In September 2013 EPA announced it is opening a comment period regarding its review of the registration of phosphine. Federal law requires EPA to conduct these reviews every 15 years to ensure the pesticides still satisfy the legal requirements for safe and effective use.
Comments are due November 25. NAMA is working in coalition with other phosphine user groups to draft and submit comments to EPA in support of retaining the compound’s registration. The December 31, 2014 completion of the methyl bromide phase-out, and the current proposal to delete the tolerances for SF residues on food, add to the criticality of maintaining phosphine’s registration.
Methyl bromide (MB) has been an important tool for controlling insect pests in flour mills and warehouses. MB was to be banned with no exceptions on Jan. 1, 2001. However, NAMA successfully convinced Congress of the importance of MB as a sanitation tool, and Congress amended the law to set a new phase-out date of Jan. 1, 2005. The new law also provided opportunities to apply for “critical use exemptions.” The milling industry has cut its use of methyl bromide by about 95 percent. Methyl bromide use in mills will cease on Dec. 31, 2014.
Responding to a legal challenge of EPA’s tolerances for sulfuryl fluoride (SF) residues on foods, in 2011 the agency proposed to revoke those tolerances and cancel all associated uses. NAMA submitted 47 pages of detailed comments urging EPA to allow mills to continue using this sanitation tool.
EPA announced a second request for comments on its proposed order in 2012. In response, NAMA submitted another 11 pages of technical comments specific to milling industry usage. NAMA said it believes a thorough analysis and consideration of the comments will lead EPA to conclude a revocation of SF residue tolerances is not warranted, nor would a revocation confer health benefits for the nation’s consumers.
Even EPA states that SF’s contribution to total fluoride in the diet is “tiny.” A coalition of SF user groups including NAMA is aggressively advocating for EPA to provide flexibility to accommodate trivial SF residues on food. The coalition has been working for a year to get enabling language included in the farm bill.
Prepared by Jim Bair, Vice President, 202.484.2200, ext. 14, firstname.lastname@example.org
Last updated October 2013