importance of trifluralin in specialty crops, please read the information below.
Thanks,
Becky
Rebecca (Becky) Sisco
Western Region IR-4 Center
Regional Field Coordinator
UC Davis
Dept. of Environmental Toxicology
4218 Meyer Hall
Davis, CA 95616-8588
rsisco@ucdavis.edu
530-752-7634 (phone)
530-752-2866 (fax)
530-867-1664 (cell)
From: Dan Kunkel
Sent: Friday, January 22, 2010 10:28 AM
To: Edith' 'Lurvey ('Lurvey, Edith'); Rebecca Sisco; schwartp@ba.ars.usda.gov; Satoru' 'Miyazaki; 'Samuel-Foo, Michelle'; 'Ray Ratto Jr'; bruce@buurmafarms.com; 'Boydston, Rick'; Bob.McReynolds@oregonstate.edu; 'Roger Batts'; 'Bret, Brian'; 'McMaster, Steve'; John Jachetta; 'Marija Arsenovic'; 'Jerry Baron'; 'Debbie Carpenter'; Bill Barney; Brian Flood; Richard Bonanno (Bonanno, Richard); 'Robin Bellinder'; 'Archambault, Shirley'; 'Craig Hunter'; 'Chaput, Jim (OMAFRA)'
Subject: FW: Potential Threat to Trifluralin Production and Use - Your Input is Needed
Dear IR-4 Folks,
I was contacted by DowAgroSciences concerning a recent development with trifluralin. Trifluralin has been identified as a candidate for addition to the list of Persistent Organic Pollutants (POP's) under the United Nations Economic Commission for Europe (UNECE) convention on Long-range, Transboundary Air Pollution. Please see the e-mail correspondence below and attachment for a more information.
For a number of reasons it would behoove us to provide letters of support to keep trifluralin off this list. Primarily a letter to indicate how import this herbicide is to specialty crops. As you will see below, these letters need to address the socio- economic benefits of trifluralin (please see numeric listing under ACTION REQUESTED).
Also note that the deadline for support letters is Feb. 8, 2010.Please send your letters to Steve McMaster and send letters to the following address:
Steve A. McMaster
Dow AgroSciences LLC
9330 Zionsville Rd.
Indianapolis, IN 46268
Please pass this information on to others that would have interest in providing support.
Thanks!
Dan
Daniel Kunkel, Ph.D., IR-4 Associate Director
IR-4 Project Headquarters, Rutgers, The State University of NJ 500
College Road East, Suite 201 W Princeton, NJ 08540
phone: 732.932.9575 ext: 4616
fax: 609.514.2612,
ir4.rutgers.edu
From: Steve McMaster
Sent: Wednesday, January 20, 2010 9:43 AM
To: Dan Kunkel (E-mail)
Cc: Bret, Brian
Subject: Potential Threat to Trifluralin Production and Use - Your
Input is Needed
Dan, as we discussed, here is the information regarding the emerging issue with trifluralin. Your assistance in further understanding the benefits that trifluralin provides to the minor crop producers is appreciated.
ISSUE
Trifluralin is currently being considered for listing in an international
agreement (the Protocol on POPs (persistent organic pollutants) to
the UNECE Convention on Long Range Transboundary Air Pollution) that
could impose stringent controls on production and use of this valuable
herbicide. More information about this process is provided in the
attached
Appendix. Although key governments, including Canada and
the United States, do not support the listing of trifluralin, EU
member states have pushed hard for the listing in the agreement.
The United States EPA believes that there is insufficient information available to suggest that trifluralin is likely to have significant adverse human health and/or environmental effects. The Canadian position is trifluralin is unlikely to have significant adverse human health and/or environmental effects. Moreover, Health Canada has recently determined in Re-evaluation Decision RVD2009-09 that continued use of the herbicide would not cause unacceptable adverse effects on human health or the environment.
DowAgroSciences firmly believes that trifluralin does not meet the
criteria for listing in this agreement, and has participated in the
treaty process to provide information to policymakers that supports
that position. DAS has provided information to support the fact that
trifluralin does not meet the indicative criteria for bioaccumulation,
persistence in soil and water, nor does trifluralin meet the "P,"
"B,"and "T" (toxicity)
criteria in any single key environmental compartment (ie: any potential
effects of trifluralin are not in the environmental compartment were
exposure may occur). During 2010, the treaty review process will include
further evaluation of whether trifluralin meets the criteria for listing
in this agreement.
This international treaty process includes a socio-economic assessment
of trifluralin in which costs, benefits, advantages, disadvantages
and alternatives to trifluralin will be taken into consideration. The
parties to the protocol will then consider the results of this assessment
in potentially setting risk management control measures on the production
and use of trifluralin, if it is listed in the Protocol.
ACTION REQUESTED
The treaty process encourages input from relevant private stakeholders,
including growers who rely on trifluralin. You have an opportunity
to provide information for use in this assessment by responding to
a short survey circulated under auspices of this international agreement.
Survey results are due very soon: February 12, 2010. It is important
that policymakers in this international treaty process receive robust
information about the uses and value of trifluralin in order to ensure
that the full implications of control measures under the agreement
are taken into account.
We encourage you to take advantage of the opportunity to contribute information to the process regarding the socio- economic value of trifluralin, including information about its unique properties in crop-protection and the impacts on growers that could be expected in the absence of trifluralin.
Specifically, DAS would like your input into the following questions:
1. Benefits derived from the use of trifluralin (include the reason
why trifluralin is used in the production of this crop) This could
include cost, weed spectrum, resistance management, crop tolerance,
lack of available registered alternatives, etc.
2. Alternative weed control options, include the advantages or disadvantages
of using the alternative
*Cost per acre/hectare
Please return this information to me no later that February 8, 2010.
This will give me a few days to assemble all of the information that
I have received and provide it to the policymakers in time to meet
the deadline.
Thank you very much for your assistance in this effort. If you have any additional questions, please feel free to contact me.
Regards,
Steve
Steve A. McMaster
R&D Leader
Commodity Herbicides
317-337-4670 Of
317-337-4649 Fax
samcmaster@dow.com
