The University of Georgia College of Agricultural and Environmental Sciences
Your Source for Pest Management and Pesticide News
Volume 24, no. 3
FOOD QUALITY PROTECTION ACT/RE-REGISTRATION
you want your commodity to be ahead of the Jones, develop a Pest
Management Strategic Plan
The U.S. EPA may accelerate decisions based on cumulative risk assessments
Here is the latest schedule of EPA pesticide activities
The Natural Resources Defense Council and others have settled a lawsuit with EPA concerning implementation of FQPA
If one or more of your key pesticides are at risk, you should try to facilitate the introduction of new pesticides
Comment periods are open for diazinon and atrazine
Three avenues of communication are open between commodity organizations and EPA
As they implement FQPA, the EPA and USDA are most likely to listen to grower groups
It is NOT the time to be responsible for a pesticide incident that endangers human health or the environment
HEALTH AND THE ENVIRONMENT
People for the Ethical Treatment of Animals has sued the EPA to delay Developmental Neurotoxicity Tests
Scientists report that touching plants can make the plants significantly more or less susceptible to insect attack
EPA continues the process to phase out methyl bromide
Methyl iodide has been suggested as a substitute for methyl bromide
How do you place a dollar value on human life or the environment?
developments may help trees produce fruit sooner
The StarLink debacle is not over
DON'T DO IT!
More than 4,000 homes in the Atlanta area may not have been adequately treated with termiticide during construction
I am careful to indicate the sources of my information. Readers may want more information, and the source deserves recognition. In this issue, several stories have no indicated source. These reports are things I know (or I opine) as a result of recent discussions with EPA/USDA personnel in Washington.
If you want your commodity to be ahead of the Jones's, develop a Pest Management Strategic Plan (PMSP). A PMSP is a pest-by-pest guide to the pesticides (and alternatives) that growers depend on to produce the crop. Additionally, this guide indicates what advancements are necessary to move away from more toxic pesticides (organophosphates come to mind). A PMSP could be critical to preserve the use of a key pesticide. Both USDA and EPA will depend heavily upon PMSP when pesticide decisions are pending. If PMSP are not available for key states, EPA is likely to base the decision on a less reliable source of information. Keep in mind that the next best source of information may not be up-to-date or reflect critical regional/state differences. Imagine if EPA assumed that Georgia peanut production was similar to Virginia or Georgia peaches were grown like California peaches.
A PMSP is the next step beyond a crop profile. At last count, Georgia had two crop profiles, which means that EPA and USDA know very little about current production practices for all of the other commodities produced in Georgia. Do not underestimate the importance of crop profiles and PMSP. Without this information, EPA will make pesticide decisions that affect Georgia with, at best, information from other states.
If pesticides are an important part of your production system, contact your county extension agent and/or extension commodity specialist. Make sure they understand the importance of crop profiles and PMSP. For commodities without crop profiles, the profile and PMSP could be combined into a single document. Our office can help commodities assemble profiles and/or PMSP.
The U.S. EPA may accelerate decisions based on cumulative risk assessments. The cumulative assessment is an evaluation of a group of pesticides with a similar toxic mode of action. For example, the organophosphate (OP) insecticides all affect the nerve enzyme, acetyl cholinesterase. Both insects and humans depend upon the same enzyme.
Until now, the Agency has made decisions based on the risk estimates associated with a single OP individually. As you have seen, some of the decisions will have tremendous impacts. Imagine how the impacts may increase as EPA considers all of the OP insecticides together. Your commodity needs a crop profile and PMSP!
The Agency is under some pressure to resolve the cumulative assessment. The evaluations completed for individual OP insecticides will not 'count' until the cumulative assessment is complete for the OP insecticides. The EPA needs to make decisions. Your commodity needs a crop profile and PMSP!
Finally, integrated pest management (IPM) is clearly the future. The USDA, EPA, and other agencies support IPM. Therefore, pesticides with a role in IPM are more likely to receive favorable treatment. However, a solid explanation is critical. When I was working for EPA, it became apparent that people thought "IPM" was an EPA buzzword. Every document contained the words, "and this product [insert pesticide name] is critical for IPM programs." Understandably, we became quite cynical about that phrase. Keep in mind that the current definition of 'IPM' includes an element that minimizes pesticide risks.
Here is the latest schedule of EPA pesticide activities. In Fiscal Year 2001 (FY 2001 ends Oct. 1, 2001), the EPA plans to issue Re-Registration Eligibility Decisions (RED) for:
The EPA will issue an IRED (Interim RED) in FY 2001 for:
A final RED cannot be issued for any of these OP pesticides until the cumulative risk assessment is complete. The IRED may include risk reduction measures or eliminating registrations that the registrant does not plan to support. In some cases, the registrant has agreed to eliminate a pesticide registration that was critical for some minor crop or use. Make sure that the pesticide company, the USDA, and EPA understand why particular pesticides are critical. Your commodity needs a crop profile and PMSP!
The EPA plans to issue TREDs (I don't know what the 'T' stands for) for:
A TRED may be issued for a pesticide registered after Nov. 1, 1984 (pesticides registered earlier are subject to reregistration under FIFRA '88); for a pesticide with a RED completed before passage of FQPA; or for a pesticide not registered in the United States with a tolerance that allows import of foreign commodities.
Be active early in the process. Your commodity needs a crop profile and PMSD!
You may more information about REDs, IREDs, TREDs, and RETREDs (OK, I made up that one) at the EPA web site, http://www.epa.gov/pesticides/
The Natural Resources Defense Council and others have settled a lawsuit with EPA concerning implementation of FQPA. Under the agreement, specific deadlines were established for the completion of RED and IRED documents (which explains the schedule in the previous story). Additionally, the preliminary cumulative risk assessment for the organophosphate pesticides must be complete by December 1, 2001.
The Agency must also decide what groups of pesticides have a similar toxic mode of action. Decisions must be made for several groups of chemicals, including carbamates (by December 31, 2001) and triazines (by March 31, 2002). The EPA also agreed to move ahead on a process to evaluate endocrine disruptors.
On the other hand, Congress may overturn the proposed settlement. The new Bush administration has issued an order to delay all proposed rules for 60 days. During this review period, no proposed or final rules will be published in the Federal Register. (Pesticide & Environmental News, 1-22-01 via Chemically Speaking, 2-01)
If one or more of your key pesticides are at risk, you should try to facilitate the introduction of new pesticides. If your commodity or particular pesticide use is classified as 'minor' (typically less than 300,000 acres), the pesticide is eligible for assistance from the USDA IR-4 program. This program exists to help minor crops/uses obtain new pesticide registrations.
If your commodity group expects to lose a key pesticide, visit www.epa.gov/opprd001/workplan/newchem.html for a list of new chemicals that EPA plans to register in FY 2001. Your county extension agent or extension specialist may be able to help you register other IR-4 candidates.
After you identify a potential pesticide, contact your state IR-4 coordinator (Georgia: Dave Langston, 229-386-7495 or email@example.com
He can guide your group through the IR-4 process. Individual growers should not apply for IR-4 assistance individually. Work through your commodity organization, or band with other growers.
Comment periods are open for diazinon and atrazine. If you are interested in the continued availability of these chemicals, review these documents. Early reports indicate relatively low concern for risks associated with atrazine. A few years ago, the EPA implemented several measures to mitigate risks linked to triazine herbicides, including atrazine.
Three avenues of communication are open between commodity organizations and EPA. 1) Jim Jones of EPA (Director of Registration Division) is very interested in the concerns of minor crops/uses. We can help you schedule an appointment with EPA. 2) The UGA College of Environmental and Agricultural Sciences is a partner in the EPA Pesticide Environmental Stewardship Program. This collaboration provides the College with a liaison within EPA. The College represents the interests of Georgia agriculture. Therefore, Georgia agriculture has a liaison with the EPA. (logical, yes?) 3) I am a new delegate for the EPA Pesticide Program Dialogue Committee. Share your pesticide concerns (and especially good ideas) with me, and I will present them as if they were my own.
As they implement FQPA, the EPA and USDA are most likely to listen to grower groups. Other groups (e.g., pesticide registrants, anti-pesticide groups) will also submit information. Your commodity needs a crop profile and PMSD!!
In a final word to the wise, it is NOT the time to be responsible for a pesticide incident that endangers human health or the environment. (thanks to John Taylor) Train your application personnel; prepare for emergencies; and FOLLOW the pesticide label.
People for the Ethical Treatment of Animals (PETA) has sued EPA to delay Developmental Neurotoxicity Tests (DNT) required as part of an October 2000 Data Call-In. The DNT are used to determine how pesticides or other chemicals affect the developing nervous systems of infants and children. The tests are typically conducted on rats. The EPA argues that DNT will fill an important data gap in the continuing aggregate estimate risk assessment of organophosphate pesticides. PETA argues that DNT data have not been shown to apply to humans; therefore, it is cruel and unjustified to kill thousands of rats in DNT experiments. (Pesticide & Environmental News, 2-19-01)
Many people would agree that the results from rodent experiments are not relevant to evaluate human risks. However, risk scientists would argue that rodent experiments are one of very few sources for this type of data. In short, flawed rodent data may be all the information we can generate for now.
