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FDACS— REVIEW COUNCIL INFORMATION DATA ANALYSIS NEEDS COMPILATION

COUNCIL DATA ANALYSIS NEEDS DISCUSSION BACKGROUND INFORMATION

OVERVIEW

INFORMATION DATA ANALYSIS NEEDS AGENDA TOPIC INTRODUCTION At the September 2012 meeting Jeff Blair reported that the purpose of the agenda item was to tee- up a discussion at the September meeting and to ensure members understand the topic and have time to prepare comments in advance of the meeting. Jeff explained that the Council is being asked to consider whether from their individual perspectives there is any type of information or data they believe should be provided to the Council relevant to their scope and charge.

The agenda item was suggested by Joe Gaudino (chair) and he provided written comments explaining his thoughts regarding the topic. Following are Joe’s comments:

Joe suggested identifying several key metrics that provide important perspective on the overall progress, or deficiencies, in the field of pesticide management. These metrics could then be tracked by the council over time and might be included in the annual report. The metrics or questions could address a variety of subjects such as:

1. The efficacy of pesticide use a. Are keeping up with the threats and challenges presented in agriculture and other areas? b. What constraints limit the efficacy of pesticide use? c. Can we measure trends relative to the problem of pesticide resistance?

2. The safety of pesticides a. What pesticides have been removed from the market as a result of safety concerns? b. In what areas have pesticides become safer or less toxic? c. What pesticides are at risk for removal in the near future?

3. The quantities of pesticides applied year to year a. What materials are used in the greatest volume? b. What materials are increasing in usage? c. What materials are decreasing in usage?

4. The growth of pesticide alternatives such as biological controls a. Are biological controls making a significant contribution to pesticide control? b. What barriers exist that prevent the widespread use and adoption of pesticide alternatives? c. What trends can we identify regarding the use of pesticide alternatives over time?

Data Analysis Needs 1 Joe noted that it may be possible to limit the PRC’s inquiry to information that is currently available or to seek assistance from the University System in providing information or studying questions they deem significant and worth pursuing.

Summary of Discussion at the May 15, 2012 PRC Meeting: • Steve Dwinell: proposed that there was a need to fine-tune the topics because of the vastness of the subject. The Council needs to ensure that the focus of the inquiry is relevant to their scope and mission. • The other issue is determining what information is actually available and what resources would be needed to provide the information in terms of time, personnel, research, etc. • Tim Fitzpatrick: asked who the audience was. Important to know whether the PRC is providing relevant information. Steve Dwinell: offered that it might be useful to develop a pesticide primer along the lines of the mosquito control handbook developed by the FCCMC. Dennis Howard: suggested that staff could look into generic information to streamline development of a handbook effort. Brian Katz suggested looking at available information before planning a course of action (the handbook effort may be an overwhelming project). Dan Botts: indicated that he has spent a 35-year career trying to develop a handbook (with great effort and little success). • FDACS will provide information/links to questions already posed, showing what type of information is available. Once members receive an update on what is available they will send their thoughts on what information data needs they think should be explored by the Council. • Jeff Blair will send members an e-mail asking that they identify other information/data need requests for discussion at the September meeting (in addition to Joe’s suggestions).

The FDACS response was sent to members on August 15, 2012 with a deadline of August 22, 2012 for submitting comments for compilation and distribution.

MEMBER COMMENTS

Mel Kyle: 1. The efficacy of pesticide use: a. Are pesticides keeping up with the threats and challenges presented in agriculture and other areas? A = For the most part YES. Thanks to the pesticide registrants for their discovery and synthesis, along with assistance from the university researchers and programs to evaluate for biological efficacy, environmental risk and food safety. Also critical to this “keeping up” is an USEPA registration and the effectiveness of FDACS-AES to register and regulate pesticide use in Florida. b. What constraints limit the efficacy of pesticide use? Is the product efficacious in the first place? A = If the product is not efficacious when used according to the label, the registrant would not go to the time and expense to obtain a registration. Also the market will eliminate it in short order. Constraints to limit the efficacy of pesticide use include (1) label use restrictions, (2) cost, (3) application technology and methods needed to reach the target, (4) application timing and requirements, (5) weather conditions, (6) environmental restraints, (7) etc.

Data Analysis Needs 2 c. Can we measure trends relative to the problem of pesticide use? A = YES to a degree, as long as the exercise is balanced with the trends relative to the advantages and benefits of pesticide use!

2. The safety of pesticides: a. What pesticides have been removed from the market as a result of safety concerns? A = Removed by whom, federal, state, registrants, etc.? What time period, last how many years? Reasons = safety to human health (food, potable water, worker protection), drift to non target crops and sites, etc. With relation to the state of Florida, this would be an FDACS-AES question to answer. b. In what areas have pesticides become safer or less toxic? A = All areas of pesticide use have become safer or less toxic over the last 50+ years through the use of good science and research for application technology, GMO crops, basic biological research in pest behavior, biology, life cycles, etc.; regulations and enforcement; 4-R’s = right source/product, right rate, right time & place. c. What pesticides are at risk for removal in the near future? A = Methyl Bromide is in the process of being removed, otherwise none that I am aware of at least from the State of Florida. A question for FDACS-AES.

3. The quantities of pesticides applied year to year: a. What materials are used in the greatest volume? A = Question for FDACS-AES. b. What materials are increasing in usage? A = Question for FDACS-AES. c. What materials are decreasing in usage? A = Question for FDACS-AES.

4. The growth of pesticide alternatives such a biological controls: a. Are biological controls making a significant contribution to pesticide control? A = Define biological organism as a living beneficial organism used to control a non-beneficial organism. YES in certain areas and conditions. Not so much in large mono-copying venues where high yields and crop rotations are required for supplying in large numbers and large quantities i.e. feeding the world. b. What barriers exist that prevent the widespread use and adoption of pesticide alternatives? A = Economics! Practical application and containment to the target. Production/rearing the control agent(s). Transporting living organisms from production/rearing site to target site. Environmental conditions and challenges of any introduced living organism. Handling by humans throughout the whole process from production/rearing to field application. Establishment of an introduced living organism to a new environment. Biological establishment and persistence/survival. c. What trends can we identify regarding the use of pesticide alternatives over time? A = Pesticide alternatives will always be in play for but will not totally replace pesticides when “feeding the world” and in 3rd world countries where application and establishment of biological controls are impractical.

Data Analysis Needs 3 Bill Caton: 2. The safety of pesticides: Adverse incidents resulting from pesticide use a) Incidents of confirmed pesticide misuse 1. Application rate violation 2. Violation of label use restrictions 3. Improper container disposal 4. Etc. b) Incidents resulting in human health problems c) Incidents resulting in environmental harm, e.g. fish kill, bird kill, etc.

I believe this information could be used to identify trends and possibly specific areas/issues that the PRC could recommend changes to the Commissioner that might reduce adverse incidents.

Richard Pfeiffer: 3. The quantities of pesticides applied year to year: One item that is at the beginning of all the issues is what and how much of a pesticide is being used in Florida. But, as pointed out, Florida does not have a legal reporting requirement nor the budget to do appropriate surveys. With the current situation, I was wondering if IFAS/University of Gainesville could be leveraged by utilizing the students to do this work. Potentially using this as a class or individual student exercise? That way if a particular pesticide issue is identified, an evaluation could be done to see if it could be a Florida problem.

The suggestion of developing a handbook is a good idea. It could cover the national based process/procedures and well as items that are specific to Florida.

2. The safety of pesticides: Finally, I also think it is quite the irony that some of the old long ago banned pesticides are still a major environmental concern. Which also brings up that there is one more need (and it is part of the workplan; C3) of a better/more adequate means of evaluation of environmental residues of pesticides.

Joe Gaudino: I appreciate the thorough response to my questions about data metrics and information resources that would be beneficial to the PRC. The volume of data and information provided by FDAC to assist council member with understanding these questions and complex issues was substantial and the material provided significantly enhanced my perspective and understanding of the questions.

I agree with Steve Dwinell’s comment that the PRC would need to be more focused in attempting to establish an ongoing informational resource or report that addresses such complex subject matter. While I feel the questions are important, I recognize that synthesizing the information and drawing meaningful conclusions is very difficult given the vastness of the topics. Clearly a number of scientific, educational, and governmental entities are collecting data and providing educational resources on all of the topics I was questioning. I can see where reviewing this data would lead to discussion about a handbook or primer that could be used to inform and orient council members,

Data Analysis Needs 4 other interested parties, and/or the public. Perhaps our focus could be on identifying other existing resources that could be used for this same purpose such as the National Academies Press Reports or some of the EPA resources identified by FDAC in response to the questions.

I suggest our discussion during the next meeting focus on whether we should or how we might process and find a useful outlet for the information and resources identified as a result of this inquiry. At a minimum I think it useful to identify information that should be made available to new Council members or other interested parties engaged in discussions with the PRC.

FDACS DATA AVAILABILITY RESPONSE

1. The efficacy of pesticide use a. Are pesticides keeping up with the threats and challenges presented in agriculture and other areas? http://agrochemicals.iupac.org/index.php?option=com_sobi2&sobi2Task=sobi2Details&catid=3&sobi2Id=31 http://www.nap.edu/catalog.php?record_id=9598#toc http://www.nap.edu/catalog.php?record_id=13147 b. What constraints limit the efficacy of pesticide use? Is the product efficacious in the first place?

Application methods, weather, timing of application, etc. c. Can we measure trends relative to the problem of pesticide resistance?

IFAS would likely have information on this. http://www.irac-online.org/wp-content/uploads/2009/09/Resistance-The-Facts.pdf (The above link will work if you paste it into the internet address line.)

2. The safety of pesticides a. What pesticides have been removed from the market as a result of safety concerns?

All of the older, original organochlorine pesticides and many organophosphates have been removed from the market. However, the significant restriction or removal of the uses of , spirotetramat, methyl iodide, methyl bromide, MSMA, and were higher profile and potentially more impacting. It should be noted that the reasoning and process under which these products were restricted/canceled varied significantly. On a more general note, the EPA re-reviews all pesticide active ingredients on a 15-year cycle to incorporate the latest available data into the risk assessment and to make sure a pesticide continues to meet today’s standard for acceptable risk. This is the main mechanism for taking regulatory action on a registered pesticide. The outcomes of these registration reviews are posted on the federal docket. FDACS routinely reviews the docket for regulatory actions on pesticide active ingredients, and if appropriate, can submit commentary to the EPA during the public comment period.

Data Analysis Needs 5 Certain databases (e.g., NPIRS, NSPIRS) can be searched for the registration status of individual active ingredients. However, there is not a readily available comprehensive list of active ingredients that have been cancelled due to health and safety or environmental concerns. Specific formulations (brands) are often cancelled while the active ingredient remains active in other brands. Also, for active ingredients, specific uses are continually added or deleted. There are numerous reasons for an active ingredient being cancelled. Unless otherwise noted, the following are examples of active ingredients that have had all uses cancelled in the U.S. as a result of health and safety or environmental concerns:

Reregistration Update for PPDC– October 78, 2008: AZM, cyanazine, fenamiphos, , , molinate, zineb http://www.epa.gov/pesticides/ppdc/2008/oct2008/reregistration-update.pdf

Restricted Use Products (RUP) Report (EPA, 2002): Acrolein, acrylonitrile, allyl alcohol, alachlor, avitrol, cyanide, , , clofentezine, coal tar creosote, creosote oil, cyanazine, demeton, diallate, dichloropropene, diclofop methyl, , dodemorph, , ethyl , hydrocyanic acid, isazofos, lambda , magnesium phosphide, methyl bromide, methyl parathion, meviphos, , sodium pentachlorophenate, sulfotepp, TEPP, . http://www.epa.gov/opprd001/rup/rupdec02.htm

