Many growers may not realize that By March 31, the EPA has been court-ordered to make a final decision on whether to revoke all food use tolerances for chlorpyrifos, commonly sold as Lorsban. The comment period has ended so all we can do is wait and see.

Pyrethroids now appear to be next on the chopping block. This includes products like bifenthrin, Warrior/Karate, Mustang Max, Baythroid, Asana, Permethrin, etc, which are the primary materials we have available to manage weevils and ambrosia beetles. See below for instructions on making comments to EPA regarding pyrethroid use:

IF PYRETHOIDS ARE IMPORTANT IN PRODUCTION OF YOUR CROPS, YOU ARE ENCOURAGED TO SUBMIT COMMENTS TO EPA ON THIS EVALUATION.

The current deadline is Jan. 30 at 11:59 p.m. (ET). 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 preharvest 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.

To comment, click on the following link:
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.

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.

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