In the February issue of Ecology, scientists report that touching plants can make the plants significantly more or less susceptible to insect attack. These results may have little direct effect on production agriculture, but the findings have tremendous implications for the research that underlies modern pest management recommendations. It is very common for plant scientists to touch plants during pest management experiments. The Ecology study investigated a small variety of plants, but the research will probably spur a great deal of similar investigation.
The EPA continues the process to phase out methyl bromide, but recent developments will affect the final outcome. Currently, the complete phase out will be complete in 2005. Most other countries (with some notable exceptions like China) are subject to a similar phase out period. The phase out process in an individual country is subject to the will of the national legislative body. In the United States, for example, Congress passed exceptions for quarantine uses and 'critical' uses. The meaning of 'quarantine' is pretty clear; a great deal of discussion is necessary before 'critical' is defined. The exceptions will not count toward the overall methyl bromide cap.
In the end, methyl bromide production is likely to continue even if major agriculture uses (85% of the current market) are lost. Methyl bromide is not difficult or expensive to produce, and it is often a byproduct or intermediate for other industrial processes.
Methyl iodide has been suggested as a substitute for methyl bromide. It has a similar range of efficacy, and methyl iodide does not harm the stratospheric ozone layer. Methyl iodide is in the registration queue, but it will not be available before 2005. Even if methyl iodide can pass stringent EPA health and environmental standards, it may be registered too late.
How do you place a dollar value on human life or the environment? Most people would quickly reply that a human life is beyond price. This sentiment is not true. We can immediately save thousands of lives if we establish a national speed limit of 35 mph.
This argument sounds ludicrous even if it is true. In reality, society places a dollar value on a human life. In a recent arsenic decision, EPA used a statistical life valued at $6.1 million. In another recent decision, the U.S. Supreme Court ruled that EPA decisions under the Clean Air Act did not have to consider the cost of implementing new regulations. Under FQPA regulations, the EPA gives much less weight to the benefits of pesticides. It is unclear if the court would consider pesticide regulations equivalent to the Clean Air regulations. The decision would probably depend on the exact language of the two acts. The court strives to interpret the law as written by Congress. The courts and other agencies do not have authority to create or remove any law. Only Congress has that power; if you want to change the law, work through your Congressional representatives. (The Washington Post, 3-5-01)
New developments may help trees produce fruit sooner. Perennial crops (e.g., peaches) have one big problem. A grower must plant and maintain the trees for years before any fruit can be picked. Citrus growers may wait up to 20 years for peak fruit production. Spanish researchers have introduced a gene that allows oranges to produce fruit within two years. The genes were introduced from mustard weed. The scientists suspect the genes will produce similar effects in other citrus. (Nature Biotechnology, 3-01 via The Washington Post, 3-1-01)
The StarLink debacle is not over; corn seed for this season is contaminated with genetically engineered corn. Farmers that want to sell corn overseas are concerned that contamination will cost them market sales. The StarLink registrant (Aventis) and USDA are downplaying public concern. Certainly, the level of contamination is very low. Additionally, there is little reason to believe that the StarLink corn poses any threat to human health. (The Washington Post, 3-1-01)
Put yourself in the place of a European consumer who is very concerned about the safety of genetically engineered products. It may appear that U.S. consumers and regulatory agencies do not have control of genetically engineered products. If your company depends on these consumers, you may wish to buy from countries other than the United States.
According to the Georgia Department of Agriculture, more than 4,000 homes in the Atlanta area may not have been adequately treated with termiticide during construction. The homes in question were serviced by RSA Services Termite and Pest Control. If this company treated your new home for termites, have a qualified pest control expert inspect your home for termite infestation. The Department will fine the company, but the amount of the penalty is undetermined. (The Market Bulletin, 2-28-01)
The appearance of any trade name in this newsletter is not intended to endorse that product nor convey negative implications of unmentioned products.
The Georgia Pest Management Newsletter is a monthly journal for extension agents, extension specialists, and others interested in pest management news. It provides information on legislation, regulations, and other issues affecting pest management in Georgia.
Do not regard the information in this newsletter as pest management recommendations. Consult the Georgia Pest Control Handbook, other extension publications, or appropriate specialists for this information.
Your input in this newsletter is encouraged.
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Department of Entomology
University of Georgia
Athens, GA 30602
Or visit us on the Web. You will find all the back issues there and other useful information. http://www.ces.uga.edu/Agriculture/entomology/pestnewsletter/newsarchive.html
Paul Guillebeau, Associate Professor & Extension Entomologist