On Monday, October 23, 2006, at 11:06 AM, Dan Digiacomandrea wrote:
Here is an update on what's happening with Guthion. USApple is fighting hard for an extension with the support of Bayer but it's an up hill battle!
Any support from industry is greatly appreciated. Forward your comments to me and Jim Cranney.
Dan DiGiacomandrea
Bayer CropScience
68 Chadwick Manor
Fairport, NY 14450
585-330-3263
Fax 585-425-8774
[EMAIL PROTECTED]
http://www.bayercropscienceus.com/rep/~dan.digiacomandrea
-----Original Message-----
From: Jim Cranney [mailto:[EMAIL PROTECTED]
Sent: Friday, October 20, 2006 6:25 PM
To: Administrator
Subject: Azinphos Methyl (Guthion®) Phase Out
M E M O R A N D U M
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TO: USApple Science Advisory Subcommittee
CC: USApple Board of Trustees
State and Regional Producer Organizations
FROM: James R. Cranney, Jr.
SUBJECT: Azinphos Methyl (Guthion®) Phase Out
DATE: October 20, 2006
The U.S. Environmental Protection Agency’s (EPA) Assistant Administrator Jim Gulliford has reached a decision regarding azinphos methyl and is proposing to phase out the use as proposed, but over a slightly longer period to 2012. The Assistant Administrator has directed EPA staff to work with agricultural commodity groups to develop a phase out plan, which is expected to be finalized later this month or in early November.
EPA has proposed to phase out azinphos methyl using sharp regional use reductions that do not meet grower needs. USApple is attaching EPA’s proposal language for your information as follows:
Apples
The current label rate is 1.0-1.5 lbs ai/A/application with seasonal max of 4.5 lbs ai/A.
Nationally, the average rate is 0.78 lbs ai/A/application with 2.4 applications. The seasonal average application rate is 1.88 lb ai/A/year. However, in the Western apple production region, the average rate is 0.99 lb ai/A/application with 1.8 applications and a seasonal average of 1.78 lb ai/A/year. In the Eastern production region (in contrast), the average rate is 0.63 lb ai/A/application with 3.4 applications and a seasonal average of 2.05 lb ai/A/year. (All figures from USDA NASS, 2006)
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Under the approach outlined in the table above, the 2008 seasonal max application rate would be reduced to 2 lb ai/A West of the Rocky Mountains and to 3 lb ai/A East of the Rocky Mountains. The seasonal max in the Eastern region would decline to 2.0 lb ai/A in 2009 and 1.0 lb ai/A in 2011. The Eastern production region option offers the most flexibility to growers.
Limiting the number of applications does not offer as much flexibility to growers as the limiting the seasonal maximum application rate option. It’s possible that limiting the number of applications would lead growers in the Eastern US to increase rates above what they are currently using (0.63 lb ai/A) to the maximum allowable. Limiting the number of applications would have a bigger (initial) impact on PA and MI than WA.
USApple and the Northwest Horticultural Council’s Mike Willett met with EPA today to propose an alternative plan that would maintain more of the use over the period of the phase out.
USApple proposed a framework for an agreement which included the following issues:
I. Use reduction proposal
II. MRL review before the 2010 growing season to evaluate the availability of international MRLs for azinphos methyl alternatives. (top 15 markets)
III. Apple pest management summit in 2010 or 2011 to evaluate the state of apple pest management to consider any need for adjustment of the schedule based upon critical need for the chemical.
IV. Request EPA to allow Section 18 permits or other similar regulatory mechanism for azinphos methyl use after 2012 in cases where there is a critical need.
V. Ask EPA to reduce its proposed 100 foot buffer to 60 feet from permanent bodies based on data submitted showing that apple orchards have extensive vegetative buffers which reduce runoff.
USApple proposed the following alternative schedule for phase out of the apple use:
2008, 2009 3 lbs. a.i. maximum annual use per acre
(6 lbs. formulated product)
2010, 2011, 2012 2 lbs. a.i. maximum annual use per acre
(4 lbs. formulated product).
EPA acknowledged that USApple’s proposal was reasonable, but further discussion was necessary to finalize some of the issues in the agreement. A primary concern was the need for a mechanism to demonstrate that progress would be made in reducing the use. USApple has agreed to meet with EPA staff on Friday, Oct. 27 to try to finalize the agreement. USApple will continue to do everything possible to maintain the use according the USApple proposal.
Please contact me by telephone at (800) 781-4443 or via e-mail at [EMAIL PROTECTED] if you have questions or need additional information.
Dan DiGiacomandrea
Bayer CropScience
68 Chadwick Manor
Fairport, NY 14450
585-330-3263
Fax 585-425-8774
[EMAIL PROTECTED]
http://www.bayercropscienceus.com/rep/~dan.digiacomandrea
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