You acted and the U.S. Environmental Protection Agency listened! In 1999, Conservation Action Network activists in the United States sent more than 3,000 messages to the EPA asking that a new chemical, chlorfenapyr, not be used as a pesticide. The vast majority of the comments sent to the EPA came from Conservation Action Network Activists. See below for a letter of response that the EPA asked us to share with our activists.
In response to this outcry and to concerns expressed by its own scientists and scientists from the U.S. Fish and Wildlife Service, the EPA decided not to permit the use of chlorfenapyr because it poses an unreasonable risk to birds. This is a tremendous victory and a rare example of when EPA has denied registration of a pesticide solely because of risks to birds.
American Cyanamid, the company that had applied to the EPA for permission to use the pesticide, withdrew their application in March 2000 when it became clear that EPA would deny the request. Chlorfenapyr is a new chemical compound and is of particular concern because it lasts for long periods in the soil and poses acute risks to freshwater fish and invertebrates and acute and chronic risks to estuarine and marine organisms, in addition to being a sure reproductive hazard to birds. In fact chlorfenapyr was characterized by EPA staff as "…one of the most reproductively toxic pesticides to avian species" that the agency has evaluated.
World Wildlife Fund
Dear World Wildlife Fund:
Thank you for actively participating in the Environmental Protection Agency's (EPA) assessment of the pesticide chlorfenapyr - more commonly recognized by its trade name, Pirate. We have been working to provide opportunities to actively engage the public in our pesticide registration and reregistration processes. As a result, we received over 3,200 letters from concerned citizens urging us to deny the registration of Pirate. Although we are committed to responding to everyone that writes to the Agency, we do not have the means to respond to each of the 3,200 letters individually. I would greatly appreciate your assistance in spreading the news of this momentous decision to your supporters.
In March 2000, the Agency completed its review of the pesticide chlorfenapyr for use on cotton. EPA made the determination that chlorfenapyr does not meet the requirements for registration under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA). EPA made this determination after considerable evaluation and external peer consultation. In particular, we consulted with the FIFRA Scientific Advisory Panel (SAP), a collection of leading experts on pesticide science issues, to address specific technical aspects of the review conducted for Pirate. In addition, we consulted with the US Fish and Wildlife Service on a number of issues, particularly regarding potential risks to endangered species. Also, for the first time, we solicited comments from the general public during the actual registration process. Through these various efforts, our experts amassed significant evidence that led us to the determination that chlorfenapyr used on cotton would persist in the environment and have harmful reproductive effects on birds. The Agency, thus, concluded that the potential environmental risks posed by the proposed cotton use of chlorfenapyr significantly outweigh the projected economic benefits from this use. American Cyanamid subsequently withdrew their registration application for the cotton use.
EPA recognizes that cotton production is critical to American agriculture. We have worked to ensure that our farmers have effective lower-risk alternatives to control cotton pests. In helping farmers to find such alternatives, we will continue to safeguard public health and the environment.
Our decision on this chemical represents an important step in the Agency's effort to use advanced scientific analyses and more stringent environmental protections in our registration process. If you are interested in learning more details about the SAP's findings, you can find the two SAP reports on-line: