Cooperative Extension Service
The University of Georgia College of Agricultural and Environmental Sciences
for the sky on February 17 and take part in our statewide pesticide-training
Also, on February 8, we will be cooperating with the Georgia Pest Control Association to offer 'IPM in Schools' training in Macon
FOOD QUALITY PROTECTION ACT
EPA has issued preliminary risk assessments for dicrotophos, trichlorfon,
EPA has approved TPTH (triphenyltin hydroxide) for reregistration
The EPA has released the revised risk assessments for oxydemeton methyl and methidathion
The revised risk assessment for dimethoate has been released
The EPA wants the Scientific Advisory Panel (SAP) to consider proposals that would 'bundle' cumulative risk assessments and defer assessments that fit specific criteria for exemption
HUMAN HEALTH AND THE ENVIRONMENT
debate ensues when discussions arise concerning the use of human data for
estimating pesticide risks
According to Jim Wilson (senior fellow at Resources for the Future and past-president of the Society for Risk Assessment), EPA could make animal data more useful by calibrating the results with human data.
DDT: Good news and bad
The EPA has released the Phase II report of the Consumer Labeling Initiative
EPA is concerned about the lack of public participation in their decision-making process
NEWS YOU CAN USE
people rely on DuPont Tyvek materials for personal protection from
Gempler's company publishes IPM Solutions, and I have found some useful information in their pages
Rosette fungus is a primary limiting factor for the production of blackberries in the Southeast; the USDA Agricultural Research Service report the disease can be managed by revising fungicide schedules
Do you think that public funds should be used to pay for agricultural research
Just in case you ever wanted a complete set of everything in the 1999 Federal Register
to Nature magazine (12-2-99), Bt corn plants release the insecticidal toxin
into the soil
If you have an opinion about the introduction of genetically engineered foods, it is time to make your voice heard
We must be having fun because time has really flown by. This year will be the fifth year of GPMN, and we have more readers than ever before. We are delivering information via snail-mail, e-mail, and the Internet. If you want to receive GPMN via e-mail, just let us know. We want to thank you, the University of Georgia, and my Maker for giving us an opportunity to serve. I hope that we have provided some useful service.
We especially appreciate our readers who have provided positive (or negative) feedback. The positive comments give us incentive to persevere. The negative comments (at least the written ones) make good paper wads for trashcan basketball. Seriously, if you have something to say, say it. I will be glad to publish it and give you a FREE year's subscription to GPMN. After all, everyone (even me) is entitled to his or her own stupid opinion.
Reach for the sky on February 17 and take part in our statewide pesticide-training workshop. If you have a commercial pesticide license, watch your mailbox for information and a registration form. If you do not receive a form, call your local county extension office. The workshop costs $20, and it will be offered at ten different locations across Georgia.
Also, on February 8, we will be cooperating with the Georgia Pest Control Association to offer 'IPM in Schools' training in Macon. This workshop is free and open to both pest control companies and schools. The purpose of this workshop (and the entire IPM in Schools program) is to reduce pesticide risks in schools. Contact the Georgia Pest Control Association for details.
The EPA has issued preliminary risk assessments for dicrotophos, trichlorfon, and propetamphos. The EPA identified no great human concerns for dicrotophos, but the ecological risks were estimated to be considerable. Exposure estimates for trichlorfon generate some concern for homeowner uses. However there are considerable missing data concerning trichlorfon. Propetamphos is not registered for food use, but EPA has concerns about the applicator and residents in homes treated with this insecticide.
If you know something about dicrotophos/trichlorfon/ propetamphos or how they are used, take the time to review these reports and offer comments to EPA. There will also be another opportunity for public comment after the EPA revises the risk assessments. You can find these assessments and others on the web, http://www.epa.gov/pesticides
EPA has approved TPTH (triphenyltin hydroxide) for reregistration. TPTH, a fungicide, is widely used on a variety of important diseases on pecans, potatoes, and sugar beets. TPTH is classified as a 'probable' human carcinogen based on animal studies. However, the use of TPTH is quite limited, so there is little dietary concern. The EPA has some concern about exposure in drinking water, but buffer zones around water are expected to mitigate this risk.
Worker exposure is of greater concern. Worker risk will be addressed by personal protective equipment, the existing Worker Protection Standard, and closed cab requirements. Additionally, the registrant is expected to change label directions to reduce the maximum seasonal use from 40 percent to 70 percent, primarily to reduce environmental concerns. Look for re-registration eligibility documents (REDs) at http://www.epa.gov/REDs/ (Pestic. & Tox. Chem. News, 12-2-99)
The EPA has released the revised risk assessments for oxydemeton methyl and methidathion. If you care about either one of these pesticides, take the time to give EPA the benefit of your opinion (of the assessment and the process) and any information you may have. Keep in mind the entire process is intended to be transparent. If you do not understand the assessments, let EPA know. The new rules of the game are being written now. Participate now or don't whine later.