Status of Pesticides in Special Review (EPA, 2000): Sodium arsenite, strobane, trysben, DDD (TDE; dichlorodiphenyl dichlorothane) , DDT (dichlorodiphenyl trichloroethane), , cadmium, captafol, cyanazine, DBCP (dibromochloropropane), dinoseb, EPN (ethyl (p- nitrophenyl)thiobenzene phosphonate), lead arsenate, calcium arsenate, sodium arsenite, sodium fluoroacetate, 2,4,5- T/Silvex, 2,4,5-Trichlorophenol (TCP), benzene, chlordane, , cyhexatin, , mercury, mevinphos, monocrotophos, nitrofen (TOK), sporocidin, tributyl tins, zineb, BHC, chloranil, methazole, OMPA (Octamethylpyrophosphoramide), perthane, phenarsazine chloride, pronamide, ronnel, safrole, diallate. http://www.epa.gov/oppsrrd1/special_review/ http://www.epa.gov/oppsrrd1/docs/sr00status.pdf

Cancelled “Level 1 Pesticides” (EPA, 2000): , , chlordane, p,p-dichlorodiphenyltrichloroethane (DDT), mirex, and toxaphene http://www.epa.gov/pbt/pubs/pestaction.htm

Recognition and Management of Pesticide Poisonings (EPA, 1999): Hexachlorobenzene, terpene polychlorinates, chlordimeform, cyhexatin, Sodium fluosilicate (sodium silico fluoride), 2,4,5-T, dinosulfon, dinoterb acetate, dinoterb salts, dinoterbon, dibromochloropropane (DBCP): http://www.epa.gov/pesticides/safety/healthcare/handbook/handbook.pdf

EPA Rainbow Report, 1998: http://www.epa.gov/oppsrrd1/Rainbow/98rainbo.pdf

Economic Impacts of Cancelled Pesticides (EPA, 1980): DDT, Aldrin/ dieldrin, chlordane, heptachlor, mercury, kepone, chlorobenzilate, , DBCP, 2,4,5-T/ Silvex http://nepis.epa.gov/Exe/ZyNET.exe/9100CCCM.TXT?ZyActionD=ZyDocument&Client=EPA&Index =1976+Thru+1980&Docs=&Query=FNAME%3D9100CCCM.TXT%20or%20(%20T%20or%20cance llation)&Time=&EndTime=&SearchMethod=1&TocRestrict=n&Toc=&TocEntry=&QField=&QFieldYe ar=&QFieldMonth=&QFieldDay=&UseQField=&IntQFieldOp=1&ExtQFieldOp=1&XmlQuery=&Fil e=D%3A%5Czyfiles%5CIndex%20Data%5C76thru80%5CTxt%5C00000014%5C9100CCCM.txt&User =ANONYMOUS&Password=anonymous&SortMethod=h%7C- &MaximumDocuments=10&FuzzyDegree=0&ImageQuality=r75g8/r75g8/x150y150g16/i425&Display=

Data Analysis Needs 6 p%7Cf&DefSeekPage=x&SearchBack=ZyActionL&Back=ZyActionS&BackDesc=Results%20page&Maxi mumPages=1&ZyEntry=1&SeekPage=x&ZyPURL#

Suspended and Cancelled Pesticides (EPA, 1979): Copper arsenate, BHC, Chloranil, DDD, Kepone (chlordecane), Mirex, OMPA, PCB’s, Phenarzide chloride, Polychlorinated Terphenyls, Safrole, Strobane, Thallium sulfate, and Vinyl chloride. http://nepis.epa.gov/Exe/ZyNET.exe/20015G5I.TXT?ZyActionD=ZyDocument&Client=EPA&Index=1 976+Thru+1980&Docs=&Query=FNAME%3D20015G5I.TXT%20or%20(%20%20(%20cancelled%20 pesticides%20))&Time=&EndTime=&SearchMethod=1&TocRestrict=n&Toc=&TocEntry=&QField=&Q FieldYear=&QFieldMonth=&QFieldDay=&UseQField=&IntQFieldOp=1&ExtQFieldOp=1&XmlQuer y=&File=D%3A%5Czyfiles%5CIndex%20Data%5C76thru80%5CTxt%5C00000009%5C20015G5I.txt &User=ANONYMOUS&Password=anonymous&SortMethod=h%7C- &MaximumDocuments=10&FuzzyDegree=0&ImageQuality=r75g8/r75g8/x150y150g16/i425&Display= p%7Cf&DefSeekPage=x&SearchBack=ZyActionL&Back=ZyActionS&BackDesc=Results%20page&Maxi mumPages=1&ZyEntry=1&SeekPage=x&ZyPURL#

