Illinois Pesticide Review
November / December 2009
In This Issue
EPA Seeks Public Comments on New Drift Label Language
The U.S. EPA recently released a proposed new guidance on pesticide drift labeling. The proposal was released as a Pesticide Registration Notice (PRN) on Pesticide Drift Labeling; it is identified as PNR 2009-X. The stated goal of the new guidance is "to protect people and other non-target organisms and sites from adverse effects that may be caused by off-target pesticide drift."
The notice points to the availability of three documents. The first is titled "Pesticide Drift Labeling" and contains guidance for applicants and registrants of certain pesticide products on how to revise label drift language. It includes proposed label statements and formats. The EPA's hope is that the new drift statements on labels will provide "consistent, understandable, and enforceable directions" to protect against harm from drift. The second document is titled "Pesticide Drift Labeling Interpretation" and is intended to provide guidance for government agencies responsible for enforcing pesticide laws on how to interpret the proposed labeling statements found in the first document. It includes several example drift scenarios and how the new labeling would be interpreted in each scenario. The third document, titled "Additional Information and Questions for Commenters," provides additional information explaining the EPA's rationale for the proposed drift labeling.
To review the documents, visit www.regulations.gov and enter "EPA–HQ–OPP–2009–0628" in the "Enter Keyword or ID:" field in the top right hand section of the page. You will then be directed to all documents pertaining to this docket. Comments submitted to the EPA are posted along with the original documents, so you will need to scroll through the pages to find the three documents from the EPA. They are listed with a Document Type of "Supporting & Related Materials." The EPA is seeking public comments on these documents, which must be received by January 4, 2010. Comments can be submitted by mail, personal deliveries, or online at http://www.regulations.gov. When submitting comments, direct them to docket ID number EPA-HQ-OPP-2009-0628.
IFCA Recycles Thousands of Pesticide Mini-bulk Containers
Crop protection chemicals are essential in agricultural production to protect crops against insects and disease, to control weeds, and to enhance plant health. Getting the agrichemicals from the manufacturer to the ag retailer and to the farm requires the use of thousands of plastic pesticide containers, from 2.5 gallon jugs up to 250 gallon containers called mini-bulks. But once these containers have served their purpose, disposing of them can be problematic due to the sheer number of tanks and the fact that they once contained pesticides.
For the past 20 years, the Illinois Department of Agriculture has coordinated the recycling of small pesticide containers with funding from the Ag Container Recycling Council. However, mini-bulk containers are not accepted at this program. Hearing the demand for mini-bulk recycling, the Illinois Fertilizer & Chemical Association, which represents the ag input industry in Illinois, coordinated an extensive effort with the Illinois Department of Agriculture to assist ag retailers in properly disposing of pesticide mini-bulks.
This fall, IFCA member GROWMARK Inc. provided statewide route truck pickups of clean, triple-rinsed tanks, and eight IFCA ag retail members hosted collection sites for the tanks. At the collection sites, Illinois Department of Ag personnel inspected the tanks to ensure they were clean. Once approved, IFCA staff with assistance from ag retail facility employees loaded the tanks into semi-trucks. The tanks were transported to FarmChem in Floyd, Iowa, to be chipped and then shipped to Texas, where the plastic is recycled and used to make parking bumpers, buoys, field tiles, pallets, and other products for non-food uses. The program collected 2,275 tanks.
IFCA was able to secure financial assistance from pesticide manufacturers including BASF, Bayer, Dow AgroSciences, DuPont, Monsanto, MANA, Syngenta, Winfield Solutions, and other registrants to help fund the collection program. Each ag retailer also paid a fee to participate in the program.
"We are very proud of the commitment that our members at all levels within the agrichemical industry showed in supporting this program, and working side by side with the IL Dept of Agriculture we were able to ensure that these tanks ended up being safely recycled for useful purposes instead of ending up in landfills or taking up valuable space in warehouses" said Jean Payne, President of the IFCA.(Source: IFCA press release, Oct. 21, 2009, posted at: http://agprofessional.com/show_story_du.php?id=61445)
New Pesticide Dealer Manual
The revised Illinois Pesticide Applicator Training Manual 39-14, Pesticide Dealer, was published in November 2009. It replaces the original Dealer manual published in January 2002. This manual has been completely revised with the number of pages rising from 46 to 54.
The "Labels and Labeling" chapter was improved to help dealers understand pesticide labels. An additional two pages of information was added.
The "Illinois Pesticide Act" chapter incorporates the requirement of a dealer license for any business selling non-restricted-use pesticides for production of an agricultural commodity in containers of 2.5 gallons or 10 pounds or more. This is a change made in 2005 that brought additional facilities under the law.
The "Agrichemical Facilities" chapter underwent major changes to incorporate the addition of non-commercial agrichemical facilities and on-farm storage facilities to numerous requirements of the law. This chapter includes three new pages of text specifically addressing on-farm storage facility containment.
The "Lawn Care Products Application and Notice Act" chapter incorporates the new requirements for day care centers just signed into law in late summer 2009.
BCERF Loses Funding
The Cornell University Program on Breast Cancer and Environmental Risk Factors (BCERF) has provided high quality, balanced information on the impact of pesticides and other factors on breast and other cancers of both women and men for fourteen years. Due to cuts in the New York State budget, this program has lost too much funding to remain active.
Dr. Suzanne Snedeker and her staff have done an excellent job of critically reviewing the research and review literature. Although their information has been produced primarily for the citizens of New York State, most of it has been applicable and easily available to the rest of the U.S. and the world through the program web site at http://envirocancer.cornell.edu/.
Over 50 fact sheets have been written and posted at this site, along with video, slide presentations, and newsletters, providing a tremendous amount of quality information. Also at this web site are an Environmental Chemical and Cancer Database, a Turf Pesticides and Cancer Risk Database, and a Bibliographic Database. With the loss of New York State funding, there is no longer any financial support for the web site or Dr. Snedeker and her staff. Although efforts are being made to archive the information in some way, this site will be discontinued within the next few months, so it is important to download useful information soon.
The Turf Pesticides and Cancer Risk Database contains evaluations on 114 active ingredients that are components of 3233 products. Because this database is used heavily nationwide, there is some optimism that funding may be located to keep this portion of the web site available.
The program also has several on-going research studies. These will continue, since they are supported by other funding sources.
It is unusual to find such a solid scientific and balanced approach to the effects of pesticides and other environmental chemicals on breast and other cancers. The efforts of Dr. Snedeker and her staff will be greatly missed.
Fungicides are used worldwide in industry, row crops, home landscapes & gardens, and vegetable and fruit production. Fungicides are used for multiple reasons, including seed protection during storage, shipment, and germination, and protection of growing as well as mature crops from edible to ornamental. Fungicides are also used in paints, paper pulp, carpets and fabrics in the home and shingles on many roofs.
The potential for injury or adverse effects in humans caused by fungicides varies enormously. In the past, the worst harm was caused by fungicides containing organic mercury or hexachlorobenzene. Fungicide risks today are much lower than they were years ago. Many of the current fungicides are unlikely to cause frequent or severe systemic poisoning for several reasons.
Today, many fungicides have a low inherent toxicity to mammals and are not absorbed though the skin very efficiently. Another reason is that many fungicides are suspensions of wettable powders or granules that have limited ability for rapid and efficient adsorption.
Current modern methods of application are such that intensive exposure is limited for most individuals. Proper use of protective clothing and equipment (commonly known as PPE) protects the skin and eyes. Reading and following all label directions also limits exposure.
In general, fungicides in use vary in their level of toxicity and other than organic mercury compounds, most fungicides are not likely to be absorbed efficiently or rapidly enough to cause systemic poisoning. Poison signs and symptoms are variable. Eye and skin decontamination as well as GI decontamination (if swallowed/ingested) needs to be done. Sometimes intravenous fluids may need to be administered. Fungicides are not cholinesterase inhibitors, so routine testing is not conducted.
Following are some of the widely used fungicides. Additional fungicides will be covered in future newsletters. If a listed fungicide has been known to cause systemic poisoning, National Pesticide Information Center information on management of poisoning and injuries are listed. For fungicides not known to have caused systemic poisoning, only general National Pesticide Information Center guidelines are listed.
Chloroneb is a wettable powder used to treat both soil and seed. It has very low oral toxicity in mammals but may cause a moderate skin and mucus membrane irritation. The metabolite dichloromethoxyphenol is excreted in urine. There are no reported cases of systemic poisoning in humans.