See the assessments at http://www.epa.gov/pesticides/op/status.htm
The comment period ends February 7. For more information, contact Karen Angulo at 703-308-8004 or by email at firstname.lastname@example.org.
The revised risk assessment for dimethoate has been released. Publication of the revised assessment means that EPA is getting closer to a decision. If you are interested in dimethoate, it is time for action. Review the revised assessment at http://www.epa.gov/pesticides/op/status.htm
Comments will be accepted until February 14. You can enclose a Valentine to EPA if you feel that way about them.
The EPA wants the Scientific Advisory Panel (SAP) to consider proposals that would 'bundle' cumulative risk assessments and defer assessments that fit specific criteria for exemption. The FQPA requires EPA to prepare cumulative risk assessments for all pesticides with a similar toxic mode of action (e.g., organophosphate insecticides). Nothing is wrong with the principle behind this requirement, but the data for various compounds and use scenarios vary considerably in quantity and quality. To avoid a very confusing mix, the EPA is asking SAP to consider an idea for separate assessment pathways food/drinking water and residential exposure. Additionally, EPA wants suggestions for better use of existing, although inconsistent, data.
Some of the problems with the data could be reduced if EPA excludes some sources of exposure from the cumulative risk assessment. An exclusion could be allowed if a particular pathway of exposure contributes less than 1% of the total exposure, i.e., limited use (or low consumption of a particular food), route of exposure is unimportant, or the particular pesticide is dangerous for some reason other than the common mechanism of toxicity. For example, if a dermal absorption of a particular pesticide use is very low, EPA could logically ignore that route of exposure in the overall cumulative assessment. (Pestic. & Tox. Chem. News, 12-16-99)
This idea makes sense, but EPA tried something equally logical when they dealt with the Delaney clause. The EPA chose to ignore 'de minimis' risks, and the Agency was sued over the meaning of the law. The EPA lost the case and was forced to implement the Delaney clause to the letter. The end result was the Food Quality Protection Act. If activist groups do not agree with the EPA's exclusionary idea, look for lawsuits to define FQPA and EPA's implementation of the new law. Part of the problem will be deciding exactly how much exposure constitutes '1%' with the current, irregular data.
Considerable debate ensues when discussions arise concerning the use of human data for estimating pesticide risks. In an earlier edition of GPMN, I spoke adamantly against the use of human data because I was worried that poor/ignorant people would be the guinea pigs. Since that time, education has blurred the lines for me (things always seem so much simpler when you don't know much). I will present both sides of the debate, and you can decide for yourself. Some points from each argument seem to have merit.
Before approving any new drug for human use, the FDA requires a great deal of human and animal testing. Many OSHA workplace regulations are based upon human data. Why should pesticide testing be any different? If EPA will not use human data, is the Agency not registering pesticides with little idea of potential risks to human health? After all, tests with rats or mice are not always good predictors for human effects. Finally, the EPA requires excessive margins of safety because they do not have sufficient human data.
ON THE OTHER HAND, humans may be cured of a life-threatening disease with new drugs. The tremendous potential advantage of new pharmaceuticals justifies human testing. If the EPA encourages the development of human data, registrants may recruit test subjects from third-world countries and unfairly make poor people the guinea pigs for industrialized nations. Registrants may use human data selectively to circumvent existing EPA margins of safety. If the focus of FQPA is children's safety, will children be used to evaluate the safety of pesticides?
According to Jim Wilson (senior fellow at Resources for the Future and past-president of the Society for Risk Assessment), EPA could make animal data more useful by calibrating the results with human data. The basic idea is that EPA could compare animal and human data concerning pesticide effects. For other pesticides, the Agency would have a better idea of how the animal data would relate to human effects. For example, if an organophosphate pesticide seems to be twice as active in human systems, probably the other organophosphates would have a similar effect.
Wilson was 'astounded' by current EPA protocols regarding risk assessment, and he called the results of EPA risk assessments 'nearly useless to a well-informed decision.' 'EPA cannot appropriately analyze risks posed by residues of organophosphate insecticides without making use of human data.' (Pestic. & Tox. Chem. News, 12-9-99)
Two big ironies lurk behind the 'human data' debate. The EPA is aware of a large body of human data for organophosphates and some other pesticides. Much of the current argument concerns whether EPA should use this data or ban the use of it on ethical grounds. In other words, the Agency may force their scientists to make decisions that must not consider the best data available. Secondly, from my experience, I bet that many EPA staff scientists think it absurd to ignore human data if it is available. The staff members of any big bureaucracy are often frustrated because agency policies prevent them from doing their best work.
In many ways, the balancing and regulation of pesticide risks/benefits are similar to the regulation of drugs. Drugs that are considered to be low-risk may be self-prescribed. More dangerous drugs may only be obtained with a doctor's prescription. Lower risk pesticides are available off-the-shelf; the use of more risky pesticides is regulated through the EPA certification program for pesticide applicators.
As society ponders the risks of pesticides, some people propose that we need a system through which dangerous pesticides are 'prescribed' for severe pest problems. Society would realize greater protection from pesticides, and prescriptive use could prevent complete cancellation of critical pesticides. Louisiana implemented a prescriptive use program for azinphos-methyl in sugarcane in the wake of repeated fish kills in the 1990s.
Although pesticides-by-prescription is very attractive on the surface, the consequences should be carefully considered. The medical system has an enormous infrastructure of physicians licensed to evaluate patients and issue prescriptions. Currently, agriculture does not have a similar system. The Extension Service is overburdened already. Crop consultants in sufficient numbers are available for only a small number of crops (like sugarcane in LA). Additionally, there are no regulations to establish the credentials for a person to become a 'pesticide prescriber.' Doctors specialize, but they are all examining humans. To prescribe pesticides, specialists would be required for the large number of U.S. crops and growing regions.
For a more complete discussion of the feasibility of prescriptive pesticide use, read 'Feasibility of Prescription Pesticide Use in the United States' published by the Council for Agricultural Science and Technology (August 1998). Visit http://www.cast-science.org/
DDT: Good news and bad. According to the Lancet (12-18-99), DDT may be linked to pancreatic cancer. Researchers noted higher-than-normal serum concentrations of DDT and PCBs in patients with a gene mutation linked to pancreatic cancer. These results do not prove that DDT or PCBs cause cancer, but the possible link between organochlorines and cancer merits further investigation.
On the other hand, Cornell scientists argue that current tests for DDT in soil may overestimate environmental risks. Apparently, DDT binds more tightly with soil as time goes by. Although the DDT may still be detected with conventional tests, the pesticide may not be available to biological organisms. Imagine a loaded gun encased in cement. Technically, it is still very dangerous, but it is not available. (Pestic. & Tox. Chem. News, 12-2-99)
The EPA has released the Phase II report of the Consumer Labeling Initiative. The Agency hopes to improve the understandability of pesticide labels, and I applaud them heartily for this project. I constantly preach that following the pesticide label is the foundation of safe use. Unfortunately, many labels (particularly labels for homeowner-type pesticides) are terribly misleading or ambiguous. If a pesticide label has ever confused you, have a look at http://www.epa.gov/opptintr/labeling/
Or you can order a copy of the report by calling 202-260-1023 or sending an e-mail to email@example.com
Believe it or not, the EPA is concerned about the lack of public participation in their decision-making process. Unfortunately, the public typically provides no input or comment when important decisions are made. The consequences are dire and far-reaching; small, well-organized groups are able to influence major decisions that affect all of us. However, these groups rarely reflect the majority of public opinion. For example, look at the powerful influence of small anti-pesticide groups. A number of them seem to be misled (to put it kindly), and some groups border on crazy. Their influence extends far beyond their numbers because the majority of people say nothing/do nothing.
The EPA is working to improve public participation. Look for a report from them soon. We will keep you informed.
Many people rely on DuPont Tyvek materials for personal protection from pesticides. Do you ever wonder if you are using the right product? DuPont offers free information for their products via FAX-on-Demand (1-800-558-9329) or the web at http://www.duponttyvek.com/us/protective-apparel/English/
Gempler's company publishes IPM Solutions, and I have found some useful information in their pages. Although Gempler's is a commercial operation, this newsletter is free. Visit them on the web to review back issues; subscribe if you find them useful. http://www.ipmalmanac.com
Rosette fungus is a primary limiting factor for the production of blackberries in the Southeast; the USDA Agricultural Research Service report the disease can be managed by revising fungicide schedules. The ARS indicates that blackberries are cheaper to establish than blueberries or strawberries and can produce more than $3,000 per acre.
Do you think that public funds should be used to pay for agricultural research? For example, the USDA supports an entire agency, the Agricultural Research Service. Their work finds solutions like the one listed above about the Rosette fungus. Sure, blackberry farmers may make more money, but why should my tax dollars help to pay for it? A recent news story lambasted federal funding for research to help reduce pollution problems caused by large-scale hog operations.
Public funding for agricultural research has been reduced dramatically. What are the effects? More and more agricultural research relies on private funding, often from pesticide or seed companies. Guess who the results benefit the most? The findings may help us all indirectly, but private companies fund research primarily to help them make more money.
