Triazine Network Sends Letter to EPA Fighting for Atrazine

Below is the letter sent to EPA Administrator Lisa Jackson by the Triazine Network, co-signed by over 120 organizations and supported by thousands of individual growers.  If you would like to show your support, click here.

September 7, 2010

The Honorable Lisa P. Jackson, Administrator
U.S. Environmental Protection Agency
Ariel Rios Federal Building
1200 Pennsylvania Avenue, N.W.
Washington, DC 20460

Dear Administrator Jackson:

No one cares more about the safety of the herbicide atrazine than those of us who use it in the fields where we raise our families. We drink the local water. We swim and fish in local lakes, rivers, and ponds. We look forward to passing our way of life onto our children and grandchildren. Simply stated, we care about keeping our environment healthy and our foods safe and abundant.

But we are becoming increasingly concerned by the serious irregularities in the EPA’s current re-review of the herbicide atrazine. Atrazine and its companion triazine herbicides have a 50-year history as safe and effective weed-control products used on more than 30 commodities in over 40 states and 60 countries. Atrazine is a staple product for producers, who use it as a critical tool for weed control in growing the vast majority of corn, sorghum and sugarcane in the United States. Use of atrazine fights weed resistance, reduces soil erosion and increases crop yield.

Five decades of continued and rigorous EPA testing has shown time and again that atrazine poses no danger to public health. Over the last half century, more than 6,000 atrazine studies have been submitted to EPA. These studies confirmed, and EPA agreed, that atrazine does not affect human health. EPA’s current 3 parts per billion limit for lifetime exposure or the 298 ppb limit for short-term exposure, are standards that are more than 1,000 times safer than a level shown to have no effect. We would also note, atrazine’s status as one of the most widely tested herbicides adds a high level of confidence in its safety profile.

EPA’s unscheduled and rushed re-review departs from the normal regulatory process. Pesticides like atrazine are subject to regular review. In fact, atrazine was re-registered in 2006 and not scheduled for re-review until 2013. In October 2009, EPA scheduled an unprecedented four Scientific Advisory Panels (SAPs) within 11 months. Since 2000, EPA reviews have included more than 16 opportunities for public comment, including six SAP meetings convened under the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA).

The current SAP proceedings are: taking on an unprecedented range of topics over the course of four SAP meetings in a single year, each of which is focused on a range of considerations; being conducted on an abbreviated timeline, resulting in rushed science; and focused on studies and data that are not made available until shortly before the scheduled meeting.

Assistant Administrator Owens said that the Agency was initiating the review to evaluate new science. Upon considering these studies that EPA used to initiate the new review of atrazine, the February SAP concluded that “the overall quality of these studies was relatively low, thus limiting their applicability…” Had the Agency followed its own process of internal data evaluation it would have known that the new studies were not useful in a regulatory decision making process.

Agency scientist Anna Lowitt, Ph.D., said at the April SAP that the Agency has assembled a “small army” with a “very large task in a very short time frame.” However, the Agency has also testified before Congress that the new review is being used in its preparation for the scheduled 2013 reregistration of atrazine. The actions of a rushed re-review process do not align with the Agency’s position on a reregistration process that’s still three years away.

The rushed re-review process departs dramatically from the Obama Administration’s commitment to sound science-based policy. EPA has an established, scientific process for reviewing the human health and environmental effects of atrazine. In the past 15 years alone:

• A June 27, 2000, SAP overseen by Clinton EPA Administrator Carol Browner found that atrazine is not likely to cause cancer in humans;
• A re-review concluded on October 31, 2003, conducted principally under Bush EPA Administrator Christine Todd Whitman, found a reasonable certainty of no harm;
• A cumulative risk assessment on June 22, 2006, found a reasonable certainty of no harm associated with the use of atrazine in accordance with EPA guidelines with regard to both human health and environmental effects;
• A 2003 SAP proceeding focused on reports of atrazine’s effect on amphibian reproductive development found that the evidence submitted provided insufficient basis for any definitive judgment; and
• In 2007, EPA concluded that it was reasonable to reject the 2003 hypothesis that atrazine exposure can affect amphibian gonadal development. EPA also determined that there was no compelling reason to pursue additional testing.

A July 21, 2010 memorandum from Tina Levine, Ph.D., said that “the Agency plans to propose updated points of departure for use in risk assessment…” in the September SAP. We are very concerned about how the EPA could suggest a new regulatory position without evaluating all the science proposed by the Agency.

