Testimony on the Implementation of the Food Quality Protection Act
Before the Subcommittee on Department Operations, Nutrition, and Foreign Agriculture of the Committee on Agriculture of the U.S. House of Representatives
Leonard P. Gianessi
June 25, 1998
National Center for Food and Agricultural Policy
1616 P Street, NW, First Floor
Washington, DC 20036
Tel.: 202-328-5048
Fax: 202-328-5133
e-mail: ncfap@ncfap.org
My name is Leonard Gianessi. I am a Senior Research Associate at the National Center for Food and Agricultural Policy, a private, non-profit, non-advocacy research organization located here in Washington, DC. For the past 18 months we have been conducting a project funded by the USEPA and by the Department of Agriculture to collect information on the uses of organophosphate insecticides. The Agency asked us to compile information on the usage patterns of these chemicals and on what might the alternatives be to their use if they were canceled. All of the manufacturers of the organophosphates provided information on their usage patterns. In addition 43 commodity organizations provided information on how the organophosphates are used by growers of the crops they represent. We provided the Agency with a 600 page report that includes individual sheets describing the usage patterns for individual organophosphates on specific crops. I will summarize what we learned from these organizations. Our findings are summarized in the attachment: "The Uses and Benefits of Organophosphate and Carbamate Insecticides in U.S. Crop Production."
First, many commodity groups are concerned that they have no alternatives or inadequate alternatives to current usage of organophosphates and would suffer great yield losses because of their inability to control insects if the organophosphate uses were banned. Some examples are: wild rice growers in Minnesota, date growers in California, cranberry growers in Massachusetts and New Jersey, asparagus growers in California and Washington, peanut growers in Virginia and North Carolina, blueberry growers in Maine and Michigan, Texas citrus producers, cherry growers in Michigan, California tomato growers, New York onion growers, Louisiana sweet potato growers, Minnesota and North Dakota sugarbeet growers. All of these groups rely on organophosphate insecticides to control key insect pests for which alternatives are non-existent or seriously inadequate.
Second, several commodity groups reported that although effective alternatives exist for certain pests, their use would not be desirable because of disruption of Integrated Pest Management programs. Some examples are: California strawberry growers, Georgia pecan growers, Washington apple and pear growers, Pennsylvania apple growers. The alternatives would kill beneficial insects that control other pests biologically. The organophosphates do not kill these beneficial insects, and, as a result, some pests are managed chemically while other pests are managed biologically. With the alternatives, more insecticides would have to be used because the biological controls would be eliminated.
Third, several groups reported that organophosphates are the only effective means of controlling mycotoxins that are spread by insect pests. In passing FQPA, Congress acknowledged the dangers of aflatoxin in the food supply. Aflatoxins are naturally occurring carcinogenic toxins that are spread into several crops by insects that currently are controlled by organophosphates. Pistachio, peanut and almond growers are concerned because organophosphates provide the only effective means of controlling the insects that spread aflatoxin. Our findings are summarized in the attachment: "Aflatoxin and the Food Quality Protection Act."
Fourth, many commodity groups are concerned that although new products may be registered as alternatives to organophosphates, these new products will cost significantly more. Organophosphates generally are inexpensive to apply ($3–$5 per acre per application). New products are costing in the range of $15–$25 per acre per application. The new products tend to be less broad-spectrum than the organophosphates and it may require three or more products per acre to control the range of pests that are controlled by the organophosphates. With intense competition in world markets these increased costs may mean loss of export sales for many crops.
EPA has not proposed to cancel any organophosphate insecticide use although the Agency has released some preliminary risk assessment data indicating there may be excessive dietary risks from certain of these compounds. Federal officials have warned growers that some organophosphate uses will be canceled. No one knows how many uses or which uses. One concern is that if a significant number of uses are canceled in the U.S., it will no longer be economically viable for chemical companies to manufacture these products for the U.S. market. If the regulatory cost of complying with FQPA becomes very high, companies simply may choose voluntary cancellation of their products entirely. This has happened already in one case. Within the last year, the manufacturer of the organophosphate insecticide fonofos voluntarily canceled its use rather than go through the regulatory requirements of re-registration. As a result, growers of mint and other specialty and vegetable crops in the Willamette Valley of Oregon have been left with no alternative to control a key insect pest, and face the prospect of large yield losses in the next few years. Pennsylvania potato growers also are faced with no alternative in controlling a key insect pest following the voluntary cancellation of this chemical.
Most of the individual organophosphate insecticides represent annual sales in U.S. crop production of between $1 and $20 million. These chemicals are off patent and are relatively inexpensive. Significant new regulatory requirements may threaten their continued economic viability in the United States.
Insect pests must be controlled in the production of fruit and vegetable crops. Uncontrolled insects would lower significantly fruit and vegetable crop yields in the U.S. In making decisions as to which insecticides to apply, U.S. growers of most fruit and vegetable crops select organophosphate insecticides to treat about one-half of all insecticide treated acres. The organophosphate insecticides were the first class of pesticides to incur the full force of FQPA requirements. These compounds are very important to the production of crops in this country. The grower organizations with which we worked in our study have been extremely forthcoming with information for EPA to use in its assessment of how these compounds are used. It is everyone’s fervent hope that EPA has enough information to conduct realistic risk assessments because of the enormity of the decisions that it is about to make.
Commodity Organization Contacts
for Organophosphate Information Sheets
Almond Board of California
American Sugarbeet Growers Association
American Sugarcane League
Apricot Producers of California
Artichoke Research Association
California Alfalfa Seed Research Advisory Board
California Asparagus Commission
California Association of Winegrape Growers
California Beet Growers Association
California Celery Research Advisory Board
California Fig Advisory Board
California Pepper Commission
California Pistachio Commission
California Potato Research Advisory Board
California Strawberry Commission
Cherry Marketing Institute, Inc.
Concord Grape Association
Cranberry Institute
Del Monte Foods
Grower & Shipper Vegetable Association of Central California
Melon Research Board
Michigan Apple Committee
Michigan Asparagus Advisory Board
Michigan Blueberry Growers Association
Minnesota Cultivated Wild Rice Council
Mint Industry Research Council
National Pecan Shellers Association
National Sunflower Association
New York State Vegetable Growers Association
North American Blueberry Council
Northwest Horticultural Council
Nutgrowers Society of OR/WA/BC
Olive Growers Council
Oregon Raspberry & Blackberry Commission
Processed Tomato Foundation
Sun Diamond Growers
Texas Citrus Mutual
Texas Vegetable Association
US Apple Association
US Canola Association
US Hop Industry Plant Protection Commission
Western Growers Association
Wild Blueberry Commission of Maine
Information Required From Nongovernmental Witnesses
House Rules now require nongovernmental witnesses to provide their resume or biographical sketch prior to testifying. If you do not have a resume or biographical sketch available, you can answer the following questions instead:
Education: B.A. George Washington University, 1971
Professional: 1976-1993, Fellow, Resources For the Future
1993-present, Senior Research Associate, National Center for Food and Agricultural Policy
Member: International Organization for Pest Resistance Management, Weed Resistance Working Group
Interagency Pesticide Usage Data Planning Group
Principal Author: Pesticide Use in U.S. Crop Production: National Data Report (February 1995)
An Economic Profile of the U.S. Crop Protection Pesticide Industry (November 1995)
Federal Grants, Contracts, Subcontracts and Cooperative Agreements Awarded to the National Center for Food and Agricultural Policy Since October 1, 1994
May 30, 1995 USDA/NAPIAP 50,000
(Subcontract with Univ. of Illinois)
August 23, 1995 USDA/ERS 15,000
August 29, 1995 USDA/ARS 45,000
September 27, 1995 USDA/ARS 35,000
April 24, 1997 Amendment 40,000
September 30, 1997 Amendment 50,000
February 5, 1996 USDA/ERS 25,000
January 23, 1997 USDA/FAS 15,000
March 11, 1997 USDA/ARS 119,218
January 16, 1998 Amendment 176,902
March 24, 1997 USEPA/OPP 63,000
(Subcontract with Abt Associates)
August 21, 1997 USDA/ERS 146,000
November 26, 1997 USDA/FAS 76,095
February 4, 1998 Amendment 102,885
April 2, 1998 Amendment 220,000
Leonard P. Gianessi
December 1997
National Center for Food and Agricultural Policy
1616 P Street, NW, First Floor
Washington, DC 20036
202-328-5048
FAX: 202-328-5133
e-mail: ncfap@ncfap.org
TABLE OF CONTENTS
Alfalfa
Apples
Artichokes
Avocados
Blackberries
Blueberries
Cherries
Corn
Dates
Figs
Grapes
Hazelnuts
Hops
Kiwi
Mint
Olives
Raspberries
Soybeans
Sugarbeets
Sugarcane
Sunflowers
Walnuts
Wild Rice
Asparagus
Cranberries
Apples
Rice
Cotton
Lettuce
Potatoes
Almonds
Pistachios
Peanuts
Table 1
Table 2
Table 3
Table 4
Table 5
Table 6
Table 7
Table 8
Table 9
Table 10
This paper classifies 23 active ingredients in the organophosphate (OP) class and seven active ingredients in the carbamate class of chemistry as "insecticides." Many of these products are not strictly insecticides, but also act as miticides, aphicides and nematicides. The OP and carbamate pesticide active ingredients that are subject to FQPA rulemaking are not limited to insecticides, but also include certain fungicides, herbicides and plant growth regulators. This paper is limited to the 30 active ingredients. It does not include any analysis of the uses of the fungicides, herbicides or growth regulators.
The usage data used in this report reflects registrations of organophosphates and carbamates in 1995. Several of the active ingredients have been withdrawn from use in the U.S.: sulprofos and fonofos. In addition, all but three of the uses of methamidiphos have been withdrawn.
Thirty pesticide active ingredients belonging to the organophosphate (OP) and carbamate classes of chemistry are widely used as insecticides in U.S. production of fruit, vegetable and field crops. These active ingredients, their trade names and major crop uses are identified in Table 1. The organophosphate and carbamate insecticides are used to control insect pests that, otherwise, would lower crop yields significantly. Although alternative chemical and non-chemical controls are available for most of these crops, the organophosphate and carbamate insecticides, generally, are more effective and/or significantly less costly.
In August 1996, the President signed the Food Quality Protection Act (FQPA), which had passed Congress unanimously. FQPA includes significant amendments to the nation’s laws regulating pesticide registrations and tolerances in foods. Congress included sections in FQPA that broaden the consideration of health risk factors while reducing the role that pesticide benefits play in granting tolerances. FQPA requires the EPA to reassess all existing pesticide tolerances considering the best available data on aggregate exposure to the pesticide, the cumulative effects from pesticides sharing a common mechanism of toxicity, exposure to children and potential as an endocrine disrupter.
EPA plans to review 33 percent of existing tolerances by August 1999. On August 4, 1997, EPA published a list of its tolerance reassessment priorities and reregistration scheduling priorities. For the August 1999 deadline, EPA intends to reassess those pesticides that appear to pose the greatest risk to the public health. EPA has included pesticides of the organophosphate and carbamate classes of chemistry in this first group of pesticides to be subject to FQPA’s requirements. Initially, EPA plans to review the registrations of the organophosphate and carbamate insecticides individually, using FQPA requirements regarding aggregate exposure, protection of children and endocrine effects. Following the individual assessments, EPA plans to conduct a cumulative effects analysis of exposure to all of the active ingredients sharing a common mechanism of toxicity. For this analysis, it is likely that all of the organophosphates will be considered as one group and all of the carbamates as another group. Although the results of the aggregate risk analyses are unknown at this time, it may be that EPA will propose canceling many organophosphate and carbamate insecticide uses in order to reduce the calculated risk to human health to below the acceptable safety standard.
The organophosphate and carbamate insecticides share the ability to depress the levels of cholinesterases enzymes in the blood and nervous systems of insects, animals and humans. Most of the organophosphate and carbamate insecticides are regulated currently by EPA on the basis of threshold effects. FQPA specifically instructs EPA not to consider the benefits of a pesticide when considering threshold human health risks. If the theoretical risk exceeds the safety standard, risk must be reduced by cancellation of uses or otherwise until the standard is met, no matter the cost. However, Congress did not preclude EPA from conducting cost-effective rulemaking. Careful analysis of the individual uses of the organophosphate and carbamate insecticides might identify those crops for which the use of alternatives would be least costly as replacements. On the other hand, EPA may determine that it has no recourse but to propose cancellations of a long list of organophosphate and carbamate insecticide registrations, which may leave many growers without effective alternatives, and be very disruptive to U.S. production of crops. When EPA proposes these regulations, it will be necessary for the Agency to estimate the costs of this rulemaking. However, if pesticide registrants propose to remove registrations voluntarily, it will not be necessary for the EPA to estimate the resulting economic effects. FQPA provides only broad outlines for implementation of the "reasonable certainty of no harm" standard. The impact of FQPA will depend largely on the policies, procedures and default assumptions EPA uses in its implementation. Extremely conservative policies, procedures and assumptions will increase the cost impact of FQPA.
