Hi all, I'm sitting in an airport about to leave for Quebec to talk about Crop-Adapted Spraying to a group of apple researchers.
Now that I've figured out how to post properly, I wanted to speak to Jonathan's point that regulatory agencies should make clear labelled changes to reflect the reality of orchard applications. In Canada, I've spoken with Heath Canada's Pest Management Regulatory Agency (who control label language and product registration) and Croplife Canada (the registrants that create agrichemicals) about this very point. A few registrants from the states claimed that they have attempted to put concentrations on their label, but the regulatory agencies insisted on per-acre units of measurement. When I asked the PMRA why that was, they said they had so much infrastructure oriented towards those units that it was a huge undertaking to consider changing them. All of their models for toxicity, rick, contamination, etc. are based on ground-area units. Both groups acknowledge the disconnect between units and grower practices, but don't seem to know what to do about it. Researchers have made a few suggestions to close the gap, and Jonathan touched on a few. One is establishing a standardized tree for determining label rates. Everyone would know it's volume, density, stage of growth and the environmental conditions for each and every product. Two is to use airblast sprayers with standardized set-up; no more spray guns for testing. Three is to publish coverage and efficacy variability on the label. For example, it might state discrete droplets per square centimetre in key locations on the tree, with variability. And/or it might note how many trees achieved what level of protection out of the total sprayed. All three approaches equal "transparency". They make test methods that establish label rates as close to standard grower methods as realistically possible and they give the grower the data to adjust their methods based on the standardized conditions - a basis for comparison. This would still leave growers making adjustments in an ad hoc manner, but they would be based on more solid ground. None of this, however, changes the current fact that if a growers applies a rate and/or volume that departs from label-recommended values, they assume responsibility for any consequences. Sadly, I'm not sure how that would change. My hope is to either encourage standardized testing, encourage system-wide change to accept new label units, or give growers a simple and flexible tool to interpret labels (Crop-adapted spraying). Looking forward to comments. Jason Deveau Application Technology Specialist OMAFRA -------------------------- Sent using BlackBerry ----- Original Message ----- From: [email protected] <[email protected]> To: [email protected] <[email protected]> Sent: Mon Jan 25 21:14:37 2010 Subject: Re: Apple-Crop: Pesticide Rates and Tree Row Volume Hello All, I have found the discussion that has arisen from my initial questions fascinating and the answers nowhere near as clear-cut as I had imagined. My original post included a plea to the pesticide manufacturers, EPA and what is left of our unfortunately underfunded extension experts to come up with a product labeling requirement that takes into consideration the complexities of applying pesticides to fruit trees. I would assume that CLARITY would be of utmost interest to the EPA, whether or not they actually care if the product works. ( Maybe important enough that they would back it up with dollars for research?) I don't buy the "Don't confuse the poor farmer by making them do algebra." argument. I also have trouble accepting the argument that a small tree equals a big tree. There is a limit to how dense the fruit and foliage can be before fruit quality suffers from light deprivation. Small trees put tree and fruit closer to the sprayer and have a smaller row volume. Our big old trees might not have grown as good quality fruit in the center of the tree, but there was still a need to protect it from insects and disease and thus a need to fill that volume of space with a cloud of spray mist that deposited an effective dose of pesticide. The variation on the TRV calculation that Jason Deveau discusses in his post might be based on better assumptions than our current approach, but it still contains the caveat that reducing the rate is at the grower's risk. We need a methodology that everyone can agree on so that if you do it right, the manufacturer will stand behind the product instead of hiding behind the lawyerly language written in tiny print on the label. I understand, as Dave Rosenberger points out, that from the manufacturer's perspective they might be recommending the least amount of product possible to leave more room in there "risk cup" for other crops, but if the rate is so close to the line so there is no margin for error, this needs to be communicated more effectively. Perhaps if the EPA was comparing how much Avaunt it really took to actually control Apple Maggot versus the actual rate of an O.P. that was being sprayed to accomplish complete control of the same pest ( I was one of those 1/4 - 1/8th rate growers that Kathleen Leahy referred to) they wouldn't feel quite the need to give the O.P.'s the bum's rush! As growers we have no way to know what assumptions have gone into the labeling of the pesticides we use. For example, if all the testing is already done on smaller trees and there really is no room to cut the rate further, this needs to somehow be made clear on the product label. I think Dave Kollas' frustration (one that I share) with labels that don't include a rate/100 gallons is based on a recognition that we need to have a common reference point.( not to mention a method for a small grower with a few trees and a backpack sprayer to figure out a dilute rate for his hand sprayer.) If the old assumptions are no longer valid, fine... lets develop some new ones, but it seems plain silly to plod forward with the kind of "tower of babble" labeling that we have now. Regards, Jonathan Bishop ??????????????????????????????????????????????????????????? B.W. Bishop & Sons, Inc. Bishop's Orchards 1355 Boston Post Road Growers of Fine Fruit Guilford, CT 06437 Since 1871 Vistit us on the web at: www.bishopsorchards.com ?????????????????????????????????????????????????????????? -------------------------------------------------------------------------- The 'Apple-Crop' LISTSERV is sponsored by the Virtual Orchard <http://www.virtualorchard.net> and managed by Win Cowgill and Jon Clements <[email protected]>. Apple-Crop is not moderated. Therefore, the statements do not represent "official" opinions and the Virtual Orchard takes no responsibility for the content. N���^ �),��HDU��)�{(��[��^V*�N��Z��m���� /��njZ+r�vw�jwfjv�y��Z)£"�V�t�' W�z{l���j�^����楢�!j�gz�)�W���b�z-��^��^u8^�����az�Z�鞞� �z-��kzǧ��߉Ț��b�*'��ݶ���njS�r�v֤z����)�{"n)b�'���^r��z{
