February 8, 1999
Action Alert: Cotton Pesticide Poses Reproductive Risks to Birds
The American Bird Conservancy's Pesticides and Birds Campaign urges
the scientific, conservation and advocacy communities to call on the
U.S. Environmental Protection Agency (EPA) to deny registration of
the insecticide chlorfenapyr because of reproductive risks to birds.
Chlorfenapyr has been characterized by EPA as "one of the most
reproductively toxic pesticides to avian species that Environmental
Fate and Effects Division has evaluated." Because of the agency's
concerns regarding ecological risks, EPA's Office of Pesticide
Programs has opened a public comment period through February 19.
American Cyanamid has proposed use of chlorfenapyr (brand names
Pirate and Alert) as an insecticide and miticide on cotton. It is
touted as one of the most effective controls available for beet
armyworm in chemically intensive cotton agriculture. Applications
for use on citrus and vegetables and for termites and ants are also
pending. Chlorfenapyr belongs to a new class of chemical called
"pyrrole" -- never before registered by EPA. When metabolized, it
acts on the mitochondria and disrupts production of ATP (adenosine
triphosphate), leading to cell death and, ultimately, mortality.
The following ecological concerns are detailed in the EPA risk
assessment:
** In a chronic reproductive study of mallards, declines were seen
in number of eggs laid (-41%), number of viable embryos (-44%), and
number of normal hatchlings (-56%). A decrease in body weight of
adult males and females (males: -14%; females -15%) was also evident
and in females appeared in the first few weeks of exposure.
** American Cyanamid's testing shows chlorfenapyr to be persistent
in soils, with a half-life of one or more years. Applications made
to the same fields in consecutive years can result in a build-up in
the soil to as much 2.5 times the annual application rate. Such
persisting residues could contribute to levels of dietary exposure
higher than those suggested by a single year of application.
** Chlorfenapyr residues are found in avian food items including
weed seeds, insects and foliage. Levels of chlorfenapyr in avian
diets may be as much as 68 times higher than the EPA threshold for
reproductive effects, and EPA states that these toxicological
thresholds may be exceeded for up to five weeks after initial
application to cotton crops.
** The timing of chlorfenapyr applications coincides with critical
reproductive events for most, if not all, of the more than 50 avian
species that, according to American Cyanamid, are associated with
cotton fields. Many of the tested species are showing downward
population trends in cotton growing states.
American Cyanamid has proposed numerous mitigation measures and
restrictions for use of chlorfenapyr; however, EPA believes that
such measures "still yield dietary exposure estimates that exceed
chronic toxicity thresholds for birds." In addition, EPA's risk
assessment does not include effects of ingestion of the chemical
through preening or via drinking water, dermal exposures or
inhalation of suspended particles. American Cyanamid also has not
provided a field study of chlorfenapyr that specifically addresses
avian reproductive effects.
At least 13 pesticides documented as causing die-offs in migratory
birds are currently registered for use on cotton. The American Bird
Conservancy is concerned that the addition of another chemical with
evidence of reproductive risks for avian species is imprudent.
Send comments to the EPA by February 19 asking EPA to deny
registration status for chlorfenapyr under Section 3 of the Federal
Insecticide, Fungicide, and Rodenticide Act (FIFRA) given its
reproductive toxicity for birds. In addition, call for EPA to
discontinue the registration process for all other applications of
chlorfenapyr. Comments that add scientific information on
chlorfenapyr and its particular effects on avian species are
extremely valuable, as are comments on the scientific soundness of
EPAUs ecological risk and/or economic benefit characterizations.
Include docket number OPP-34162 and send to:
Public Information and Records Integrity Branch, Information
Resources and Services Division (7502C), Office of Pesticides
Programs, Environmental Protection Agency, 401 M St. SW, Washington
DC 20460. Email can be sent to opp-docket@epamail.epa.gov as an
ASCII attachment without special characters or encryption codes.
Full text of the chlorfenapyr risk benefit assessment can be found
at: www.epa.gov/pesticides/reg_assessment. Additional information
can be found at the American Bird Conservancy web site:
www.abcbirds.org
Source/contact: Kelley R. Tucker, Director, Pesticides and Birds
Campaign, American Bird Conservancy, 1250 24th St. NW, Washington,
DC 20037; phone (202) 778-9666; fax (202) 778-9778; email
ktucker@abcbirds.org.
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