Illinois Pesticide Review
January / February 2011
In This Issue
- Consider Getting an NPDES Permit Before You Spray
- Independent Study Shows Soybean Seed Treatments Increase Yields and Profits
- Nursery Dealer Certification
- IDOA Establishes Driftwatch™ Website
- DDT Controversy Renewed
- Pesticide Applicators – Provide your opinions to pesticide manufacturers and EPA.
- Illinois 'Phosphorus Law' Now in Effect: Recommendations for Turf Management
Consider Getting an NPDES Permit Before You Spray
If you've attended one of our training clinics this winter or if you've been a regular reader of this newsletter, you know that NPDES (National Pollutant Discharge Elimination System) permits will soon be required in order to apply pesticides in many instances involving water sources.
If you are new to this challenging topic, we'll try to simplify this evolving issue here. For reference, you can check out our past articles in the May/June 2010 and July/August 2009 issues. We apologize if the topic is somewhat confusing. Hopefully, when the final state regulations are released near or around April 9, everything will be a little clearer. We hope.
The Illinois Environmental Protection Agency (IL-EPA) is set to publish rules and establish permits related to the Clean Water Act (CWA) and the use of pesticides in, on or near water sources. An initial general draft permit was published in late December 2010, and an open comment period was held over the holidays. Various state agencies and agricultural groups submitted concerns and suggestions; the University of Illinois Pesticide Safety Education Program provided thoughts as well.
It is anticipated that IL-EPA will finalize their general permit sometime in March after the USEPA publishes their final permit for the states to model theirs after. Permits will be required beginning April 9, 2011. IL-EPA did not ask for this new task. The intention of requiring permits is to protect water quality per court action and interpretations of the Clean Water Act.
Those pesticide applicators who aren't properly covered by a permit could be found in violation of the Clean Water Act. NPDES permits are required for any discharge to waters of the State from any biological or chemical application that leaves a residue when the pesticide is applied.
Specific pesticide applications that will be affected include the following:
• mosquito and other insect control
• weed and algae control
• aquatic nuisance animal control
• forested areas pest control
• other pesticide uses
This last category – Other Pesticide Uses – is meant to offer protection to those applicators, who wish to be covered by a permit due to the possibility of an overspray ending up in a body of water and thus a potential violation of the Clean Water Act. Examples include controlling weeds, insects or diseases on turf, in an ag field, or related area.
The method of application can vary as well, so the possibilities of geographic areas and types of applications are seemingly endless. If your application doesn't directly fall into one of the other four categories, it may fall into this one. With that said, some stakeholders suggested that IL-EPA omit this category.
This new requirement will affect anyone who applies pesticides in, on or near water. You can avoid having to have a permit by simply keeping your spray away from surface water. However, it is important to note the following:
• Dry ditches are included
• Off-target spray drift, agricultural storm water run-off, and irrigation return flow are exempt from the statutes
• The focus of the CWA is surface water, not ground water
Current proposals call for anyone applying a pesticide, whether commercial or private, to file a Notification of Intent (NOI) that pesticides will be applied to the waters of the State and obtain a permit from the IL-EPA.
The definition of "waters of the State" is one of the terms that will be defined more exactly with the final draft, but the term currently applies to any private or public waters within the state's boundaries that move, which includes lakes, streams, rivers, ditches and ponds with overflows. Backyard home ponds and swimming pools are exempt in the current proposal.
Permits may be obtained by either the landowner or the applicator. An additional requirement is that permittees receive confirmation from the IL Dept. of Natural Resources that no endangered species will be adversely affected.
Currently, a permit may last for 5 years with permittees billed annually by IL-EPA. The IL-EPA will be setting thresholds for pesticide applications whether directly applying on the water or near it. ("Near" is also a term that will hopefully be defined in greater detail.)
Applications over the established thresholds could require additional paperwork on your part:
• Best Management Plans (BMP)
• IPM plans
• Discharge plans
• Annual reports to IL-EPA documenting pesticide treatment areas.
Permits will be more expensive for those who exceed thresholds. Naturally, it is recommended that you stay below these thresholds if at all possible so that the process is simpler. Alternatively, you may choose to "estimate big" when filling out your NOI, so you are fully covered.
Keep in mind that your applications for the year will be cumulative. For example, if you apply a pesticide on or in a 50-acre pond three times, the total area is now 150 acres. Five applications to 5 miles of shoreline is now a total of 25 miles. Twenty-five miles may exceed the set threshold which would require the additional paperwork.
The purpose of the application such as mosquito control versus agriculture application will also come into play. It is anticipated a tier structure will be created, so some permit holders will be exempt from certain reporting requirements and large fees. This will be created in response to the large number of comments EPA received.
Regardless of thresholds, the following is required of all permittees. Many of these aren't new to most pesticide applicators, as the IL Department of Agriculture requires some of these based on FIFRA:
• Visual monitoring for adverse effects during application and during any post application surveillance
• Monitoring of best management practices to ensure compliance with effluent limits
• Maintaining records including agency correspondence
THINGS TO NOTE: The lead agency is the IL-EPA and not the IL Department of Agriculture. The IL-EPA permit is in addition to the pesticide licensing required by the IL Department of Agriculture. Technically, NPDES requirements will apply to private or commercial applicators on public or private lands.
Stay tuned! We will post further developments to our website: www.Pesticidesafety.uiuc.edu.
For more information:
• USEPA -
• Illinois EPA
General NPDES Permit for Pesticide Application Point Source Discharges
• Division of Water Pollution Control
Attn: Permit Section
P.O. Box 19276
Springfield, Illinois 62794-9276
Independent Study Shows Soybean Seed Treatments Increase Yields and Profits
An independent study shows that soybean seed treatments improve the average yield by 3.5 bushels per acre versus untreated seed. This study was run by Direct Enterprises Inc., an independent provider of agricultural products and services.
Test plots compared insecticide and fungicide soybean seed treatments across 10 Midwestern states. The top two seed treatments averaged 59.3 bushels per acre and 58.6 bushel per acre versus the untreated test average of 53.3 bushels per acre.
This independent study was run at 35 sites throughout Illinois, Indiana, Iowa, Michigan, Minnesota, Missouri, Nebraska, Ohio, South Dakota, and Wisconsin.
The same variety was used within each maturity group to increase statistical accuracy. Three randomized testings were run in three separate randomized replications. A third party did the planting, spraying, and harvesting of the test plots. The manufacturer's application rates were used on the soybean seeds. The testing showed seed treatments can provide value.
For a copy of the complete report, call Direct Enterprises at 1-888-895-7333.
(Submitted by James E Schuster, Extension Specialist, PSEP – Plant Pathology. Summarized from an article in AG Professional Weekly - Monday, Jan. 17, 2011).
Nursery Dealer Certification
If you are a nursery dealer in Illinois, you must hold a Nursery Dealer Certification from the Illinois Department of Agriculture.
This regulation has been in effect since 1928, says Nanette Kalscheur, an Illinois Department of Agriculture Plant Inspector. It is intended to certify people who are dealing in nursery stock, other than the growers.
Back in 1928 there were few landscaping companies. Plant material was bought from the local nursery and the nursery usually planted what was purchased. Today, however, nursery stock comes from all over the United States and sometimes from other areas in the world.
According to Kalscheur "there are numerous landscapers in every town who are buying and transporting stock everywhere that the Department of Agriculture is unaware of. One can easily see how we wind up with so many destructive insect pests and infectious diseases."
Kalscheur recently sent a letter to the unlicensed landscapers at the nurseries that she inspects in DuPage County only. The first paragraph read as follows: "Your company may be unaware of Section Seven of the Illinois Insect Pest and Plant Disease Act (ILCS505, Act 90, Sections 90/1 et seq.), which requires anyone who sells or offers for sale, delivers and/or installs any nursery stock to hold a Nursery Dealer's Certificate, which is renewed annually. This requirement includes landscape companies whose services include the delivery and/or installation/planting of any type of nursery stock."
PLEASE NOTE: You may not have received a letter from IDA, but you still may need to be certified. Only landscapers in DuPage County received the letter from Kalscheur.
If you are an unlicensed nursery dealer, you can download the Nursery Dealer Certificate application form at http://www.agr.state.il.us/pdf/nurserydealerregistration.pdf or an application form can be requested by calling the Illinois Department of Agriculture at 815-787-5476 or 217-785-2427.
