TO: Get an Emergency Exemption for a Pesticide (Section 18)
BOOKS OF INTEREST
HEALTH AND THE ENVIRONMENT
This article is the first in a series of 'how to' accomplish (or at least attempt) pesticide regulatory activities.
The Food Quality Protection has changed some of the rules for getting an emergency exemption. For example, there must be an established tolerance (the amount of pesticide that can remain on a food) before a Section 18 can be granted. This article tells you everything that you need to know.
In order to obtain a Section 18, there must be some pest outbreak for which there is no chemical or nonchemical control available. Additionally, the circumstances must be urgent and nonroutine. Finally, the situation must present risks to human health or the environment or cause significant economic loss.
Here is the explanation again, in plain English. Your situation must be something different, either a new pest has moved into the area, or there is some reason why the old controls do not work (e.g., resistance). If the pest problem is routine, you are not eligible for an exemption. It does not matter if a new and better pesticide has come on the market. Emergency exemptions are intended to prevent economic losses, not increase farm revenues. There must be nothing that you can feasibly do about the problem. If there are chemical or nonchemical alternatives available, you must explain why they will not work. Finally, the pest must cause a significant problem. A mosquito population that carries encephalitis would be significant; a new tick that threatens an endangered species is significant. An agriculture pest must cause an economic loss that would not occur in five years. Crops with a widely variable income are less likely to receive a Section 18.
If you think your situation qualifies for an emergency exemption, follow these guidelines.
If you need additional information or help in preparing your package, contact me.
The University of California Sustainable Agriculture Research and Education Program has a new book to help farmers and other agricultural people surf the Net effectively. The book is called Internet Guide for Farmers, Extension Agents. You can find excerpts on the Web (where else?). Visit http://www.sarep.ucdavis.edu/ or 800-994-8849 to order.
Georgia growers have received an emergency exemption to apply spinosad to control Western Flower Thrips on tomato, pepper, and eggplant. The tolerance expires 9-30-97.
The new revised rules for structural pest control are available on computer disk by request. Send a 3.5" disk to:
Georgia Department of Agriculture
19 Martin Luther King Jr. Drive
Atlanta GA 30334-4201
The EPA has put two groups of pesticides on the fast track for registration. The Agency will expedite the registration of conventional pesticides that qualify as 'reduced risk' by having one or more of the following advantages over existing products: 1) lower impact on human health, 2) lower toxicity to other nontarget organisms, 3) lower potential for groundwater contamination, 4) lower potential for pest resistance, 5) greater compatibility with IPM programs. It is not clear whether a reduced risk product has to be 'reduced risk' compared to all other existing products for the same use, just safer than some of them, or safer than the 'average' alternative.
Biological pesticides will also be registered more quickly. This group includes microbials, pheromones, growth regulators, hormones used as pesticides, and plant pesticides (i.e., agricultural plants genetically engineered to control pests).
It currently takes about 14 months to register a reduced risk or biological pesticide, compared with 38 months for a conventional pesticide that does not qualify as reduced risk. (EPA For Your Information, 9-97)
Georgia growers have a new Special Local Need registration for control of residual pines and hardwoods in the establishment of pine plantations. Krenite UT Brush Control Agent will provide an additional tool for site preparation and will increase the time window for regenerating plantation sites. (SLN GA-970003)
Here is a book that may interest you if you wonder what Ma and Pa Kettle are up to these days. Reorganizing U.S. Agriculture: The Rise of Industrial Agriculture and Direct Marketing looks at the rise of corporate agriculture and associated shift in production decisions to off-farm firms. It also discusses changes in some state laws meant to prevent corporations from controlling agriculture, and provides sales and production data about farmers' markets. It will cost you $6. Henry A. Wallace Institute for Alternative Agriculture, 9200 Edmonston Rd, Suite 117, Greenbelt, MD 20770; phone (301) 441-8777
Making the Most of Freedom to Farm: Innovative Uses of Flexible Planting Rules and Conservation Programs, will give you information about U.S. federal farm programs and how farmers can use them to adopt new agriculture practices. It presents examples of farmers who have found ways under 1996 Farm Bill to implement practices that were difficult to adopt under old system of commodity payments, including crop rotations, integrated crop management and innovative livestock management systems. The price is right, $4.
