Pesticide Q&A

Pesticide Q&A

By Corey Lacey, Ph.D., Policy Manager - Illinois Soybean Growers

Pesticides, an essential tool for our growers, have come under increasing scrutiny by local, state, and federal governments, as well as the public. Illinois Soybean Growers (ISG) feels that public misconceptions about farm operations and on-farm pesticide use are best countered by enabling farmers to share their stories. This Q&A is an example of how ISG works to enable our grower members to be advocates for themselves and their families.

Pesticide Policy, FIFRA, and the EPA

Q: How does FIFRA (Federal Insecticide, Fungicide, and Rodenticide Act) govern the EPA’s authority over pesticides?

A: In 1972, an amendment to FIFRA transferred the authority to set pesticide standards and registration from the USDA to the newly created Environmental Protection Agency (EPA), establishing the basis for current U.S. pesticide policy. Amendments to FIFRA were made in 1988 (registration of older pesticides), 1996 (Food Quality Protection Act), and Pesticide Registration Improvement Acts of 2003, 2007, 2012, 2018, and 2022.

FIFRA requires the EPA to regulate the sale, distribution, and use of pesticides in the United States through national pesticide registration and labeling policy. As part of this process, the Agency conducts scientific review of pesticides and restricts their use to prevent “unreasonable adverse effects on people and the environment” while also considering the costs and benefits of a pesticide’s various uses.

Q: What are the roles of federal versus state governments in pesticide regulation?

A: FIFRA confers primary enforcement authority of pesticide sale and use to states however, states must regulate within certain parameters established by EPA and FIFRA. In Illinois, pesticides are overseen by the Illinois Department of Agriculture, which is delegated authority by the Illinois Pesticide Act.

Q: Are there policies farmers can support that help protect access to pesticide products?

A: On both the federal and state-level, farmers can engage on legislation or submit comments on regulatory proposals that recognize the need for science-based pesticide policy. Illinois Soybean Growers tracks these proposals and can make farmers aware of advocacy opportunities.

On-Farm/Off-Farm Benefits

Q: Would food security and hunger issues be impacted if farmers were not allowed to use pesticides?

A: Yes, pesticides help address food security in the U.S. and internationally; they are a key tool allowing both row crop (soybean, corn, wheat) and specialty crop (vegetables, nuts, fruit) farmers to maintain productivity. Without access to these crop protection tools, yields could decrease by as much as 50 percent. The result would be increased food prices, exacerbating food security issues locally, nationally, and globally.

Q: How would on-farm profitability be impacted by limited access to pesticides?

A: It is important to remember that most farmers operate on very thin profit margins; thus, they are naturally economical with input costs and only apply pesticides where and when it is needed. Without pesticides, decreased yields would put most farmers at risk of going out of business.

Interim Mitigation Strategies

Q: What is the “deal” with the upcoming Interim Pesticide Mitigation Strategies proposed by EPA?

A: As part of the pesticide registration process, the EPA is required by the Endangered Species Act (ESA) to ensure registered pesticide uses do not “jeopardize the continued existence of federally threatened or endangered (listed) species or adversely modify their designated critical habitats.” This is a complicated process considering there are more than 1,600 listed species in the U.S. and the data needed to evaluate the impact of a specific pesticide is often limited. As a result, EPA has not historically fulfilled its ESA obligations, resulting in increased lawsuits and vacaturs of pesticide registrations by federal courts. To attempt to meet its compliance obligations, EPA is proposing additional pesticide mitigations that farmers must adopt to protect listed species and reduce environmental risks.

While it is understandable that EPA is eager to bring its pesticide program into compliance with ESA and avoid additional lawsuits, the agency must also consider that these measures pose significant, long-term implications for growers. Requiring, in many cases, mitigations can be costly and challenging to implement. If the agency wishes to create workable solutions for ag stakeholders, there needs to be more outreach to farmers on this topic.

Illinois Pesticide Policy

Q: What happened with the over-the-top (OTT) dicamba cutoff date this year?

A: On February 16, 2023 EPA approved label changes moving up the cutoff date for OTT dicamba applications on soybeans to June 12 or V4 growth stage in Illinois, Iowa, Indiana, and South Dakota. This was done in coordination with product registrants and approved by EPA, with the intent of reducing alleged off-target incidences. It is important to note Illinois already had a state-mandated June 20 cutoff of OTT applications from a prior label change, which is earlier than most other states. Remember that all other Illinois-specific Dicamba rules remain in place. Find out more at https://agr.illinois.gov/ pesticides/dicamba.