HAWAII CROP IMPROVEMENT ASSOCIATION
\ April 8, 2016 /
We appreciate the opportunity to comment on the draft report. The Joint Fact Finding Group (JFF) has requested corrections of factual, logical, and empirical evidence. The Hawaii Crop Improvement Association (HCIA) has identified numerous examples below, and we hope they will be addressed before the final report is released.
We categorized comments into eight sections: a) Lack of acknowledgment of existing regulatory infrastructure, b) Factual errors, c) Contradictory statements, d) Inaccurate claims from insufficient data, e) Scope of work discrepancies, f) Use of unqualified reports and data, g) Lack of transparency, and h) Significant missing findings in the draft report.
One overarching concern is the apparent assumption by the JFF that adverse health impacts would be found, if only more information were available (e.g., first sentence on p. 9). This assumes, without evidence, that there are adverse health impacts associated with agricultural use of pesticides by the island’s large agricultural organizations. More data could also affirm the earlier conclusion that pesticides are used appropriately and that there are no adverse environmental or health impacts.
To authentically reflect its intention of using “actual data rather than individual stories and anecdotes,” the JFF final version should include only actual peer-reviewed studies, meta-analyses, verifiable data, and official reports.
In addition to the HCIA response to the draft report, member companies may also submit responses specific to their particular products or concerns.
HCIA acknowledges the work that the JFF put into its report, which validates the responsible and safe practices of our industry and the professionalism of its employees.
Download the full response to the Joint Fact Finding Group (10 pages):