Land Stewardship Project, 2200 4th St., White Bear Lake, MN 55110; phone (612) 653-0618. (PANNA, 10-26-97)
Tulane University retracted its findings concerning the synergistic effects of pesticide combinations on the endocrine system, but the EPA will not alter policy nor research regarding endocrine systems. The Agency contends that Tulane's retraction does not negate the substantial body of scientific literature on endocrine disruption and synergism. I am familiar with other publications concerning pesticide effects on the endocrine system, but I have not heard of other studies regarding the type of synergism that was reported by Tulane.
The EPA must develop and present a screening and testing program for endocrine disrupting chemicals to Congress by August 1999. The EPA Endocrine Disruptors Screening and Advisory Committee (10 industry reps, 10 government wonks, 10 academics, and 10 public interest folks).
The EPA is scheduled to revise one third of 9,728 food tolerances by August 1999,the next third by August 2002, and the final third by August 2006. Only a handful of tolerances have been reviewed thus far. Any bets on whether EPA can meet this schedule? Should we care? You bet we should. If the Agency cannot meet these deadlines, the courts may assume control of the process. The courts typically do not have expertise in this area, so they could mandate 10 reviews per week, and EPA would have to do those 10 reviews per week, regardless of the quality. When the EPA does poor quality work, we all suffer.
All uses of dienochlor (Pentac) are scheduled to be cancelled by Novartis Crop Protection because of registration costs, including nut trees, fruit trees, and all ornamental herbaceous and woody plants. A recent survey indicated that dienochlor is a very important pesticide for the ornamental industry. Novartis is interested in offers to purchase or support registration. Contact Chuck Buffington, Novartis Turf and Ornamentals at 910-632-2513 or email@example.com
Thiophanate-methyl (Topsin M) will delete registration on celery. Elf Atochem plans to support all other uses. Contact Rebecca Clemmer, Elf Atochem North America at 215-419-7667
Vinclozolin (Ronilan, Ornalin): delete grapes, plums, prunes, tomatoes, and ornamental turf (noncommercial uses). BASF has requested these deletions in order to obtain a new registration for succulent beans. Without these deletions, the EPA found the aggregate dietary risk from exposure to vinclozolin was too great to allow a new registration on succulent beans. Vinclozolin has been identified by EPA as an endocrine disrupter. Existing stocks of products with the previously approved labeling may be sold, distributed, or used by retailers, distributors, or end-user until such supplies are exhausted.
The following registrations will cancelled at the request of the registrant.
|Algacide 701||Laser Flea Killer|
|Amersperse||Mintol-128 Fragrant Mint Disinfectant|
|ARO Mint Disinfectant||Pryfon 6 Insecticide|
|Bicep Lite Herbicide||Turfic Trichlorfon|
|Bicep Herbicide||Wintergreen Mint-Odor Germicide|
|Blanco Nonselective Weed Killer||X-O-Trol Flea and Tick Fogger|
|Concentrated Arofect Pine Odor Disinfectant||X-O-Trol Flea and Tick Spray for Dogs|
|FBA-1-Mildew Fungistatic Film||X-O-Trol Flea and Tick Househould Spray|
|Lannate L Insecticide||ZEP 50% Malathion Emulsifiable Concentrate|
Reports available from the Spray Drift Task Force summarize their findings regarding aerial, ground, and chemigation studies. To get copies, call David Johnson at 816-762-4240.
