The National Ag Statistics Service, USDA released Wednesday the 1996 field crop survey results -- basic fertilizer and pesticide use data on corn, soybeans, wheat, cotton, and fall potatoes. The full report is on USDA's web site (go to NASS page). The data on corn herbicide use provides significant insights into whether the herbicide use reductions required in the 1994 conditional registration of acetochlor will be achieved. If not achieved, EPA is presumably bound by law/its regulations to cancel the registration.

I developed a spreadsheet a year ago to track compliance with the acetochlor conditional registration use reduction triggers. I have updated the spreadsheet with crop year 1996 data for the six other herbicides and acetochlor -- percent acres treated, applications per acre, rate, pounds applied, and changes since 1992 and 1994.

1996 use data make it clear that the registration of acetochlor has not markedly changed reliance on and use of high-risk corn herbicides. EPA based its decision, made reluctantly, in large part on a projected 33% reduction in the application of six other corn herbicides. By one key and direct measure, use has actually gone up since the registration of acetochlor in 1994.

Acetochlor has been on the market for three crop years. The first two seasons saw dramatic growth in acres treated and pounds applied, almost completely away from alachlor and to acetochlor. Given the almost one-for-one shift in acres between these two closely related products, the net impact on corn herbicide use since the 1994 introduction of acetochlor boils down to a one-to-one comparison of alachlor and acetochlor use patterns. Here, the use data is pretty clear --

• Most of the shift in acres occurred in 1994 and 1995; the corn herbicide market settled down markedly in 1996, even though acreage jumped from 64.1 to 70.2 million acres planted; most indicators of use and reliance were largely unchanged on a per acre basis, the most logical way to assess trends in reliance at the farm level.

• Acetochlor is being applied at about 115% the rate of alachlor, not the projected one-third less. (Average acetochlor application rate in 1996 was 1.88 pounds a.i.; average alachlor rate, 1.64 pounds a.i. per acre).

• The sum total of the six a.i. pounds applied in 1996 -- 115,618,000 pounds, or 1.65 pounds a.i. per acre.

• Total six a.i.'s plus acetochlor pounds applied in 1996 -- 145,468,000, or 2.07 pounds per acre.

• On a per acre basis, six a.i. plus acetochlor use is down 0.14 pound per acre from 1992, a 6.3 percent drop, but has risen 3.5 percent since 1994, from 2.0 to 2.07 pounds per acre.

• Total pounds applied of the six a.i.'s plus acetochlor is up over 20 million pounds from 1994 -- the year of acetochlor's introduction.

• Conditional registration of acetochlor has changed market share between two herbicides posing comparable risks, but has not altered markedly reliance on high-risk corn herbicides.

• Passage of the FQPA, growing evidence of widespread contamination of drinking water in areas where substantial corn acreage is treated with acetochlor (see the recent EWG report "Tough to Swallow: How Pesticide Companies Profit from Poisoning America's Tap Water";   for the latest data), and trends in reliance on high-risk corn herbicides is likely to lead to re-evaluation of the 1994 decision to conditionally register acetochlor.

9/7/97