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The Triazine Network is a coalition
of agricultural grower organizations and individuals formed in 1995 as a
result of the U.S. Environmental Protection Agency's (EPA) Special Review
of the Triazine herbicides.
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Special Review Nears End
EPA Releases Favorable Risk Assessment
for Triazines
Network Thanks the Many Groups Who Submitted Comments by Aug. 21,
2006 Deadline
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EPA concluded "...there is a reasonable certainty that no harm will
result to the general U.S. population, infants, children, or other
major identifiable subgroups of consumers from aggregate exposure…to
cumulative residues of atrazine and the other chlorinated triazine
pesticides." |
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Growers from across the nation were happy to see the Environmental
Protection Agency’s (EPA) favorable risk assessment for the Triazine
herbicides. The assessment was released in June and EPA "..the
Agency has found that there is a reasonable certainty that no harm
will result to the general U.S. population, infants, children, or
other major identifiable subgroups of consumers from aggregate
exposure…to cumulative residues of atrazine and the other
chlorinated triazine pesticides."
EPA also released a Reregistration Eligibility Decision for simazine
and a tolerance assessment for propazine. These actions bring the
special review of the Triazine near an end.
“We weren’t asking for much, just that EPA used good science to make
a decision on the Triazine herbicides,” White said. “If sound
scientific research proved that the Triazines posed a danger, we
were ready to accept that. However, the research proved what we
believed all along—the triazines are safe.”
Network Was Key to Success
The Triazine Network was formed in 1995 after the EPA announced the
special review of the Triazine herbicides atrazine, simazine and
cyanazine. Cyanazine was later removed after the registrant
voluntarily offered to phase out its use. Propazine was added based
on the intent of a registrant to expand the existing greenhouse
label to include grain sorghum.
The Network made the unprecedented move of bringing growers of more
than 30 commodities to the table for the special review.
“EPA told us they had never had grower involvement like this,” White
said. “The special review process is open to stakeholders and I
can’t think of anyone who had a bigger stake in this process than
growers. Our network included some of the top names in agriculture
across the board. Without the expertise and commitment of our
members, we would not have succeeded.”
White has been chairman of the Network since its inception and on
many occasions participated in meetings, hearings and technical
briefings giving the growers’ perspective, including the importance
and usage, to EPA officials.
“We’ve had a lot of things thrown at us since 1994 from fear
mongering to frogs,” White said. “But it all comes down to using
good scientific studies to reach the decision. We applaud EPA for
sticking to the science.”
Next Step—Public Comment Period
EPA has now opened a public comment period that ends August 21,
2006. Growers are encouraged to submit comments to the docket in
support of the Triazine herbicides. This issue of the Triazine
Network News provides information on how to make your docket
submission.
Understanding the Three Regulatory Actions
As required by the Food Quality Protection Act (FQPA), a cumulative
risk assessment, which evaluates exposures based on a common
mechanism of toxicity, was conducted to evaluate the risk from food,
drinking water, and non-occupational exposure resulting from all
registered uses of chlorinated triazine pesticides. The chlorinated
triazine group includes the pesticides atrazine, simazine, and
propazine, in addition to their three chlorinated degradates.
Propazine, however, was not incorporated into the cumulative risk
assessment because no dietary, drinking water, or residential human
exposure to propazine is anticipated from any of the currently
registered uses. The Agency concurrently issued for public comment
the Reregistration Eligibility Decision (RED) for simazine and the
Tolerance Reassessment Progress and Risk Management Decision (TRED)
for propazine.
Triazine Cumulative Risk
Assessment
Environmental Protection Agency (EPA) has issued a favorable risk
assessment for the Triazine herbicides. The assessment was released
in June and EPA concluded that the cumulative risks associated with
Triazine herbicides “pose no harm that would result to the general
U.S. population, infants, children or other … consumers.”
Click here for talking
points.
Simazine Reregistration
Eligibility Decision (RED)
Simazine is a systemic herbicide that is usually applied to soil,
absorbed through roots, and acts by inhibiting photosynthesis within
the targeted plant. EPA has reviewed simazine through the public
participation process that the Agency uses in developing pesticide
reregistration and tolerance reassessment decisions. EPA has
determined that the database to support reregistration is
substantially complete and that products containing simazine are
eligible for reregistration provided the risks are mitigated either
in the manner described in the RED or by another means that achieves
equivalent risk reduction.
Click here for talking points.
Propazine Tolerance
Reassessment Progress and Risk Management Decision (TRED)
Propazine, also a systemic herbicide, currently is registered in the
U.S. for indoor greenhouse use only, and has existing tolerances
established for residues on sorghum. EPA has evaluated the existing
propazine sorghum tolerances and determined that there is a
reasonable certainty that no harm to the general population,
infants, children, or other major identifiable subgroups of
consumers will result from these tolerances. Dietary exposure to
propazine was determined to be essentially zero; propazine,
therefore, was found to pose no risk concerns. The four propazine
sorghum tolerances (forage, grain, stover, and sweet) are considered
reassessed and meet FQPA safety standards. No mitigation measures
are necessary for propazine at this time. The Agency has received
and will consider a request for a new use of propazine on sorghum in
the U.S. EPA's Propazine TRED that is available for public comment
until August 21, 2006.