Arsenicals

Arsenic Acid: http://water.epa.gov/drink/info/arsenic/upload/2005_11_10_arsenic_occurrence.pdf

Sodium arsenate, potassium dichromate, sodium pyroarsenate, sodium chromate, ammonium arsenate http://www.epa.gov/oppsrrd1/reregistration/REDs/cca_red.pdf

DSMA, CAMA, cacodylic acid and its sodium salt: http://www.gpo.gov/fdsys/pkg/FR-2009-09-30/html/E9-23319.htm

Azinphos methyl: http://www.epa.gov/oppfead1/cb/csb_page/updates/2008/cancel-azinphos.htm https://www.federalregister.gov/articles/2008/02/20/E8-3112/azinphos-methyl-product-cancellation-order-and- amendments-to-terminate-uses

Benomyl: http://www.epa.gov/EPA-PEST/2003/September/Day-29/p24560.htm

Carbofuran: http://www.epa.gov/oppsrrd1/reregistration/carbofuran/carbofuran_noic.htm

Clofencet: http://www.epa.gov/oppsrrd1/registration_review/clofencet/

Dicofol: http://www.epa.gov/oppfead1/cb/csb_page/updates/2011/vc-.html

Difenzoquat: http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OPP-2009-0787-0009;oldLink=false

Disulfoton:

Data Analysis Needs 7 http://www.gpo.gov/fdsys/pkg/FR-2009-09-23/html/E9-22921.htm

Ethyl parathion: http://www.epa.gov/fedrgstr/EPA-PEST/2007/November/Day-16/p22374.htm

Ethylene dibromide (EDB): http://www.epa.gov/aboutepa/history/topics/legal/02.html

Fenvalerate: http://www.epa.gov/fedrgstr/EPA-PEST/2008/July/Day-09/p15314.htm

Iodomethane: http://www.panna.org/sites/default/files/MIDASPress3-20-12FINAL_1.pdf

Lindane: http://www.epa.gov/oppsrrd1/REDs/factsheets/lindane_fs_addendum.htm

Methamidophos: http://www.gpo.gov/fdsys/pkg/FR-2009-09-23/html/E9-22921.htm

Methoxychlor: http://www.epa.gov/oppsrrd1/REDs/methoxychlor_red.htm

Methyl Bromide (all uses except post-harvest): https://www.federalregister.gov/articles/2011/05/20/2011- 12478/methyl-bromide-cancellation-order-for-registration-amendments-to-terminate-certain-soil-uses

Methyl parathion: http://www.epa.gov/oppfead1/cb/csb_page/updates/2010/methylparathion-vc.html

Molinate: http://www.epa.gov/EPA-PEST/2004/April/Day-07/p7868.htm

Oxadixyl: http://www.epa.gov/raf/publications/pdfs/DERMALFRN.PDF

Rodenticides: http://www.epa.gov/fedrgstr/EPA-PEST/2008/December/Day-24/p30495.htm

Rotenone: http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OPP-2005-0494-0065;oldLink=false

Tributyl tin: http://www.epa.gov/fedrgstr/EPA-PEST/2007/November/Day-16/p22374.htm

Wood preservatives: http://www.epa.gov/EPA-PEST/2003/September/Day-29/p24560.htm

Colorado State Banned Pesticides: http://www.cepep.colostate.edu/Fact%20Sheets/141BannedPesticides.pdf

PANNA 1992 list of EPA banned pesticides: http://archive.sare.org/sanet-mg/archives/html-home/1-html/0032.html 1. aldrin 2. benzene hexachloride [BHC] (vol. cancellation) 3. 2,3,4,5-Bis(2-butylene)tetrahydro-2-furaldehyde [Repellent-11] 4. bromoxynil butyrate (vol. cancellation) 5. cadmium compounds (vol. cancellation) 6. calcium arsenate (vol. cancellation) 7. captafol (vol. cancellation) 8.

Data Analysis Needs 8 9. chloranil (vol. cancellation) 10. chlordimeform (vol. cancellation) 11. chlorinated camphene [Toxaphene] (vol. cancellation) 12. chlorobenzilate. cancellation) 13. chloromethoxypropylmercuric acetate [CPMA] 14. copper arsenate (vol. cancellation) 15. cyhexatin (Vol. cancellation) 16. DBCP 17. decachlorooctahydro-1,3,4-metheno -2H-cyclobuta (cd) pentalen-2-one [] 18. DDT 19. Dieldrin 20. dinoseb and salts 21. Di(phenylmercury)dodecenylsuccinate [PMDS] (vol. cancellation) 22. endrin ~vol. cancellation) 23. EPN (vol. cancellation) 24. ethyl hexyleneglycol [6-12] (vol. cancellation) 25. hexachlorobenzene [HCB] (vol. cancellation) 26. lead arsenate (vol. cancellation) 27. leptophos (Never received initial registration) 28. mirex (vol. cancellation) 29. monocrotophos (vol. cancellation) 30. nitrofen (TOK) (vol. cancellation) 31. OMPA (octamethylpyrophosphoramide) 32. phenylmercuric oleate [PMO] (vol. cancellation) 33. potassium 2,4,5-trichlorophenate [2,4,5-TCP] 34. pyriminil [Vacor] (vol. cancellation) 35. safrole (vol. cancellation) 36. silvex 37. sodium arsenate 38. sodium arsenite 39. TDE (vol. cancellation) 40. Terpene polychlorinates [Strobane] (vol. cancellation) 41. thallium sulfate 42. 2,4,5-Trichlorophenoxyacetic acid [2,4,5-T] 43. vinyl chloride

Notice of Receipt of Requests to Voluntarily Cancel Certain Pesticide Registrations (EPA, 2008-2011): https://www.federalregister.gov/articles/2011/09/07/2011-22847/notice-of-receipt-of-requests-to-voluntarily- cancel-certain-pesticide-registrations http://www.gpo.gov/fdsys/pkg/FR-2010-02-03/pdf/2010-1583.pdf http://www.epa.gov/fedrgstr/EPA-PEST/2009/March/Day-18/p5828.htm

EPA Criteria and Process for Cancelling Pesticides: http://www.epa.gov/pesticides/regulating/labels/56-FR-29362.pdf http://www.epa.gov/pesticides/regulating/cancellations.htm

Data Analysis Needs 9

Restricted Use Products: http://www.epa.gov/pesticides/regulating/restricted.htm b. In what areas have pesticides become safer or less toxic?

It is common for FDACS to receive a request for registration of a new active ingredient that exhibits lower application rates, higher specificity to the target organism, lower leaching ability, and lower mammalian toxicity. Taken together, this reduces the risks to humans, primarily, but also to many taxa of non-target species (birds, fish). However at the same time, these new active ingredient, if persistent enough, can be more apt to present risks to aquatic organisms due to their environmental fate (more prone to erosion and runoff) and more potent toxicity to non-target organisms of the same taxa (i.e., invertebrates) as the target organism. With regard to protecting non-target aquatic species, we are seeing more labels requiring setbacks from water bodies, or maintenance of a vegetative strip to mitigate drift and runoff, respectively.

Reduced Risk Pesticides: http://www.epa.gov/opprd001/workplan/reducedrisk.html http://www.epa.gov/pesticides/health/reducing.htm EPA gives priority in its registration program for conventional chemical pesticides to pesticides that meet reduced risk criteria: low-impact on human health, low toxicity to non-target organisms (birds, fish, and plants), low potential for groundwater contamination, lower use rates, low pest resistance potential, and compatibility with Integrated Pest Management.

