Illinois Pesticide Review
In This Issue
Illinois Pesticide-Misuse Case Summary for 2007
In December, I attended a meeting of the Interagency Committee on Pesticides at which a summary of pesticide-misuse cases for 2007 was presented. It was reported that the number of cases for the year was about average but a little higher than in recent years. Please note, this list is not all-inclusive, as it does not represent data from pesticide-containment violations, dealer violations associated with restricted-use pesticides, or general applicator license violations not associated with a complaint. All of the following 117 formal complaints were submitted to the department for evaluation and review. Sixty-four cases were closed with no determination of misuse. A warning letter or advisory letter was issued in 42 cases, and 25 cases have resulted in an administrative hearing and potential monetary penalty.
117 formal complaints received
61 ag cases
42 lawncare cases
14 other cases
64 cases closed (no misuse)
42 warning and advisory letters
21 ag, of which 18 involved drift
18 lawncare, of which 17 involved drift
25 administrative hearings
• 5—$750 fine—misuse
3 ag, of which 2 involved drift
2 lawncare, of which 1 involved drift
• 2—$1,000 fine—misuse
1 ag, involved drift
• 19—$500 fine—applicator license violation, as a result of the complaint
• 1—$100 fine—Lawncare Act violation, as a result of the complaint
ag complaints involving aerial applicators (These complaints are included above.)
11 cases, involving 9 incidents, with
3 involving beekeepers
• All involved potential drift.
• 10 cases closed with no evidence of misuse
• 1 applicator license violation
• 1 administrative hearing—$750 fine, drift involved
Chemical Security Regulation
The Department of Homeland Security (DHS), under the 2007 Chemical Facility Anti-Terrorism Standards (CFATS), is to identify, assess, and ensure effective security at high-risk chemical facilities. The goal is to make it less likely that terrorists can use dangerous chemicals in attacks. The DHS has published the list of regulated chemicals and their screening-threshold quantities in Appendix A of CFATS, DHS Chemicals of Interest. This list of approximately 300 chemicals was based on three chemical security issues: (1) release, (2) theft and diversion, and (3) sabotage and contamination. Any facility that possesses or plans to possess any of the chemicals listed in Appendix A at or above the screening-threshold quantity must register with DHS and complete an online assessment tool, known as a Top-Screen. From this initial assessment, the DHS will then determine whether the facility presents a high level of security risk and is to prepare a site security plan. Not all facilities that complete the Top Screen will be subject to further regulation by DHS. For more information about this new regulation and to view the list of regulated chemicals, go to the DHS Web site at www.dhs.gov/chemicalsecurity. Another good resource for information is www.EDEN.lsu.edu/Agrosecurity/DHSChemical.
Questions were raised about the applicability of the Top Screen requirement for agricultural facilities. As a result, the DHS has extended the deadline for submitting a Top Screen indefinitely and, until further notice, will not require a Top Screen assessment for agricultural operations involved in the preparation of treatment or application to crops, feed, land, livestock, or other areas of an agricultural production facility. This extension applies to farms; ranches and rangeland; poultry, dairy, and equine facilities; turfgrass growers; golf courses; nurseries; floricultural operations; and public and private parks. Please note that commercial chemical application services and a few others discussed below are NOT included in this extension. The DHS may review its approach toward Chemicals of Interest used in agricultural operations following the recent passage of the Appropriations Act of 2008, which authorizes DHS to regulate the sale and transfer of ammonium nitrate. The implication of this law will, undoubtedly, affect many farmers and other agricultural operations.
Other Agricultural Facilities
The extension mentioned for a Top Screen assessment given to farmers and other agricultural operations doesnâ€™t include the entire agricultural industry. Chemical manufacturers, chemical- distribution facilities, and commercial chemical-application services are still subject to all of the DHSâ€™s rule. For such facilities, the deadline to submit the Top Screen assessment was January 22, 2008, 60 days after Appendix A was published in the Federal Register. The biggest impact to agriculture will be propane and anhydrous ammonia, each with a screening-threshold quantity to be met by all co-ops. Business managers may call the DHS help desk at (866)323-2957 for information and assistance.
The pesticide products listed below (including CAS numbers) are included on the Chemicals of Interest list and are registered for use in Illinois, but only aluminum and magnesium phosphide (fumigants used in grain storage) may have any significance in Illinois agriculture. Please note that this list may be incomplete. Other listed pesticides (bromine, bromine chloride, ethylene oxide) are mostly used in other industries. On the other hand, several major crop-nutrient products are included (28% nitrogen, anhydrous ammonia, ammonium nitrate, potassium nitrate, sodium nitrate, etc.).
Aluminum Phosphide (20859-73-8)
Magnesium phosphide (12057-74-8)
Sodium chlorate (7775-09-9)
(Adapted by Michelle Wiesbrook from a press release written by Roger Flashinski, PAT Program University of Wisconsinâ€"Madison, January 2008.)
Pyraclostrobin Fungicide Poisoning Reported
The agricultural fungicide chemical pyraclostrobin is used to control fungal diseases, such as many of the blights, molds, mildews, and rusts on food crops and field corn. There is the risk of this fungicide causing skin irritation and eye injury, as well as other problems. In July 2007, the Iowa Department of Public Health reported 27 migrant workers injured by drift from an aerial application. Even though the pilot saw the workers in the neighboring field, he sprayed anyway. (The pilot soon lost his license.) Workers could feel the fungicide spray on their skin. Clothes, soil, plant material, and safety glasses were checked the next day: They all tested positive for the fungicide, even though there was a heavy rain during the night The most common complaint (26 of the 27 workers) was upper- respiratory injury or irritation. Twenty of the workers complained of chest pain. Other pesticide-exposure symptoms include redness of skin, nausea, eye pain, dizziness, and so on. All were "skin decontaminated" by a hazardous materials team and then taken to an emergency department until symptoms went away. In 2007, six other people reported being exposed to this fungicide and having a reaction to it. The symptoms ranged from slight to moderately severe. Other pesticides were used on the corn where the migrant workers were detasseling. However, more than 40 days had passed since they had been applied, thus these chemicals were not considered the cause of the poisoning.
Pyraclostrobin is cleared for use on food crops such as grapes, almonds, and tomatoes. Before 2006, there were twelve reported cases of poisoning of workers working in food crop pyraclostrobin-treated fields. The fields were in Michigan, California, Washington, and Florida. In all cases, no affected person required hospitalized. Pyraclostrobin is classed as a category 2 fungicide and carries the signal word of WARNING (LD50 between 50 and 500). First aid, if this fungicide has been swallowed, is to call a poison control center immediately and have the person drink a glass of water slowly. You are NOT to induce vomiting unless a doctor or poison control tells you to, and DO NOT give anything to a person who is unconscious. For skin and clothing contamination, treatment includes stripping off contaminated clothing and washing/rinsing skin immediately for 15 to 20 minutes; call a physician or a poison control center for additional treatment information. For inhalation, the affected person/people need to get into fresh air. If they have stopped breathing, call 911 or an ambulance and start artificial respiration (mouth-to-mouth, preferably).
Even though pyraclostrobin was approved for sale in 2002 for some crops, it was 2004 before it was approved for corn diseases. It was 2007 before there was widespread use of this fungicide on corn. The increased use of this fungicide, as well as the other related fungicides, can be attributed to several reasons—one being the increase of planted acres to corn for ethanol production.
These pesticide poisonings reinforce the need for staying in compliance with current regulations and pesticide label requirements—especially for aerial application of pesticides when workers are in nearby fields. It also shows the need to reduce pesticide drift and to consider worker risks and the benefits of the pesticide before using a pesticide.(Slightly modified by Jim Schuster from the article found in the Morbidity and Morality Weekly Report by the Center for Disease Control and Prevention; first-aid information was taken from the BASF specimen label for Headline fungicide.)
Carbofuran (Furadan) Uses Cancelled
Carbofuran is an N-methyl carbamate insecticide and nematicide registered to control pests in soil and on leaves in a variety of field, fruit, and vegetable crops. No residential uses are registered. In Illinois, carbofuran sold as Furadan has been used for corn rootworm control in field corn and as a dip for nursery stock. Its usage in these areas has greatly diminished in recent years.
As of January 2008, the Environmental Protection Agency (EPA) has determined that all products containing carbofuran generally cause unreasonable adverse effects on humans and the environment, and are ineligible for reregistration.
In August 2006, EPA issued an Interim Reregistration Elegibility Decision (IRED) document <http://www.epa.gov/pesticides/reregistration/REDs/carbofuran_ired.pdf>, in which it announced its determination that all products containing carbofuran are not eligible for reregistration. This decision was based on public input and scientific review under the agency's full public-participation process for pesticides undergoing reregistration. Since that determination, the registrant submitted a number of studies and other documents to the agency for review.
EPA has reviewed all submitted data, as well as additional data developed by the EPA Office of Research and Development, and continues to believe that carbofuran registrations do not meet the risk/benefit standard of the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) and that the tolerances do not meet the safety standard of the Federal Food, Drug and Cosmetic Act (FFDCA). However, the agency has concluded that a transition period for certain uses and retention of certain import tolerances are justified, provided all other uses are canceled, voluntarily or otherwise, and all other tolerances are revoked.
EPA has developed a draft Notice of Intent to Cancel (NOIC) All Carbofuran Registrations, consistent with FIFRA.
The public docket (EPA-HQ-OPP-2007-1088) <http://www.regulations.gov/fdmspublic/component/main?main=DocketDetail&d=EPA-HQ-OPP-2007-1088> opened January 8, 2008. The SAP meeting, which is open to the public, is scheduled to occur February 5 to 8, 2008, at an EPA Office of Pesticide Programs conference room at One Potomac Yard in Arlington, Virginia. Details about the meeting, including how and when to submit oral and written comments are provided in the agency's November 20, 2007, Federal Register notice <http://www.epa.gov/fedrgstr/EPA-PEST/2007/November/Day-20/p22612.htm> that announced the meeting.
EPA concluded that current uses of carbofuran present significant risks to workers and wildlife that are not outweighed by the benefits associated with these uses. In addition, the agency determined that carbofuran presents human dietary exposures that are not considered safe. EPA proposed immediate cancellation of most uses, a four-year transition period for six crops that have moderate benefits to growers, and retention of tolerances for four imported commodities because associated dietary risk is low.
Since EPA issued the Carbofuran IRED, the registrant has submitted studies for agency review addressing ecological and human dietary risk, as well as other informational documents, including a model to predict the probability that carbofuran uses would cause mortality in birds. Also, EPA's Office of Research and Development has developed additional carbofuran data. The new test data include
• Comparative cholinesterase-inhibition data in juvenile and adult rats
• Dermal toxicity in adult rats
• Brain acetylcholinesterase inhibition and recovery in birds
• The effect of food-matrix on carbofuran toxicity in birds
• The effects of carbofuran on food intake in birds
Additionally, the registrant submitted information on the benefits of carbofuran use for corn, melons, potatoes, and sunflowers.
These submissions have resulted in certain refinements to EPA's assessment but do not result in changes to the conclusion that all uses of carbofuran should be canceled.
Carbofuran poses a significant hazard to exposed persons resulting from its toxicity following acute exposure. Because carbofuran is extremely toxic, exposure to even small amounts of it creates a substantial risk to human health.
Acute dietary risk from food alone is of concern for all population subgroups, especially for children age 1 to 2 years old. Exposure through drinking water adds to the risk for consumers of water from specific, vulnerable sources, such as shallow wells associated with specific soil types and carbofuran-use patterns.
Occupational risks are of concern even with existing stringent safety restrictions. EPA's risk concerns are supported by data from human poisoning incidents associated with occupational exposure from carbofuran use.
Carbofuran also presents risks of concern to terrestrial and aquatic nontarget species, especially birds. It poses a risk of bird death from acute poisoning, as well as significant concerns for the survival of many bird species.
After considering four groups of use sites and registrant-submitted data for several sites, EPA has concluded that most carbofuran uses provide minimal, if any, benefits either to the individual grower or at a national level.
Benefits were determined to be low for most uses: alfalfa, bananas and plantains, chili peppers, coffee, corn (field and sweet), cotton, cucurbits (cucumbers, pumpkins, squash, and melons), flax, grapes, ornamentals, potato, small grains (barley, oats, and wheat), sorghum, soybeans, sugarcane, sugarbeets, and tobacco. A few uses result in moderate benefits: artichokes, pine seedlings in the southeastern United States only, spinach grown for seed (granular formulation only), and sunflowers.
Because carbofuran poses significant dietary risks, especially to children, EPA is revoking carbofuran's existing tolerances and cancelling the associated food uses.
EPA proposes to allow existing stocks of the following carbofuran uses to continue for 3 years because these uses provide moderate benefits for growers, sufficient pest-control alternatives are not available, and the geographic scope of these uses is small:
• Pine seedlings in the southeastern United States
• Spinach grown for seed (granular formulation only)
All other carbofuran uses will be terminated when the cancellation order becomes effective.
EPA also proposes to retain tolerances for the following imported commodities because the associated dietary risk is acceptable:
Additional information can be obtained at http://www.epa.gov/pesticides/reregistration/carbofuran/carbofuran_noic.htm.