The estimates of the usage of organophosphate and carbamate insecticides used in this paper are drawn from the National Pesticide Use Database issued by the National Center for Food and Agricultural Policy (NCFAP) in 1995 [1]. The NCFAP pesticide use database accounts for the use of 200 active ingredients by crop and state. The NCFAP database is the only comprehensive, publicly available pesticide use database for the U.S. and reflects usage patterns circa 1992. The NCFAP database currently is being revised to reflect 1995/96 usage patterns. A key part of the update is an ongoing review of usage estimates for organophosphate and carbamate insecticides, that is being conducted by NCFAP in coordination with EPA, pesticide registrants and commodity organizations. The revised NCFAP usage database will be available in Spring 1998.
The following data summaries are based on the NCFAP usage database issued in 1995 without revision. Tables 2 and 3 show the national usage patterns for the 23 organophosphate and seven carbamate insecticides. National usage for each active ingredient is summarized in terms of the acreage of each crop for which the active ingredient is used in the U.S. As can be seen, acephate is used on 13 crops in the U.S., azinphos methyl on 40 crops, malathion on 61 crops, etc. In all, there are 690 use sites for organophosphate and carbamate insecticides in U. S. crop production. Table 4 lists the number of crop use sites for each organophosphate and carbamate active ingredient. In many cases, different organophosphates and carbamates are used on the same crop. For example, 23 of the organophosphate and carbamate insecticides are used on cotton. Each of the 690 use sites for organophosphate and carbamate insecticides warrants an analysis as to why a particular active ingredient is used on that crop (What are the target pests?) and warrants an analysis of the potential alternatives if the use of the organophosphate or carbamate for that particular crop were canceled.
One readily apparent feature of the national usage pattern for individual organophosphates and carbamates is that there are very few use sites where the active ingredient is used on more than half of U.S. acreage. Of the 690 use sites, only 27 represent more than 50 percent of the nation’s acreage of the crop. On the other hand, 442 use sites represent less than 10 percent of the nation’s acreage of a crop treated with an individual active ingredient. The NCFAP use estimates reflect normal, average usage patterns. In some cases, risk assessments are conducted with the assumption that 100 percent of the crop acreage is treated with all registered products. The NCFAP data indicate that such assessments are gross overstatements of the normal usage patterns for the organophosphate and carbamate insecticides. On the other hand, insecticide usage can vary tremendously depending on pest pressure and unusual weather patterns. The NCFAP database does not identify the likely maximum usage patterns for these chemicals. While it is accurate to say that few individual products are used on the majority of the acreage of any crop, it may be the case that the majority of the acreage of many crops is treated with one or more organophosphate or carbamate insecticides during the same growing season.
4. OP AND CARBAMATE USAGE ANALYSIS
The organophosphate and carbamate products represent 30 of the 59 active ingredients used as insecticides in U.S. crop production. The other major classes of insecticides used in U.S. crop production are pyrethroids and biological products. Oil is used widely to control insects in tree crops. Of the acres treated with insecticides in U.S. crop production, 70 percent are treated with organophosphate or carbamate insecticides. Tables 5 and 6 list the shares of insecticide treated acres for each crop that is accounted for by organophosphate and carbamate active ingredients. As can be seen for certain crops, organophosphate and carbamate insecticides are the only ones used: barley, canola, dates, flax, oats, rice, rye, safflower, sweet potatoes and wild rice. For 35 crops in the U.S., organophosphate and carbamate insecticides account for more than 70 percent of the insecticide treated acres. Tables 7 and 8 summarize the use of organophosphates and carbamates by state. As can be seen, for most states, the majority of insecticide treated acres are treated with organophosphate and carbamate insecticides.
The total use of organophosphate and carbamate insecticides in U.S. crop production is 83 million pounds. NCFAP estimates that the poundage of insecticides used in U.S. agriculture is 149 million pounds total. However, 51 million pounds of the national usage is accounted for by oil, that is used at a high per pound rate per acre. Organophosphate and carbamate insecticides respectively represent approximately 65 percent and 19 percent of the poundage of insecticides used in U.S. crop production (exclusive of oil).
Tables 9 and 10 show the distribution of poundage of organophosphate and carbamate insecticides used by crop in the U.S. As can be seen, two crops, corn and cotton, account for 54 and 40 percent of national poundage of organophosphate and carbamate insecticides, respectively. Twenty-four crops account for 95 percent of the poundage of organophosphate and carbamate insecticide use while 60 crops, collectively, account for the remaining 5 percent of national use.
For 22 of the crops treated with organophosphate and carbamate insecticides in the U.S., a literature search was conducted to identify the pests and reasons for usage.
Alfalfa:
Weevils, potato leafhoppers and aphids are the three top pests of alfalfa in the U.S. The organophosphate insecticides dimethoate and chlorpyrifos and the carbamate insecticide carbofuran are the most widely used products because of their efficacy against all the major pests. Pyrethroids were introduced for alfalfa insect pest management about 10 years ago. Weevil control with pyrethroids has been uneven. The pyrethroids do not control aphids.
Apples
San Jose scale and codling moth are two of the key pests which organophosphate insecticides control. The scale is a tiny insect that sucks the plant juices from twigs, branches, fruit and foliage. This pest has become of increasing concern to apple growers in the northwest because of the importance of exports, as phytosanitary regulations ban infested fruit from some countries [46]. The most effective method of control is to use oil plus an organophosphate insecticide, such as malathion, diazinon, phosmet, methidathion or chlorpyrifos during the dormant season [47]. Oil could be used at higher rates without the organophosphates, but increased use of oil could lead to increased plant injury. Fruit infestation with scale can be prevented with summer applications of insecticides (oil cannot be used in the summer). The only insecticides recommended for scale control during the summer are organophosphates – diazinon, chlorpyrifos and methyl parathion. Although it could control scale insects, esfenvalerate (a pyrethroid) is not recommended as a summer spray since it is very toxic to beneficial mites, and its application would be disruptive of the biological of harmful mite species [47].
Codling moth is the key pest of apples in Washington State. Apple losses from this insect alone would each 50 percent in one or two years if no insecticides were applied for control [48]. Its larvae bore deeply into the fruit and feed on seeds. Brown frass, or excrement, extrudes from the hole [47]. Survey data indicate that 96 percent of the growers apply an average of three applications of an organophosphate insecticide (azinphos methyl, phosmet, methyl parathion, chlorpyrifos) for control of codling moth [48]. Available alternatives to the organophosphates tend to be less effective, more expensive or disruptive of IPM programs [48]. Carbaryl and esfenvalerate are toxic to predatory mites and can cause severe mite outbreaks. Codling moth has not been controlled adequately with soft pesticides (such as BT) in the northwest [47]. Generally, efficacy of these compounds, even when applied five to seven times as often as azinphos methyl, do not provide equal control [48]. A synthetic insect pheromone (Isomate C) is available to disrupt codling moth mating. However, mating disruption is a less effective alternative in areas of high codling moth pressure. Growers in this situation usually supplement mating disruption with azinphos methyl.
Artichokes:
In California, the plume moth is the most serious pest of artichokes. The insect feeds on the leaves and tunnels throughout the main stem. Over the past decade the number of insecticide applications has been reduced by half, following the registration of the organophosphate insecticide methidathion, that provides longer residual control than alternatives [13].
Avocados:
The major insect pest of California avocado orchards is Greenhouse thrips. Areas on which thrips have been feeding are browner in color and covered with black specks of their excrement. Fruit scars can result in economic losses of 50 percent [14]. The organophosphate insecticide malathion has been used for several decades and controls the thrips with residual control of up to three weeks. A botanical insecticide is registered, but has no residual control and has to be sprayed two to three times [15]. A parasitic wasp has been introduced but has not proven effective in broad scale biological control.
Blackberries:
The raspberry crown borer is one of the most damaging pests of blackberries in the U.S. The insect damages the underground crown of the perennial blackberry plants. The organophosphate insecticide diazinon is applied as a drench on the row to kill the young larvae prior to their tunneling into the crown [16]. Once inside the crown, they cannot be killed with insecticides.
Blueberries
The blueberry maggot, or blueberry fruit fly, is the major insect pest of blueberries in Maine [49]. Flies emerge from the soil from June through August. Once mated, the females seek ripening blueberries in which to lay eggs. In seven to 10 days the eggs hatch, and the larva (maggot) begins feeding. As the larva feeds and grows, the berry begins to shrink. After two to three weeks the berry is destroyed almost completely. The presence of infested fruit at harvest can result in the condemnation of whole fields of harvested fruit. Maggots became serious problems in Maine blueberries in the 1920’s [50]. Dusting with arsenic was the common control method employed in the 1930 - 1950 time period. Currently, blueberry fruit fly emergence is monitored with sticky traps. Action thresholds have been developed to guide the timing and necessity of treatment. The only insecticides recommended by the University of Maine for blueberry maggot control are OP’s (malathion, phosmet, azinphos methyl) and a carbamate (carbaryl). Azinphos methyl and phosmet are most widely used because they are the most effective. Some Maine growers who do not use insecticides use the tactic of late harvesting as a means of eliminating some of the maggot infested berries, as these berries tend to drop off the bush as the maggots inside them mature. Research results suggest that this technique may work well in some years, but not in others [51].
Cherries
The most important insect pests in Michigan tart cherry orchards are cherry fruit fly and plum curculio. Both insects directly damage the fruit. Female fruit flies lay their eggs under the skin of the fruit (each female can lay from 50 to 200 eggs). The hatched larvae feed inside the fruit. A Food and Drug Administration rule mandates a zero tolerance for cherry fruit fly maggots in processed cherries. In unsprayed trees a high percentage of fruit is likely to be attacked
The organophosphate insecticides azinphos methyl, phosmet and chlorpyrifos are used widely in Michigan tart cherry orchards because they provide effective control of all the major insect species [45]. Alternatives to the organophosphates include pyrethroids, including esfenvalerate and permethrin. The pyrethroids are less effective and more costly. Unlike the organophosphates, the pyrethroids destroy beneficial mites. With the resulting build-up of damaging mite species, miticide use would have to be increased.
Corn:
Corn rootworm larvae are the primary and most damaging insects pests in corn production. The larvae chew on and tunnel inside or along the roots in summer months. As they feed, the larvae prune roots back to the stalk. Injured plants cannot take up water and nutrients efficiently. Yield losses of up to 55 percent can occur as a result of both root pruning and lodging [3]. For continuous corn production, granular soil insecticides, applied at planting, are the primary method used to control corn rootworm. The three major corn rootworm insecticides are the organophosphates chlorpyrifos and terbufos and the pyrethroid tefluthrin. Chlorpyrifos is used most frequently in the Corn Belt because of its efficacy against both cutworms and rootworms. Terbufos is the market leader in the Western Plains, where the predominant rootworm species is the western corn rootworm, and where rootworm populations are higher. Terbufos also is the market leader in Southern states, where billbugs are problems in corn. Crop rotation has long been an acceptable alternative to insecticide use for control of corn rootworm. However, for the past several years, a new phenomenon has been causing serious rootworm infestations in first-year corn fields in Illinois and Indiana. Extension personnel believe that the Western corn rootworm beetle has adapted to laying eggs in soybeans, thus minimizing the utility of a corn/soybean rotation for corn rootworm control [4].
Dates:
Four species of beetles are pests of dates in California. In addition to the primary damage caused by feeding, losses result from the presence of excreta, larvae and the moulting skin in the damaged dates. Crop damage is higher during years with above-average rainfall. In the late 1940’s, up to 75 percent of the date crop was lost to insect damage in some years [17]. Since 1953, the organophosphate insecticide malathion has been recommended and widely-used for beetle control in California date trees.
Figs:
The major insect pests of California figs are dried fruit beetles, that feed on ripening or overripe fruit. During years of unseasonable rains, fig orchards attract insects from great distances, and populations reach astronomical levels [18]. In order to salvage a portion of the crop after unseasonable rain, fig growers employ the organophosphate insecticides malathion or diazinon.
Grapes:
A Special Local Needs label for the use of the organophosphate insecticide chlorpyrifos for control of grape mealybug exists for California and Washington (approved in 1996/97). Mealybugs feed on grape sugars and proteins and secrete the ingested sugars, leaving behind honeydew, that promotes the growth of sooty mold on the fruit. Grape pickers dislike the mealybug infested grape clusters because the black mold gets all over their clothing and is transferred by their hands from infested bunches to uninfested bunches. Chlorpyrifos, when directed at the vines’ trunks and applied in a delayed dormant application, has proven to be the most effective control material against the grape mealybug [19].
Hazelnuts:
Until the 1990’s, the organophosphate insecticide chlorpyrifos was used widely for management of the filbert aphid. In addition, sporadic use occurred when leafrollers were an economic threat. In recent years, chlorpyrifos use has declined because of the successful introduction of a parasitoid wasp for biological control of filbert aphids [20]. Leafrollers remain a sporadic pest, and chlorpyrifos is most commonly used for its control currently.
Hops:
Hop aphid is a primary pest of hops in the U.S., and chemicals are used on 100 percent of U.S. hop acreage every year for its control. Hop aphids excrete prolific amounts of honeydew. Sooty mold grows on the honeydew and can render hop cones unmarketable as moldy hops cannot be used for brewing [27]. Until recently, the organophosphate insecticide diazinon was used on 100 percent of U.S. hop acreage for aphid control. However, the recent registration of imidacloprid has resulted in a significant decline in diazinon’s use. Diazinon is used currently as an early season spray for aphid control and is also important for resistance management for imidacloprid.
Kiwi:
In California, heavy infestations of scale insects cause premature fruit softening, which is a significant problem for packers storing kiwi fruit [22]. Although widely used to control scale, research indicates that spray oil does not provide adequate control of high populations. In kiwi vineyards with high scale populations, the organophosphate methidathion is used [23]. Methidathion is registered for kiwi under a Special Local Needs registration.
Mint:
The organophosphate insecticides chlorpyrifos and acephate are used to control cutworms in mint fields. Even low populations of cutworms will reduce plant vigor significantly or will kill plants through feeding on roots [24]. Currently, chlorpyrifos is the only insecticide registered for control of mint root borer and garden symphylans. The mint root borer weakens plants by feeding within the rhizomes, making these plants susceptible to winter injury. Garden symphylans is a severe pest in Oregon’s Willamette Valley [25]. It feeds on the fine roots of mint and can reduce mint yields in newly planted fields and destroy entire stands of mint.
Olives:
Efforts to control black scale in California olive orchards have encompassed one of the largest biological control programs ever attempted. Beginning in the 1890’s, about 70 species of natural controls have been introduced; however, none has proven to be effective [26]. Dormant oil treatments are effective against light to moderate populations. However, for heavy infestations, in the summer months, the organophosphate and carbamate insecticides diazinon and carbaryl are recommended.
Raspberries:
Most raspberries are machine harvested. Any insects shaken loose by machine harvesting contaminate the crop and can result in downgrading the product with a loss of up to $1,400 per acre [27]. Insecticide tests have indicated that the organophosphate insecticide malathion essentially reduces insect contamination of harvested raspberries to zero [28].
Soybeans:
Typically, insecticides are not used in Midwestern soybean fields. Parasites and diseases usually maintain insect populations well below the economic injury level [5]. However, in drought years, such as 1988, when high populations of spider mites develop, 30 percent of Midwestern soybean acreage has been treated, primarily with organophosphate insecticides, including chlorpyrifos and dimethoate in order to prevent substantial yield losses [6]. Insecticide use is more commonplace in Southern U.S. soybean fields, where insects typically arrive on winds from the Tropics. Insect populations in Southern soybean fields have developed a high level of resistance to pyrethroids and the most commonly used insecticides currently in Southeastern soybean fields are the organophosphate methyl parathion and the carbamates carbaryl, methomyl and thiodicarb [7].
Sugarbeets:
The sugarbeet root maggot is the most destructive insect pest of sugarbeets in the U.S. Adult female flies migrate to beet fields and deposit their eggs in the soil around small beet plants. A single female lays up to 200 eggs. The damage to the sugarbeet is done by the larvae. They scrape the root surface with their mouth hooks causing irregular scars that later become darkened from sap escaping from the injured root. Small tap roots can be severed completely, and such plants usually die [8]. Typically 85 to 90 percent of the sugarbeet acreage in the Red River Valley is treated with an application of an organophosphate insecticide (terbufos, chlorpyrifos) for control of the maggot [9]. Research has indicated that uncontrolled maggots can reduce beet yields by 42 percent in comparison to the most effective insecticide control. No commercially viable alternatives to insecticides are available currently to sugarbeet growers [10].
Sugarcane:
The sugarcane borer reduces sugar yield by causing retarded growth and stunted stalks, thus causing losses in plant weight (tonnage). Despite the repeated use of inorganic compounds, sugarcane fields in Louisiana lost about 13 percent of their annual cane yield to the sugarcane borer prior to 1960 [11]. Since the 1960’s, azinphos methyl has been the most commonly used insecticide for sugarcane borer control. Two azinphos methyl sprays substituted for 12 annual applications of the inorganic compounds. Currently, azinphos methyl is limited to one application per year and is used typically in combination with a pyrethroid. Applications of the pyrethroid can cause secondary outbreaks of aphids because of disruption of natural controls of aphids.
Sunflowers:
The primary insect pest targeted by ethyl parathion are seed weevils, that feed on pollen and deposit eggs within the developing seeds. The larvae consume the inner meat of the seed and there is considerable difficulty in separating undamaged from weevil-damaged seeds [12]. Pyrethroid insecticides are equally efficacious with ethyl parathion for early season applications; however, for late season applications, when the heads of the sunflower plants are drooping, ethyl parathion is considered more effective because of its volatility that allows penetration into the head from below.
Walnuts:
No adequate cultural or biological controls are currently available for managing codling moth in walnuts [29]. The organophosphate insecticide chlorpyrifos has been the most widely used insecticide since it is effective and is less toxic to beneficial organisms in the orchard [30]. The recent registrations of the insect growth regulators diflubenzuron and tebufenozide for codling moth in walnuts has provided growers with alternatives. However, these products do not control high worm populations and do not affect adult worms [31].
Wild Rice:
The organophosphate insecticide malathion is the only registered insecticide for controlling riceworm in Minnesota wild rice paddies. There are no cultural alternatives. Other chemicals researched have low efficacy. Replicated experiments in 1971 indicated that malathion reduced riceworm populations by 92 percent [32]. A single larva per plant will reduce wild rice yields by 11 percent [37].
Very few studies exist that project the effects of the potential removal of organophosphate and carbamate insecticides. Five studies recently have included an analysis of the potential impacts of banning certain organophosphate and carbamate insecticides. These estimates are for asparagus, cranberries, apples, rice and cotton.
Asparagus:
Special Local Needs Registrations permit the organophosphate insecticide disulfoton to be applied to asparagus in California and Washington for control of the asparagus aphid. This aphid was first detected in the West in 1979. The aphids feed by sucking plant juices, causing shrinking, dwarfing and death of asparagus shoots [38]. Natural enemies and diseases have kept the aphid under control in the Eastern U.S., but have not proven effective in the West. Washington State University recently concluded that [39]:
Loss of disulfoton would result in total collapse of the California and Washington asparagus industry unless a replacement compound could be made available within one or two years.
Cranberries:
There are many species of insects that affect the roots, shoots and fruit of the cranberry plant. The University of Wisconsin recently concluded that the loss of organophosphate insecticides would have a major impact on U.S. cranberry production [40]:
If the four major insecticides, chlorpyrifos, diazinon, azinphos methyl and acephate, were no longer available . . . in most places yields would be significantly reduced since the remaining insecticides are not as effective and cultural or biological alternatives do not provide as good or as fast control as the chemicals. At least half of the crop could be lost to direct pests alone, the first year in East Coast beds, with yield reductions of 15 to 50 percent estimated elsewhere. In subsequent years, pest pressure would be higher, and losses more severe, enough to drive many growers out of business.
Apples
Currently, azinphos methyl and other organophosphates are used to control most of the major insect pests of Michigan apple orchards, including codling moth, apple maggot, plum curculio, leafrollers, leafhoppers and oriental fruit moth. A recent study from Michigan State University estimated that currently eight organophosphate insecticide sprays are applied at a cost of $125/A. The MSU study simulated two replacement strategies for organophosphates. In the first strategy, growers would use eight applications of a pyrethroid – esfenvalerate. However, since the pyrethroid would destroy beneficial mite predators, resulting mite problems would require three applications of miticides. The total cost of this scenario is $201/A. The resulting mite problems would only be partial controllable with the available miticides and increased mite damage would result in losses of 20 percent of marketable yield, as well as shifting 17 percent of the remaining yield from fresh apples to lower priced processing uses [45]. In a second scenario, mating disruption is used to control codling moth. Synthetic pheromones confuse male codling moths and overwhelm their ability to detect pheromone scent from real females. This scenario also relies on three late-season applications of esfenvalerate plus two applications of BT and two miticide applications. The total cost of this scenario is $341/A. Uneven codling moth control is estimated to result in a 10 percent yield reduction compared to current controls with organophosphates and a 27 percent shift from fresh market to processing use.
Rice:
Organophosphates and carbamates are used as insecticides on 28 percent of U.S. rice acreage. Target pests include stinkbugs and rice water weevil. The University of Arkansas recently estimated that without the use of these insecticides, rice yields would decline by 6 to 30 percent [41]. The main non-chemical alternative is water management, to flood or dry out insect pests. Weather variations from year to year would lead to varying impacts.
Cotton
U.S. cotton growers rely on organophosphate and carbamate insecticides to control a wide variety of insect pests – bollworms, budworms, fleahoppers, aphids, boll weevils, lygus bugs, loopers, thrips, leafhoppers, cutworms, whiteflies and armyworms. The USDA has estimated that without carbamates U.S. cotton production would decline by 4 percent, while without organophosphate insecticides the decline in U.S. cotton production would be 8 percent [44]. These estimates assume that growers would use available substitutes.
In recent years, USEPA has banned or suspended several uses of organophosphate and carbamate insecticides. In some cases severe economic effects did not occur, even though a widely used organophosphate insecticide was banned because growers switched to using another organophosphate insecticide as a replacement. Such a replacement will not be allowable under FQPA’s assessment of cumulative risks of all the pesticides with a common mechanism of toxicity. In other cases, serious economic effects did occur, prompting the USEPA to restore a suspended use.
Lettuce:
Following the USEPA ban of the organophosphate insecticide ethyl parathion for use in California lettuce fields, growers switched to another organophosphate insecticide diazinon, that increased their insecticide costs by about $50 per acre. Since diazinon had less efficacy in controlling a key pest, the lettuce root aphid, the State of California took the drastic step of cutting down all poplar trees near lettuce fields (The poplar trees are an alternate host for the aphids).
Potatoes:
The carbamate insecticide aldicarb was removed voluntarily for use on potatoes after detection of residues over tolerance. Following research to identify application methods whereby the product could be used without a residue problem, aldicarb was restored for use on potatoes in the Pacific Northwest and Florida. Washington State University estimated the increased cost caused by the loss of aldicarb to the Washington State potato industry. This included the substitution of two or three aerial applications of insecticides for a single aldicarb application at planting [36]. The substituted alternatives did not prove as efficacious in controlling green peach aphid, an insect that transmits a virus that results in a potato disease known as net necrosis. The aggregate loss to the Washington State potato industry from the increase in net necrosis was estimated by Washington State University at $36 million [36].
Several organophosphate insecticides play a key role in reducing toxic contaminant levels in foods by controlling insects that spread aflatoxin. If the organophosphate registrations are removed, growers of peanuts, pistachios and almonds would have less effective insecticides to control the insects that spread aflatoxin. For pesticides with non-threshold effects risk concerns, FQPA instructs EPA to consider whether the removal of pesticide registrations would lead to a greater health risk. For pesticides with threshold human health risk concerns (such as organophosphates and carbamates), FQPA makes no allowance for the possibility that canceling a pesticide use might lead to a greater risk to human health than the risk posed by the pesticide.
Aflatoxins are powerful, tasteless, odorless and colorless mycotoxins that are chemical metabolites produced by certain strains of Aspergillus fungi. Aflatoxins are mutagenic, carcinogenic, teratogenic, and acutely toxic to most animals and humans. They can cause animals, including humans, to lose their appetites, decrease their feed efficiency and/or cause death. Aflatoxins inhibit the body’s immune system and reduce the effects of vaccines. Concern exists for possible adverse effects from long-term exposure to low levels of aflatoxins in food [35]. In the U.S., the aflatoxins are the only mycotoxins that are specifically regulated by FDA. The allowable residue level of aflatoxin is 20 ppb total aflatoxins, with the exception of milk that has a action level of .5ppb [34].
Almonds:
Aflatoxins are associated with almond kernels damaged by navel orangeworm larvae. Research has shown that the most direct means of controlling aflatoxin contamination of almonds is to reduce insect damage [33]. The current recommendation for insect control in almond orchards is to spray almond trees every year in the winter with a dormant spray of oil and organophosphate insecticides [2].
Pistachios:
Navel orangeworm infected kernels account for 84 percent of aflatoxin in pistachios according to research conducted by the University of California [21]. The organophosphate insecticide azinphos methyl is the preferred compound for navel orangeworm control because of its longer residual and effectiveness in the control of hatching navel orangeworms.
Peanuts:
Peanuts are frequently contaminated by aflatoxin if the pods develop during hot conditions, and/or if the pods are partially eaten by an insect – the lesser cornstalk borer. This eating provides a point of entry for the aflatoxin producing fungi. Research has found a 94 percent correlation between damage caused by the lesser cornstalk borer and the number of aflatoxin producing fungi [42]. The organophosphate insecticide chlorpyrifos reduces the insect population by about 80 percent while the most efficacious non-organophosphate insecticide reduces the populations by about 40 percent [43].
CONCLUSIONS
The organophosphate and carbamate classes of insecticides are extremely important for insect control for many crops grown in the U.S. Collectively, these two classes of chemistry are applied to 70 percent of the acreage treated with insecticides in the U.S. For 11 crops the organophosphate and carbamate products are the only ones used currently. Two crops, corn and cotton, account for 50 percent of the poundage of organophosphate and carbamate insecticides used in U.S. crop production. Twenty-four crops account for 95 percent of the poundage of organophosphate and carbamate insecticides while 60 crops, collectively, account for the remaining 5 percent of national use.
For many small acreage fruit, nut and vegetable crops, the organophosphate and carbamate insecticides have been the main means of controlling key pests for several decades. Although considerable research has been conducted to find alternatives for crops like kiwi, date, figs, avocados, wild rice and olives, the organophosphate and carbamate products remain the primary means of controlling key pests.
