The Pyrethroid Working Group thanks you for agreeing to voice your support of pyrethroids! Your input will provide helpful information to address concerns that the EPA's preliminary ecological risk assessment for this group of pesticides does not take into account the totality of relevant scientific data, and fails to fully recognize the critical role pyrethroids play in the success of your industry and business.
In order to draft an effective comment, we encourage you to supply EPA with detailed information specific to each pyrethroid you use by crop, as well as application rates, methods of application, the target pests controlled and uses in Integrated Pest Management (IPM) to help EPA refine its assumptions on how the products are used.
Additional information on the importance of pyrethroids to your toolbox -- including efficacy, economy, resistance management, and lack of effective alternatives -- will provide the EPA realistic data to assess the benefits. (e.g. all pyrethroids are not applied at maximum label rates and the maximum number of applications to all available acres).
It is Critically Important:
If you grow multiple crops or use multiple pyrethroids within a crop(s), please provide application and benefits information specific to each pyrethroid use and not generalize across crop(s).
(e.g. if you grow tomatoes and peppers, please provide the use rate, # of applications, application method, target pests, etc. for each pyrethroid used by crop).
The EPA Docket Number for each pyrethroid referenced is included in the body of your comments.
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