Alkylphenol Ethoxylate Surfactants (APEs) are commonly used as surfactants in many products, including pesticides. A new book recommends that they be phased out for potential environmental and health effects. If you want to read more, call Washington Toxics Coalition, 4516 University Way, NE, Seattle, WA 98105; phone (206) 632-1545
In a county-wide program in San Francisco, a new law has reduced the amount of pesticide used by 2/3 and has eliminated nearly all use of pesticides linked to cancer and reproductive effects. Last October, the county government passed an ordinance that banned the use of the most toxic pesticides, including those suspected of causing cancer and reproductive harm, by city departments and contractors in 1997, and the remaining pesticides by the year 2000. The only exemptions are for water and wastewater treatment, anti-microbials (cleaners and sterilizers) used in health care, and swimming pool water treatment. The results of this program will be interesting. I doubt if they can eliminate the use of all pesticides and maintain adequate pest control, but San Francisco may discover that need only a fraction of the pesticide they once used. (PANNA, 10-20-97)
The Prior Informed Consent Procedure(PIC), is an international voluntary agreement (154 countries participate) on pesticide trade administered by the UN Food and Agriculture Organization (FAO) and UN Environment Programme (UNEP). The exporting country must obtain permission from the importing country before shipment can be made. Five concentrated formulations of organophosphates have been added to the list including methamidophos, methyl parathion, monocrotophos, parathion and phosphamidon; 17 pesticides and five industrial chemicals were on the PIC list. The specific formulations of the newly-listed pesticides may not necessarily be banned or severely restricted in any country, but have been included because of potential problems under conditions of use in developing countries. Growers in developing countries may not understand the hazards involved with these pesticides, or they may not be able to purchase the necessary protective equipment.
Studies on the application of organophosphates have demonstrated that during normal spraying farmers are exposed to contamination by absorption through the skin of residues on clothing. In China alone, 27 provinces in 1995 reported a total of 48,377 poisoning cases, including 3,204 fatalities. More than 7,500 of these cases were attributed to normal agricultural use of parathion and methamidophos. In addition, studies have shown that there are many unreported pesticide poisoning cases in rural areas of developing countries. Worldwide, there are more reported cases of pesticide poisoning with parathion than with any other pesticide. (PANNA, 10-13-97)
The Federal government spent approximately $4.5 billion last year to clean up toxic waste sites (most of them not pesticides). Less than $700 million was actually used to clean up toxic wastes. More than 55% of the money was spent for administration and support (e.g., rent, utilities, legal expenses). Approximately 15% (more than $200 million) was spent on legal fees. (Pestic. & Tox. Chem. News, 9-24-997)
A study by the Fish & Wildlife Service indicates that the Clean Water Act and Farm Bill provisions are protecting our wetlands. From 1985 to 1995, a total of 1.2 million acres of wetlands were lost or approximately 1% of the U.S. total wetlands (101 million acres). By comparison, we had already lost almost 80% of the U.S. wetlands that existed in the 1700s.
Critics point out that the aerial photographs used by FWS may be too old to present an accurate picture. Most of the pictures were taken during the 1980s. The Competitive Enterprise Institute report evidence from federal sources that indicate a net gain of wetlands since 1995 at a rate of 200,000 acres per year. It looks like there are data to support both sides of the wetlands argument. (Ag. Reg. Response on Water, 9-97)
Look for EPA to get tough on nonpoint source pollution. The Agency announced a new comprehensive strategy, 'Picking Up the Pace,' aimed at nonpoint source pollution. The strategy will focus on these highlights.
(Ag. Reg. Response on Water, 10-97)
In a related story, the EPA reports that 21% of U.S. watersheds have serious problems with water quality. The quality of a watershed was based on seven indicators: 1) rivers that meet all designated uses, 2) fish/wildlife consumption advisories, 3) drinking water sources, 4) contaminated sediments, 5) ambient water quality based on four toxic pollutants, 6) ambient water quality based on four conventional pollutants, and 7) wetlands loss. If you want more details, hit the Web. http://www.epa.gov/surf/iwi (Ag. Reg. Response on Water, 10-97)
Toxicologists with EPA report that they overestimated the cancer risk from atrazine. This statement means that all of the excitement, expense, and anxiety caused by new drinking water limits, state management plants, and water quality limits was based on false assumptions. I applaud EPA for stepping forward to admit a mistake, but I must criticize them as well. Could they not have reviewed their estimates carefully before they caused all of this trouble? The Agency's announcement could relax current limits on drinking water and water quality, and it could affect the regulations concerning state management plans. (Ag. Reg. Response on Water, 10-97)
Conservation tillage reduces that chance of atrazine leaching into ground water. The increased bacterial growth associated with reduced tillage degrade atrazine and other pesticides. Additionally, the increase in carbon effects higher sorption rates of atrazine. (Pestic. & Tox. Chem. News, 9-17-97)
The EPA had considered not testing larger molecules for endocrine disruption because the human body was unlikely to absorb such large molecules. It turns out that infants younger than five months old may be able to absorb larger molecules, and developing children may be at the greatest risk from endocrine disruptors. If EPA decides to test the larger molecules as well, it will add about 30,000 chemicals. (Pestic. & Tox. Chem. News, 10-15-97)
We are in danger of losing many important species of wildlife, but the loss of domestic species have been largely ignored. All domestic livestock belong to about 80 species, and most agriculture relies on about 14 species. For example, 91% of the U.S. dairy stock is one species, Holstein. And why not? Holsteins produce an average of 2,275 gallons of milk per year compared with 1,820 gallons/year for Brown Swiss and less than 1,600 gallons/year for Jersey.