Although only a few projections have been made regarding the potential impacts of banning the organophosphate and carbamate insecticides, the available reports for cranberries, rice and asparagus indicate that severe declines in production likely would occur.
Although FQPA does not allow EPA to consider the benefits of a pesticide’s use when acute dietary risks are the concern, a prudent course of action would be for the Agency to conduct cost effective rulemaking. For example, it may be prudent to preserve organophosphate registrations for pistachios, peanut and almonds in order to prevent increased amounts of aflatoxin. Likewise, a careful examination of each use site for organophosphates and carbamates would indicate to the Agency which crops are most dependent and have fewest alternatives. Although the outcomes of the risk analyses of EPA’s proposals are unknown at this time, it may be that U.S. growers, potentially, could lose many organophosphate and carbamate uses because of these concerns.
As a result, U.S. growers of many crops may lose the most effective pesticides to control key pests, and crop losses may occur. Resistance to the remaining insecticides may accelerate. It is likely that USEPA would face a large number of emergency exemption requests to replace lost organophosphate or carbamate uses.
An alternatives database needs to be developed to help guide EPA decision making. For each use of organophosphates and carbamates, the key pests and control efficacies of available alternatives need to be identified.
Aggregate economic analysis needs to be undertaken so that policy makers and regulators can gain an appreciation of the magnitude of the impacts that may result from FQPA implementation.
10. REFERENCES
|
TABLE 1 |
||
|
Organophosphate and Carbamate Insecticides Used in U.S. Crop Production |
||
|
Active Ingredient |
Trade Name(s) |
Major Crop Uses |
|
Organophosphates |
||
|
Acephate |
Orthene, Payload |
Cotton, Lettuce, Tobacco |
|
Azinphos Methyl |
Guthion, Sniper |
Cotton, Apples, Sugarcane |
|
Chlorpyrifos |
Lorsban |
Corn, Cotton, Alfalfa |
|
Diazinon |
D-Z-N |
Alfalfa, Lettuce, Corn |
|
Dicrotophos |
Bidrin |
Cotton |
|
Dimethoate |
Cygon |
Alfalfa, Cotton, Wheat |
|
Disulfoton |
Di-syston |
Corn, Cotton, Wheat |
|
Ethion |
Ethion |
Citrus |
|
Ethoprop |
Mocap |
Potatoes, Tobacco, Peanuts |
|
Ethyl Parathion |
Alfalfa, Sorghum, Sunflowers |
|
|
Fenamiphos |
Nemacur |
Tobacco, Cotton, Grapes |
|
Fonofos |
Dyfonate |
Corn, Peanuts, Potatoes |
|
Malathion |
Cythion |
Alfalfa, Cotton, Sorghum |
|
Methamidophos |
Monitor |
Cotton, Potatoes, Tomatoes |
|
Methidathion |
Supracide |
Almonds, Citrus, Plums |
|
Methyl Parathion |
Penncap M |
Corn, Cotton, Wheat |
|
Naled |
Dibrom, Legion |
Cotton, Grapes, Citrus |
|
Oxydemeton Methyl |
Metasystox R |
Cotton, Broccoli, Cauliflower |
|
Phorate |
Thimet |
Corn, Cotton, Potatoes |
|
Phosmet |
Imidian |
Apples, Alfalfa, Potatoes |
|
Profenofos |
Curacron |
Cotton |
|
Sulprofos |
Bolstar |
Cotton |
|
Terbufos |
Counter |
Corn, Sorghum, Sugarbeets |
|
Carbamates |
||
|
Aldicarb |
Temik |
Cotton, Peanuts, Sugarbeets |
|
Carbaryl |
Sevin |
Alfalfa, Apples, Corn |
|
Carbofuran |
Furadan |
Alfalfa, Corn, Rice |
|
Formetanate HCL |
Carzol |
Citrus, Apples, Nectarines |
|
Methomyl |
Lannate |
Cotton, Sorghum, Peanuts |
|
Oxamyl |
Vydate |
Cotton, Apples, Potatoes |
|
Thiodicarb |
Larvin |
Cotton, Soybeans, Sweet Corn |
TABLE 2 ORGANOPHOSPHATE INSECTICIDE USE
ACTIVE CROP ACRES % ACRES ACRES
INGREDIENT PLANTED TREATED TREATED
ACEPHATE
CAULIFLOWER 60324 13 7546
CELERY 34649 44 15222
COTTON 11120700 15 1697085
CRANBERRIES 28600 34 9806
DRY BEANS 1802394 2 44645
GREEN BEANS 304152 28 86243
GREEN PEAS 385617 1 4930
LETTUCE 272242 59 161308
MINT 153542 50 77119
PEANUTS 1651000 10 167610
SOYBEANS 58414278 <1 94600
SWEET PEPPERS 77481 41 31444
TOBACCO 784770 96 752652
AZINPHOS-METHYL
ALFALFA 24276084 <1 13099
ALMONDS 390000 31 120900
APPLES 497903 72 360067
APRICOTS 17800 4 712
BARLEY 7338164 <1 900
BLACKBERRIES 5045 12 581
BLUEBERRIES 56153 39 21982
BRUSSEL SPROUTS 3000 1 30
CABBAGE 87688 9 8098
CANTALOUPES 112749 3 2990
CAULIFLOWER 60324 1 549
CELERY 34649 4 1376
CHERRIES 99543 29 28950
CITRUS 878300 1 7796
COTTON 11120700 16 1769000
CRANBERRIES 28600 43 12306
CUCUMBERS 145697 <1 662
EGGPLANT 4633 1 39
GRAPES 764921 1 6839
GREEN ONIONS 22300 3 630
GREEN PEAS 385617 <1 575
HAZELNUTS 26800 17 4556
MELONS 25600 18 4680
NECTARINES 27100 8 2168
ONIONS 151676 1 1844
PEACHES 183815 34 62070
PEARS 72226 79 57370
PECANS 444823 2 10966
PISTACHIOS 51800 39 20202
PLUMS 135095 7 9851
1
ACTIVE CROP ACRES % ACRES ACRES
INGREDIENT PLANTED TREATED TREATED
POMEGRANATES 3449 6 207
POTATOES 1326000 15 197079
RASPBERRIES 13266 8 1109
SPINACH 38560 3 1224
SQUASH 53457 1 332
STRAWBERRIES 57778 11 6222
SUGARCANE 857300 25 211800
SWEET PEPPERS 77481 2 1773
TOMATOES 413361 3 11558
WALNUTS 183996 24 43440
CHLORPYRIFOS
ALFALFA 24276084 6 1367296
ALMONDS 390000 31 120900
APPLES 497903 57 283227
ASPARAGUS 89653 35 31376
AVOCADOS 81300 3 2187
BEETS 11640 2 282
BROCCOLI 120427 36 43489
BRUSSEL SPROUTS 3000 90 2700
CABBAGE 87688 27 23585
CAULIFLOWER 60324 56 33661
CHERRIES 99543 7 6934
CITRUS 878300 23 201405
COLLARDS 11328 12 1371
CORN 78156196 9 6801980
COTTON 11120700 10 1070892
CRANBERRIES 28600 44 12471
DRY BEANS 1802394 <1 774
GRAPES 764921 1 9870
GREEN BEANS 304152 <1 1125
GREEN PEAS 385617 2 7388
HAZELNUTS 26800 39 10452
HOPS 39553 11 4386
MINT 153542 27 42069
NECTARINES 27100 17 4607
ONIONS 151676 19 28676
PEACHES 183815 28 51622
PEANUTS 1651000 37 610240
PEARS 72226 13 9334
PECANS 444823 39 173614
PLUMS 135095 7 9938
RADISHES 37253 19 6989
SEED CROPS 1516139 3 44267
SOD 152438 6 9612
SORGHUM 12183011 5 607571
SOYBEANS 58414278 1 298300
STRAWBERRIES 57778 15 8954
SUGARBEETS 1411000 22 314140
SUNFLOWERS 2044491 1 15096
2
ACTIVE CROP ACRES % ACRES ACRES
INGREDIENT PLANTED TREATED TREATED
SWEET CORN 761045 14 105265
SWEET POTATOES 84768 53 45164
TOBACCO 784770 37 291640
TOMATOES 413361 4 16480
WALNUTS 183996 58 106790
WHEAT 62407000 1 692200
DIAZINON
ALFALFA 24276084 <1 107400
ALMONDS 390000 24 93600
APPLES 497903 5 23898
APRICOTS 17800 62 11036
BEETS 11640 35 4076
BLACKBERRIES 5045 12 606
BLUEBERRIES 56153 11 6333
BROCCOLI 120427 20 24189
BRUSSEL SPROUTS 3000 90 2700
CABBAGE 87688 16 14136
CANTALOUPES 112749 12 13590
CARROTS 109640 16 17659
CAULIFLOWER 60324 21 12474
CELERY 34649 14 4768
CHERRIES 99543 12 11991
CITRUS 878300 3 25811
COLLARDS 11328 19 2142
CORN 78156196 <1 84570
COTTON 11120700 <1 11050
CRANBERRIES 28600 48 13847
CUCUMBERS 145697 4 5607
DRY PEAS 249191 2 4767
EGGPLANT 4633 4 189
FIGS 14400 17 2448
GRAPES 764921 5 37353
GREEN BEANS 304152 4 11705
GREEN ONIONS 22300 5 1170
GREEN PEAS 385617 4 15791
HAZELNUTS 26800 6 1608
HOPS 39553 63 25018
HOT PEPPERS 22700 <1 97
LETTUCE 272242 34 92263
MELONS 25600 36 9240
NECTARINES 27100 45 12195
OLIVES 30100 2 602
ONIONS 151676 14 20966
PARSLEY 1550 4 62
PEACHES 183815 11 19998
PEARS 72226 15 10669
PECANS 444823 1 6547
PLUMS 135095 28 38394
POTATOES 1326000 1 7896
3
ACTIVE CROP ACRES % ACRES ACRES
INGREDIENT PLANTED TREATED TREATED
PUMPKINS 33833 <1 79
RADISHES 37253 4 1347
RASPBERRIES 13266 17 2311
SOD 152438 <1 356
SORGHUM 12183011 <1 24621
SPINACH 38560 16 6063
SQUASH 53457 4 2363
STRAWBERRIES 57778 12 7065
SUGARBEETS 1411000 5 68350
SWEET CORN 761045 3 26303
SWEET PEPPERS 77481 4 2912
SWEET POTATOES 84768 9 7323
TOBACCO 784770 3 21410
TOMATOES 413361 9 36136
WALNUTS 183996 7 13449
WATERMELONS 258197 2 5961
WHEAT 62407000 <1 200
DICROTOPHOS
COTTON 11120700 22 2468909
DIMETHOATE
ALFALFA 24276084 5 1212050
APPLES 497903 15 75067
BARLEY 7338164 <1 13390
BROCCOLI 120427 22 26780
CABBAGE 87688 25 21788
CANTALOUPES 112749 11 11885
CAULIFLOWER 60324 19 11494
CHERRIES 99543 9 9159
CITRUS 878300 12 108584
COLLARDS 11328 25 2882
CORN 78156196 1 523922
COTTON 11120700 14 1604002
CUCUMBERS 145697 2 2394
DRY BEANS 1802394 4 68488
DRY PEAS 249191 2 5567
GRAPES 764921 <1 3410
GREEN BEANS 304152 13 40422
GREEN PEAS 385617 27 103506
HOT PEPPERS 22700 3 682
LETTUCE 272242 49 134616
MELONS 25600 35 8884
OATS 4524882 <1 17350
ONIONS 151676 <1 228
PEARS 72226 2 1694
PECANS 444823 16 72333
POTATOES 1326000 2 31456
SAFFLOWER 112665 19 21043
SEED CROPS 1516139 <1 4411
4
ACTIVE CROP ACRES % ACRES ACRES
INGREDIENT PLANTED TREATED TREATED
SORGHUM 12183011 5 561384
SOYBEANS 58414278 <1 76200
SPINACH 38560 6 2324
SQUASH 53457 3 1786
SWEET CORN 761045 <1 380
SWEET PEPPERS 77481 22 16780
TOMATOES 413361 8 34089
WATERMELONS 258197 6 15963
WHEAT 62407000 2 1140060
DISULFOTON
ASPARAGUS 89653 35 31732
BARLEY 7338164 1 43090
BROCCOLI 120427 11 13038
BRUSSEL SPROUTS 3000 84 2520
CABBAGE 87688 3 2848
CAULIFLOWER 60324 27 16544
CORN 78156196 <1 214800
COTTON 11120700 6 616058
DRY BEANS 1802394 <1 5957
DRY PEAS 249191 2 4972
GREEN BEANS 304152 11 32626
GREEN PEAS 385617 <1 858
LETTUCE 272242 6 16861
OATS 4524882 <1 2950
PEANUTS 1651000 7 118380
PECANS 444823 4 19778
POTATOES 1326000 6 80195
SORGHUM 12183011 2 208968
SOYBEANS 58414278 <1 13800
SWEET PEPPERS 77481 3 2000
TOBACCO 784770 2 13230
TOMATOES 413361 1 5560
WATERMELONS 258197 <1 12
WHEAT 62407000 1 697100
ETHION
APPLES 497903 1 3898
AVOCADOS 81300 2 1680
CITRUS 878300 29 257114
MELONS 25600 1 360
ONIONS 151676 8 12300
PECANS 444823 2 9128
ETHOPROP
CABBAGE 87688 1 575
CUCUMBERS 145697 1 836
GREEN BEANS 304152 4 10936
PEANUTS 1651000 1 24600
POTATOES 1326000 11 148532
SUGARCANE 857300 5 39190
5
ACTIVE CROP ACRES % ACRES ACRES
INGREDIENT PLANTED TREATED TREATED
SWEET CORN 761045 3 26281
SWEET POTATOES 84768 15 12565
