RE: Apple-Crop: RE:_Apple-Crop:_Azinphos_Methyl_=28Guthion_R=29_Phase_Out

[Miller, Stephen]

Butch:   Excellent comments.  Those of us who have worked in this business (research and/or as growers - I happen to be lucky enough to be both) know that it takes many approaches and the wise use of pesticides is one of those.  To grow fruit in the eastern US we need a broad toolbox with many options because we have a very broad range of pests and problems.  With the number of abandoned orchards in our area I figure we'd (our family's orchard) be lucky to get by with less than 30-40% loss if we didn't have the wide range of pesticides available that we do, including Guthion.  Don't get me wrong, I'm all for safer more effective pesticides (or production methods), but let's not throw something out just because we think it may be bad.  It takes time to develop alternatives that really work and research and industry have only begun this process.  Remember, the pests are changing (evolving) as time passes too.   As a youngster  50 years ago I applied parathion (and other materials) with a high pressure spray gun, no mask no gloves, nothing.  We didn't know any better then.  Today I wouldn't dream of doing that and I handle pesticides with the respect they command, but I'm not afraid to use them including  Guthion and I've never seen any evidence that pesticide residues on fruit (which by the way are either non-existent or in such small quantities they require the most sophisticated methods to even detect) have caused anyone serious injury or illness.  Also the newer IGR and target pesticides that we now use that have been introduced in the past 10 years - they have increased the cost of production, significantly, and I've seen little or no increase in the returns for the product.   And oh, by the way Butch, my Dad still does all the airblast spraying in our family's orchard, no cab (he does wear a mask and coveralls, but I remember when he didn't use any PPE).  He's not as old as your Dad though- he's only 86!  He's also picked about 400 bushels of apples this fall for our market, not bad for an old guy on two artificial knees!   Steve Miller   Stephen S. Miller, Ph.D. Research Horticulturist Appalachian Fruit Research Station 2217 Wiltshire Road Kearneysville, WV 25430 Phone: (304) 725-3451 x325 Fax: (304) 728-2340 [EMAIL PROTECTED]     From: apple-crop@virtualorchard.net [mailto:[EMAIL PROTECTED] On Behalf Of W.H. "Butch" Palmer Sent: Wednesday, October 25, 2006 8:17 AM To: 'Apple-Crop' Subject: Apple-Crop: RE:_Apple-Crop:_Azinphos_Methyl_=28Guthion_R=29_Phase_Out 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: apple-crop@virtualorchard.net [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. 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