However, Holsteins only produce these phenomenal numbers if they are kept cool and receive high quality food. What if some disease or other pest becomes prevalent in Holsteins, or what if farmers cannot afford to maintain these high-maintenance herds? We may need traits that allow cows to produce milk without a lot of care; these traits are carried in cattle like Kerrys, Dutch Belted, and Milking Devons. It is important to preserve these traits, but there is little economic incentive with today's conditions.
Swine and poultry are no different. Fifty years ago, there were 15 different purebred swine breed reared in the United States; eight are extinct. Four or five companies genetic stock for broiler chickens. Five chicken breeds supply almost all meat and brown eggs; white eggs are almost exclusively produced by one breed.
It is a serious mistake if we allow the genetic diversity of our livestock to disappear, but some groups are working to save it. Some countries are provide incentives to preserve rare breeds. The Colonial Williamsburg Foundation uses breeds from the 18th century. (Sci. News, 10-4-97)
The EPA has exempted from tolerance glyphosate oxidoreductase and the genetic material necessary for its production in all plants. Glyphosate oxidoreductase is the 'active ingredient' in Roundup Ready crops. Effective 10-8-97, Federal Register.
Some growers who planted Roundup Ready cotton this season experienced an unexplained loss of bolls during midseason. Cotton bolls reportedly became misshapen following the second application of glyphosate. It is unclear how many of the 600,000 Roundup Ready cotton acres were affected. Reported estimates range from 4,000 acres to more than 20,000 acres in Mississippi alone. (PANNA, 10-7-97 )
The EPA has approved the production of a genetically engineered Rhizobium. The bacterium has been engineered to improve its ability to fix nitrogen in the roots of legumes. The product is expected to be available to farmers in 1998. (EPA News Release, 10-4-97)
More than 20 environmental groups are prepared to take EPA to court to rescind registration of transgenic crops that produce the toxin of Bacillus thuringiensis. They contend that the genetically engineered plants will render B.t. useless because of resistance, which will trigger greater use of chemical pesticides. There argument is not without merit, but I am not sure they consider all sides of this issue. (Science News, 9-27-97)
Resistance is a very complex phenomenon. It is clear that planting millions of acres of B.t. crops will make resistance more likely, and insect resistance to B.t. has been demonstrated. On the other hand, environmental groups advocate the use of B.t. instead of chemical alternatives. Let us replace chemical applications on cotton, corn, potato, etc. with foliar applications of B.t. Furthermore, if we discover, select, or create more effective B.t. strains; growers should use them because they will replace even more chemical pesticides. Again, we have created the conditions that foster resistance. Greater effectiveness of B.t. and greater usage increase the likelihood of resistance.
What would environmental groups have us to do? Should we limit the use of B.t. to organic farmers only? Should we ban improvements in B.t. efficacy? Like any other scientific advance, genetic engineering carries both solutions and challenges. We must utilize the solutions and rise to meet the challenges.
The USDA has created a new office of pest management. It is part of a new, coordinated approach to minor use pesticides issues that builds on existing programs at USDA and the U.S. Environmental Protection Agency (EPA). The new office is charged with integrating and coordinating pesticideissues within USDA including pesticide usesurveys, minor use registration data development, pesticide residue data, food consumption surveys, the pest management activities program, and integrated pest management
The EPA also announced the new Minor Use Program Team. The Minor Use Team will focus on three primary goals: 1) Obtaining and Using the Best Available Usage Data, by refining the process for users to provide and verify available usage data, strengthening cooperation with USDA and Minor Use community, and using the Pesticide Environmental Stewardship Program; 2) Facilitation Open Dialogue with Minor Use Community, by increasing involvement with stakeholders early in the regulatory process; and 3) Promoting Development of Safer Pesticides for Minor Uses, by urging registrants to conduct research on minor crops and expediting registration of safer pesticides.
