![](media/image1.jpeg){width="8.504166666666666in" height="1.8in"}August
22, 2005

Public Information and Records Integrity Branch (PIRIB) (7502C)

Office of Pesticide Programs (OPP)

# U.S. Environmental Protection Agency

1200Pennsylvania Ave. NW

Washington, DC 20460-0001

> **Re: Docket ID \# OPP-2005-0163**
>
> **Aldicarb Risk Assessments (Phase 3 of 6 Phase Process)**

Dear Docket;

The National Cotton Council (NCC) is responding to a request for
comments by the EPA concerning Docket ID Number OPP-2005-0163. The NCC
is the central organization of the U.S. cotton industry representing
producers, ginners, oilseed crushers, merchants, cooperatives,
warehousemen, and textile manufacturers in 18 states stretching from
California to the Carolinas. The NCC represents producers who cultivate
over 13 million acres of farmland to produce about 17 million bales of
cotton that will add over \$4 billion to the U.S. economy this growing
season.

Docket ID Number OPP-2005-0163 regards the risk assessment for aldicarb,
an important insecticide that has been safely used in cotton for over 35
years. Aldicarb based product (Temik) is placed into the seed furrow at
planting time for control of early season insects and nematodes. EPA
risk calculations, using low-tier analysis, indicate potentially high
risks in almost every scenario. While the preliminary risk assessment
predicts nearly 100% mortality of birds and mammals for nearly all
application scenarios, there have been few documented incidences of
field kills of birds and mammals in the U.S. associated with label uses
of Temik. This enormous database based upon 35 years of actual use
experience with Temik obviously has not been seriously taken into
consideration.

Aldicarb (Temik) is the foundation for efficient cotton production in
many areas of the U.S. cottonbelt. It is estimated that Temik is used on
approximately 25% of the cotton acres in the U.S. Temik is used as a
planting time, soil-applied treatment to protect seedling cotton plants
against early season insects and, at higher rates, nematodes. Effective
protection against early season insects is of prime importance to
getting the crop off to a good start with healthy, vigorous seedling
plants. In this manner, aldicarb improves yield, quality and earliness
of maturity.

# Nematodes are a serious cotton pest and have increased in numbers and distribution over the last 10 years. The Reniform nematode, for example, has become a serious pest in the midsouth and parts of the southeast. Options for chemical control of nematodes in cotton are very limited. Temik aldicarb is by far the most effective chemical nematicide available. In areas with nematodes, the planting time rate will be increased up to 5 lbs active. I addition, nematodes, higher rates of Temik may be placed into the soil as a side dress application. Yield increases of 100- to 190 lbs of cotton lint in Temik treated plots over untreated plots on farm trials in Alabama.

Yield losses to nematodes have been recorded since the 1952 crop plant
pathologists on the Cotton Disease Loss Estimate Committee. Their data
show a loss to nematodes of \$381,810,000 in control costs and crop
losses. With nematode impact placed at more than \$380 million, and
thrips losses estimated at \$55 million, it is estimated that the
principal pests controlled by Temik cause over \$435 million in losses
would occur annually.

The NCC believes that EPA has overestimated the risk of using Temik in
cotton. It is important that calculations of risk take into
consideration figures based upon the formulated product (Temik) and that
the 35 year use history. The long use history, the extensive database on
Temik use, relative safety of the formulated product, the stewardship
efforts of Temik by Bayer, label refinements, and Bayer's educational
programs provide strong evidence that Temik aldicarb has been used for
over 35 years without evidence of bird kills that one would expect based
upon the risk calculations in the EFED document. The NCC appreciates the
opportunity to provide the Agency with this information on the risk
assessment of aldicarb.

Sincerely,

![](media/image2.jpeg){width="2.1243055555555554in"
height="0.6104166666666667in"}

Frank L. Carter, Ph. D.

Senior Scientist, Pest Management

Cc: John Maguire

Andy Jordan