WSSA COMMENTS ON EPA DRAFT BIOLOGICAL EVALUATIONS FOR GLYPHOSATE
EPA’s glyphosate biological evaluations (BEs) lack a workable and consistent approach to endangered species assessments. An assessment process which essentially equates any exposure to a pesticide as a possible concern to any species does little to advance appropriate options which could be tailored to improve species protection. The implications of unrealistic analyses will result in unjustified restrictions on the use of glyphosate products which remain critical weed management tools across the U.S.
NATIONAL INVASIVE SPECIES AWARENESS WEEK (NISAW): SHOW ME THE MONEY: MOVING FROM AUTHORIZATION TO APPROPRIATIONS
Presented on Feb. 26, 2021. The U.S. federal agencies responsible for invasive species management in aquatic and terrestrial ecosystems, in general, have sufficient legislative authority from Congress to manage invasive species. However, federal invasive species programs remain extremely underfunded. In FY 2020, the Department of the Interior estimated it spent $143 million to manage invasive species for 400+ million acres of public lands. That’s roughly 35 cents per acre for all invasive species research, prevention, EDRR, management and restoration. As invasive species stakeholders, we need to seek full appropriations as authorized for these programs. This presentation reviews the leaders and members of four of the Appropriations Subcommittees in the 117th U.S. Congress that have jurisdictions for funding invasive species management programs.
WSSA COMMENTS ON EPA DRAFT BIOLOGICAL EVALUATIONS FOR THE TRIAZINES
EPA’s triazine biological evaluations (BEs) lack a workable and consistent approach to endangered species assessments. An assessment process which essentially equates any exposure to a pesticide as a possible concern to any species does little to advance appropriate options which could be tailored to improve species protection. The implications of unrealistic analyses will result in unjustified restrictions on the use of triazine products which remain critical weed management tools across the U.S.
WSSA COMMENTS ON PARAQUAT PROPOSED INTERIM DECISION
Given the value of paraquat as a unique weed management tool and the updated human health mitigation measures, WSSA is opposed to the following two application restrictions proposed by EPA: 1) prohibition of all aerial applications of paraquat except for cotton desiccation; and 2) prohibition of all paraquat applications using mechanically pressurized handguns and backpack sprayers. Those application restrictions would eliminate many unique weed management options and put undue pressure on other broad-spectrum burndown treatments.
SOCIETIES URGE PASSAGE of FY 2021 APPROPRIATIONS and COVID RELIEF BILLS
In early December, WSSA and APMS joined more than 170 other organizations and institutions across all disciplines and areas of science and research in a letter to congressional leadership, urging swift action to finalize the annual funding levels for science agencies and programs and provide emergency research relief funding to mitigate the impact of the COVID-19 pandemic.
WEED SCIENCE SOCIETIES COMMENT ON INTERIOR’S DRAFT INVASIVE SPECIES STRATEGIC PLAN
The National and Regional Weed Science Societies applaud the Department of the Interior’s efforts to develop a concise, yet comprehensive Invasive Species Strategic Plan. Invasive weeds are a significant problem with their potential roles in displacing native species, altering structure and function of ecosystems, disrupting natural and agricultural landscapes, and causing economic damage. Invasive weeds in terrestrial and aquatic ecosystems are estimated to cost nearly $30 billion per year.
WEED SCIENCE SOCIETIES OPPOSE NEGUSE/UDALL LEGISLATION
The National and Regional Weed Science Societies, joined by more than 300 agriculture and conservation organizations, sent a letter to all members of the U.S. Senate and House of Representatives affirming their support for pesticide regulations under the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA). The letter is in response to recently introduced legislation (H.R. 7940, S. 4406) by Rep. Neguse and Sen. Udall that would undermine the science-based standards contained within our nation’s pesticide laws.
WEED SCIENCE SOCIETIES SUPPORT $380 MILLION SUPPLEMENTAL APPROPRIATIONS REQUEST FOR AG RESEARCH, EDUCATION, AND EXTENSION
The National and Regional Weed Science Societies joined over 270 other national, regional and state organizations to urge Congress to provide $380 million to our agricultural research, education, and extension system as it considers the next supplemental appropriations package in response to COVID-19. This request reflects a commitment to agriculture, families, businesses, and communities. It includes $300 million of job-saving support for USDA-NIFA capacity and competitive research and is consistent with the research community’s broader recommendations across the science agencies. Dramatic disruptions to our research talent pipeline, including the facilities and equipment that support it, will require additional support. The request also supports an $80 million request for the Cooperative Extension System to meet the direct needs of the public related to spread of, and recovery from, COVID-19. The synergy between research and extension is essential.