Increased Use of : http://www.epa.gov/pesticides/biopesticides/ http://www.epa.gov/pestwise/publications/biodemo/biopesticides_fact_sheet.pdf

Food Quality Protection Act (FQPA) of 1996: http://www.epa.gov/pesticides/regulating/laws/fqpa/index.htm With the enactment of the Food Quality Protection Act (FQPA) of 1996, Congress presented EPA with an enormous challenge of implementing the most comprehensive and historic overhaul of the Nation's pesticide and food safety laws in decades. The FQPA amended the Federal , Fungicide, and Rodenticide Act (FIFRA) and the Federal Food Drug, and Cosmetic Act (FFDCA) by fundamentally changing the way EPA regulates pesticides. Some of the major requirements include stricter safety standards, especially for infants and children, and a complete reassessment of all existing pesticide tolerances.

Review of Older Pesticides: http://www.epa.gov/pesticides/reregistration/ In 2008, EPA completed a review of older pesticides (those initially registered prior to November 1984) under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) to ensure that they met current scientific and regulatory standards. This process, called reregistration, considered the human health and ecological effects of pesticides and resulted in actions to reduce risks of concern.

Integrated Pest Management (IPM): http://www.epa.gov/pesticides/food/ipm.htm Age-old, common-sense practices are what many people associate with IPM. Today many growers no longer apply pesticides to food on a regular basis regardless of whether or not there are insects, weeds, or other pest problems. In some parts of the country, food is being marketed as IPM food. Some practices for preventing pest damage may include inspecting crops and monitoring crops for damage, and using mechanical trapping devices, natural predators (e.g., insects that eat other insects), insect growth regulators, mating disruption substances (pheromones), and if necessary, chemical pesticides. The use of biological

Data Analysis Needs 10 pesticides is an important component of IPM. In technical terms, IPM is the coordinated use of pest and environmental information with available pest control methods to prevent unacceptable levels of pest damage by the most economical means and with the least possible hazard to people, property, and the environment.

Pesticide Reregistration Performance Measures and Goals: Annual Progress Report: Fiscal Year 2011: http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OPP-2011-0959-0002 http://www.epa.gov/pesticides/regulating/laws/fqpa/index.htm http://www.epa.gov/oppsrrd1/reregistration/reports.htm http://www.epa.gov/pesticides/health/reducing.htm http://www.epa.gov/aboutepa/history/topics/report.pdf pages 43, 44 and 54. http://www.epa.gov/opp00001/biopesticides/regtools/25b_list.htm http://www.npic.orst.edu/ingred/lowrisk.html http://nepis.epa.gov/Exe/ZyNET.exe/2000JJFJ.TXT?ZyActionD=ZyDocument&Client=EPA&Index=20 00+Thru+2005&Docs=&Query=FNAME%3D2000JJFJ.TXT%20or%20(%20promoting%20or%20safety %20or%20for%20or%20america's%20or%20future)&Time=&EndTime=&SearchMethod=1&TocRestrict=n &Toc=&TocEntry=&QField=&QFieldYear=&QFieldMonth=&QFieldDay=&UseQField=&IntQField Op=1&ExtQFieldOp=1&XmlQuery=&File=D%3A%5Czyfiles%5CIndex%20Data%5C00thru05%5CT xt%5C00000009%5C2000JJFJ.txt&User=ANONYMOUS&Password=anonymous&SortMethod=h%7C- &MaximumDocuments=10&FuzzyDegree=0&ImageQuality=r75g8/r75g8/x150y150g16/i425&Display= p%7Cf&DefSeekPage=x&SearchBack=ZyActionL&Back=ZyActionS&BackDesc=Results%20page&Maxi mumPages=1&ZyEntry=1&SeekPage=x&ZyPURL http://www.csupomona.edu/~zywang/carson.pdf c. What pesticides are at risk for removal in the near future?

This is very difficult to answer. Any pesticide going through the registration review process is at risk, or at least certain use patterns could be at risk. It is, therefore, probably easier to identify those chemicals that have received attention from the EPA in the recent years, but this does not equate to risk of removal of their uses. Clearly, atrazine and the are at the top of the list, but only because EPA has been evaluating their risks to water quality and pollinators, respectively. The second generation anti-coagulant rodenticides have been heavily reviewed and scrutinized, and organophosphates are always being challenged by environmental groups and EPA has considered each of these challenges.

