The
Berry DisPatch
Newsletter of the Wisconsin
Berry Growers Association
November, 2004
Teryl Roper
UW Madison Extension Horticulturalist
For most Wisconsin berry growers pesticides are still the primary means of
controlling insect, disease, and weed pests in the orchard. We have been
fortunate over the past few years to have had several new compounds become
registered for use. Most pesticides are registered for use on agronomic
crops such as corn, soybeans, rice, and cotton before they are registered on
minor use crops like berries. Because of the huge acreages of these crops
chemical companies can quickly recoup their development costs. Only later
do these materials become available for minor crops. The process for
registering pesticides for crops is long and arduous. Some additional
steps are required for minor crops. This article will seek to describe
this process so that you can see what is involved to obtain new pesticide
registrations.
Usually the first step in the process is discovery work or pesticide
screening work where an array of promising unregistered pesticides are applied
to a crop or a pest to see if it works and if it causes damage to the crop plant
(phytotoxicity). Frequently, but not always, this work is done at
universities. Chemical companies used to support such work as they would
like independent people to look at the efficacy of their material on a new crop
or a new pest. Most of this money has dried up over the past 10 years.
Once a compound is known to be effective against a target pest and does not
cause crop injury a company may be willing to work towards registration.
The biggest hurdle is to obtain a food residue tolerance for a pesticide.
This entails treating the target crop with the top of the proposed label rate at
the shortest pre-harvest interval that might be found for that crop, collecting
samples of the edible portion, and analyzing the samples for residues of the
pesticide. This work can be done by the chemical company or by a
university related group called IR-4.
IR-4 is short for interregional project number 4. It was established
in 1964 for the express purpose of providing data on efficacy, phytotoxicity,
and residues to regulatory agencies to procure pesticide registrations for minor
use crops. They maintain four analytical labs in New York, Michigan,
Florida, and California. IR-4 sets priorities each year and, working
cooperatively with universities, does residue trials under EPA approved good
laboratory practices. These standards ensure that data collected is
meaningful and that all potential sources of variation in an experiment have
been accounted for.
Once IR-4 or the manufacturer has the data that EPA requires a request is
submitted to the EPA for approval. The EPA looks at a variety of issues
before approving a registration. These include crop safety; handler and
applicator safety; aquatic, avian, and mammalian toxicities; duration of
residues; the risk of residues in foods to human health in terms of cancer risk
and total dietary exposure. If all goes well a residue tolerance is
established and a registration for use of a specific pesticide on a specific
crop at a specific time to control a specific pest or pest complex is approved
and published in the Federal Register.
The process takes a long time. The manufacturer discovers a product
that has potential, it is registered for use on major crops, efficacy and safety
for minor crops is established, formal residue studies are completed and a
packet is submitted to EPA for approval. