A Sixth Circuit Court of Appeals' ruling stated that a National Pollutant Discharge Elimination System (NPDES) permit is required under the Clean Water Act for any pesticide application on, over or near "waters of the United States." The NCC was an original plaintiff in a suit against EPA on this issue and joined with other agricultural groups in filing a petition of certiorari to the U.S. Supreme Court seeking reversal of the Sixth Circuit decision in NCC vs. EPA. The NCC also is actively engaged with EPA to develop a general permit system, despite our concerns with the Justice Department's response that says there is no need for a Supreme Court review. The Justice Department's rationale is there is adequate time to mitigate the impact of the Sixth Circuit's incorrect decision by issuing "general permits" for pesticide use.
The NCC also is active in a coalition to ensure that final food safety legislation does not include many of the objectionable provisions of the House-passed food safety bill. That measure contained several negotiated on-farm exemptions but still includes gins and cottonseed facilities under its provisions. The NCC joined several other organizations and the grain trade on a letter outlining concerns with the House bill's provisions and noting recommended improvements for the Senate bill prior to markup.
Another concern is the Occupational Safety and Health Administration's (OSHA) proposed regulation of combustible dust in the workplace. The NCC and seven other cotton industry organizations submitted detailed comments that urged the agency to focus its efforts on industries that have experienced problems with combustible dust. OSHA should not attempt to regulate operations such as gins, warehouses, cottonseed storage and processing facilities, and textile mills that can provide science supportive of why such incidences cannot occur. Answers also were provided to 69 OSHA-posed questions.
source : cottonfarming
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