An explanation of how a food safety law may impact pest management on ornamental plants
The Food Quality Protection Act ( FQPA) became a law on August 3, 1996. The purpose of this law is to protect the public from pesticide residues found in dietary and non-dietary sources. In order to accomplish this goal, the FQPA changes components of the Federal Food, Drug and Cosmetic Act (FFDCA) which ensures food safety and regulates the tolerance of pesticide residues and the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) which governs the registration and use of pesticides.
The FQPA implemented a number of changes to FFDCA and FIFRA, including these major provisions that have the potential to impact the ornamental plant industry.
- The FQPA establishes a new, uniform standard for setting pesticide residue tolerances in raw and processed food. It defines “safe” tolerances as “a reasonable certainty that no harm will result from “aggregate exposure.” The FQPA considers both raw and processed food when setting residue tolerances.
- The tolerance for exposure, or the risk factor, for infants and children can be multiplied by up to 10. (Example: If a safe residue is generally regarded as 10 ppm, then that residue might be lowered to 1 or even 0.l ppm for foods consumed heavily by children.)
- Before the FQPA, pesticide residue tolerances were established on a pesticide-by-pesticide basis for each given crop. Pesticides will now be reviewed based on common mechanisms of toxicity (organophosphates reviewed together, carbamates reviewed together, etc.), and pesticides must be reviewed under the consideration of cumulative exposure (i.e. exposure through all non-dietary sources such as structural or lawn/landscape contact, as well as through dietary exposure).
- The Environmental Protection Agency will review tolerance levels for registered pesticides within the next 10 years.
In addition, the FQPA requires that risks other than carcinogenicity (the ability of a given compound to cause cancer) be considered. Factors such as endocrine disruption (mimicking the effects of estrogen or testosterone in the human body), teratogenicity (the ability of a compound to cause gross malformations of the developing fetus), and mutagenicity (the ability of a compound to cause cell mutations) must also be considered in estimating the relative safety of a pesticide.
SO WHAT DO THESE CHANGES MEAN?
Why should nursery professionals need to worry about pesticide residues in food crops — with the exception of fruit trees and shrubs, the plants that are produced by the nursery industry are not edible commodities. Many of the compounds used on nursery crops, however, are also used on many food crops, and unacceptable residues have been detected in food crops. These residues contribute to the toxicity loading of these foods, and add to the amount in the risk cup, and so the compound will be under increased scrutiny for banning or for a change in use registration. For example, iprodione, the active ingredient in Chipco, is low in acute and chronic toxicity, but it is classed by the EPA as a “probable human carcinogen,” which accounts for most of its toxicity loading. The registration of iprodione will be reviewed by the EPA for this reason.
In order to review tolerances, the EPA is collecting pesticide use data to make decisions on risk assessment. The two data components are exposure data and application rates. For exposure data, results will depend on where samples taken for analysis are gathered. For application rates, without real-world data, EPA will assume maximum use rates and treatment applications on the maximum crop acres.
HOW CAN THESE CHANGES POTENTIALLY IMPACT THE GREEN INDUSTRY?
As pesticides are reviewed, chemical manufacturers may learn that certain classes of pesticides have exceeded the risk cup. If this occurs, manufacturers will have to change the label in regards to their use or change formulations so that products are safer. A more drastic option available to manufacturers is to drop specific uses or the production of the pesticide all together. This is where minor use crops, such as greenhouse, nursery and turf crops, could be at risk. Minor use crops are those grown on fewer than 300,000 acres, including nursery crops. If a chemical active ingredient is available for both minor use and major crops (corn, cotton, soybean and wheat), pesticide manufacturers may chose to remove minor use crops from the label to fit the product into the risk cup; while at the same time, still reaching the more profitable major crop markets. The future of pesticide active ingredients is still very much undecided.
There is the potential that the Green Industry may see changes to their current pesticide options. Some insecticides labeled for use on ornamental plants that have been reviewed include: carbamates – bendiocarb (Dycarb, Turcam) and carbaryl (Sevin); and the organophosphates -acephate (Orthene, Pinpoint), azinphos-methyl (Guthion), chlorpyrifos (Dursban, DuraGuard), diazinon, dimethoate (Cygon), disulfoton (Di-Syston), malathion, naled (Dibrom), oxythioquinox (Joust, Morestan) and phosmet (Imidan).
Many fungicides labeled for use on nursery crops that will be or have been reviewed include: captan, chlorothalonil (Daconil), DCNA (Botran), iprodione (Chipco, Ronilan), PCNB (Terrachlor), thiabendazole (Mertect), triadimefon (Bayleton), and vinclozolin (Ronilan).
WHAT CAN YOU DO?
Now is the time to evaluate your pesticides to see which are the most important to your business. What will the outcome be if this product is lost? Are there alternatives? Also, if asked by a state or national association, provide real-use pesticide data so that these groups can accurately respond to EPA or USDA. There is little pesticide use data available to EPA for minor use crops. So, it will not be beneficial if they use their conservative estimate of pesticide use.
However, there is some good news. The Food Quality Protection Act requires that EPA give special attention to pesticides that are important to IPM or for managing resistant pests. Thus, some pesticides may be retained because of their unique role in pest management.
There are some insecticides that are not under review that you may want to incorporate into your pest management practices. You may already be familiar with some of these products and use one or more in your pest management program. If you are not familiar with these materials, there are a couple of points to consider. Certain products may not be labeled for the specific pest of concern. Also, because of their mode of action, some of the biological insecticides may kill pests more slowly than the more familiar synthetic chemicals. Remember to follow the label instructions.
Azadirachtin (Azatin XL, Neem) is an insect growth regulator derived from the neem tree. It is labeled for aphids, cankerworm caterpillars, leaf hoppers and whiteflies.
Bacillus thuringiensis (Dipel, MVP II, Biobit, Javelin) contains bacterial spores that produce a destructive toxin when ingested. It is labeled for early instar caterpillars, but not sawfly larvae.
Beauvaria bassiana (Naturalis-O, Naturalis-T, BotaniGard) is made of insect-attacking fungal spores that infect through contact. Naturalis-O is labeled for aphids, mites, leaf-feeding caterpillars and leaf hoppers. Naturalis-T attacks billbugs, chinch bugs, cutworms and sod webworms.
Horticultural oil (Sunspray Ultra Fine Spray Oil) is a refined petroleum product that blocks breathing holes (spiracles) and/or piercing-sucking mouth-parts of insects. It is labeled for soft-bodied insects such as aphids, mites, scale crawlers, lace bugs, mealy bugs and whiteflies.
Imidacloprid (Marathon, Merit) is a soil-applied systemic insecticide labeled for aphids, adelgids, lace bugs, leafminers, soft scales, whiteflies and white grubs.
Insecticidal soap (Olympic Insecticidal Soap, Safer Soap, M-Pede) is produced from biodegradable fatty acids and labeled for aphids, caterpillars, lace bugs, mites and scale crawlers.
Insect pathogenic nematodes (Heterorhabditis bacteriophora and Steinernema carpocapsae.). H. bacteriophora is a cruiser-type nematode labeled for weevil larvae, white grubs and wood borer larvae. S. carpocapsae is an ambusher-type nematode that attacks armyworms, cutworms, sod webworms and wood borer larvae.
Spinosad (Conserve SC) is a toxin derived from the soil-dwelling organism Saccharopolyspora spinosa. It is labeled for caterpillars, sawfly larvae, gall midges, Dipterous (fly) leafminers and leaf-feeding beetles.
Unfortunately, for many of the fungicides under consideration for registration changes, there are no good alternatives. Nursery professionals will have to rely on increased use of IPM and other cultural practices to reduce the impact of diseases.
This is only a brief introduction to the Food Quality Protection Act and its potential impact on ornamental plant production and care. Further information can be found at the following websites:
Tim Abbey, Nursery IPM Specialist, Connecticut Agricultural Experiment Station, Windsor, CT
Vicki Smith, Ornamental Plant Pathologist, Connecticut Agricultural Experiment Station, New Haven, CT
from: Yankee Grower. May/June 1999. Volume 1, Number 3. p.3-5
Updated by: Mary Concklin, IPM, University of Connecticut. 2011
This information was developed for conditions in the Northeast. Use in other geographical areas may be inappropriate.
The information in this document is for educational purposes only. The recommendations contained are based on the best available knowledge at the time of publication. Any reference to commercial products, trade or brand names is for information only, and no endorsement or approval is intended. The Cooperative Extension System does not guarantee or warrant the standard of any product referenced or imply approval of the product to the exclusion of others which also may be available. The University of Connecticut, Cooperative Extension System, College of Agriculture and Natural Resources is an equal opportunity program provider and employer.