WEED SCIENCE SOCIETIES COMMENT ON THE REVISION OF APPLICATION EXCLUSION ZONE REQUIREMENTS
The Weed Science Society of America (WSSA), along with the Aquatic Plant Management Society, the North Central Weed Science Society, Northeastern Weed Science Society, Southern Weed Science Society and the Western Society of Weed Science welcome the opportunity to comment on the Revision of the Application Exclusion Zone (AEZ) Requirements. We applaud the Environmental Protection Agency (EPA or the Agency) for its efforts and time on the current standards and for allowing public comments to improve and simplify the AEZ for pesticide applicators. In this letter, the National and Regional Weed Science Societies communicate our support for the proposed changes to the AEZ Requirements.
WEED SCIENCE SOCIETIES COMMENT ON EPA’S INTERIM PROCESS FOR EVALUATING POTENTIAL SYNERGISTIC EFFECTS OF PESTICIDES DURING THE REGISTRATION PROCESS
To date, EPA has used an interim process to evaluate 24 new active ingredient registrations. None of these reviews have ultimately impacted an existing EPA ecological risk assessment. The results from the analysis of the first 24 active ingredients reflects that there is a low probability that claims asserting greater than additive (GTA) effects will impact ecological risk assessments for pesticide active ingredients. Therefore, the National and Regional Weed Science Societies support EPA’s plans to evaluate the results of the interim process, and once a sufficient number of reviews are completed, to decide whether continuing the process has utility in evaluating ecological risk associated with product use. If the outcome of EPA’s future evaluation demonstrates that the interim process does not have utility in evaluating ecological risk associated with product use, our societies agree that EPA and registrants should not exhaust additional time and resources in this endeavor and suspend evaluations.
AMERICA GROWS ACT WOULD BOOST AG RESEARCH FUNDING
The six National and Regional Weed Science Societies joined over 80 other organizations in supporting legislationintroduced by Senator Dick Durbin (IL) that would authorize a 5% inflation-adjusted annual increase for the next 5 years for agricultural research at USDA-ARS, NIFA, ERS, and NASS. The America Grows Act (S. 2458) is modeled after the 21st Century Cures Act passed in 2016, which spurred additional funding for NIH.
WSSA’S POSITION ON GLYPHOSATE
In 2015, glyphosate was classified as a “probable carcinogen” by the International Agency for Research on Cancer (IARC). IARC has applied the same classification to red meat, hot beverages, and emissions from high-temperature frying, as well as to more than 70 other chemicals. This designation has caused widespread public concern about the safety of glyphosate while being the recent focus of multiple lawsuits. WSSA has developed this document to inform the membership and general public of its position on this topic.
WEED SCIENCE SOCIETIES COMMENT on EPA’s PROPOSED INTERIM REVIEW DECISION for GLYPHOSATE
The National and Regional Weed Science Societies compliment EPA on the many positive aspects of their proposal to mitigate potential risks with glyphosate use while noting its importance in the management of invasive and noxious weeds in agricultural and non-agricultural settings. Scientific literature has clearly shown that the benefits of glyphosate outweigh any potential ecological risks. We agree that improvements to labels that are consistent across all glyphosate products will help to further mitigate these risks.
RECOMMENDED BEST PRACTICES FOR REDUCING WEED SEEDS IN U.S. SOYBEAN EXPORTS
By taking steps to reduce weed seeds in soybeans, participants along the supply chain will make U.S. soy even more competitive in the global marketplace. Fortunately, there are a number of best practices—many of which are already in use here in the United States—that can be applied on farm and at U.S. grain elevators to help reduce weed seeds in U.S. soybeans.The full report can be accessed here.
Listen to the interview by Dr. Lee Van Wychen on this topic.
DICAMBA RESEARCH WORKSHOP PRESENTATIONS
The Weed Science Society of America (WSSA) sponsored a research workshop on off-target movement of dicamba on April 16 -17, 2018 in Arlington, VA. WSSA invited a broad group of subject experts including weed scientists, state and federal regulators, application technology specialists, and representatives of dicamba registrants to discuss technical issues related to the off-target movement of dicamba observed and reported in 2016 and 2017, and to identify potential research objectives. The final report of the meeting can be accessed here. This report is a compilation of notes, presentations, and action items from the discussions held at the workshop.