Chlorothalonil is supplied as a wettable powder, a flowable powder and as a water dispersible granular. This fungicide is known to cause irritation to skin and mucus membranes of the eye and respiratory tract on contact. Allergic dermatitis contact has been reported. One case of immediate anaphylactoid reaction to skin contact has been reported. Chlorothalonil seems to be poorly absorbed through skin and the gastrointestinal lining. No cases of systemic human poisoning have been reported.
Dicloran, a widely used broad-spectrum perishable produce fungicide is sold as a wettable powder, flowable powder, and a dust. It is or is partially eliminated via urine. One of the resulting breakdown products, DCNA, caused liver injury and corneal opacities when given in extremely high doses to lab animals. Based on these lab studies, large doses might cause liver injury, pyrexia, corneal opacities, and maybe methemoglobinemia. However, none of these symptoms have been seen in humans exposed to DCNA.
Hexachlorobenzene (not to be confused with the insecticide hexachlorocyclohexane) is usually available as dusts and powders for use as a seed protectant. At low dosage, this fungicide has only slight irritant effects and relatively low single-dose toxicity. In the 1950s, long term ingestion by Turkish farm dwellers of HCB-treated grain caused several thousand cases of toxicity. Most adults recovered after they stopped eating the treated grain. However, some nursing mothers' infants died while the mothers were eating the HCB-treated grain. Hexachlorobenzene is dechlorinated and oxidized in humans; exposed workers usually show only slight elevations of blood HCB concentrations. HCB can be measured in blood by gas chromatography. Chlorophenol metabolites can be measured in the urine.
Skin exposure should be immediately washed off with soap and water. Flush contaminated eyes with plenty of water for 15 minutes. If irritation persists, seek specialized medical care. If a large volume of fungicide is swallowed, and no copious vomiting occurs, proper medical GI decontamination should be strongly considered. First aid directions for poisoning can be found on the product label. For more guidance, it is also recommended you call the Poison Control Hotline, 1-800-222-1222. Of course, in the event of an emergency, call 911.(Summarized from information on the National Pesticide Information Center web site by Jim Schuster.)
Update on Protecting Endangered Species
We've been telling our readers for some time now that new pesticide label language related to protecting endangered species is coming. It is still forthcoming, but it is going to be a while yet for applicators in Illinois.
A short and sweet explanation as to why the process has been delayed.
Revisions are still being made to the EPA's Bulletins Live! system, which can be accessed from this page: http://www.epa.gov/espp/bulletins.htm. From a state map on the site, you can click on the county in which you wish to apply a pesticide. It will notify you if there are further application restrictions than what is already covered on the label. You can also search by active ingredient. Currently, there are no further restrictions for any applications in Illinois.
Clomazone (Command, Strategy) and fomesafen (Flexstar GT, Reflex, etc.) are the first two pesticides to be evaluated for their effects on endangered species. We await EPA's final risk assessment, proposed registration decisions, and proposed risk mitigation if needed. Learn more at: http://www.epa.gov/oppsrrd1/REDs/factsheets/clomazone-fomesafen-fs.html.
Progress has been drastically slowed by the consultation process with the U.S. Fish and Wildlife Service, which is required for pesticides that may affect endangered species. In addition, EPA's efforts have shifted focus a bit. Various lawsuits over pesticides potentially harming endangered species such as salmon in the Northwest have taken precedent and consumed significant amounts of EPA's time and resources. In July 2009, the Center for Biological Diversity filed a notice of intent to sue in order to force the EPA to protect polar bears in the Arctic from pesticide contamination. Polar bears, you say? Yes, even polar bears. Learn more at: http://www.biologicaldiversity.org/news/press_releases/2009/polar-bear-07-08-2009.html. Thus far, no lawsuit has been filed.
A few bulletins do exist!
In Wisconsin and Michigan, there was special concern about protecting the Karner blue butterfly from applications of methoxyfenozide (Intrepid) in 22 counties. Also, in Door County, Wis., there was a need to protect the Hines Emerald Dragonfly. Bulletins now exist for those affected counties. For example, you can view a bulletin for Monroe or Adams county in Wisconsin.
You can search statewide for Wisconsin and 16 counties will pop up. However, the manufacturer also specifically listed those affected counties on new Intrepid 2F and Intrepid 80WSP labels that will be available in the channels of trade once accepted by USEPA. All parties involved realized this was the most practical solution, rather than burdening all applicators with having to go through the Bulletins Live! system needlessly at this time.
EPA is still perfecting the system. Ultimately, labels will include generic language that directs users to the Bulletins Live! Website, and specific counties will not be detailed on the label. This will happen eventually, but I'm told it will still be a long time coming. I've seen the generic language on a few labels so far (Corvus and Balance Flexx). Watch for this language coming to a label near you:
"ENDANGERED SPECIES PROTECTION REQUIREMENTS
This product may have effects on federally listed threatened or endangered species or their critical habitat in some locations. When using this product, you must follow the measures contained in the Endangered Species Protection Bulletin for the county or parish in which you are applying the pesticide. To determine whether your county or parish has a Bulletin, and to obtain that Bulletin, consult http://www.epa.gov/espp/, or call 1-800-447-3813 no more than 6 months before using this product. Applicators must use Bulletins that are in effect in the month in which the pesticide will be applied. New Bulletins will generally be available from the above sources 6 months prior to their effective dates."
For salmon and steelhead mitigation in the states of California, Oregon, Washington, and Idaho, enforceable labels may hit the marketplace for 6 insecticides in 2011. I trust this label language will be specific to the region.
Industry efforts in protecting endangered species
Monsanto has a stewardship program called the Glyphosate Endangered Species Initiative. This is independent of EPA's efforts mentioned above. Growers use a simple web-based tool called Pre-Serve, which is available at www.pre-serve.org.
After answering a short series of simple questions about their intended glyphosate application, maps are provided that identify areas where threatened or endangered plants may exist near agriculture. Best management practices are then listed.
With certain use patterns and application rates, these practices must be implemented by growers in these identified areas. This is done to minimize risks to protected plant species.
Most agricultural applications of glyphosate in Illinois aren't in these sensitive areas and there are many times during the series of questions where the user is told his or her application is not impacted by Pre-Serve.
With that said, there are several sensitive areas in 27 counties highlighted on the map of Illinois. You can click on a listed county and zoom in for a closer look. You can then print the map and relevant worksheet, which includes a series of short questions about the application. Instructions are then given, which typically include guidance on drop size and application rate.
Growers using Roundup Ready traits are required by their contract obligations with Monsanto to "observe all mitigation instructions" on the Pre-Serve website. The company says that their program "will have a minimal impact on grower practices while meeting the important objective of protecting threatened and endangered plant species." Monsanto plans to phase out Pre-Serve once EPA has Bulletins Live! up and running. It is an interesting web tool. Check it out when you have a few spare minutes.
A good read on the controversy surrounding agriculture and the Endangered Species Act
Also of interest is the recent CAST (Council for Agricultural Science and Technology) commentary titled, "The Endangered Species Act: Interfacing with Agriculture and Natural Ecosystems." It is a short eight pages and is available for free at: http://www.cast-science.org/websiteUploads/publicationPDFs/Endangered%20Species%20FINAL%209o16%20QTA2009-2166.pdf. The following is CAST's description of this commentary.
"This Commentary explores the interaction between the regulatory policy of the Endangered Species Act, public perception, and science in relation to the interpretation of risk to endangered species from various "stressors" associated with agricultural practices. In the absence of definitive government policy, courts are establishing risk mitigation procedures that may adversely affect agricultural productivity and practices. The authors address several potential remedies, including (1) better communication, (2) clear policy and agency coordination, (3) recognition and consideration of long-term impacts, and (4) balanced and consistent implementation."
If eight pages are too long for you, be sure to at least read the highlights in the left-hand margin. The commentary is good, but I wouldn't call it light reading. It does a great job of describing problems with the Endangered Species Act and those who enforce it. It offers recommendations for how players can work together in a more timely fashion to effectively protect endangered species.
For past articles that discuss protecting endangered species from pesticides, check out:
September 2007 (https://webs.extension.uiuc.edu/ipr/i4110_829.html#1)
November 2005 (https://webs.extension.uiuc.edu/ipr/i4150_829.html#1)
March 2004 (https://webs.extension.uiuc.edu/ipr/i4160_829.html#1)
Here are a few useful EPA web pages on this topic.
• EPA's registration review process schedule:
• EPA's pesticide registration review status:
• EPA's process for assessing pesticide risks to endangered species:
• Endangered species effects determinations: