The U.S. apple industry will be put at even more of a
competitive disadvantage with the loss of ANY of the pest control
products/practices we now have. Responsible growers, with the help of the Extension
Service and university research people, have learned how to judiciously use
products like azinphos methyl with minimum or no adverse effects on beneficials
or the environment.
As commercial
tree fruit growers and independent research folks, we are now looking at many
mating disruption programs. One thing that is quickly apparent is that we can’t
afford to loose any of our present insecticides without delaying our commercial
use of mating disruption since mating disruption can’t stand alone. Since
we are a family operation, we need all the good products we now have to remain
in the fruit growing business.
We
are also starting organic apple production. It looks feasible as long as we can
get our processing customers to accept 15% insect damage and triple the price.
One
thing that is apparent is that opinions about sensitive issues like “pesticides”,
“organic”, etc. are often based on our preferential values
determined completely outside of any scientific evidence. (By the way, I came
out of a liberal Ivy League university and worked for the first company to
commercialize attractants and insect growth regulators for insect control in
apple orchards.)
Finally,
I remember my dad spraying DDT, parathion, etc. with an airblast sprayer (first
one in the state), no cab on the tractor, and he didn’t even know what “PPE”
was. He’ll be 96 next week.
W. H. "Butch" Palmer
Cell: 315-945-0945
Alternate e-mail: [EMAIL PROTECTED]
-----Original Message-----
From: [email protected]
[mailto:[EMAIL PROTECTED] On
Behalf Of Stina Booth
Sent: Tuesday, October 24, 2006
9:22 PM
To: Apple-Crop
Subject: Re: Apple-Crop: Azinphos
Methyl (Guthion ®) Phase Out
Its high time Guthion was phased out. The sooner the
better. The industry will benefit by no longer being associated with big-gun
broad spectrum products like Guthion.
On Monday, October 23, 2006, at 11:06 AM, Dan Digiacomandrea wrote:
Here is an update on what's happening with Guthion. USApple is
fighting hard for an extension with the support of Bayer but it's an up hill
battle!
Any support from industry is greatly appreciated. Forward your comments to me
and Jim Cranney.
Dan DiGiacomandrea
Bayer CropScience
68 Chadwick Manor
Fairport, NY 14450
585-330-3263
Fax 585-425-8774
[EMAIL PROTECTED]
http://www.bayercropscienceus.com/rep/~dan.digiacomandrea
-----Original Message-----
From: Jim Cranney [mailto:[EMAIL PROTECTED]
Sent: Friday, October 20, 2006
6:25 PM
To: Administrator
Subject: Azinphos Methyl
(Guthion®) Phase Out
M
E M O R A N D U M
TO:
USApple Science Advisory Subcommittee
CC:
USApple Board of Trustees
State and Regional Producer Organizations
FROM:
James R. Cranney, Jr.
SUBJECT:
Azinphos Methyl (Guthion®) Phase Out
DATE:
October 20, 2006
The U.S. Environmental Protection Agency’s (EPA) Assistant
Administrator Jim Gulliford has reached a decision regarding azinphos methyl
and is proposing to phase out the use as proposed, but over a slightly longer
period to 2012. The Assistant Administrator has directed EPA staff to
work with agricultural commodity groups to develop a phase out plan, which is
expected to be finalized later this month or in early November.
EPA has proposed to phase out azinphos methyl using sharp regional use
reductions that do not meet grower needs. USApple is attaching
EPA’s proposal language for your information as follows:
Apples
The current label rate is 1.0-1.5 lbs ai/A/application with seasonal max of 4.5
lbs ai/A.
Nationally, the average rate is 0.78 lbs ai/A/application with 2.4
applications. The seasonal average application rate is 1.88 lb ai/A/year.
However, in the Western apple production region, the average
rate is 0.99 lb ai/A/application with 1.8 applications and a seasonal average
of 1.78 lb ai/A/year. In the Eastern production region (in contrast), the
average rate is 0.63 lb ai/A/application with 3.4 applications and a seasonal
average of 2.05 lb ai/A/year. (All figures from USDA NASS, 2006)
<image.tiff>
<image.tiff>
Under the approach outlined in the table above, the 2008 seasonal max
application rate would be reduced to 2 lb ai/A West of the Rocky Mountains and
to 3 lb ai/A East of the Rocky Mountains. The seasonal max in the Eastern
region would decline to 2.0 lb ai/A in 2009 and 1.0 lb ai/A in 2011. The
Eastern production region option offers the most flexibility to growers.
Limiting the number of applications does not offer as much flexibility to
growers as the limiting the seasonal maximum application rate option.
It’s possible that limiting the number of applications would lead
growers in the Eastern US to increase rates above what they are currently using
(0.63 lb ai/A) to the maximum allowable. Limiting the number of
applications would have a bigger (initial) impact on PA and MI than WA.
USApple and the
Northwest Horticultural Council’s Mike Willett met with EPA today to
propose an alternative plan that would maintain more of the use over the period
of the phase out.
USApple proposed a framework for an agreement which included the following
issues:
I.
Use reduction proposal
II.
MRL review before the 2010 growing season to
evaluate the availability of international MRLs for azinphos methyl
alternatives. (top 15 markets)
III.
Apple pest management summit in 2010 or 2011 to
evaluate the state of apple pest management to consider any need for adjustment
of the schedule based upon critical need for the chemical.
IV. Request
EPA to allow Section 18 permits or other similar regulatory mechanism for
azinphos methyl use after 2012 in cases where there is a critical need.
V.
Ask EPA to reduce its proposed 100 foot buffer
to 60 feet from permanent bodies based on data submitted showing that apple
orchards have extensive vegetative buffers which reduce runoff.
USApple proposed the following alternative schedule for phase out of the apple
use:
2008, 2009 3 lbs.
a.i. maximum annual use per acre
(6 lbs. formulated product)
2010, 2011, 2012 2 lbs. a.i. maximum annual use per
acre
(4 lbs. formulated product).
EPA acknowledged that USApple’s proposal was reasonable, but further
discussion was necessary to finalize some of the issues in the agreement.
A primary concern was the need for a mechanism to demonstrate that
progress would be made in reducing the use. USApple has agreed to meet with EPA
staff on Friday, Oct. 27 to try to finalize the agreement. USApple will
continue to do everything possible to maintain the use according the USApple
proposal.
Please contact me by telephone at (800) 781-4443 or via e-mail at [EMAIL PROTECTED]
if you have questions or need additional information.
Dan DiGiacomandrea
Bayer CropScience
68 Chadwick Manor
Fairport, NY 14450
585-330-3263
Fax 585-425-8774
[EMAIL PROTECTED]
http://www.bayercropscienceus.com/rep/~dan.digiacomandrea
<image.tiff>
The information contained in this e-mail is for the
exclusive use of the intended recipient(s) and may be confidential,
proprietary, and/or legally privileged. Inadvertent disclosure of this
message does not constitute a waiver of any privilege. If you receive
this message in error, please do not directly or indirectly use, print, copy, forward,
or disclose any part of this message. Please also delete this e-mail and
all copies and notify the sender. Thank
you.
For alternate languages please go to http://bayerdisclaimer.bayerweb.com
<image.tiff>