Public funding finds answers for problems that help all of us. The above examples with blackberries and hogs are excellent illustrations. Blackberry farmers will make money; I would not do my job (as much as I love it) if I made no money. Hog operations do need help to manage wastes; the results of this type of research will protect us all from hog pollution and keep a ham on the table at an affordable price.
Support agricultural research with public funding so that your voice helps to establish the research agenda.
If you ever purchase or use pesticides in containers, you should review the new proposals for pesticide containers. The EPA has extended the comment period to February 19. The issues open for comment:
For additional information, please contact Nancy Fitz at 703-305-7385 or firstname.lastname@example.org.
Just in case you ever wanted a complete set of everything in the 1999 Federal Register . . . The Federal Register is a daily publication of everything (and I mean EVERYTHING) that the federal government does. All federal laws, rules, proposed rules, notices, etc., etc. are included.
The 1999 U.S. Federal Register with complete text, tables and graphics will be available on a single CD-ROM in January. The CD-ROM features PDF format -- it looks and prints exactly like the original publication -- and instant search/retrieve software.
(I think I will wait for the greatest hits CD)
The USDA CSREES (Cooperative State Research, Education, and Extension Service) announces the establishment of a website to facilitate easy access to the priorities of USDA stakeholders. The site will provide a direct link to a priority listing of organizations.
These links will provide a resource that may be helpful to those working on agricultural issues. The primary targets are scientific organizations and commodity, environmental, consumer and other public-interest groups with established research and/or educational priorities. Faculty and others will find the priority information useful as they prepare grant proposals. The stakeholder website will be linked to the Funding Opportunities location.
Organizations that wish to be listed should contact Julie Simmons at email@example.com; Fax: 202-205-3641; Phone: 202-401-6996, Assistant Program Director in CSREES' National Research Initiative. Organizations should provide: (1) organization's full name; (2) the website address where their priorities are listed; and (3) an organizational contact person.
Organizations should also be apprized that the Stakeholder Priorities index is designed for organizations, not individuals. Inclusion of an organization's priorities does not imply an endorsement or certification by the U.S. Department of Agriculture.
If you have questions about this web site, contact either Peter J. Johnson at firstname.lastname@example.org; phone: 202-401-1896, or William C. Wagner at email@example.com; phone: 202-401-4952.
According to Nature magazine (12-2-99), Bt corn plants release the insecticidal toxin into the soil. Until recently, scientists thought that the pesticidal molecules were too large to pass out of root membranes. No one knows what effects, if any, that the toxins will have on the soil or soil organisms. The toxin may be broken down very quickly, with little or no effect. A persistent supply of toxin may exacerbate resistance among pest species, or the toxin may have adverse effects on beneficial organisms. After this report and the monarch/Bt publication (pollen from Bt corn will kill monarch caterpillars in the lab), look for a ton of studies concerning genetically engineered plants and potential environmental impacts.
This type of result certainly bears additional scrutiny, but a related issue actually troubles me more. Did the companies that developed Bt corn not know the Bt toxin was being exuded from the roots? I remain convinced of the enormous benefit that will come from genetic engineering, but I do not like surprises associated with new technology that has already been released.
A class-action lawsuit claims that Monsanto, Delta & Pine Land Co., DuPont, Dow Chemical, Mycogen, Novartis, and others conspired to rush potentially unsafe genetically engineered products to the market. The suit further alleges that these companies sought to monopolize the biotechnology market and fix prices. Additionally, consumer rejection of genetically engineered crops (particularly in Europe) hurts the ability of all American farmers to sell agricultural products. Monsanto says the suit is completely without merit. (Pestic. & Tox. Chem. News, 12-16-99)
If you have an opinion about the introduction of genetically engineered foods, it is time to make your voice heard. The FDA recently completed a series of public hearings concerning genetically engineered foods. Responses ranged from a moratorium on engineered foods to labeling on all genetically modified products. You should have an opinion. After all, you are going to be eating it.
Comments may be sent directly to FDA by visiting their Web site at http://www.fda.gov/oc/biotech/ Click on "Comment on Federal Register Notice."
Or write to:
Commissioner Jane Henney
FDA Dockets Management Branch
Attn: Docket No. 99n-4282
5630 Fishers Lane, Rm 1061
Rockville, MD 20852
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.
If you wish to be added to the mailing list, just call us at 706-542-1765
Or write us:
Department of Entomology
University of Georgia
Athens, GA 30602
Receive GPMN via e-mail if you prefer. Just let us know.
Or visit us on the Web. You will find all the back issues and other useful information.
Paul Guillebeau, Assistant Professor & Extension Entomologist