Decision making should be arrived at through a transparent, data-driven process. Data must be made available to the public, including stakeholders such as farmers. There must be a regularity of process. Deviations from well-established, science driven practices impair the integrity of resulting decisions.

Large sectors of American agriculture today rely on atrazine to support their businesses and workers. Its loss would result in the elimination of tens of thousands of jobs during one of the longest employment recessions in our history. Rural communities would feel the most economic pain. In rural America, loss of farm gate dollars mean reduced resources essential to community services such as emergency medical care, and that is far from a theoretical risk.

The integrity of the process is critical if the American people are to accept the regulatory decisions made by EPA, which so dramatically affect the livelihoods of millions across the nation. That’s why we believe it is essential that you address the concerns that we have stated here and guarantee that the process from now forward will be fair, transparent, and given enough time for sound science to prevail.

Ms Jackson, we are very concerned. Specifically, why after the extensive review and reregistration completed in 2006 and with a scheduled reregistration up in 2013, were Agency staffers directed to assemble an “army”, as reported earlier, with a “very large task in a very short time frame”? When this statement was made, much of the hyped up activists/media claims against atrazine last fall had already been debunked by the Agency as low quality and not very useful.

We will be sharing our concerns and your response with our Congressional contacts and look forward to understanding current internal EPA directives as we prepare for the September SAP process.

Yours sincerely,

Jere White, Chairman

Cosigned by the following:

National Corn Growers Association
632 Cepi Drive
Chesterfield , MO , 63005

National Sorghum Producers
4201 N. I-27
Lubbock, Texas 79403

American Soybean Association
12125 Woodcrest Executive Dr . Suite 100
St. Louis, Missouri 63141

Agricultural Retailers Association
1156 15th Street, NW Suite 302
District of Columbia, Washington DC 20005

American Agri-Women
2103 Zeandale Road
Manhattan, Kansas 665

National Potato Council
1300 L Street Suite 910
Washington, DC 20005

National Agricultural Aviation Association
1005 E Street, SE
Washington, DC 20003

Agribusiness Association of Iowa
900 Des Moines St.
Des Moines, Iowa 50309

Albany Weed Man
640 Old Salem Rd NE P.O. Box 3395
Albany, Oregon 97322

Arizona Crop Protection Association
1110 E. Missouri, Ste 340
Phoenix, Arizona 85014

Biotreat Agronomy, Inc.
PO Box 852
Spearman, Texas 79081

Brown Milling, Inc.
8731 e. Rosebush Rd.
Mt. Pleasant, Michigan 48858

California Citrus Mutual
512 N Kaweah Ave.
Exeter, California 93221

California Grape and Tree Fruit League
978 W Alluvial Ave Ste 107
Fresno, California 93711

California Women for Agriculture
9337 E. South Ave.
Selma, California 93662

Campbell TImberland Management
P.O. Box 1540 227 Main #220
McCloud, California 96057

Cenex Harvest States, Inc.
PO Box 1598
Hereford, Texas 79045

Chemical Industry Council of Illinois
400 W. Monroe St. Suite 205
Springfield, Illinois 62704

Citizens LLC
870 South Main Street
Vermontville, Michigan 49096

Claiborne Farmer’s Co-op
PO Box 160
New Tazewell, Tennessee 37824

Cocke (TN) Farmers Co-op
4048 E Morris Blvd
Morristown, Tennessee 37813

Colorado Corn Growers Association
127 22nd Street
Greeley, Colorado 80631

Conservation Technology Information Center
3495 Kent Avenue Suite J100
West Lafayette, Indiana 47906

Corning Crop Production Services
11 Airport Hwy 980
Corning, Arkansas 72422

Covington Crop Production Services
2425 Rialto Rd
Covington, Tennessee 38019

Crotolaria Seed Specialists, LLC
95-1048 Kelakela St.
Mililani, Hawaii 96789

Dahle Orchards
5070 Cherry Heights Rd
The Dalles, Oregon 97058

Dyersburg Crop Production Services
4180 Highway 104 West
Dyersburg, Tennessee 38024

El Rancho Nuevo
246 B St
Independence, Oregon 97351

Environmental Resources Coalition
Suite 110 3118 Emerald Lane
Jefferson City, Missouri 63552

Foreseman Farms
6801 Fegan Rd
Summerfield, Illinois 27358

Gillett Crop Production Services
P.O. Box 69
Tichnor, Arkansas 72166

Hampton Affiliates
42235 Old Highway 30
Astoria, Oregon 97103

Hampton Resources, Inc.
PO Box 2315
Salem, Oregon 97308

Hawaii Agriculture Research Center
94-340 Kunia Road
Waipahu, Hawaii 96797

Hawaii Crop Improvement Association
91-1012 Kahiuka St.
Ewa Beach, Hawaii 96706

Hawaii Farm Bureau Federation
75 Kawehi Place
Kula, Hawaii 96790

Hawaiian Commercial and Sugar Company
PO Box 266
Puunene, Hawaii 96784

Idaho Council on Industry & Environment
PO Box 255
Boise, Idaho 83701

Illinois Corn Growers Association
PO Box 1623
Bloomington, Illinois 61702-1623

Illinois Farm Bureau
1701 Towanda Avenue
Bloomington, Illinois 61701

Indiana Corn Growers Association
5730 W 74th St
Indianapolis, Indiana 46278

Indiana Farm Bureau, Inc.
225 S. East St. PO Box 1290
Indianapolis, Indiana 46206

Indiana Soybean Alliance
5730 W 74th St
Indianapolis, Indiana 46278

Iowa Corn Growers Association
5505 NW 88th Street
Johnston, Iowa 50131

Iowa Farm Bureau Federation
5400 University Ave
West Des Moines, Iowa 50266

Iowa Seed Association
900 Des Moines Street
Des Moines, Iowa 50309

Kansas Agribusiness Retailers Assn.
816 SW Tyler
Topeka, Kansas 66612

Kansas Corn Growers Association
110 W. 4th
Garnett, Kansas 66032

Kansas Farm Bureau
800 SW Jackson, Suite 1300
Topeka, Kansas 66612

Kansas Grain Sorghum Producers Association
110 W. 4th
Garnett, Kansas 66032

Kentucky Corn Growers Association
PO Box 90
Eastwood, Kentucky 40018

Lebanon Crop Production Services, Lebanon, IN
394 N Mt Zion Rd
Lebanon, Indiana 46052

Lone Rock Timber Management Company
PO Box 1127
Roseburg, Oregon 97470

Longview Timber Corp
PO Box 340
Silverton, Oregon 97381

Louisiana Farm Bureau Federation
P.O. Box 95004
Baton Rouge, Louisiana 70895

Menasha Forest Products Corp.
PO Box 588
North Bend, Oregon 97459

Michigan Agri-Business Association
1501 North Shore Drive Suite A
East Lansing, Michigan 48823

Michigan Bean Shippers Association
1501 North Shore Drive Suite A
East Lansing, Michigan 48823

Michigan Corn Growers Association
13750 S. Sedona Parkway, Suite 5
Lansing, Michigan 48906

Michigan Farm Bureau
7373 W. Saginaw Hwy
Lansing, Michigan 48917

Midwest Food Processors Association
4600 American Parkway Suite 110
Madison, Wisconsin 53718

Minnesota Agri-Growth Council
408 St. Peter Street Suite 20
Saint Paul, Minnesota 55102

Minnesota Chamber of Commerce
400 Robert St N, Suite 1500
St Paul, Minnesota 55101

Minnesota Corn Growers Association
738 1st Ave. East
Shakopee, Minnesota 55379

Minnesota Crop Production Retailers
7500 Flying Cloud Dr Suite 900
Eden Prairie, Minnesota 55344

Missouri Agribusiness Association
410 Madison St P.O. Box 1728
Jefferson City, Missouri 65102

Missouri Corn Growers Association
3118 Emerald Lane
Jefferson City, Missouri 65109

Monsanto Molokai
HC01 Box 104 1351 Maunaloa Highway
Kaunakakai, Hawaii 96748

Montana Agricultural Business Association
PO Box 7325
Helena, Montana 59604

Mt. Fanny Farms, Inc.
76122 Rosenberg Rd
Echo, Oregon 97826

Natural Plant Products, Inc. (NPP)
707 13th St. SE Suite 275
Salem, Oregon 97301

NC Agribusiness Council, Inc.
2500 Regency Parkway
Cary, North Carolina 27518

NC Farm Bureau
P. O. Box 27766
Raleigh, North Carolina 27611

Nebraska Corn Growers Assn
1327 H Street
Lincoln, Nebraska 68508

Nebraska Grain Sorghum Board
P.O. Box 94982
Lincoln, Nebraska 68509

Nebraska Grain Sorghum Producers Association
P.O. Box 94982
Lincoln, Nebraska 68509