TOBACCO 784770 13 101907
ETHYL PARATHION
ALFALFA 24276084 3 736400
BARLEY 7338164 1 46380
CANOLA 39206 <1 121
CORN 78156196 1 461540
COTTON 11120700 3 345400
OATS 4524882 <1 7350
RYE 386366 1 3462
SORGHUM 12183011 6 710754
SOYBEANS 58414278 <1 249300
SUNFLOWERS 2044491 24 488885
WHEAT 62407000 1 381730
FENAMIPHOS
BROCCOLI 120427 14 16490
BRUSSEL SPROUTS 3000 13 390
CABBAGE 87688 6 4905
CAULIFLOWER 60324 13 7819
CITRUS 878300 1 12335
COTTON 11120700 1 83974
GRAPES 764921 8 59004
KIWI 7100 9 639
NECTARINES 27100 3 813
PEACHES 183815 1 1267
PEANUTS 1651000 1 19780
RASPBERRIES 13266 6 765
TOBACCO 784770 29 225942
FONOFOS
ASPARAGUS 89653 5 4690
BEETS 11640 3 372
BROCCOLI 120427 2 2627
CABBAGE 87688 1 728
CAULIFLOWER 60324 6 3422
CORN 78156196 3 2248570
DRY BEANS 1802394 <1 3079
GREEN BEANS 304152 6 18073
HOT PEPPERS 22700 3 682
MINT 153542 21 32202
ONIONS 151676 2 2721
PEANUTS 1651000 10 157040
POTATOES 1326000 4 47780
RADISHES 37253 5 1823
SEED CROPS 1516139 <1 4022
SORGHUM 12183011 <1 1680
STRAWBERRIES 57778 <1 62
SUGARBEETS 1411000 1 17980
6
ACTIVE CROP ACRES % ACRES ACRES
INGREDIENT PLANTED TREATED TREATED
SUGARCANE 857300 <1 393
SWEET CORN 761045 4 31408
SWEET PEPPERS 77481 4 3230
SWEET POTATOES 84768 17 14355
TOBACCO 784770 1 8106
TOMATOES 413361 4 16680
MALATHION
ALFALFA 24276084 2 564000
APPLES 497903 10 51975
ASPARAGUS 89653 6 5710
AVOCADOS 81300 <1 336
BARLEY 7338164 1 41310
BEETS 11640 1 174
BLACKBERRIES 5045 28 1419
BLUEBERRIES 56153 32 17959
BROCCOLI 120427 6 7781
CABBAGE 87688 1 928
CANOLA 39206 <1 81
CANTALOUPES 112749 9 9730
CARROTS 109640 6 6839
CAULIFLOWER 60324 3 1687
CELERY 34649 7 2580
CHERRIES 99543 16 16414
CITRUS 878300 <1 3700
COLLARDS 11328 2 185
CORN 78156196 <1 15720
COTTON 11120700 7 795517
CRANBERRIES 28600 1 378
CUCUMBERS 145697 2 2290
DATES 5200 75 3900
DRY PEAS 249191 3 7953
EGGPLANT 4633 3 121
FIGS 14400 1 144
GARLIC 25377 1 230
GRAPES 764921 1 7382
GREEN BEANS 304152 1 1783
GREEN ONIONS 22300 9 1980
GREEN PEAS 385617 1 4572
HOT PEPPERS 22700 1 146
LETTUCE 272242 4 11694
MELONS 25600 13 3420
MINT 153542 8 12772
OATS 4524882 1 26559
OKRA 3226 21 689
ONIONS 151676 10 15519
PEACHES 183815 2 4443
PEANUTS 1651000 <1 2590
PECANS 444823 3 11987
POTATOES 1326000 <1 858
7
ACTIVE CROP ACRES % ACRES ACRES
INGREDIENT PLANTED TREATED TREATED
PUMPKINS 33833 6 1954
RADISHES 37253 <1 51
RASPBERRIES 13266 47 6175
RICE 3130000 4 136460
RYE 386366 <1 7
SORGHUM 12183011 2 190170
SPINACH 38560 5 2031
SQUASH 53457 2 1247
STRAWBERRIES 57778 19 11044
SUGARBEETS 1411000 2 32870
SUNFLOWERS 2044491 1 30200
SWEET CORN 761045 <1 414
SWEET PEPPERS 77481 <1 315
TOBACCO 784770 1 6291
TOMATOES 413361 2 6317
WALNUTS 183996 5 8426
WATERMELONS 258197 1 3740
WHEAT 62407000 <1 133500
WILD RICE 24198 27 6533
METHAMIDOPHOS
ALFALFA 24276084 <1 48000
BEETS 11640 4 417
BROCCOLI 120427 11 13146
BRUSSEL SPROUTS 3000 82 2460
CABBAGE 87688 25 22018
CANTALOUPES 112749 19 21690
CAULIFLOWER 60324 5 2978
CELERY 34649 21 7362
COTTON 11120700 4 445665
CUCUMBERS 145697 1 2024
EGGPLANT 4633 26 1215
HOT PEPPERS 22700 1 244
LETTUCE 272242 4 11198
MELONS 25600 16 4044
POTATOES 1326000 23 310941
SUGARBEETS 1411000 4 51000
SWEET PEPPERS 77481 6 4472
TOMATOES 413361 31 126152
WATERMELONS 258197 6 14814
METHIDATHION
ALFALFA 24276084 <1 28800
ALMONDS 390000 16 62400
APPLES 497903 3 14735
APRICOTS 17800 10 1780
ARTICHOKES 9400 90 8460
CHERRIES 99543 2 2350
CITRUS 878300 4 32728
COTTON 11120700 <1 22100
8
ACTIVE CROP ACRES % ACRES ACRES
INGREDIENT PLANTED TREATED TREATED
KIWI 7100 13 923
NECTARINES 27100 19 5149
OLIVES 30100 1 301
PEACHES 183815 12 22949
PEARS 72226 5 3773
PECANS 444823 1 6290
PLUMS 135095 22 29645
SAFFLOWER 112665 42 47623
SUNFLOWERS 2044491 <1 1932
TOBACCO 784770 <1 85
WALNUTS 183996 10 18100
METHYL PARATHION
ALFALFA 24276084 2 535964
APPLES 497903 21 105016
ARTICHOKES 9400 7 658
BARLEY 7338164 <1 4350
BROCCOLI 120427 2 1810
BRUSSEL SPROUTS 3000 4 120
CABBAGE 87688 6 4866
CANTALOUPES 112749 1 780
CARROTS 109640 2 1800
CAULIFLOWER 60324 1 436
CELERY 34649 1 494
CHERRIES 99543 9 8633
COLLARDS 11328 10 1107
CORN 78156196 2 1356520
COTTON 11120700 24 2619464
CUCUMBERS 145697 <1 287
DRY BEANS 1802394 <1 8317
DRY PEAS 249191 <1 264
GRAPES 764921 2 12220
GREEN BEANS 304152 11 34444
GREEN PEAS 385617 1 3316
LETTUCE 272242 1 3890
NECTARINES 27100 7 1897
OATS 4524882 <1 13350
ONIONS 151676 19 28114
OTHER HAY 28111089 <1 37500
PEACHES 183815 22 41077
PEARS 72226 2 1284
PECANS 444823 4 17168
PLUMS 135095 2 2444
POTATOES 1326000 3 36387
RICE 3130000 10 304300
SOYBEANS 58414278 <1 257100
SPINACH 38560 3 1137
STRAWBERRIES 57778 <1 50
SUGARBEETS 1411000 1 12000
SUNFLOWERS 2044491 6 130970
9
ACTIVE CROP ACRES % ACRES ACRES
INGREDIENT PLANTED TREATED TREATED
SWEET CORN 761045 10 74663
SWEET PEPPERS 77481 1 616
TOMATOES 413361 1 3090
WATERMELONS 258197 5 12540
WHEAT 62407000 1 620100
NALED
ALFALFA 24276084 <1 16200
BROCCOLI 120427 4 4850
BRUSSEL SPROUTS 3000 33 990
CABBAGE 87688 10 8557
CANTALOUPES 112749 1 640
CAULIFLOWER 60324 3 1735
CELERY 34649 6 2076
CITRUS 878300 2 17269
COLLARDS 11328 6 669
COTTON 11120700 <1 44200
DRY BEANS 1802394 <1 1539
DRY PEAS 249191 <1 515
GRAPES 764921 10 78672
GREEN BEANS 304152 <1 1035
GREEN PEAS 385617 <1 427
SAFFLOWER 112665 20 22150
SEED CROPS 1516139 1 12065
STRAWBERRIES 57778 6 3464
SUGARBEETS 1411000 <1 5350
WALNUTS 183996 1 1810
OXYDEMETON-METHYL
BEETS 11640 1 157
BROCCOLI 120427 56 66863
BRUSSEL SPROUTS 3000 90 2700
CABBAGE 87688 10 8591
CANTALOUPES 112749 12 13365
CAULIFLOWER 60324 56 33672
CORN 78156196 <1 1320
COTTON 11120700 2 217626
CUCUMBERS 145697 2 2922
EGGPLANT 4633 3 146
GREEN BEANS 304152 <1 552
GREEN PEAS 385617 <1 1904
HAZELNUTS 26800 3 804
HOT PEPPERS 22700 3 779
LETTUCE 272242 4 9725
MELONS 25600 33 8460
MINT 153542 13 20014
ONIONS 151676 2 3214
POTATOES 1326000 <1 1074
PUMPKINS 33833 4 1359
RASPBERRIES 13266 8 1071
10
ACTIVE CROP ACRES % ACRES ACRES
INGREDIENT PLANTED TREATED TREATED
SEED CROPS 1516139 2 32172
SORGHUM 12183011 <1 10367
SQUASH 53457 6 2975
STRAWBERRIES 57778 7 4020
SUGARBEETS 1411000 1 14350
SWEET CORN 761045 <1 2910
SWEET PEPPERS 77481 2 1200
WALNUTS 183996 1 1810
WATERMELONS 258197 3 8796
PHORATE
CORN 78156196 2 1808790
COTTON 11120700 4 418294
DRY BEANS 1802394 <1 5981
GREEN BEANS 304152 4 12393
HOPS 39553 1 565
PEANUTS 1651000 9 141780
POTATOES 1326000 30 394090
SORGHUM 12183011 1 113240
SUGARBEETS 1411000 4 52490
SUGARCANE 857300 10 84170
SWEET CORN 761045 3 25661
WHEAT 62407000 <1 196150
PHOSMET
ALFALFA 24276084 1 130900
ALMONDS 390000 4 15600
APPLES 497903 26 130173
APRICOTS 17800 1 178
BLUEBERRIES 56153 3 1623
CHERRIES 99543 12 12064
DRY PEAS 249191 9 22281
GRAPES 764921 5 41327
GREEN PEAS 385617 5 19115
KIWI 7100 5 355
NECTARINES 27100 18 4878
PEACHES 183815 17 30579
PEARS 72226 33 24007
PLUMS 135095 9 11613
POTATOES 1326000 4 48685
PROFENOFOS
COTTON 11120700 16 1788574
SULPROFOS
COTTON 11120700 6 636885
TERBUFOS
CORN 78156196 9 7205810
SORGHUM 12183011 2 276430
SUGARBEETS 1411000 30 424180
11
ACTIVE CROP ACRES % ACRES ACRES
INGREDIENT PLANTED TREATED TREATED
SWEET CORN 761045 7 53400
TABLE 3 CARBAMATE INSECTICIDE USE
ACTIVE CROP ACRES % ACRES ACRES
INGREDIENT PLANTED TREATED TREATED
ALDICARB
CITRUS 878300 12 104712
COTTON 11120700 25 2738993
DRY BEANS 1802394 1 19249
PEANUTS 1651000 48 788210
PECANS 444823 4 18654
SORGHUM 12183011 <1 45000
SUGARBEETS 1411000 11 157550
SWEET POTATOES 84768 3 2799
TOBACCO 784770 9 70686
CARBARYL
ALFALFA 24276084 1 360683
ALMONDS 390000 1 3900
APPLES 497903 36 179894
APRICOTS 17800 9 1602
ASPARAGUS 89653 30 26669
BARLEY 7338164 <1 9060
BEETS 11640 17 1964
BLACKBERRIES 5045 33 1645
BLUEBERRIES 56153 50 27836
BROCCOLI 120427 4 4341
CABBAGE 87688 4 3200
CANOLA 39206 <1 121
CANTALOUPES 112749 7 8198
CARROTS 109640 4 4291
CAULIFLOWER 60324 4 2265
CELERY 34649 3 1200
CHERRIES 99543 12 11890
CITRUS 878300 2 17086
COLLARDS 11328 4 421
CORN 78156196 <1 353170
COTTON 11120700 <1 22100
CRANBERRIES 28600 39 11146
CUCUMBERS 145697 14 20446
DRY BEANS 1802394 1 11684
DRY PEAS 249191 3 6270
EGGPLANT 4633 5 212
FLAX 164000 1 1400
GRAPES 764921 14 103314
GREEN BEANS 304152 23 68932
GREEN PEAS 385617 2 6136
HAZELNUTS 26800 4 1072
LETTUCE 272242 1 2473
MELONS 25600 70 18000
NECTARINES 27100 18 4878
1
ACTIVE CROP ACRES % ACRES ACRES
INGREDIENT PLANTED TREATED TREATED
OATS 4524882 1 23300
OKRA 3226 32 1044
OLIVES 30100 11 3311
ONIONS 151676 1 1377
OTHER HAY 28111089 1 384900
PEACHES 183815 25 45090
PEANUTS 1651000 8 129090
PEARS 72226 3 1818
PECANS 444823 23 101654
PISTACHIOS 51800 17 8806
PLUMS 135095 5 6482
POTATOES 1326000 3 36636
PUMPKINS 33833 38 12952
RASPBERRIES 13266 5 628
SAFFLOWER 112665 1 1108
SOD 152438 <1 216
SORGHUM 12183011 2 218582
SOYBEANS 58414278 1 332800
SQUASH 53457 11 6012
STRAWBERRIES 57778 17 9787
SUGARBEETS 1411000 4 55300
SUNFLOWERS 2044491 1 28266
SWEET CORN 761045 4 27152
SWEET PEPPERS 77481 13 10034
SWEET POTATOES 84768 18 15658
TOBACCO 784770 2 13286
TOMATOES 413361 18 76470
WALNUTS 183996 1 1810
WATERMELONS 258197 13 32809
WHEAT 62407000 <1 77850
CARBOFURAN
ALFALFA 24276084 9 2193880
ARTICHOKES 9400 60 5640
BARLEY 7338164 <1 7200
CANTALOUPES 112749 1 849
CORN 78156196 3 2697340
CRANBERRIES 28600 1 168
CUCUMBERS 145697 9 13671
GRAPES 764921 3 26266
HOT PEPPERS 22700 12 2674
OATS 4524882 <1 6113
POTATOES 1326000 16 213173
PUMPKINS 33833 6 2016
RICE 3130000 14 434000
SEED CROPS 1516139 <1 649
SORGHUM 12183011 4 460560
SOYBEANS 58414278 <1 13800
SQUASH 53457 5 2496
STRAWBERRIES 57778 5 2999
2
ACTIVE CROP ACRES % ACRES ACRES
INGREDIENT PLANTED TREATED TREATED
SUGARBEETS 1411000 4 57980
SUGARCANE 857300 6 53254
SUNFLOWERS 2044491 1 29713
SWEET CORN 761045 6 47838
SWEET PEPPERS 77481 2 1343
TOBACCO 784770 5 41537
WATERMELONS 258197 3 8102
WHEAT 62407000 <1 29700
FORMETANATE HCL
ALFALFA 24276084 <1 9600
APPLES 497903 13 65638
CITRUS 878300 16 137325
NECTARINES 27100 89 24119
PEACHES 183815 3 5826
PEARS 72226 12 8489
PLUMS 135095 1 1222
METHOMYL
ALFALFA 24276084 1 209824
APPLES 497903 21 106918
ASPARAGUS 89653 15 13255
BARLEY 7338164 <1 7200
BEETS 11640 6 683
BLUEBERRIES 56153 18 10066
BROCCOLI 120427 13 15057
BRUSSEL SPROUTS 3000 1 30
CABBAGE 87688 36 31391
CANTALOUPES 112749 8 9358
CARROTS 109640 7 7429
CAULIFLOWER 60324 30 18260
CELERY 34649 64 22247
CITRUS 878300 3 27137
COLLARDS 11328 19 2207
CORN 78156196 <1 270870
COTTON 11120700 9 990364
CUCUMBERS 145697 17 24677
DRY BEANS 1802394 1 10776
DRY PEAS 249191 1 1501
EGGPLANT 4633 44 2051
GARLIC 25377 13 3220
GRAPES 764921 15 112019
GREEN BEANS 304152 19 56735
GREEN ONIONS 22300 11 2430
GREEN PEAS 385617 4 13834
HOT PEPPERS 22700 1 292
LETTUCE 272242 48 130302
MELONS 25600 11 2700
MINT 153542 10 16087
NECTARINES 27100 45 12195
3
ACTIVE CROP ACRES % ACRES ACRES
INGREDIENT PLANTED TREATED TREATED
OATS 4524882 <1 5438
ONIONS 151676 16 24854
OTHER HAY 28111089 <1 62500
PARSLEY 1550 19 294
PEACHES 183815 7 13000
PEANUTS 1651000 16 262270
PEARS 72226 2 1756
PECANS 444823 3 14683
POMEGRANATES 3449 66 2276
POTATOES 1326000 3 36554
PUMPKINS 33833 6 2094
RADISHES 37253 34 12800
RASPBERRIES 13266 <1 9
SORGHUM 12183011 2 263645
SOYBEANS 58414278 <1 69000
SPINACH 38560 25 9504
SQUASH 53457 22 11696
STRAWBERRIES 57778 19 10977
SUGARBEETS 1411000 6 83100
SWEET CORN 761045 28 212956
SWEET PEPPERS 77481 52 40557
SWEET POTATOES 84768 1 450
TOBACCO 784770 12 95228
TOMATOES 413361 28 115390
WATERMELONS 258197 16 41094
WHEAT 62407000 <1 93600
OXAMYL
APPLES 497903 21 102938
CANTALOUPES 112749 30 34110
CARROTS 109640 2 2242
CELERY 34649 36 12438
COTTON 11120700 11 1256154
CUCUMBERS 145697 9 13410
EGGPLANT 4633 30 1384
GARLIC 25377 1 230
MELONS 25600 47 12000
MINT 153542 33 50845
ONIONS 151676 1 1155
PEACHES 183815 1 1920
PEARS 72226 2 1360
POTATOES 1326000 3 40709
PUMPKINS 33833 3 1159
SQUASH 53457 9 4892
SWEET PEPPERS 77481 18 14152
TOMATOES 413361 10 40554
WATERMELONS 258197 2 6344
THIODICARB
COTTON 11120700 16 1766971
4
ACTIVE CROP ACRES % ACRES ACRES
INGREDIENT PLANTED TREATED TREATED
SOYBEANS 58414278 <1 274200
SWEET CORN 761045 12 93961
|
TABLE 4 |
||
|
Crop Use Sites for Organophosphate and Carbamate Insecticides |
||
|
Active Ingredient |
Number of Crop Uses |
|
|
Organophosphates |
||
|
Acephate |
13 |
|
|
Azinphos Methyl |
40 |
|
|
Chlorpyrifos |
44 |
|
|
Diazinon |
59 |
|
|
Dicrotophos |
1 |
|
|
Dimethoate |
37 |
|
|
Disulfoton |
24 |
|
|
Ethion |
6 |
|
|
Ethoprop |
9 |
|
|
Ethyl Parathion |
11 |
|
|
Fenamiphos |
13 |
|
|
Fonofos |
24 |
|
|
Malathion |
61 |
|
|
Methamidophos |
19 |
|
|
Methidathion |
19 |
|
|
Methyl Parathion |
42 |
|
|
Naled |
20 |
|
|
Oxydemeton Methyl |
30 |
|
|
Phorate |
12 |
|
|
Phosmet |
15 |
|
|
Profenofos |
1 |
|
|
Sulprofos |
1 |
|
|
Terbufos |
4 |
|
|
Subtotal |
(505) |
|
|
Carbamates |
||
|
Aldicarb |
9 |
|
|
Carbaryl |
64 |
|
|
Carbofuran |
26 |
|
|
Formetanate HCL |
7 |
|
|
Methomyl |
57 |
|
|
Oxamyl |
19 |
|
|
Thiodicarb |
3 |
|
|
Subtotal |
(185) |
|
|
TOTAL |
690 |
|
TABLE 5 ORGANOPHOSPHATE INSECTICIDE
USE BY CROP
CROP
% OF INSECTICIDE TREATED ACRESALFALFA 54
ALMONDS 38
APPLES 43
APRICOTS 35
ARTICHOKES 16
ASPARAGUS 52
AVOCADOS 31
BARLEY 86
BEETS 64
BLACKBERRIES 36
BLUEBERRIES 52
BROCCOLI 59
BRUSSEL SPROUTS 75
CABBAGE 42
CANOLA 63
CANTALOUPES 24
CARROTS 41
CAULIFLOWER 49
CELERY 23
CHERRIES 58
CITRUS 30
COLLARDS 31
CORN 68
COTTON 46
CRANBERRIES 72
CUCUMBERS 12
DATES 100
DRY BEANS 28
DRY PEAS 82
EGGPLANT 12
FIGS 58
GARLIC 4
GRAPES 15
GREEN BEANS 55
GREEN ONIONS 40
GREEN PEAS 55
HAZELNUTS 41
HOPS 26
HOT PEPPERS 41
KIWI 44
LETTUCE 37
MELONS 29
MINT 55
NECTARINES 24
OATS 66
OKRA 32
CROP
% OF INSECTICIDE TREATED ACRESOLIVES 10
ONIONS 46
OTHER HAY 8
PARSLEY 3
PEACHES 41
PEANUTS 47
PEARS 26
PECANS 38
PISTACHIOS 28
PLUMS 37
POMEGRANATES 8
POTATOES 53
PUMPKINS 8
RADISHES 31
RASPBERRIES 37
RICE 50
RYE 100
SAFFLOWER 99
SEED CROPS 63
SOD 94
SORGHUM 67
SOYBEANS 37
SPINACH 22
SQUASH 10
STRAWBERRIES 28
SUGARBEETS 73
SUGARCANE 65
SUNFLOWERS 72
SWEET CORN 30
SWEET PEPPERS 29
SWEET POTATOES 81
TOBACCO 84
TOMATOES 28
WALNUTS 64
WATERMELONS 24
WHEAT 65
WILD RICE 100
The "% of insecticide treated acres"
represents the sum of acres treated with
carbamates as a % of the sum of acres
treated with all insecticides
TABLE 6 CARBAMATE INSECTICIDE USE BY
CROP
CROP
% OF INSECTICIDE TREATED ACRESALFALFA 32
ALMONDS 0
APPLES 19
APRICOTS 4
ARTICHOKES 10
ASPARAGUS 28
AVOCADOS 0
BARLEY 14
BEETS 31
BLACKBERRIES 23
BLUEBERRIES 41
BROCCOLI 5
BRUSSEL SPROUTS 0
CABBAGE 12
CANOLA 37
CANTALOUPES 17
CARROTS 22
CAULIFLOWER 8
CELERY 25
CHERRIES 7
CITRUS 13
COLLARDS 10
CORN 11
COTTON 19
CRANBERRIES 17
CUCUMBERS 51
DATES 0
DRY BEANS 8
DRY PEAS 14
EGGPLANT 26
FIGS 0
FLAX 100
GARLIC 65
GRAPES 14
GREEN BEANS 27
GREEN ONIONS 25
GREEN PEAS 7
HAZELNUTS 3
HOPS 0
HOT PEPPERS 46
KIWI 0
LETTUCE 11
MELONS 25
MINT 20
NECTARINES 31
OATS 34
CROP
% OF INSECTICIDE TREATED ACRESOKRA 48
OLIVES 35
ONIONS 11
OTHER HAY 91
PARSLEY 14
PEACHES 12
PEANUTS 44
PEARS 3
PECANS 16
PISTACHIOS 12
PLUMS 3
POMEGRANATES 88
POTATOES 13
PUMPKINS 45
RADISHES 39
RASPBERRIES 2
RICE 50
RYE 0
SAFFLOWER 1
SEED CROPS 0
SOD 2
SORGHUM 25
SOYBEANS 26
SPINACH 16
SQUASH 28
STRAWBERRIES 17
SUGARBEETS 26
SUGARCANE 10
SUNFLOWERS 6
SWEET CORN 33
SWEET PEPPERS 30
SWEET POTATOES 19
TOBACCO 13
TOMATOES 26
WALNUTS 1
WATERMELONS 34
WHEAT 3
WILD RICE 0
The "% of insecticide treated acres"
represents the sum of acres treated with
carbamates as a % of the sum of acres
treated with all insecticides
TABLE 7 ORGANOPHOSPHATE INSECTICIDE USE
BY STATE
STATE
% OF INSECTICIDETREATED ACRES
ALABAMA 50
ARIZONA 40
ARKANSAS 44
CALIFORNIA 43
COLORADO 62
CONNECTICUT 43
DELAWARE 57
FLORIDA 33
GEORGIA 44
IDAHO 52
ILLINOIS 78
INDIANA 68
IOWA 78
KANSAS 46
KENTUCKY 58
LOUISIANA 54
MAINE 46
MARYLAND 27
MASSACHUSETTS 44
MICHIGAN 65
MINNESOTA 58
MISSISSIPPI 48
MISSOURI 53
MONTANA 44
NEBRASKA 66
NEVADA 37
NEW HAMPSHIRE 29
NEW JERSEY 41
NEW MEXICO 69
NEW YORK 49
NORTH CAROLINA 49
NORTH DAKOTA 59
OHIO 71
OKLAHOMA 66
OREGON 59
PENNSYLVANIA 48
RHODE ISLAND 29
STATE
% OF INSECTICIDETREATED ACRES
SOUTH CAROLINA 38
SOUTH DAKOTA 70
TENNESSEE 58
TEXAS 52
UTAH 45
VERMONT 29
VIRGINIA 57
WASHINGTON 53
WEST VIRGINIA 50
WISCONSIN 76
WYOMING 77
The "% of insecticide treated acres"
represents the sum of acres treated with
carbamates as a % of the sum of acres
treated with all insecticides
TABLE 8 CARBAMATE INSECTICIDE USE BY STATE
STATE
% OF INSECTICIDETREATED ACRES
ALABAMA 29
ARIZONA 15
ARKANSAS 23
CALIFORNIA 12
COLORADO 12
CONNECTICUT 24
DELAWARE 14
FLORIDA 19
GEORGIA 32
IDAHO 22
ILLINOIS 9
INDIANA 10
IOWA 5
KANSAS 17
KENTUCKY 26
LOUISIANA 21
MAINE 19
MARYLAND 18
MASSACHUSETTS 25
MICHIGAN 17
MINNESOTA 7
MISSISSIPPI 18
MISSOURI 24
MONTANA 24
NEBRASKA 12
NEVADA 22
NEW HAMPSHIRE 27
NEW JERSEY 27
NEW MEXICO 22
NEW YORK 27
NORTH CAROLINA 35
NORTH DAKOTA 17
OHIO 12
OKLAHOMA 10
OREGON 11
PENNSYLVANIA 18
RHODE ISLAND 17
STATE
% OF INSECTICIDETREATED ACRES
SOUTH CAROLINA 35
SOUTH DAKOTA 18
TENNESSEE 22
TEXAS 21
UTAH 31
VERMONT 42
VIRGINIA 31
WASHINGTON 11
WEST VIRGINIA 24
WISCONSIN 7
WYOMING 23
The "% of insecticide treated acres"
represents the sum of acres treated with
carbamates as a % of the sum of acres
treated with all insecticides
TABLE 9 ORGANOPHOSPHATE
INSECTICIDE USE
CROP
% OF NATIONAL USE(POUNDS)
CORN 34
COTTON 20
ALFALFA 5
TOBACCO 5
POTATOES 4
PEANUTS 3
CITRUS 3
SORGHUM 3
WHEAT 3
APPLES 3
SUGARBEETS 2
SUNFLOWERS 1
SUGARCANE 1
PEACHES 1
ALMONDS 1
PECANS 1
SWEET CORN 1
WALNUTS 1
SOYBEANS 1
DRY BEANS <1
CHERRIES <1
COLLARDS <1
CRANBERRIES <1
DATES <1
DRY PEAS <1
GARLIC <1
HAZELNUTS <1
EGGPLANT <1
FIGS <1
CUCUMBERS <1
BROCCOLI <1
APRICOTS <1
ARTICHOKES <1
ASPARAGUS <1
AVOCADOS <1
BARLEY <1
BEETS <1
CANTALOUPES <1
BLUEBERRIES <1
CELERY <1
BRUSSEL SPROUTS <1
CABBAGE <1
MINT <1
CANOLA <1
GRAPES <1
CARROTS <1
CAULIFLOWER <1
CROP
% OF NATIONAL USE(POUNDS)
BLACKBERRIES <1
SPINACH <1
PUMPKINS <1
RADISHES <1
RASPBERRIES <1
RICE <1
RYE <1
SAFFLOWER <1
LETTUCE <1
SOD <1
PISTACHIOS <1
SQUASH <1
STRAWBERRIES <1
SWEET PEPPERS <1
SWEET POTATOES <1
TOMATOES <1
WATERMELONS <1
SEED CROPS <1
OATS <1
GREEN ONIONS <1
GREEN PEAS <1
HOPS <1
HOT PEPPERS <1
KIWI <1
MELONS <1
POMEGRANATES <1
NECTARINES <1
PLUMS <1
OKRA <1
OLIVES <1
ONIONS <1
OTHER HAY <1
PARSLEY <1
PEARS <1
GREEN BEANS <1
WILD RICE <1
TABLE 10 CARBAMATE INSECTICIDE USE
CROP
% OF NATIONAL USE(POUNDS)
COTTON 23
CORN 17
ALFALFA 9
PEANUTS 7
SORGHUM 4
SWEET CORN 4
PECANS 3
APPLES 3
SUGARBEETS 3
SOYBEANS 3
CITRUS 3
POTATOES 2
GRAPES 2
OTHER HAY 2
TOBACCO 2
WHEAT 1
SWEET PEPPERS 1
LETTUCE 1
PASTURE 1
RICE 1
PEACHES 1
GREEN BEANS 1
TOMATOES 1
COLLARDS <1
CUCUMBERS <1
DRY BEANS <1
DRY PEAS <1
EGGPLANT <1
CRANBERRIES <1
BRUSSEL SPROUTS <1
ALMONDS <1
APRICOTS <1
ARTICHOKES <1
ASPARAGUS <1
BARLEY <1
BEETS <1
BLACKBERRIES <1
CAULIFLOWER <1
BROCCOLI <1
CHERRIES <1
CABBAGE <1
CANOLA <1
CANTALOUPES <1
NECTARINES <1
CARROTS <1
HAZELNUTS <1
CELERY <1
CROP
% OF NATIONAL USE(POUNDS)
BLUEBERRIES <1
POMEGRANATES <1
WATERMELONS <1
WALNUTS <1
SWEET POTATOES <1
SUNFLOWERS <1
SUGARCANE <1
STRAWBERRIES <1
SQUASH <1
SPINACH <1
SOD <1
SEED CROPS <1
SAFFLOWER <1
RASPBERRIES <1
MELONS <1
PUMPKINS <1
FLAX <1
PLUMS <1
PISTACHIOS <1
PEARS <1
PARSLEY <1
ONIONS <1
OLIVES <1
OKRA <1
OATS <1
MINT <1
HOT PEPPERS <1
GREEN PEAS <1
GREEN ONIONS <1
GARLIC <1
RADISHES <1
Leonard P. Gianessi
May 1997
CROP PROTECTION ISSUES PAPER #1
