The SFIREG Joint Working Committes met at US EPA Potomac Yards, Crystal City, VA on September 19-20, 2016
Pesticide Operations and Management Chairperson, Bonnie Rabe, NM
Environmental Quality Issues Chairperson, Gretchen Paluch, IA
Paluch introduced the issue-in her region there have been large numbers of incidents investigated due to use of dicamba on dicamba-resistant soybeans. Lots of need for resources, labs, enforcement, coordination for the states and regions. Paluch says the committee would like to hear from others who may be having issues, and determine ways to move forward into the future, and opened it up to the committee and audience.
Would EPA like to comment on the advisory? Lott said that dicamba has created a lot of enforcement for the agency, beginning with Missouri. Lots of damage on a wide variety of crops, residential as well, peach orchards, tomatoes, other soybeans, etc….significant damage, verified by analytical laboratories, costing a lot of resources. OECA is doing a broad investigation. The advisory is to head off second crop soybeans after cotton had run its course. Some reported soybean incidents, even complaints as far north as Minnesota…mostly in the cotton belt though. Probably one of the most extensive situations he has dealt with in 30 years-just one incident after another. Lott thanked the states for working so well together with OECA. Rabe asked Lott to describe how OECA can help states…bring in federal investigators, use FIFRA authority to gather information from registrants/dealers about incidents, who is buying and using the products., using legal resources to assist states on some of the types of investigations and outcomes. Consult on the criminal side as well if necessary. Since the states have primacy they may choose to refer to EPA for enforcement, otherwise it is the states authority to manage the enforcement outcomes.
Rabe mentioned the issue of lab support and how a situation like this can wipe out lab resources. We need to have more discussion on how to handle these large-scale investigations from the lab side.
Can we get the project officers in the relevant regions to put together a table for full SFIREG of the number of incidents they are working on and require lab work? Can Dan Kenny do anything with the label to prevent issues into the future? LOTT says yes.
Lott discussed lab capacity as well and OECA’s recognition of the need to support them. These cases are due to misuse: the seeds were released prior to the low volatility product being registered.
Keigwin added that OPP had a proposed registration decision, received comments into the thousands, are going through the comments, the proposed registration was very specific, including very specific nozzles, and the registration is pending. They are doing studies to understand the amount of product that could volatilize, looking at what types of programs may be available with extension programs informally to educate growers on what needs to be done to use the products properly. Hoping to make a registration decision this fall.
QAPP/QMP- see presentation
Tolerance issues with degradates-see presentation.
Kachadoorian described issues with exporting commodities that were found to have residues of pesticides which are not labeled for use on the crop. Oregon discovered that some labeled pesticides were lawfully used, which then degraded into degradates which are also labeled pesticides-but are not labeled for use on these particular crops and therefore created a confusing situation. Kachadoorian asked EPA to respond to the issue, either by creating degradate charts for use by states, and wanted acknowledgment from the agency of the issue. Meredith Laws responded that while she recognizes the issue, the agency will not be pursuing a remedy and had no response beyond that recognition that may be useful to states working on this issue. Laws also requested that states contact her if this issue arises in the context of exports.
Echeverria gave an update on the acute risk mitigation for pollinators policy:
- Label restrictions will be for highest risk exposure;
- Continue to encourage MP#
The policy should be out by end of year. POM can provide input on label language in NOVEMBER.
Why does PPDC have a new MP3 committee?-The faca will discuss how MP3s are effective in meeting EPA’s goals related to pollinator protection, and determining measures for evaluating MP3s. The intent is to build on each other-not throw away past efforts.
Gretchen opened the meeting with introductions, as most of the committee is new, and had folks mention their backgrounds:
Gretchen Paluch: Iowa, entomology, toxicology and statistics
Gary Bahr: WA, 25 years in ID, just moved in the fall of 2015, natural resources manager, water quality manager, gw quality, tes-fish, technical topics-pollinators, RNAi, registration support
Davis Daiker, FL, oversees environmental fate and assessment, mosquitos, tes, water quality, invasive species, termites, technical outreach, toxicology background
Lebelle Hicks, ME, risk assessment work, risk communication, applicator training
Laura Mensch, DE, hydrologist, gw monitoring
Tim Drake, Clemson, biology, ag and urban entomology, oversees licensing and certification, all product registration, state entomologist, qa for labs, and emergency response
Carrie Leach, OSIC, qa director
John Allran, NC, enviro toxicology, risk assessment for registrations, enviro fate and risk assessment, pesticide disposal, tes, container recycling, water quality, herbicide injury diagnosis
The educational module was discussed, and suggestions related to the EPA Aquatic Life Benchmarks page were reviewed.
Current water models used by EPA-see presentation
Plant back restrictions
The committee reviewed the issues related to plant back restrictions and is continuing to discuss ways to address label language and field use off line.
States are happy that the final rule addressed most of the concerns raised during the comment period and feel that the rule will allow for implementation. Statute or rule changes are issues the states will have to work with and it may take time, perhaps even more than the 2 year implementation period provided for in the rule.
State registration resources and coordination mechanism
Endangered Species- see presentation
The states continue to coordinate to develop a 24c label for use on cannabis. Use data and efficacy remain challenging areas for registrations.