WSSA CONCERNS ABOUT NIFA RELOCATION
The Weed Science Society of America (WSSA) wrote to USDA Sec. Perdue to express concerns our members have about the relocation of the National Institute of Food and Agriculture (NIFA) outside the National Capitol Region (NCR).
SUPPORT IR-4 AT $19 MILLION IN FY 2019
There is currently a push to get IR-4 funded at $19 million in FY 2019. Annual funding for IR-4 has been stagnating at around $11.9 million for nearly a decade. On April 26, Sen. Menendez (D-NJ) sent a “Dear Colleague” letter to Senate Ag Appropriations Committee Chair John Hoeven (R-ND) and Ranking Member Jeff Merkley (D-OR) requesting an appropriation of $19 million for the IR-4 Project for FY 2019. The letter was co-signed by 13 Senators and supported through the efforts of the IR-4 Commodity Liaison Committee, the Minor Crop Farmers Alliance, and endorsed by nearly 60 organizations including the six National and Regional Weed Science Societies.
CAST PAPER: REGULATORY BARRIERS TO THE DEVELOPMENT OF INNOVATIVE AGRICULTURAL BIOTECHNOLOGY BY SMALL BUSINESSES AND UNIVERSITIES
This report examines the current U.S. regulatory system for genetically engineered (GE) crops, compares it with those of major trading partners, and considers the effects it has on agricultural biotechnology. Led by the Task Force Chair Alan McHughen, these experts show that despite foundational contributions requiring considerable public resource commitments for GE crop innovation and development, academic institutions and small private entities have been almost entirely excluded from the agricultural biotechnology market. Read the following documents associated with this report.
LETTER TO SENATE URGING SUPPORT OF S.340
The National and Regional Weed Science Societies joined over one hundred fifty organizations in a letter to the Senate urging support of S. 340, the Sensible Environmental Protection Act of 2017. The bill provides a legislative fix for the duplicative NPDES permitting currently required for FIFRA-approved aquatic use herbicides. The letter can be downloaded from here.
WEED SCIENCE SOCIETIES COMMENT ON APHIS REVISION OF ITS BIOTECHNOLOGY REGULATIONS
The National and Regional Weed Science Societies submitted comments on APHIS’s proposed rule regarding the importation, interstate movement, and environmental release of certain genetically engineered (GE) organisms. APHIS’s proposed revisions are in response to advances in genetic engineering and APHIS’s accumulated experience in implementing the current regulations. While we complimented APHIS on the many positive aspects of the proposal, we encouraged APHIS to re-propose a rule that minimizes regulatory uncertainty related to their weed risk assessment model.
The comments by Weed Science Societies can be accessed here
LETTER TO CONGRESS URGING SUPPORT OF H.R. 953
The National and Regional Weed Science Societies join over one hundred organizations in a letter to Congress urging support of H.R. 953, the Reducing Regulatory Burdens Act of 2017. The letter can be downloaded from here.
CAST PAPER ON CROP PROTECTION CONTRIBUTIONS TOWARD AGRICULTURAL PRODUCTIVITY
The authors of this CAST Issue Paper examine the current plant protection revolution that is driven by the biological realities of pesticide resistance, various market forces, and real or perceived side effects of pesticides. They point out that “crop protection chemicals have been miraculous, but their automatic use is no longer efficacious or justifiable.” Led by Task Force Chair Susan T. Ratcliffe, the authors of this paper consider new technologies such as drones, smart sprayers, and specially designed cultivators–and they examine current biotech advancements such as CRISPR-Cas9 and other techniques that may fit well into integrated systems. They emphasize the need for research, communication, and collaboration as scientists “develop integrated strategies for managing pests while preserving ecosystem services and farm productivity.” The paper can be downloaded from here.
WSSA COMMENTS ON TRIAZINE DRAFT ECOLOGICAL ASSESSMENT
Oct. 5, 2016. A number of concerns have been raised by various stakeholders relative to EPA’s draft ecological risk assessment for the triazines. These concerns include: errors in endpoint data and the water monitoring database; use of models that are not validated with field data; estimates of inflated hypothetical risks (e.g. atrazine applications resulting in 36% bird mortality) that have not been observed in over 55 years of atrazine use; use of data or findings not conducted in accordance with EPA’s scientific guidelines required under FIFRA; and ignoring the advice and findings of previous Science Advisory Panels on atrazine. The WSSA stresses the importance of addressing these concerns in order to maintain stakeholder confidence in the Agency’s science-based regulatory framework. However, our main concern, based on the current ecological draft risk assessment, is that atrazine and simazine would be restricted to less than 0.25 lbs a.i./A and 0.5 lbs a.i./A, respectively. At these low rates, atrazine and simazine would not provide efficacious weed control. In addition, using sub-lethal rates of atrazine or simazine is not an effective option for resistance management as it has been shown that this practice is likely to result in weeds with multiple-site or polygenic resistance which would make it more difficult to control these weeds. Comments are here.
WSSA COMMENTS ON FIFRA SCIENCE ADVISORY PANEL (SAP) REVIEW OF GLYPHOSATE CARCINOGENICITY
Oct. 4, 2016. WSSA fully supports EPA’s Cancer Assessment Review Committee’s (CARC) report on glyphosate (Docket ID: EPA-HQ-OPP-2016-0385-0014) and appreciates the scientific rigor and thoroughness of the CARC’s review of all available epidemiology and carcinogenicity studies. WSSA agrees with the CARC’s assessment that the few studies that the International Agency for Research on Cancer (IARC) selectively chose for its glyphosate review suffered from small sample sizes of cancer cases related to glyphosate exposure and had risk/odds ratios with large data variance beyond acceptable limits. Furthermore, WSSA feels that the IARC review process for glyphosate was flawed and represents a case of gross scientific negligence. There is no question that IARC arrived at their conclusion due to their inclusion of the positive findings from a selection of studies with known limitations, a lack of reproducible positive findings, and the omission of the negative findings from credible and reliable research. Finally, WSSA commented on the ongoing importance of glyphosate as a weed management tool and submitted information we developed surrounding some common misconceptions about glyphosate and herbicide resistance management. Comments are here.
WEED SCIENCE SOCIETIES COMMENT ON EPA’S DRAFT GUIDANCE ON HERBICIDE RESISTANCE MANAGEMENT
Sept. 1, 2016. This summer EPA issued a Pesticide Registration Notice (PRN) that proposes an approach to address herbicide-resistant weeds by providing guidance on labeling, education, training, and stewardship for herbicides undergoing registration review or registration. The National and Regional Weed Science Societies recognize the critical need to protect all available weed management tools and are on record supporting proactive measures by EPA to combat the further evolution and spread of herbicide-resistant weeds. EPA’s proposal represents a significant change in how resistance is monitored, mitigated and communicated to weed management stakeholders. We consider this proposal a first iteration that will need adaptation and evolution as our experience with it grows and we hope the Agency has those same expectations. Comments are here.
EPA MANUAL AVAILABLE ON HOW TO COMPLY WITH THE REVISED WORKER PROTECTION STANDARDS
The EPA in conjunction with the Pesticide Educational Resources Collaborative (PERC) has made available a guide to help users of agricultural pesticides comply with the requirements of the 2015 revised federal Worker Protection Standard (WPS). You should read this manual if you employ agricultural workers or handlers, are involved in the production of agricultural plants as an owner/manager of an agricultural establishment or a commercial (for-hire) pesticide handling establishment, or work as a crop advisor. The “How to Comply” manual includes:
• Details to help you determine if the WPS requirements apply to you
• Information on how to comply with the WPS requirements, including exceptions, restrictions, exemptions, options, and examples
• “Quick Reference Guide”- a list of the basic requirements (excluding exemptions, exceptions, etc.) new or revised definitions that may affect your WPS responsibilities, and
• Explanations to help you better understand the WPS requirements and how they may apply to you.
The revised EPA Pesticide Worker Protection Standard “How to Comply” Manual is available here.
2016-2018 NISC MANAGEMENT PLAN
The National Invasive Species Council (NISC) announced the release of their 2016-2018 Management Plan. The plan sets forth high priority, interdepartmental actions for the Federal government and its partners to take to prevent, eradicate, and control invasive species, as well as restore ecosystems and other assets adversely impacted by invasive species. The thirteen Federal Departments and Agencies whose senior officials comprise NISC will:• Provide Federal leadership on invasive species issues by establishing the structures, policy, and planning priorities necessary to enable Federal agencies to effectively prevent, eradicate, and/or control invasive species, as well as restore impacted ecosystems and other assets;
• Limit the spread and impact of invasive species through high-level policy and planning by strengthening coordination between the United States and other governments, across the Federal government, and between the Federal government and non-governmental stakeholders;
• Raise awareness of the invasive species issue and mobilize the policies, programs, and financial resources necessary to minimize the spread and impact of invasive species;
• Remove institutional and policy barriers to the Federal actions needed to prevent, eradicate, and control invasive species, as well as restore ecosystems and other assets;
• Conduct assessments of Federal capacities to meet the duties set forth in Executive Order 13112, as well as other high-level policy priorities, and build Federal capacities, as needed;
• Foster the scientific, technical, and programmatic innovation necessary to enable Federal agencies and their partners to prevent and mitigate the impacts of invasive species in a timely and cost-effective manner with negligible impacts to human and environmental health.