All uses of diflubenzuron and paraquat dichloride are eligible for reregistration. (RED Facts, 8-97)
According to Organic Farming Research Foundation, the USDA spends less than 0.1% of its research budget on organic farming. However, they do not consider IPM or biocontrol research as 'organic.' (Pestic. & Tox. Chem. News, 10-15-97)
There are some new, more stringent rules regarding adverse effects are on the way. Pesticide registrants are already required to report some adverse effects associated with pesticides; the new rules clarify the requirements and add some new ones.
For the first time, registrants must report:
The new rules will take effect June 1998. (EPA For Your Information, 9-97)
From now on, all pesticide label changes mandated by EPA throughout the fiscal year (Sept. 1-Aug. 31) will made by October 1. Existing stocks (without new labeling) must be released for distribution by Oct. 1. Normally, there will be no compliance date set for any except registrants and supplemental distributors. For more information, call 703-308-9071. (PR Notice, 97-7)
Additionally, 'inert' ingredients may be replaced with 'other' ingredients; registrants are not required to make this change, but they are encouraged to do so. (PR Notice, 97-6)
Registrants will also be able to omit the chemical names of pesticides on the label; they must have at least the common name of the active ingredients. Registrants are not required to omit chemical names, but the EPA requests that homeowner products use common names. (PR Notice 97-5) For more information, contact Jean Frane at 703-305-5944 or firstname.lastname@example.org. Tell her Paul sent you.
Registrants are strongly encouraged to include an informational/emergency telephone number on all homeowner products. The number could be the company's number, or they can use the number of the National Pesticide Telecommunications Network (800-858-7378). (PR Notice, 97-4)
The 1994 and 1995 estimates for the Pesticide Industry are available from EPA. There are some interesting data in there for all of you number nerds. The United States used more than 4.5 billion pounds of pesticides in 1995 (about 17 pounds per person), primarily chlorine and hypochlorites (water treatment and swimming pools). There are about 18 major pesticide manufacturers, 2,200 formulators, 17,000 farms using pesticides, 384,000 certified commercial applicators, and 70 million households (out of 95 million total U.S. households) that use pesticides. If you would like a copy of the report, call 703-308-8136.
The head of the EPA Office of Pesticide Programs is stepping down. Dan Barolo became the Director of Pesticide Programs in 1994, and his progressive, take-charge attitude was a boost for EPA these last three years. Good job, Dan!
The EPA has proposed allowing workers to wear disposable glove liners inside chemically resistant gloves. Currently, WPS prohibits any absorbent glove liners inside of chemically resistant gloves. The liners must be disposed of at the end of the day or after 8 hours of use, and the liners cannot extend beyond the outside of the gloves.
Additionally, the Agency proposes to eliminate the regulation that requires agricultural pilots to wear chemically resistant gloves when entering or exiting aircraft used to apply pesticides. (FR, 9-9-9-97)
The international phaseout of methyl bromide was set at the most recent edition of the Montreal Protocol. Industrialized nations will reduce methyl bromide use by 25% in 1999, 50% in 2001, 70% in 2003, and complete elimination by 2005. Developing nations will freeze use in 2002 and eliminate methyl bromide use by 2015. The United States plans to stop using methyl bromide by 2001; it was surprising that the United States did not push for our competitors to meet a similar deadline. (PANNA, 9-26-97)
In the meantime, a bill has been introduced to delay the phase-out of methyl bromide in the United States. HR 2609 would give EPA the right to delay the phaseout until effective substitutes are found. This bill could be a two-edged sword. A Florida study predicts a 43% decline in affected vegetable acreage in Florida with current alternatives. On the other hand, there would be little incentive to develop alternatives if methyl bromide remains on the market indefinitely. Given the united front of world scientists for protection of the ozone layer and congressional concern over environmental issues, I do not give this bill much of a chance. However, the political heat will continue build as the phaseout date for methyl bromide approaches. There will be a real battle over the current U.S. phase out date. (Pestic. & Tox. Chem. News, 10-15-97)