(Submitted by James E Schuster, Extension Specialist PSEP – Plant Pathology).
IDOA Establishes Driftwatch™ Website
New, web-based program to enhance communication between pesticide applicators and specialty growers.
The Illinois Department of Agriculture (IDOA) has introduced a new, webbased tool that aims to protect pesticide-sensitive crops by improving communication between growers and commercial pesticide applicators.
Driftwatch™ is an online program that allows organic and specialty growers to enter the location of their fields on an Internet map that pesticide applicators can consult to avoid spraying sensitive crops.
Every time a new field is added, the program sends an e-mail alert to applicators who have registered to use the site.
"Our objective is to raise awareness about Illinois' specialty crop production and reduce the potential for pesticide drift, or the accidental application of farm chemicals to unintended areas, especially those that are susceptible to damage," Warren Goetsch, IDOA Bureau Chief of Environmental Programs, said.
"It's going to take shared responsibility for that to happen, though. Growers must make certain they not only enter the locations of their fields, but also enter them accurately, and pesticide applicators must make a commitment to check the site before they spray."
Purdue University originally developed Driftwatch™ for the state of Indiana. The program was adapted for use in Illinois with funding from the U.S. EPA. Michigan, Minnesota and Wisconsin also are implementing Driftwatch™ this year, while Ohio is planning to implement it in 2012.
"The Illinois Senate Ag Committee, during a special hearing on pesticides in 2009, asked the ag industry to work together so that modern grain production and specialty agriculture can both thrive here," Jean Payne, President of the Illinois Fertilizer and Chemical Association, said.
"We believe Driftwatch™ provides a technology-based bridge to enhance communication and encourage additional drift mitigation efforts for everyone involved in production agriculture and we will teach our members how to use this program this week at our convention in Peoria."
The department plans to promote the site during its annual pesticide training and testing clinics for commercial and private applicators.
Driftwatch™ is free of charge to its users and can be located by visiting the Illinois Department of Agriculture's website at www.agr.state.il.us and clicking on the Driftwatch™ link on the right side of the homepage.(Press release from the Illinois Department of Agriculture, Jan. 20, 2011. Available at http://www.illinois.gov/PressReleases/ShowPressRelease.cfm?SubjectID=15&RecNum=9170).
DDT Controversy Renewed
The new Stockholm Convention on Persistent Organic Pollutants treaty developed in mid-October 2010 and currently being presented to Congress for ratification by President Obama caused a renewal of the controversy over the use of DDT.
In 2005, this treaty included the eventual elimination of the use of DDT to control malaria-carrying mosquitoes as alternative insecticides become available. Although there are alternative insecticides available, they are much more expensive than DDT.
Although some countries with malaria problems have switched to alternatives such as pyrethroid insecticides, many countries report that the lower cost of DDT allows them to provide protection from malaria to more of their people.
Most uses of DDT were banned in the US in 1972 by the U.S. Environmental Protection Agency (which was established in 1970) due to environmental concerns. The book "Silent Spring" by Rachel Carson did much to alert the U.S. public to the effects of this insecticide on birds and to generally raise environmental awareness.
DDT use is generally credited as having a major role in almost eliminating malaria in the U.S. by controlling malaria-carrying mosquitoes. Other important activities that were instituted or increased at the same time were major water drainage programs, stocking fish that fed on mosquito larvae, mosquito larval control with oil-based products, development and use of mosquito repellents, and major public education campaigns.
Malaria is still a major killer in the world, particularly of children. The World Health Organization's World Malaria Report 2009 and the Global Malaria Action Plan report that:
• 3.3 billion people (half the world's population) live in areas at risk of malaria transmission in 109 countries and territories.
• 35 countries (30 in sub-Saharan Africa and 5 in Asia) account for 98% of global malaria deaths.
• In 2008, malaria caused an estimated 190 - 311 million clinical episodes, and 708,000 - 1,003,000 deaths.
• 89% of the malaria deaths worldwide occur in Africa.
• Malaria is the 5th cause of death from infectious diseases worldwide (after respiratory infections, HIV/AIDS, diarrheal diseases, and tuberculosis) in low-income countries.
• Malaria is the 2nd leading cause of death from infectious diseases in Africa, after HIV/AIDS.
