Information Requests Monitoring System

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Request ID: 190
Request From: Steve Toth
Date Requested: Nov 14, 2008
Request: Please note the following request from Al Jennings, USDA OPMP, regarding future data needs with Registration Review. Submit your comments to the Southern Region IPM Center's Information Requests Monitoring System by Friday, November 21, and I will forward them to Al and Nikhil Mallampalli at EPA. Steve Toth ------------------------------------------------------- All, At the last Director’s meeting, EPA agreed to identify data needs associated with Registration Review. Nikhil Mallampalli (EPA, BEAD) has worked with the Environmental Fate and Effects Division and the Special Review and Re-registration Division to assemble the attached draft list of potential needs. Please keep in mind that this is just a draft to serve as a starting point with more discussion to follow. At this point, we would like your comments on the draft list of needs. Specifically, for typical pesticide chemicals, what information either exists or is easily obtained? What information could be obtained with a reasonable amount of time and effort? What are alternative sources of the information and what other data and information are available that might help illuminate the usage and use practices? Could you please get back to Nikhil and me by November 21 with your reactions? Thanks, Allen L. Jennings, Ph.D. Director, Office of Pest Management Policy USDA 202-720-5375 allen.jennings@usda.gov

Responses
Responder: Darrell Hensley
State: TN
Date Requested: Nov 24, 2008
Response: The HUC will be be excellent data if you could ever get it. Information concerning average rainfall for the years in question. Heavy rainfalls vs light showers. Tillage usage (conventional vs no-till or minimal tillage. If anyone has degree day information or UV intensity info. Also, soil types in areas, organic matter or clay amounts.... These all can influence the activity of products used....... Darrell D. Hensley University of Tennessee Entomology & Plant Pathology 2431 Joe Johnson Dr., 218 PSB. Knoxville, TN 37996-4560 EMAIL "dhensley@mail.ag.utk.edu" OR "dhensley@utk.edu" Phone (865) 974-7958 FAX (865) 974-8868

Responder: Mike Weaver
State: VA
Date Requested: Nov 24, 2008
Response: Here is my response to this request: LIST: - Contact information for people at the USDA who could help direct us to the relevant local 'agricultural experts'. RESPONSE: This information could be made available from our existing stakeholder network participants. As a state contact person for the IPM Center in my region, we have established a network of stakeholders based on crop and industry as well as those working in our own institutions. We could put USDA in touch with the right people in most cases, although we can't open these lists up without considering privacy issues. But on a case by case basis this is probably no problem. USAGE DATA - Median and 90th percentile reported use rate (lbs ai/acre) from usage data County/Hydrological Unit Code (HUC)* (if possible). National and State use rate may be requested for active ingredients on a case-by-case basis. (BEAD has current use rate data for many, but not all, active ingredients at the national and state levels). - Application Timing (date of first application and application intervals) by Crop - National, State, County, and HUC (if possible). - Sub-county level crop location data. - Usage/use information for non-agricultural uses (e.g., forestry, residential, right-of-ways). - Directly acquired county-level and/or HUC-level usage data (not derived from state-level data): - Maximum reported use rate (lbs ai/acre) from usage data ­ County/HUC - Percent Crop Treated ­ County/HUC - Median and 90th percentile Number of Applications ­ County/HUC - Total Pounds per Year ­ County/HUC - The year the pesticide was last used in the county/sub-county/HUC area. - The years in which the pesticide was applied in the county/sub-county/HUC area during a specified period of time - Crop acreage trends through time (over years) (i.e., how crop acreage - for specific crops - has changed through time). - IPM Œsuccess stories¹ ­ what IPM strategies have worked to decrease pesticide usage (e.g., what have been some useful alternatives to pesticides) (this could be useful for mitigation purposes)? RESPONSE: Some of these data points are available as anecdotal information only. We haven't done pesticide use surveys since 1993 - because the NAPIAP and state funding sources were eliminated and even then the data generated did not have enough datapoints to generate county by county data. Even NASS had issues with this if there were just a few growers in a county. So unless industry has something going (which we know they do with marketing data) and change their minds on sharing it (an issue that has been a sticking point for years) these data are not available. The only other option is to fund surveys again and to do a survey at this level, it would take a huge influx of money. This may be the reason that NASS has stopped doing pesticide use surveys. LABEL INFORMATION -Typical treatment Interval (days) [the label provides minimum intervals] -State or local use restrictions (may not always be on the EPA label) RESPONSE: These could be tracked on a case by case basis as needs arise. Doing so for everything would be (again) a major undertaking at a very high cost. Michael J. Weaver, Professor and Director Virginia Tech Pesticide Programs Department of Entomology 305 Sandy Hall - 0409 Blacksburg, VA 24061-0409 phone: 1-540-231-6543 fax: 1-540-231-3057 e-mail: mweaver@vt.edu program websites: vtpp.org - www.ext.vt.edu department website: www.ento.vt.edu

Responder: Jim Criswell
State: OK
Date Requested: Nov 24, 2008
Response: In response to OPMP’s request for information. I suggest that OPMP utilize the Southern Region state liaisons as contacts for ‘agricultural experts’. It may even be possible for SRIPMC to provide OPMP the reference list that each state has developed. Even with the use of this list the state liaison should be included in the communications. Regarding USAGE DATA, since USDA ceased funding the obtaining of such data we can only provide the crop acreage trends, IPM ‘success stories’ and state use restrictions.

Responder: Patricia Lucas
State: KY
Date Requested: Nov 24, 2008
Response: For Kentucky - Individual pesticide records would exist as farmers are required to keep records of all pesticides used. The State Department of Agriculture could possibly also serve as a source of information. Patty Lucas University of Kentucky Research & Education Center P.O. Box 469 Princeton, KY 42445-0469 (270)365-7541 ext. 218 plucas@uky.edu

Responder: Mark Mossler
State: FL
Date Requested: Nov 24, 2008
Response: RESPONSES TO EPA’S DRAFT LIST OF POTENTIAL PESTICIDE INFORMATION NEEDS With regard to existing and easily obtainable use data, the best source for crop and state specific information resides in the crop profile database. The State of Florida has issued several state-wide use reports, but they have not been conducted for over six years and the data is somewhat dated at this point. The information regarding use data in the crop profiles are assembled by either USDA NASS or by the author of the crop profile (when the crop is not covered by NASS). However, funding loss has largely discontinued the chemical usage data collection activities of NASS as of 2008. None of these data are presented in a hydrologic context. Hydrologic data can be found through the NAWQA program. State use estimates can be determined from crop profiles by summing the major uses of an active ingredient if they are mostly agriculture-related. The Florida Pest Management Information Program (FPMIP) has also created a profile for aquatic weed control and is endeavoring to obtain golf course data when it becomes available from the USGA. Pesticide Information is quite hard to come by due to vested interests of both producers and users of these products. Obviously, states such as CA and OR have implemented reporting schemes that estimate total state use of materials and the locations used. However, no other states have seen the urgency in funding similar programs. Indeed, the Agency itself pays a substantial amount of money to private pesticide data collection services for these metrics. Perhaps the objectives of the crop profiles could be expanded to include use data collection if not already conducted. However, the additional effort needed for this process should be reflected in higher amounts of funding for these documents. This type of information was previously collected under the NAPIAP program which was funded at several million dollars annually. It would be wishful to believe that quality information could be collected with a lower level of effort and time. Besides itself and Doane’s, the FPMIP is unaware of any other entity that is trying to collect pesticide use data for Florida, Puerto Rico, or the Virgin Islands now that NASS has discontinued surveying growers due to budgetary constraints. As previously, mentioned, there is a reasonable grasp on herbicides used in aquatic weed control as the state funds a major portion of this effort, and the USGA is now conducting a pesticide use survey for their members.

Responder: Steve Toth
State: NC
Date Requested: Nov 24, 2008
Response: Regarding the list of contacts at USDA that could help direct EPA to local "agricultural experts", the Regional IPM Center contacts would provide the contacts in the states through the State Contacts (in the Southern Region at least). I feel the State Contact network that we maintain in the Southern Region is the best mechanism for collecting regulatory information. Future requests (which would include endangered species risk assessment information and county/hydrologic unit code level usage data) will require our State Contacts to work with different "experts" in their respective states, but I can not think of any group that would be better to do this work than our existing State Contacts. Collecting county/hydrologic unit code level usage data will be a tremendous challenge as such data does not currently exist (except for California and perhaps another state or two). The lack of NASS surveys will further hinder the collection of such data. To proactively generate pesticide usage data on this scale (i.e, county, hydrologic unit) across the country appears to me to be too expensive and time consuming to be realistic goal. Perhaps this data can be collected from sales data and quick surveys of growers or county agents in selected counties or watersheds where there are concerns. However, this would require lead time of 6 months to a year at minimum to collect such information and would incur some costs. IPM success stories are, in fact, already availble by state in the USDA CSREES PPRS reporting system for viewing by the public on the web at http://www.pprs.info/IPM/index.cfm. Finally, regarding label information, typical treatment intervals used and state ort local resrictions are information that the State Contacts can collect from the agricultural experts in their states.

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