National Center for Food and Agricultural Policy
1616 P Street, NW, First Floor
Washington, DC 20036
202-328-5048
FAX: 202-328-5133
e-mail: ncfap@ncfap.org
Introduction
After years of debate and Congressional hearings, the nation’s laws regulating food uses of pesticides were amended in 1996. The Food Quality Protection Act of 1996 (FQPA) requires the EPA to consider additional risk factors while reducing the consideration of benefits of a pesticide’s use when establishing food tolerances for carcinogenic compounds. One benefit that Congress explicitly directed USEPA to consider under the new Law concerns the presence of naturally-occurring mycotoxins in foods. If a carcinogenic pesticide reduces the presence of a carcinogenic naturally- occurring compound in foods, the EPA is to determine which compound poses the greater risk. Congress used a hypothetical example to illustrate the application of this benefit provision. Since EPA has begun implementing the FQPA, it is appropriate to determine the extent to which pesticides are used currently to reduce the presence of cancer-causing, naturally-occurring compounds in foods.
The Food Quality Protection Act
In August 1996, President Clinton signed into law The Food Quality Protection Act (FQPA), which had passed both houses of Congress unanimously. The FQPA amends the two laws that regulate pesticide use in the United States -- The Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) and the Federal Food and Drug and Cosmetic Act (FFDCA). FIFRA directs EPA to register and label all pesticide products used in the United States. FFDCA requires EPA to assign pesticide residue tolerances (maximum residue limit) to each pesticide that has been labeled to be used on food consumed by humans. A separate tolerance is assigned to each crop included on the pesticide label. The tolerances are designed to help protect the public against exposure to potentially harmful chemical residues that may be found at low levels on food products.
Most major environmental statutes are risk-driven and prohibit consideration of economic costs in setting health-based standards. FIFRA is one of the few statutes administered by EPA that explicitly requires the Administrator to consider the risks and benefits of a chemical. If in some or all circumstances, a chemical’s risks outweigh its benefits, regulatory action is taken to restrict or ban its continued use. Conversely, if EPA determines that a pesticide’s benefits outweigh its risks, its registration is continued. However, since policymakers were concerned that health risks were not being adequately addressed by FIFRA, Congress included provisions in the FQPA to broaden the consideration of human health risk factors before a tolerance may be granted.[28]
In particular, the new law emphasizes the health risks pesticides pose to children and infants. Evidence suggests that they are more likely than adults to experience health problems associated with exposure to pesticide residues. Two of the provisions of the FQPA are particularly noteworthy. First, the FQPA mandated EPA to develop a comprehensive screening program to determine if each pesticide is capable of disrupting the endocrine system. Second, the FQPA requires EPA to assess the potential risks associated with aggregate pesticide exposure. Previously, EPA only considered exposure to pesticide residues in food. Now, all exposure pathways, including water and residential uses, are considered. Further, the residues of compounds that have the same mode of action, such as the organophosphate insecticides, must be jointly considered if two or more are used on the same food commodity. Prior to FQPA, pesticide risks were considered individually.[28]
The FQPA also significantly reduced EPA’s mandate to consider the benefits of pesticides when the Agency assigns tolerances. Under the old Law, EPA was required to consider the benefits of retaining the tolerances previously granted for carcinogenic pesticides that posed non-negligible risks. Among other things, the benefit considerations included the economic impacts, such as higher producer and consumer costs, that would result if certain pesticides were removed from the market. Under the new Law, the benefits derived from using carcinogenic pesticides are only considered if at least one of two conditions exists. First, the pesticide protects consumers against adverse health effects that are greater than the health risks posed by the pesticide itself. Second, the pesticide is needed to avoid a significant disruption of the domestic production of an adequate, abundant and economical food supply. If either of these conditions is met, the EPA Administrator may leave a tolerance in effect, even if it poses a non-negligible cancer risk.
The legislative history of the Food Quality Protection Act makes clear congressional intent to protect consumers from adverse health effects that pose a greater risk than the dietary risk from the pesticide chemical residue. In this instance, eating food treated with the pesticide chemical is safer for consumers than eating the same food that is not treated with the pesticide.[27] To illustrate this condition, the legislative history uses the example of aflatoxin, a naturally-occurring, cancer-causing fungus. Congress recognized that there currently are no pesticides that directly kill the aflatoxin fungus. However, Congress used the hypothetical example that if such a pesticide were to be developed, it would be a candidate for a tolerance, even if it posed a non-negligible cancer risk if its dietary risks were lower than the dietary risks of aflatoxin.[27]
Although Congress was correct in concluding that no pesticide currently in use controls aflatoxin directly, several currently used pesticides control insects that spread aflatoxin. By controlling the insects, these insecticides are important in limiting aflatoxin to low levels in food. Several of the insecticides that help to limit aflatoxin contamination are in the organophosphate class of chemistry, which is the first group of chemicals that EPA has designated for consideration under FQPA’s aggregate risk and common mechanism of toxicity requirements. Thus, in considering whether to maintain current tolerances of organophosphate insecticides, that may pose a greater than non-negligible cancer risk, the EPA must consider whether eliminating their use would lead to a greater risk of aflatoxin ingestion, that, in turn, may lead to a greater risk of cancer. The benefits conferred by organophosphate pesticides in reducing cancer risks must be included as part of the review. If their cancer reducing benefits are greater than their cancer risks, some of the organophosphate pesticides may be granted tolerances.
Background of Aflatoxin
Aflatoxins are powerful tasteless, odorless and colorless mycotoxins, which are chemical metabolites, produced by certain strains of Aspergillus fungi. Aflatoxins are mutagenic, carcinogenic, teratogenic and acutely toxic to most animals and humans.[22] They can cause animals, including humans, to lose their appetite, decrease their feeding efficiency, and/or cause death.[14] Evidence suggests that aflatoxins are one hundred times more likely to induce cancer than polychlorinated biphenyls (PCBs).[16] When aflatoxin is present in the grain fed to dairy cows, it metabolizes and forms other carcinogenic compounds that eventually find their way into milk. Aflatoxins also inhibit the body's immune system and reduces the effectiveness of vaccines. For example, an outbreak of hepatitis in India was linked to moldy corn that contained aflatoxin.[14] It also was found in the tissue of Asian children who suffered from Reye's syndrome. Concern exists for possible adverse effects from long-term exposure to low levels of aflatoxins in food.[21] A major concern is the possible role of aflatoxin exposure in the development of liver cell cancer.[21] Ten to twenty parts per billion of aflatoxin consumed regularly by sensitive young animals can result in fatal liver cancers.[14]
In the United States, the aflatoxins are the only mycotoxins that are specifically regulated.[21] Aflatoxins are regulated under the Food, Drug, and Cosmetic Act (FFDCA). In 1965 the FDA established specific guidelines for acceptable levels of aflatoxins in human food and animal feed (i.e., action levels) that allow for the removal of violative lots from interstate commerce.[21] The action levels for human food are 20 parts per billion (ppb) total aflatoxins, with the exception of milk, that has an action level of 0.5 ppb for aflatoxin M1 (a metabolite of aflatoxin B1).[21] For feeds the action level for aflatoxins is also 20 ppb with the exception of a 300 ppb action level for aflatoxins in cottonseed meal used in feeds, a 300 ppb action level for corn used for finishing (feedlot) beef cattle, 200 ppb for corn destined for finishing swine (i.e., >100 lbs.), and 100 ppb aflatoxins in feeds used for breeding cattle, breeding swine, and mature poultry.[21]
There have been several serious outbreaks of aflatoxin which have caused significant agricultural losses. In 1977, aflatoxin contaminated more than sixty percent of the corn grown in the southeastern portion of the U.S.[14] In 1988, a severe drought in the Midwest caused aflatoxin to contaminate between 5 and 25 percent of the region's corn crop.[16] After the aflatoxin was discovered, a significant amount of milk, which had been produced in more than five states, had to be destroyed because the dairy cows had been fed aflatoxin tainted corn.
