On December 8, 2020, an allied industry coalition comprised of CPDA, CLA, and RISE submitted comments to EPA in response to the Agency’s Draft Human Health and Ecological Risk Assessments for Several Pesticides for Several Isothiazolinones. The draft risk assessment was posted by EPA for public comment on May 14, 2020 as part of the registration review process under FIFRA.
CPDA would like to thank Dr. Kevin Crosby (Adjuvants Unlimited, LLC) and Jennifer Bear (Helena Agri-Enterprises, LLC) who worked as a team in providing input and recommendations on behalf of CPDA in the development of the joint industry comments for submission to EPA. The contributions of Kevin and Jennifer in articulating CPDA’s concerns regarding the isothiazolinones draft risk assessment were made in support of the Council’s ongoing collaboration with CLA as a principal member of the CPDA-CLA Joint Inerts Steering Committee (JISC). The JISC is an industry forum made up of CPDA and CLA member company representatives that allows for the exchange of information on a wide range of inert ingredient regulatory initiatives and provides the opportunity for building consensus on specific issues of importance to both associations.
IT ingredients are used as preservatives in agricultural and specialty products including BIT and CMIT/MIT. CPDA and the other groups emphasized that there are presently very few options for preservation of formulated agricultural and specialty pesticide products and no known safe and effective alternatives to the IT chemistries. The group explained that the loss of IT-based options would have a cascading impact by limiting international trade and the opportunity to export products that are developed and produced in the U.S. Conversely, the loss of IT-based options available in the U.S. would limit the availability of imported pesticides to U.S. users/growers/applicators.
CPDA and the other associations pointed out that the importance of IT chemistries to the agricultural and specialty pesticide sectors is highlighted by the BIT shortage in 2018 which was caused by regulatory restrictions and an industrial accident in China that severely disrupted production. The industry coalition explained that the only alternatives to BIT having the tolerance exemptions permitted for use on food crops are the other IT products: CMIT/MIT and MIT. The group cautioned that additional restrictions on this class of chemicals “would devastate the agricultural sector, since there are literally no other cost-effective antimicrobial alternatives that have the necessary tolerance exemptions.”
CPDA and the others concluded by reiterating that isothiazolinones are essential in supporting innovation in pesticide formulations, enabling development and introduction of water-based formulations for products used by growers, professional applicators, and consumers in the United States. “Their loss,” CPDA and other members of the industry coalition warned, “would be devastating to this market sector and would adversely impact the overall availability, safety, and quality of pest control products in the U.S.” To access a copy of the joint industry comments on the draft isothiazolinones risk assessment submitted to EPA please click here.