Although DDT was sprayed over large areas of the U.S. to control adult mosquitoes, DDT is currently used more selectively to control mosquitoes in foreign countries as a spray on building walls and treatment of mosquito nets draped over beds at night to protect people while they sleep.
Both public health and environmental groups generally view this use as a reasonable and effective compromise. In recent years, however, some foundations and other non-governmental organizations that provide financial assistance to Third World countries for malaria control have denied or restricted funds for the use of DDT.
The American Council on Science and Health (ACSH) and other organizations have recently distributed materials discounting the original banning of DDT in the U.S. The following is an excerpt from the ASCH website.
The American Council on Science and Health (ACSH) is a consumer education consortium concerned with issues related to food, nutrition, chemicals, pharmaceuticals, lifestyle, the environment and health.
ACSH is an independent, nonprofit, tax-exempt organization, whose nucleus is a board of 350 physicians, scientists and policy advisors– experts in a wide variety of fields–who review the Council's reports and participate in ACSH seminars, press conferences, media communications, and other educational activities.
ACSH was founded in 1978 by a group of scientists who had become concerned that many important public policies related to health and the environment did not have a sound scientific basis. These scientists created the organization to add reason and balance to debates about public health issues and bring common sense views to the public.
On November 11, 2010, ACSH distributed its email newsletter, the ACSH Dispatch, reporting on comments made by Richard Nehabi Kamwi, Minister of Health and Social Services, Namibia, in an article in The Wall Street Journal Europe.
He stated that when it comes to using DDT for malaria control, his country and others still face pressure from anti-insecticide activists and restrictions from athe Stockholm Convention.
The newsletter states that DDT is safe for humans and the environment and that thousands of scientific studies have investigated potential harm to human health from DDT. The newsletter states that almost all these studies are weak, inconclusive or contradictory.
The following are excerpts from a follow-up article in the November 16, 2010, issue of the ACSH Dispatch. It states that "DDT was banned in the United States since 1972 as part of a worldwide campaign against the pesticide—a crusade that has perversely (and we presume unintentionally) been responsible for the loss of millions of African children from preventable malaria deaths. But the "excellent powder" is now being blamed for thinning condor eggs in California—well, one or two eggs, anyway."
The newsletter continues, "[W]riting in The New York Times, John Moir reports that biologists with the Ventana Wildlife Society suspect a handful of breeding pairs in Big Sur have been eating dead sea lions contaminated by the pesticide. There's no known source of DDT near Big Sur, but the biologists speculate the sea lions could have been contaminated from ocean deposits off the coast of Los Angeles, where Montrose Chemical Corp. released tons of DDT into the sewer system in the 1950s and '60s."
The newsletter continues: "'A nonsensical screed,' says ACSH's Dr. Josh Bloom. "DDT is essentially non-toxic. In fact, it takes about four times as much DDT as caffeine to cause fatalities in rodents. Hardly the deadly poison that this article portrays it as."
Dr. Gilbert Ross, an ACSH scientist, says "studies purporting to show that DDT thins birds' eggshells were flawed; those birds were deficient in calcium, and when fed a proper diet, laid solid eggs. 'It's just another piece of anti-DDT propaganda — but it's in The New York Times,' he fumes." Additional information can be found at the ACSH website at http://www.acsh.org/
The other side of the story can be found on other web sites. A direct response can be found at http://info-pollution.com/ddtban.htm and supporting information is available in references cited at the end of that web page. The following is in one of the references.
Reductions in the use of DDT did occur in a number of developing nations after the US ban in 1972. This reflected concerns over environmental consequences of DDT, but was also a result of many other factors. One of the important factors in declining use of DDT was decreasing effectiveness and greater costs because of the development of resistance in mosquitoes.
Resistance was largely caused by the indiscriminate, widespread use of DDT to control agricultural pests in the tropics. This problem, in fact, was anticipated by Rachel Carson: "No responsible person contends that insect-borne disease should be ignored . . . The question that has now urgently presented itself is whether it is wise or responsible to attack the problem by methods that are rapidly making it worse."
There is very little research on the effects of DDT on eggshell thinning on birds since the 1960s. A research study on Japanese quail in 1969 showed a reduction in eggshell thickness with exposure to DDT, but the research was discounted because the birds had been fed a calcium-poor diet. Subsequent research with quail and chickens showed no effect of DDT on eggshell thinning.
Additional research has shown that DDT does not cause eggshell thinning in herring gulls, passerine birds (perching birds), and gallinaceous birds (chickens, quail, and pheasants). However, there are several studies that show that DDE, a natural metabolite of DDT, causes eggshell thinning in raptors, such as hawks, eagles, and falcons.
In 1998, Royal Society for the Protection of Birds researcher Rhys Green published a study in the Proceedings of the Royal Society B, which found that eggshell thinning of some bird species had begun 50 years before the introduction of DDT. More information is available on the International Programme on Chemical Safety web site at http://inchem.org/
Research studies on natural metabolites of DDT in recent years have shown evidence of endocrine disruption in mammals. This continues to be studied with additional research and evaluated by the EPA committee on endocrine disruptors. The initial elimination of most uses of DDT in the US was based primarily on environmental effects rather than effects on humans and other mammals.
Whether or not DDT is as serious of a problem to the environment as originally thought, some factors remain. The US public's opinion against DDT, whether correct or not, is strong enough that a return of DDT in major areas of pest management in the US is unlikely.
Many of the insects that were effectively controlled by DDT developed resistance to that insecticide before most uses were banned. The resistance today by bed bugs to pyrethroid insecticides is thought to be cross-resistance from resistance developed by that insect to DDT in the 1960s. There is the supposition that the continued use of DDT in other parts of the world since 1972 has helped increase and/or maintain that resistance.
The brown pelican and several raptors, including the bald eagle, peregrine falcon, and osprey, have rebounded in numbers in the years since 1972 when most uses of DDT were eliminated. Whether these increases in population are due to the reduction of DDT in the environment or not are probably unable to be proven.
In general, these birds have experienced a decrease in the amount of suitable environments in which to live and thrive, which should have reduced their numbers if everything else was the same. However, peregrine falcons have successfully been introduced into major cities where they nest on tall buildings.
The Clean Water Act, other environmental legislation, and a change in the public's attitude towards water pollution have resulted in cleaner water that have likely reduced other pollutants in the fish that bald eagles, ospreys, and brown pelicans feed upon.
(Submitted by Phil Nixon).
Pesticide Applicators – Provide your opinions to pesticide manufacturers and EPA.
Streamlined web-distributed pesticide labeling (WDL) is a concept being considered, on a national basis, for implementation in the future. The concept is this: pesticide manufacturers could choose to deliver simplified labels to pesticide applicators in agriculture, professional turf and landscapes, and rights-of-ways. With WDL, container labels would include basic ingredient and safety information. Instead of having a long list of use directions, the label would include an Internet address (to download just your use directions) and toll-free number (if you prefer to obtain labeling via US mail or fax). Applicators choosing to use the Internet, would simply search for their state and crop/use site using drop-down menus. The website would compile a legally-valid label for that crop/use site in your state that you could then save or print. Sixty-page labels in current form might be as short as six pages in WDL form, thus making labeling more user-friendly.
1. Shorter, crop-specific labels
2. Label revisions with new uses/protections would be available faster
1. Issues with Internet access or toll-free access for applicators
2. Demand on dealers to provide applicators with web-distributed labeling
Applicators, now is the time to share your thoughts on this concept. Consider going to the pilot website (http://wdl.greenbook.net) and searching for either Roundup (EPA Reg. # 524-537) or Headline (EPA Reg. # 7969-186). Test-drive the label search function and compare streamlined labels to full labels. There is a short, anonymous survey on the website to capture your initial reactions regarding how you would access the information (Internet vs. toll-free number) and whether the shorter labels are an improvement over the current label.
In addition, according to the Federal Register, Vol. 75, number 249, 12/29/10, EPA is seeking comments on WDL with a formal comment period which will end on March 29, 2011. This is separate from the above mentioned survey. For more information on how to submit comments, please refer to the Federal Register notice at http://edocket.access.gpo.gov/2010/2010-32036.htm.
