Permethrin Use in Hawaii
Date: March 21, 2006
To: Jacqueline Guerry
Cc: Rick Melnicoe; Wilfred
Burr; Rebecca
Sicso; Keith
Dorschner;
Mike Kawate,
Chris Davis
From: Cathy Tarutani
Subject: Re: Permethrin proposed crop label changes
Attachment
Jackie,
It seems I misunderstood your deadline. I believed that sending you
our information on March 21 would be acceptable. While I admit our information
would not have arrived by the close of businesss for you, the message
(below the closing of what was supposed to be our cover
message) did not indicate that a DECISION would be made on March 21.
Wouldn't you agree?
In any event, right before I was about to send our information, I was checking my inbox for last minute contributions to our reply in this matter when I found your message.
Imagine my surprise when I read it.
I feel obligated to send our contribution, anyway. I owe that to the people who went out of their way to provide this information. You will see that that a several areas (highlighted in yellow) where are growers will have problems with the mitigation measures for permethrin.
Following is the cover message for our response.
Dear Jackie,
I have attached a table of suggested permethrin use reductions for vegetables and melons in Hawaii. In summary, all retreatment days are set at seven (7)days (labels currently say as frequently as needed). There are also reductions in the total amount of a.i. per season. These are numbers that many growers can live with.
However, we must also report that a large grower of cucurbits (large by Hawaii standards) has expressed concerns about our suggested maximum application rates. Our proposed rates would result in a maximum of six (6) applications per year at the highest suggested applications rate. This would be the BARE MINIMUM that they can live with. Even though they do not apply eight (8) applications to their cucurbit crops every year, they would prefer to be able to apply eight applications per year, if necessary. As mentioned in our previous response, the use of permethrin on cucurbits has become more critical since the introduction of the pickleworm a few years ago. The pickleworm can be very damaging to all cucurbit crops and starts by attacking fruit at the flowering stage. Also, I would like to repeat that farmers of these crops in Hawaii are concerned about limiting the pest management tools necessary to control year-round pest pressure.
Permethrin has proven to be quite effective against the pickleworm, and, therefore, is the choice of many growers. Additionally, the ability to treat up to the time of harvest is important because growers harvest curcubit and other crops frequently for farmers' markets and other local venues.
In addition to the pickleworm, some of the insect pests managed by permethrin in Hawaii are corn thrips, corn earworm/tomato fruitworm, various caterpillar and leafhopper/planthopper insect pests. The reduction in allowable permethrin use would affect approximately 6,000 acres of vegetables and melons grown in Hawaii and 3,500 acres of seed corn (an industry valued at over $60M annually).
Questions have also arisen about the efficacy of lower application rates. In particular, some growers apply permethrin at the current maximum rate for an initial knockdown. Maintenance applications are done at lower rates. Without any research or information, many growers are, understandably, reluctant to agree to reduced rates. Is there information available about the efficacy of the reduced rates?
In the short time frame provided, we hope we have been able to address some your questions. We would also like to acknowledge the assistance of the county agents, extension specialists, the Environmental Stewardship Committee of the Hawaii Farm Bureau Federation and the growers who provided the information.
We appreciate the opportunity to provide input on this issue, which is important to many in our grower community. Please contact us if you have further question. We would also appreciate being informed about any developments with the permethrin reregistration.
Thank you,
Cathy
Cathy
Tarutani
Department of Plant and Environmental Protection Sciences
3190 Maile Way | voice: 808-956-2004
St John Plant Science Lab., Room 017 | fax: 808-956-9675
University of Hawaii |
Honolulu, HI 96822
Following is the notification of the date by which the above and attached
information were requested:
Keith, I was just asked by EPA to get all possible comments back to
them by next Tuesday March 21. I really appreciate all of the comments
you have been able to provide for us by the grower groups.
May I ask that you let any persons you expect to hear from that they
have until then?
Many thanks,
Chris"
If more info can be provided, it would need to be by March 21.
Thanks, Keith
On 21 Mar 2006 at 18:09, Guerry.Jacqueline@epamail.epa.gov wrote:
Cathy,
We met today with the registrants to finalize (or get one step closer
anyway) the permethrin mitigation for agricultural uses. We were able
to incorpate most of the requests from various growers regarding application
rate, seasonal rate, and/or retreatment interval.
Since we did not have specific information from HI, we were not
able to address your concerns. I am hoping that some of the changes we
made (increased rates or seasonal rates, and extended retreatment intervals)
addresses some of HI's concerns.
Please review the attached sheet and let me know if there is additional
areas of concern.
Thank you,
Jackie (See attached file: Rate Reductions (AG).doc)
Jacqueline
Guerry
Chemical Review Manager
Special Review and Reregistration Division, RB3
(703) 305-0024
Rm. 604W34