New York Corn & Soybean Growers Association
27 Elk St
Albany, New York 12207

New York Farm Bureau
159 Wolf Road
Albany, New York 12205

North Dakota Corn Growers Association
1411 32nd St S #2
Fargo, North Dakota 58103

Ohio Agri-Women
2274 E. Lytle Five Points Rd
Dayton, Ohio 45458

Ohio Corn Growers Association
59 Greif Parkway Suite 101
Delaware, Ohio 43015

Oklahoma Agribusiness Retailers Assn
2309 N 10th Ste E
Enid, Oklahoma 73701

Onarga Crop Production Services
112 West Washington
Onarga, Illinois 60955

Oregon Farm Bureau
3415 Commercial St SE
Salem, Oregon 97302

Oregonians for Food & Shelter
1149 Court Street NE Suite 110
Salem, Oregon 97301

Pacific Northwest Vegetable Association
100 N. Fruitland, Suite B
Kennewick, Washington 99336

Pennsylvania Energy Resources Group, LLC
PO Box 1205 Harrisburg
Pennsylvania 17108

Plains Crop Production Services
PO Box 518
Plains, Kansas 67869

Short Lane Ag
W606 Short Rd
Colby, Wisconsin 54421

South Dakota Agri-Business Association
320 E. Capitol Avenue
Pierre, South Dakota 57501

South Dakota Association of Cooperatives
116 N Euclid
Pierre, South Dakota 57501

South Dakota Corn Growers Association
5109 South Crossing Place, Suite 1
Sioux Falls, South Dakota 57108

South Texas Cotton & Grain Association
P.O. Box 4881
Victoria, Texas 77903

Southwest Council of Agribusiness
5522 US Hwy 87
Dumas, Texas 79029

Stanton Farms
802 West 2nd Street
Alta, Iowa 51002

Stimson Lumber Company
P.O. Box 68
Forest Grove, Oregon 97116

Sugar Cane Growers Cooperative of Florida
Post Office Box 666
Belle Glade, Florida 33430

Superior Ag COOP
1630 N 600 W
Jasper, Indiana 47546

Tangent Crop Production Services
PO Box 269
Tangent, Oregon 97389

Taylor Farms Inc
2538 Drift Creek Rd NE
Silverton, Oregon 97381

Texas Ag Industries Association
145 West Travis
La Grange, Texas 78945

Texas Agri Women
P. O. Box 575
Sinton, Texas 78387

Texas Citrus Mutual
901 Business Park Suite 400
Mission, Texas 78572

Texas Corn Growers Association
4205 N. I-27
Lubbock, Texas 79403

Texas Grain Sorghum Association
4201 N. I-27
Lubbock, Texas 79403

Union City Crop Production Services
530 N. Fifth St.
Union City, Tennessee 38261

United States Sugar Corporation
Ponce de Leon Avenue
Clewiston, Florida 33440

Washington Farm Bureau
975 Carpenter Road NE
Lacey, Washington 98516

Washington Friends of Farms & Forests
PO Box 6744
Olympia, Washington 98507

Washington Mint Growers Assn.
100 No. Fruitland St. Suite B
Kennewick, Washington 99336

Webbers Falls Crop Production Services
P.O. Box 577
Webbers Falls, Oklahoma 74470

Western Growers Association
17620 Fitch Street
Irvine, California 92614

Wisconsin Agribusiness Council
PO Box 46100
Madison, Wisconsin 53744

Wisconsin Christmas Tree Producers Assn.
W9833 Hogan Rd.
Portage, Wisconsin 53901

Wisconsin Corn Growers Association
W1360 Highway 106
Palmyra, Wisconsin 53156

Wisconsin Crop Production Association
2317 International Lane Suite 102
Madison, Wisconsin 53704

Wisconsin Farm Bureau Federation
1241 John Q Hammons Drive P.O. Box 5550
Madison, Wisconsin 535705

Wisconsin River Coop
PO Box 729
Adams, Wisconsin 53910

Wyoming Ag-Business Association
459 Roger Canyon Road PO Box 1778
Laramie, Wyoming 82073

York County Corn Growers
1326 McKaig Ave
York, Nebraska 68467