Click here for talking points.
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Talking Points for Triazine Cumulative Risk Assessment
On June 21, 2006, the U.S. Environmental Protection Agency (EPA)
issued the Re-registration Eligibility Decision for simazine and a
favorable cumulative risk assessment for the triazine herbicides.
These actions bring EPA’s Triazine Special Review near a close, a
process that began in late 1994.
The EPA concluded that the cumulative risks associated with triazine
herbicides pose “no harm that would result to the general U.S.
population, infants, children or other...consumers.”
We are now in a public comment period, which ends August 21, 2006,
and we ask for your help in demonstrating grower support for
atrazine and simazine. Please review the key points below and
consider writing to EPA.
In your letter, consider commending EPA for:
Its classification of atrazine and simazine as “not likely” to cause
cancer in humans
Harmonizing product labels to ensure that users of all atrazine
products engage in the same use practices—practices which have
already made a significant improvement in environmental impact
Coordinating with other Agency offices
Sticking to sound science in its comprehensive reviews
Providing many opportunities for public comment in its proceedings
Let EPA know how important the triazine herbicides are to you or
your organization or crop as reliable, cost-effective and safe tools
for weed control.
Commend EPA for further protecting people and the environment by
harmonizing certain aspects of the simazine label with current
atrazine labels. These measures include a discontinuance of non-crop
uses, such as rights-of-way, and a match of atrazine’s maximum corn
rate of 2.5 lbs per acre.
Mention that this latest decision by EPA echoes favorable safety
assessments conducted by the World Health Organization (1998),
United Kingdom for European Union authorities (2000) and Australia
(2004).
Recognize EPA for implementing site-specific monitoring, an
innovative and science-based approach which insured U.S. farmers
continue to benefit from atrazine. Now, as successes in the field
continue to lessen the need for the program, it may be time to
consider how a phase-out of the monitoring would be implemented.
IN ADDITION FOR YOUR CONSIDERATION
Ask that EPA prioritize raising the Maximum Contaminant Levels (MCLs)
for atrazine and simazine. The registration decisions establish new
drinking water levels of comparison (DWLOC) of 12.5-68 ppb for the
herbicides and their metabolites, based on the latest available
science. The MCLs should now be revised accordingly.
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Talking Points for Simazine RED
U.S. growers rely on simazine.
Simazine offers effective, broad spectrum weed control and low risk
of crop injury in a variety of fruit and nut crops. It is
particularly important to farmers who grow fruits and nuts in
California and citrus crops in Florida.
Unlike many other herbicides, depending on the crop, simazine can be
applied prior to, during or after planting the crop, or after crop
emergence, fitting a wide variety of cropping systems including
soil-saving conservation tillage systems.
Simazine is an effective tank mix partner with other herbicides,
making it an important tool in weed resistance management.
Label harmonization with atrazine makes sense.
EPA is further protecting people and the environment by harmonizing
certain aspects of the simazine label with current atrazine labels.
These measures include a discontinuance of non-crop uses, such as
rights-of-way, and a match of atrazine’s maximum corn rate of 2.5
lbs per acre.
Simazine is correctly classified as “not likely” to cause cancer.
In the RED, EPA classifies simazine as “not likely” to cause cancer
in humans. This supports a ruling in 1999 by the World Health
Organization’s International Agency for Research on Cancer (IARC),
which re-categorized simazine as “not classifiable as to
carcinogenicity in humans.”
Simazine presence in community water systems is negligible.
As it did with atrazine, EPA is requiring a site-specific program
for monitoring simazine levels in U.S. drinking water systems. Only
six water systems warrant initial inclusion in the program. Only one
of the water systems had annual average concentrations of simazine
exceeding the agency’s level of concern. The other five were added
as a result of predictive modeling.
Simazine concentrations continue to decline in U.S. drinking water
systems due to changes in use and adoption by farmers of best
management practices, such as buffer strips.
IN ADDITION FOR
YOUR CONSIDERATION
EPA has required registrants to establish a website and toll-free
number to provide updates on simazine in these systems. (Visit
www.simazine-watershed.info or call 1-888-365-2874.) Considering
how few systems are in the monitoring program, and the fact that
none warrant mitigation, requiring growers to access these updates
prior to legally using simazine places an unnecessary burden on the
agricultural community.
New setbacks have been added to wells and waterways. Please comment
on how these may negatively impact your farm.
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Talking Points for Propazine TRED
The Agency has received and will consider a request for a new use of
propazine on sorghum in the U.S.
EPA's Propazine TRED is available for public comment until August
21, 2006.
Propazine has reduced phyto and yield impact versus many
alternatives.
Growers benefit from propazine’s ease of application (preemergent
residual).
Propazine can play an important role in resistance management.
Propazine has substantial benefits in grain sorghum crop rotation
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