Pesticide Reregistration Status: http://www.epa.gov/pesticides/reregistration/status.htm

Notice of Receipt of Requests to Voluntarily Cancel Certain Pesticide Registrations (EPA, 2012): http://www.gpo.gov/fdsys/pkg/FR-2012-07-06/pdf/2012-16448.pdf

Rotterdam Convention Annex III Pesticides: 2,4,5-T and its salts and esters, alachlor, aldicarb, aldrin, binapacryl, captafol, chlordane, chlordimeform, chlorobenzilate, DDT, dieldrin, dinitro-ortho-cresol (DNOC) and its salts, dinoseb and its salts and esters, EDB (1,2-dibromoethane), endosulfan, ethylene dichloride, ethylene oxide, fluoroacetamide, HCH, heptachlor, hexachlorobenzene, (gamma-HCH), mercury compounds, monocrotophos, parathion, pentachlorophenol and its salts and esters, toxaphene, tributyl tin compounds, benomyl, carbofuran, thiram, , methyl-parathion and phosphamidon. http://www.pic.int/TheConvention/Chemicals/AnnexIIIChemicals/tabid/1132/language/en-US/Default.aspx Note: The US is a signatory to the treaty but is not a party until/unless it is ratified by the Senate.

Data Analysis Needs 11 3. The quantities of pesticides applied year to year a. What materials are used in the greatest volume?

FDACS 2010 Pesticide Use Information report showed methyl bromide, chloropicrin and petroleum distillates as the highest volume pesticides. This is likely a function of their high application rate per acre, rather than reflective of the percent agricultural acreage treated. Regarding conventional pesticides, the same report showed chlorothalonil, mancozeb, aldicarb, glyphosate and copper hydroxide as the highest volume pesticides. However, it should be noted that the USDA program that gathered these data does not survey all crops in Florida and only surveys Florida growers on a non-routine basis. Florida Statutes do not give FDACS the authority to require routine reporting of use data. b. What materials are increasing in usage?

Unlike California, Florida growers are not required to submit pesticide use data to FDACS. Therefore, there is a lack of comprehensive and up-to-date pesticide use information. In the past 10 years, FDACS has compiled available use information from various USDA reports. However, the USDA, only occasionally surveys Florida growers and only surveys a limited number of crops grown in Florida. Answering questions about trends in pesticide use is problematic given the limited data, and infrequency and inconsistency of its collection. Generally speaking, glyphosate (Roundup) use has gone up with increased planting of Roundup-ready crops. With weed resistance to glyphosate becoming increasingly prevalent, use of other older herbicides (e.g., 2,4-D) may increase. Use of methyl bromide replacements will increase, as could synthetic use to replace the organophosphates. Finally, FDACS has received information that there would likely be increased insecticide use in citrus to combat the spread of citrus greening. To identify specific ai’s would be difficult for the same reason as above, but based on discussions with the industry, increased use of and neonicotinoids would be likely. c. What materials are decreasing in usage?

Answering questions about trends in pesticide use is problematic given the limited data, and infrequency and inconsistency of its collection. However, with the phase-out of methyl bromide and its limited supplies, we can anticipate a lessened dependence on this fumigant. With the labeling for turf use removed from arsenical herbicide labels, we anticipate a steady reduction in the use of arsenicals as existing stocks are phased out of the market.

4. The growth of pesticide alternatives such as biological controls a. Are biological controls making a significant contribution to pesticide control?

Biological controls are not registered by FDACS as pesticides, so BOP would not be able to assess their growth in use. It would be more appropriate for IFAS to address this. FDACS continues to receive requests for registration of biological pesticides (fungi, bacteria), but these do not fall under the veil of biological controls. http://www.epa.gov/opp00001/about/types.htm http://www.ehow.com/about_6580742_chemical-pesticides-fertilizers.html http://en.wikipedia.org/wiki/Biopesticide b. What barriers exist that prevent the widespread use and adoption of pesticide alternatives? See previous answer. c. What trends can we identify regarding the use of pesticide alternatives over time? See previous answer.

Data Analysis Needs 12