EPA believes that "more concise labeling should increase users' comprehension and compliance with pesticide labeling, thereby improving protection of human health and the environment from risks associated with improper pesticide use." These changes, however, would come with a learning curve. What is convenient for some may not be convenient for others. WDL could change the way you shop for a pesticide. Planning ahead will certainly be required so that time is allowed to obtain the necessary labeling before mixing can occur. When forming your comments and suggestions to EPA, please consider how and when you use a pesticide label and think about how WDL would impact those use practices. Your input will help pesticide manufacturers and EPA make an informed decision about whether to move forward with web-distributed labeling. Ultimately, your actions will help shape your industry.
Written by Carol Ramsay, Extension Pesticide Education Specialist, Washington State University and adapted by Michelle Wiesbrook.
Illinois 'Phosphorus Law' Now in Effect: Recommendations for Turf Management
The Illinois Legislature has passed a bill, Public Act 096-1005 (HB 6099) that restricts any applicator for hire from applying phosphorus-containing fertilizers to a lawn unless a recently conducted soil test indicates a phosphorus (P) deficiency.
In order to make this legislation effective, Illinois must have standards for P fertilization of lawn turfs. This article will describe those standards and provide some background information on P requirements of turfs.
Turfgrasses grown for lawns do not require significant amounts of P. Phosphorus is critical for seed production and for seed establishment, but lawns are managed for vegetative growth and regular mowing discourages seed production. Phosphorus deficiencies in established home lawns are extremely rare; I have never observed a laboratory-confirmed P deficiency in a home lawn or commercial turf site.
I have observed, however, P deficiencies that were induced by growing turf in pure sand and withholding P fertilization. Under these conditions, P deficiencies developed, but only at very low levels of P as determined by soil testing.
Tables 1 and 2 outline the P soil test levels that are deemed deficient, as well as guidelines for fertilization amounts for established turfs and for new seedings. If a deficiency situation is encountered, a corrective application of P fertilizer should be made using the guidelines shown for established turf (Table 1) or for turf establishment (Table 2).
Additional, future P applications must be based upon additional soil test measurements. Once soil test levels are sufficient, i.e. above 15 PPM (parts per million) or 30 lbs./A, no further P should be applied to the site. Soil testing should be conducted every 3-5 years to monitor P levels in healthy turfs.
Clipping removal will affect P soil test values, but research has shown that removal of clippings will reduce soil test values by very small amounts, 1-2 PPM per year. Further, clipping removal is a poor management practice, and all homeowners and commercial mowing firms should return clippings with each mowing to ensure that nutrients, including P, are being returned to the soil.
Exceptions are made when mowing has been delayed due to rain or excessive spring growth, which may cause clippings to accumulate on the turf surface. Under these conditions, clipping removal may be justified.
The Illinois Phosphorus Recommendations are displayed below. Phosphorus soil test values have traditionally been presented as lbs. P2O5/A, but to present the data in this way, an assumption is made that an acre of soil to a depth of 6" weighs 2 million pounds. Data presented as PPM carry no assumptions and are more accurate. Values listed as lbs P2O5/A are for historical purposes only.
Grass species vary significantly in their response to P fertilization during establishment. Kentucky bluegrass, the most widely used turfgrass in Illinois, is very responsive to P fertilization. Other species such as perennial ryegrass or tall fescue are less responsive to P fertilization at establishment. Thus, it is difficult to establish a single soil test level where all turfgrass species would not require any supplemental P fertilization at establishment, and therefore, P is always recommended when establishing a new turf.
While an upper soil test limit for P fertilization is desirable, the research to define this limit has not been done. A lack of available P can slow the establishment rate, which can lead to soil erosion during establishment. Phosphorus losses from sediment erosion would be much higher than any potential P loss in runoff from an established turf.
(Bruce Branham, Professor, Department of Crop Sciences, University of Illinois).
Table 1. Phosphorus deficiency levels for established Illinois turfs
Phosphorus Bray P1 Soil Test Level†
Phosphorus Bray P1 Soil Test Level†
Recommended P Fertilization Levels
† Many soil testing laboratories are utilizing the Mehlich-3 test in place of the Bray P1 test. Both tests use similar extraction techniques, but Mehlich-3 tends to extract more P than does the Bray P1 test.
Table 2. Phosphorus fertilization recommendations for turf establishment
Phosphorus Bray P1 Soil Test Level†
Phosphorus Bray P1 Soil Test Level†
Recommended P Fertilization Levels
Abbreviations: M = 1000 ft2; A=acre, PPM = parts per million; lbs. = pounds