Malathion Risk Mitigation -- Hawaii Additional Response
Tom,
The pineapple growers have indicated that the application parameters you suggested are acceptable. These are: annual maximum application rate of 5 lb a.i./A; a maximum of three (3) applications per year and a 24-hour REI.
For the other crops in the table, in general, the activity which workers need to get back into the field is irrigation system monitoring. This is particularly true for cabbage, broccoli and cauliflower. However, for the most part all of the listed crops (except cucumber) are overhead irrigated which means there is a need to get back in the field as quickly as possible to ensure that their systems are working properly. Workers must monitor, among other things, to make sure they are not leaking, thus flooding the crops and wasting water as well as moving the applied malathion off site. In order to address this issue, growers can live with the 24-hour REI, but the 2 day REI would make it difficult to monitor their irrigation systems.
Seed corn issues are address in the attachment.
A concern expressed by the seed and vegetable producers is difficulty in local licensing some new chemistries in the state. For example, Actara (Thiamethoxam), a non-RUP in other states, has been consistently denied access to Hawaii, unless the products can be made available only with RUP status. This would be an effective insecticide for control of aphids, whiteflies, thrips, and plant/leafhoppers of various crops. This product has a Caution signal word with low mammalian toxicity (especially critical for handlers), a 12 hour REI, and narrow target specificity. This product is a potential replacement for malathion for some growers.
Unfortunately, in a short time frame, we are unable to address the specific issues and needs of most of the crops listed. Moreover, there is a large vegetable grower whose operation is probably the most likely to be impacted. However, their field staff and managers are not very skilled in using computers and our resource person for this farm has had prior commitments and been unable to communicate with them.
Although the time frame was short and the magnitude and breadth of this inquiry made it impossible to us to adequately determine and communicate the needs of our growers, we appreciate your efforts to understand their situation.
If you have further questions or concerns, please do not hesitate to contact either Mike Kawate (mike@hpirs.stjohn.hawaii.edu, 808/956-6008) or me.
Thank you,
Cathy
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On 27 Oct 2006 at 16:35, Moriarty.Thomas@epamail.epa.gov wrote:
Cathy...
I've updated the table based on your last email and made a few changes. you can see that there still remains about 13-15 sites where Hawaii needs a shorter REI, let work on these.
tom m
Tom Moriarty
703.305.5035