Although many fungi are controlled with chemicals, the Aspergillus fungi have proven largely immune to tested pesticides.[4] In order to minimize aflatoxin contamination in crops, a variety of approaches are used, including the use of insecticides to control insects that spread the fungal infestations. Aflatoxin causing fungi live on dead plant debris, producing spores that are distributed by wind and insects.
Aflatoxin and Peanuts
The fungi which produce aflatoxin are commonly found in the light soils used to grow peanuts.[3] Peanuts are frequently contaminated by aflatoxin if their pods develop during drought conditions and/or if the pods are partially eaten by an insect -- the lesser cornstalk borer. Prior to 1960, the contamination of peanuts by aflatoxin was not considered to be a significant problem. By 1960, the peanut industry was much more concerned after it was discovered that animals had been poisoned by aflatoxin.[1] For example, farmers in Georgia reported that their swine had been poisoned after consuming moldy peanuts. Also, more than one hundred thousand turkeys in England died after they consumed moldy peanut meal.[1] Hot and dry conditions that favor development of aflatoxin also favor population outbreaks of the lesser cornstalk borer. The caterpillars inhabit the upper soil and feed on plant stalks at or just below the soil surface.
When the cornstalk borer larvae feed on peanut pods, they often weaken or pierce the shell. This provides a point of entry for the aflatoxin producing fungi.[24] The amount of aflatoxin found in seed penetrated by insects is thirty to sixty times greater than the aflatoxin levels found in undamaged pods.[5] Tests conducted in Alabama during 1990 found a 94 percent correlation between damage caused by the lesser cornstalk borer and the number of aflatoxin producing fungi.[3] Peanut field studies found that over 50 percent of the lesser cornstalk borer larvae sampled were contaminated by aflatoxin fungus spores. Researchers also have found propagules of aflatoxin fungus in the gut of the lesser cornstalk borer larvae.[5]
Research has shown that the judicious use of pesticides significantly reduces the damage to peanut pods caused by the lesser cornstalk borer. Thus, insecticides indirectly reduce aflatoxin levels found in peanuts. When peanuts are treated with a single application of the organophosphate insecticide chlorpyrifos thirty days after planting, and again either forty-five or seventy-one days after planting, the damage caused by the lesser cornstalk borer larvae and the levels of aflatoxin are consistently lower than when no insecticides are applied.[3] Chlorpyrifos reduces the insect's population by approximately 80 percent, while the most efficacious non-organophosphate insecticide reduces the population by approximately 40 percent.[17] Insecticide treatments for lesser cornstalk borer control in peanuts have been rising in recent years because of a succession of drought years and recent research that shows the relationship between lesser cornstalk borers and aflatoxin in peanuts.[25]
Aflatoxin and Cotton
Cottonseed produced in California and Arizona is used to feed dairy cows in a number of states. Unfortunately, the cottonseed can be a significant source of aflatoxin. Cotton plants become infested with aflatoxin when the cotton bolls are open and/or when chewing insects, such as the pink bollworm and Heliothis, chew holes in the bolls.[6] In Arizona and the Imperial Valley of California, 100 percent of the cotton acreage is infested with pink bollworms.[19] The holes enable fungus spores to reach the moist lint which then germinate and grow on the lint fibers. Eventually, the fungus enters the cottonseed and produces aflatoxin which is a by-product of its normal metabolic activity. Research has shown that all of the highly contaminated cotton lots (>10,000 ppb of aflatoxin) are from bolls that have been damaged by the pink bollworm.[9] Over 90 percent of the total aflatoxin detected in one experiment was in seed produced from pink bollworm damaged bolls.[7]
The fungus is only able to infest cotton plants if the temperature and humidity are high and the moist lint is exposed. When night temperatures consistently fall between 70oF and 75oF, which is the case in most cotton growing areas, infection levels are generally low. However, in the deserts of Arizona, California and the Rio Grande Valley of Texas, aflatoxin production is usually high between early August and mid-September due to the prevailing high temperatures and humidity.[6]
Prevention of aflatoxin contamination is based on a strategy of preventing pink bollworm damage to bolls in the early and the middle of the season.[8] Research has demonstrated that chemical control of the pink bollworm reduced amounts of bright greenish-yellow fluorescence associated with aflatoxin producing fungi. Levels of aflatoxin were maintained below 20 ppb when populations of pink bollworm were held at or below the economic threshold, but this was only achieved by numerous insecticide applications.[15] Pink bollworm infested acres are treated approximately three times with insecticides, including the organophosphate insecticides azinphos methyl and methyl parathion.[19]
Aflatoxin and Corn
Aflatoxin contaminates corn grown in the cornbelt and in the southern states.[13] Insects act as a vector for aflatoxin contamination of corn. Research has shown that aflatoxin levels are higher on corn damaged by insects than on undamaged corn ears.[14]
Corn earworms are responsible for much of the spread of aflatoxin since they cause breaks in the pericarp that have been linked to increased aflatoxin production.[12] When insecticides were used during experimental trials to control corn earworms, the incidence of corn plants infected with aflatoxin was much lower.[11] However, at present, insecticides are not used to reduce the corn earworm population in field corn. As a result , during years in which aflatoxin production is favored and field corn becomes contaminated, it has sometimes been necessary to allow aflatoxin contaminated grain to be diluted with other grains to reduce the aflatoxin level below 20 ppb. For the 1988 corn crop, the FDA allowed a blending of corn containing aflatoxins with non-contaminated corn to produce a total level of contamination below the action levels for animal feeds only.[26] The use of insecticides to control insects in the field has been proposed as a means of eliminating most of the toxic contamination of field corn.[10]
Insecticides are used to control corn earworms on sweet corn since marketing standards regarding insect damage are much more stringent. In Florida, the largest domestic producer of sweet corn for the fresh market, experiments have shown that without pesticide applications, essentially 100 percent of the sweet corn would be infested with corn earworms.[20] Insecticides, which include the pyrethroids, thiodicarb and methomyl, are usually applied between seven and fifteen times to prevent corn earworms from damaging Florida sweet corn.[18]
Aflatoxin and Almonds
The two major insect pests of California almond orchards are the navel orangeworm and the peachtwig borer. Navel orangeworm larvae enter damaged nuts and go directly into the kernel to feed. Aflatoxins are associated with almond kernels damaged by navel orangeworm larvae.[22] The larvae attack the almond fruit while they are still drying on the tree. During drying, high temperatures in the orchard and moisture in the hulls provide an environment especially suited for the production of aflatoxin. Research has shown that the most direct means of controlling aflatoxin contamination of almonds is to reduce insect damage.[22] Early season feeding damage from the peachtwig borer creates openings for the navel orangeworm to enter. The frass excreted by peachtwig borer larvae attract navel orangeworm females to damaged nuts. Navel orangeworm do not attack undamaged nuts.
Since in-season applications of insecticides provide only 50 to 60 percent control of navel orangeworm, non-chemical controls and dormant season controls are recommended. The current recommendation for insect control in almond orchards is to spray almond trees every year in the winter with a dormant spray of oil and organophosphate insecticides.[23] The major organophosphate insecticides used in almond orchards include azinphos methyl, chlorpyrifos, diazinon, methidathion and phosmet.
Summary and Conclusions
Pesticides are one of the primary methods used to keep aflatoxin contamination of food within the safety standards set by FDA. Although pesticides do not directly reduce the level of aflatoxin, certain pesticides may meet the benefit standards required by the Food Quality Protection Act of 1996 by controlling insects that spread aflatoxin. Thus, any review of the pesticides for continued food tolerances and registration must consider the risk-risk tradeoff with aflatoxin. Congress clearly intends that EPA grant tolerances to pesticides that are known carcinogens if they reduce another risk more than the risk posed by the pesticide. Although chemical pesticides, such as organophosphate insecticides, pose certain dietary risks, it will be necessary for the EPA to determine the potential of increased dietary risk from aflatoxin ingestion that might be expected if those uses were canceled.
References
1. Wilson, David M., "Management of Mycotoxins in Peanut," in Peanut Health Management, APS Press, 1995.
2. Anderson, W. F., et al., "Evaluation of Preharvest Aflatoxin Contamination in Several Potentially Resistant Peanut Genotypes," Peanut Science, January-June 1995.
3. Bowen, K. L., and T. P. Mack, "Lesser Cornstalk Borer and Aflatoxin: Double Trouble for Peanut Growers," Highlights of Agricultural Research, Alabama Agricultural Experiment Station, Winter 1990.
4. Mixon, A. L., et al., "Effect of Chemical and Biological Agents in the Incidence of Aspergillus Flavus and Aflatoxin Contamination of Peanut Seed," Phytopathology, Vol. 74, No. 12, 1984.
5. Brown, Steve L., and John Baldwin, "Performance of Peanut Soil Insecticides in Hot, Dry Conditions: A Case Study," University of Georgia Cooperative Extension Service, 1995.
6. Integrated Pest Management for Cotton in the Western Region of the United States, University of California, Division of Agriculture and Natural Resources, Publication 3305, 1984.
7. Cotty, P. J., "Effect of Harvest Date on Aflatoxin Contamination of Cottonseed," Plant Disease, March 1991.
8. Cotty, P. J., and L. S. Lee, "Position and Aflatoxin Levels of Toxin Positive Bolls on Cotton Plants," 1990 Proceedings Beltwide Cotton Production Research Conferences, National Cotton Council.
9. Cotty, Peter J., "Aflatoxin Contamination: Variability and Management," Cotton, University of Arizona, Series P-87, 1991.
10. Widstrum, N. W., "The Role of Insects and Other Plant Pests in Aflatoxin Contamination of Corn, Cotton and Peanuts -- A Review," Journal of Environmental Quality, Vol. 8, No. 1, 1979.
11. Widstrum, N. W., et al., "Corn Earworm Damage and Aflatoxin in Corn Ears Protected with Insecticide," Journal of Economic Entomology, October 1976.
12. Widstrum, N. W., et al., "Aflatoxin Production and Lepidopteran Insect Injury on Corn in Georgia," Journal of Economic Entomology, December 1975.
13. Wilson, D. M., et al., "Aspergillus Flavus Group, Aflatoxin and Bright Greenish Yellow Fluorescence on Insect Damaged Corn in Georgia," Cereal Chemistry, Vol. 58, No. 1, 1981.
14. Compendium of Corn Diseases, APS Press, 1980.
15. Henneberry, T. J., et al., "Pink Bollworm: Chemical Control in Arizona and Relationship to Infestations, Lint Yield, Seasonal Damage and Aflatoxin in Cottonseed," Journal of Economic Entomology, June 1978.
16. Schumann, Gail L., Plant Diseases: Their Biology and Social Impact, APS Press, 1991.
17. Bridges, David C., et al., An Analysis of the Use and Benefits of Pesticides in U. S. Grown Peanuts: Southeastern Production Region, University of Georgia, NESPAL Report 1994-002, June 1994.
18. USDA, Agricultural Chemical Usage Vegetables: 1994 Summary, National Agricultural Statistics Service, July 1995.
19. Williams, Michael R., "Cotton Insect Losses," 1996 Proceedings Beltwide Cotton Conferences, National Cotton Council.
20. Janes, M. J., "Corn Earworm and Fall Armyworm: Comparative Larval Populations and Insecticidal Control on Sweet Corn in Florida," Journal of Economic Entomology, October 1975.
21. Mycotoxins: Economic and Health Risks, Council for Agricultural Science and Technology, Summary No. 116, November 1989.
22. Phillips, Douglas J., et al., Aflatoxins in Almonds, USDA, Science and Education Administration, Agricultural Reviews and Manuals, November 1980.
23. Integrated Pest Management for Almonds, University of California, Division of Agriculture and Natural Resources, Publication 3308, 1985.
24. "Genetic Resistance, A Key to Controlling Aflatoxin," Agricultural Research, July 1996.
25. Summary of Losses from Insect Damage and Cost of Control in Georgia (1977-1993 Separate Volumes), University of Georgia, College of Agricultural and Environmental Sciences.
26. Federal Register, May 20, 1989.
27. Food Quality Protection Act of 1996, Report to Accompany HR 1627, Committee on Commerce, U.S. House of Representatives Report 104-669, part 2, July 23, 1996.
28. Felsot, Alan, "Goodbye Delaney, Hello Confusion: Implications of the Food Quality Protection Act of 1996," 1997 Pacific Northwest Agricultural Situation and Outlook, Capital Press.