(Modified from a USEPA notice, Phil Nixon.)
Training Themselves: The PAASS Program
Education and training is an important component for most industries and groups that apply pesticides. Pesticide applicators in most states take some type of training either to assist with passing an examination or as part of a CEU program. These training programs are often developed and offered by Extension or other governmental agencies. Aerial applicators, however, are fairly unusual in that they spend a great deal of time and effort to develop their own training programs specifically tailored to their business. The aerial applicators training program is developed with the guidance of aerial applicators and is taught by the aerial applicators. Extension educators and government regulatory personnel help develop the programs, but the direction and content is determined by aerial applicators. This educational program is called PAASS, which stands for Professional Aerial Applicator Support System.
The PAASS program is managed by the National Agricultural Aviation Research and Education Foundation (NAAREF), a non-profit organization associated with the National Agricultural Aviation Association (NAAA), and was created to promote and advance research and education opportunities for aerial applicators. NAAREF determines policies for PAASS, establishes the direction of the training, coordinates committee activity related to the two programs, and handles all financial matters related to developing and offering PAASS. The PAASS program development committee, under the guidance of NAAREF, is responsible for determining the priorities for PAASS, recommending and developing the topics to be addressed, and developing program content. Members of the PAASS program development committee include aerial applicators and representatives from the government and industries allied with aerial application. The PAASS capital campaign committee is charged with securing funding to support the PAASS program.
NAAREF is also responsible for managing Compaass Rose, which will be discussed later in this article, and Operation S.A.F.E., which stands for Self-regulating Application and Flight Efficiency. The S.A.F.E. program is designed to offer aerial applicators an opportunity for a professional analysis of their aircraft's spray pattern and spray-droplet size at fly-in clinics. For more information about S.A.F.E., see Illinois Pesticide Review, vol. 17, no. 3 (May 2004); vol. 18, no. 3 (May 2005); vol. 19, no. 3 (May 2006); and vol. 20, no. 3 (May 2007).
PAASS was started in 1996 with the goal of reducing the number of agricultural aviation accidents and drift incidents associated with the application of pesticides and fertilizers by air. By providing advanced educational programs specifically created for aerial applicators, it was felt positive change could be brought about through self-education, as opposed to increased government regulation. The concept is to prevent accidents and drift problems before they occur (rather than wait for regulatory agencies to respond to problems after they have occurred by passing stricter regulations).
PAASS programs are held annually across the nation at state and regional aerial application association annual meetings and conventions. The program consists of PowerPoint presentations, videos, and group discussions involving the presenters and the audience. Many good pieces of advice are often given by members of the audience, so even the instructors learn something new at most programs. They can in turn pass this advice on to other audiences in later programs. The PAASS program is highly regarded and supported by insurance underwriters, pesticide manufacturers, governmental agencies (including the EPA and FAA), and various national agricultural associations. Many state departments of agriculture that use a CEU-based system for maintaining a pesticide applicator's license give CEU credit for PAASS.
A PAASS training session has four modules. The spray-drift module focuses on reducing the risk of spray drift. There are many tools and techniques available to aerial applicators that can dramatically reduce their risk of drift, and this module was created to help them set up and operate their aircraft. This season's program discussed the general process of how a drift complaint is investigated and resolved. By understanding the process and procedures followed by state pesticide-regulatory agencies in response to a drift complaint, aerial applicators are better suited to assist regulators in the investigation, creating a more cooperative relationship. The module last season dealt with understanding and following drift-reduction statements on pesticide labels. Pesticide labels can often be confusing and in some cases wrong, and it is critical that aerial applicators understand the statements and know how to set up and operate their aircraft in compliance with the label. Other topics covered in recent seasons were nozzle setup and how that affects spray-droplet size and thus the risk of drift, and spray-system maintenance needed to avoid misapplications.
A second module for PAASS, the human-factors module, focuses on accident avoidance. It is called human factors because it specifically targets the pilot in terms of the critical-thinking and the decision-making process required to avoid conditions and situations that dramatically increase the risk of an accident. The human-factors module is also correlated with drift mitigation because critical thinking also improves application accuracy and reduces the risk of drift. Recent topics in this module have included terrain and wire avoidance, avoiding situations that increase stress and fatigue and thus increase the risk of an accident, and the importance of good communication and procedures related to aircraft maintenance.
The two additional PAASS modules are airfield watch and hanger ag flying. Airfield watch focuses on security issues regarding the aircraft, equipment, and agricultural chemicals. The hangar ag flying section deals with the lessons to be learned from recent aerial application accidents, as well as any other current topics that needed to be addressed.
PAASS is taught by a group of presenters, all of whom are aerial applicators. This approach is important to the audience because the advice, instructions, recommendations, and explanations are coming from peers who also understand the nature of the aerial-application business, not an Extension or other government educator who, despite good intentions, might not relate as well to the audience and thus have diminished credibility. Special train-the-trainer seminars are held annually for the presenters for them to master the materials they will be teaching each season. Train-the-trainer sessions are usually taught by the subject-matter experts who developed the program content. PAASS presenters are selected by NAAREF and undergo a trial period in which they teach alongside more seasoned veteran instructors. Once they have gained suitable experience and proven themselves capable, they are officially approved as PAASS presenters by NAAREF.
The Compaass Rose program was a creation that developed directly from the PAASS program and was started when PAASS presenters realized that new ag pilots were hesitant to ask basic questions or comment in front of the more experienced pilots. Compaass Rose is intended to be an open forum where all aspects of agricultural aviation can be discussed. Compaass Rose offers new pilots just getting started in the agricultural aviation industry an opportunity to learn from more experienced pilots. The idea was to allow the veteran aerial applicators a chance to pass on knowledge so that new pilots might avoid the making the same mistakes they did. Of course, the nature of the format also means experienced pilots are also passing on knowledge to each other and thus continually expanding everyone's pool of knowledge. The name of the program stems from a compass rose, the object on a map that provides directional information. The intent of the Compaass Rose program is to provide directional information to those entering the field of aerial application.
As someone whose job it is to educate pesticide applicators about the proper selection, setup, and operation of all types of application equipment, I find most interesting about the PAASS program the self-driven desire to learn and the forward-thinking approach. Instead of taking training mandated by regulations and offered by someone else, training is being instituted within the industry on a voluntary basis to prevent additional regulations. I believe this approach to education would benefit everyone interested in the safe and effective application of pesticides.
FRAC–What Is It?
During the agricultural Pesticide Safety Education Programs in December 2007, I talked about the importance of changing/rotating fungicides between the FRAC groups when treating a crop to avoid fungi resistance to the pesticide. I was often asked what FRAC was. FRAC stands for Fungicide Resistance Action Committee. FRAC is a Specialist Technical Group of CropLife International. CropLife International used to be called Global Crop Protection Federation (GCPF). It is made up of international companies. Their purpose is to provide fungicide-resistance-management guidelines to prolong the effectiveness of "at risk" fungicides and to limit crop losses should resistance occur.
In 1980, a seminar on fungicide resistance drew international scientists together. In 1981, at another industry fungicide seminar in Brussels, 68 scientists and marketing managers representing 35 agrochemical companies from around the world realized the urgent need for collaboration on fungicide resistance, and FRAC was formed. FRAC was incorporated within the International Group of National Associations of Manufacturers of Agrochemical Products. This group later became Global Crop Protection Federation. Starting in 2000, GCPF started evolving into the current global federation, CropLife International, which still contains the FRAC committee.
FRAC tries to identify existing as well as possible resistance problems, to collate information and distribute it to fungicide researchers and to people involved with fungicide distribution and registration of the fungicides, as well as users of the fungicides. FRAC also provides advice and guidelines to reduce fungicide-resistance risks and how to manage it should it occur. FRAC provides recommended procedures for use in fungicide-resistance studies. FRAC encourages collaboration between universities, government agencies, Extension personnel, distributors, and farmers.
Because fungicides are a valuable tool for raising food crops (the American Phytopathological Society estimates a 10% crop loss with fungicides and the Western Farm Press says that fruit and vegetable yields would decline by 50 to 95% without any fungicide applications), it is important to reduce fungicide-resistance risks as much as possible. One of the ways to do this is to rotate fungicides between the FRAC groups (different modes of action that help control the fungi).
Many people do not realize that there is a difference between a fungicide and a fungistat. A fungicide kills the fungus, while a fungistat interferes with the life cycle of the fungus. Both of these groups tend to get lumped together as fungicides. As the "newer" fungicides are more site specific in their control, the concern about resistance grows. Experience has shown that fungi are able to develop resistance more easily to these pesticides.
(Modified from the history and purpose of FRAC by Jim Schuster; FRAC's Web site is http://www.frac.info/frac/index.htm.)