The 2016-2018 NISC Management Plan is available here.
FHWA ROADSIDE REVEGETATION HANDBOOK WITH EMPHASIS ON POLLINATORS
In its first major update since 2007, the Federal Highways Administration (FHWA) has expanded their roadside revegetation manual to include a major emphasis on pollinators. The handbook is now titled “Roadside Revegetation: An Integrated Approach to Establishing Native Plants and Pollinator Habitat”. With at least 17 million acres of roadsides in the U.S., roadside vegetation can serve as much needed habitat for pollinators, offering food, breeding, or nesting opportunities and connectivity that can aid pollinator dispersal. Roadside vegetation management influences how pollinators use roadsides, and even influences the number of pollinators killed by vehicles. For example, butterfly vehicle mortality rates increase with more frequent mowing and decrease with high plant diversity in roadside vegetation.
The publication is written specifically for the “designer,” those individuals or members of a road design team who will be directly involved in planning, implementing, monitoring, or maintaining a revegetation project.
LETTER SUPPORTING H.R. 897, THE ZIKA VECTOR CONTROL ACT
The National and Regional Weed Science Societies joined over 100 other organizations urging Congress to include H.R. 897, the Zika Vector Control Act (aka the NPDES-fix bill) in the final conference agreement that includes funding for the U.S. response to the Zika virus outbreak.
USDA-ARS NP 304: CROP PROTECTION AND QUARANTINE 2015-2020 ACTION PLAN
Read the USDA-ARS action plan on national program 304 – crop protection and quarantine – for the years 2015-2010, which was just released. The primary goal of the program is to conduct research to create the knowledge base necessary to develop innovative control methods and IPM strategies and also conduct applied research to produce information and material products that improve pest and disease control in agriculture.
PLANT SCIENCE SUMMIT ISSUES DECADAL VISION REPORT
On July 25 the Plant Science Research Summit released Unleashing a Decade of Innovation in Plant Science: A Vision for 2015-2025 (PDF), a call to action for the U.S. to address research priorities in plant science that could address major challenges including health, energy, food, and environmental sustainability. The report, supported by the American Society of Plant Biologists, Howard Hughes Medical Institute, the National Science Foundation, the U.S. Department of Agriculture, and the U.S. Department of Energy, provides recommendations regarding future budgets and investments at the state and federal levels.
REPORT – EVERY $1 INVESTED IN AGRICULTURAL RESEARCH RETURNS $10 WORTH OF BENEFITS TO THE ECONOMY
Over the last several decades, the U.S. agricultural sector has sustained impressive productivity growth. The Nation’s agricultural research system, including Federal-State public research as well as private-sector research, has been a key driver of this growth. Economic analysis finds strong and consistent evidence that investment in agricultural research has yielded high returns per dollar spent.
WSSA REPORT – DETERMINATION OF THE POTENTIAL IMPACT FROM THE RELEASE OF GLYPHOSATE- AND GLUFOSINATE-RESISTANT AGROSTIS STOLONIFERA L. IN VARIOUS CROPS AND NON-CROP ECOSYSTEMS
The Weed Science Society of America (WSSA) was asked by the United States Department of Agriculture-Animal Plant Health Inspection Service (USDA-APHIS) to perform an analysis of the weed management implications associated with the potential deregulation and commercialization of glyphosate and glufosinate-resistant creeping bentgrass (Agrostis stolonifera L.) varieties. This analysis is needed to determine the current and potential significance of creeping bentgrass, and other species with which it can hybridize (several other Agrostis spp. and Polypogon spp.), as weeds in managed and non-managed ecosystems in the United States. The analysis deliberately focused exclusively on the weed management implications of the potential release of these creeping bentgrass varieties and did not attempt to assess other associated environmental and economic considerations. The Weed Science Society of America does not endorse or oppose the proposed deregulation of glyphosate- or glufosinate-creeping bentgrass. The information contained in this report does not represent a position for or against the technology and should not be interpreted as such. This work was done at the request of USDA/APHIS to provide science-based information for their use as a regulatory agency.