Radiation is being promoted as alternative in many quarantine and shipping applications for methyl bromide. Irradiated strawberries can be stored in the refrigerator for than three weeks with no shrinkage or decay. Mushrooms can last up to three weeks without browning or cap separation. Tomatoes can be picked when they are ripe without subsequent spoilage. And the little arms and legs that grow out can be easily plucked off before the fruit starts to move (just kidding). Scientists are convinced that irradiation has no harmful side effects. Most spices, herbs, and dry vegetable seasonings in the U.S. are treated with radiation. (Methyl bromide alternatives, 10-97)
Methyl iodide is reported to be an effective alternative for control of Caribbean fruit fly eggs and larvae. Methyl iodide is not considered to be a threat to the ozone layer because it is destroyed rapidly by ultraviolet light. Other studies have shown methyl iodide to be an effective substitute for methyl bromide in other situations as well. However, no registrant has stepped forward to shoulder the expense of registering methyl iodide. Just because methyl iodide does not harm the ozone layer does not mean that it is not dangerous. To register this product will be an uphill road paved with money. (Methyl bromide alternatives, 10-97)
Remember that some idiots used methyl parathion to control roaches and other pests indoors. In addition to the tremendous amount of tax money spent, we almost lost methyl parathion for all agricultural uses as well. Here are the new restrictions that enable methyl parathion to remain available for agriculture. 1) There was a nationwide recall of all methyl parathion for reformulation. 2) Only a 4EC formulation remains available. 3) A lacrimator (irritates eyes) was added. You will not be able to stand to have methyl parathion sprayed in your house. 4) Methyl parathion is only available in returnable/refillable containers. 5) Every container has a tracking number. 6) The registrants offer increased stewardship and education regarding proper use.
One of those applicators was Lutellis Kilgore. He cost the American taxpayers $20 million in clean-up costs. The American taxpayers gave Mr. Kilgore three years in prison and two years of supervised release. (EPA Press Advisory, 9-19-97)
Terramycin has long been used to control American foulbrood in honeybees, and many scientists have worried about resistance. A recent study indicated that the organism that causes foulbrood is just as susceptible to terramycin as ever. That's the good news. The bad news is that beekeepers are adding terramycin to the vegetable oil patties used for control of tracheal mites. The patties remain available indefinitely; therefore, the foul brood organism is exposed to terramycin over an extended period. This type of exposure makes the development of resistance more likely. (APIS, 9-97)
The USDA is coordinating an area-wide program to control corn rootworm. Nearly one-half of all insecticides applied to row crops are used to control this one pest. The primary reason is that growers currently apply an at-planting insecticide to nearly every acre of corn because they cannot predict where rootworm damage will occur. Specialists estimate that about half of the insecticide treatments are unnecessary.
The area-wide program relies on scouting and a bait/insecticide product that lures adult rootworms to their doom. Because the bait (a cucurbitacin) is so attractive, little insecticide is required to do the job. If you want more information, contact Robert Faust at 301-504-6918 email@example.com, Laurence Chandler 605-693-5239 firstname.lastname@example.org, or James Coppedge at 409-260-9511 email@example.com (USDA Agricultural Research, 10-97)
USDA scientists have discovered that red mulch suppresses tomato injury from nematodes. In experiments comparing black and red mulches, tomatoes inoculated with 200,000 nematode eggs/plant produced 8 pounds of tomatoes over black plastic and 17 pounds over red plastic. The scientists do not know how the red mulch suppresses nematodes, but they speculate that the red plastic causes the tomatoes to put more resources into above-ground structures and providing fewer food resources for the nematodes. For more information, call Michael Kasperbauer at 803-669-5203. (USDA Agricultural Research, 10-97)
According to the World Wildlife Fund, growers may be wasting millions of dollars by not increasing the use of IPM. Growers for Campbell Soup in Ohio reduced pesticide applications by 80% and saved $26/acre. Illinois soybean growers saved approximately $23 million with crop rotation and host plant resistance. Wisconsin potato producers reduced pesticide application and saved $6 million on pesticides and irrigation. If you would like the entire report, call 410-516-6951. (Pestic. & Tox. Chem. News, 9-3-97)
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.
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
Paul Guillebeau, Assistant Professor & Extension Entomologist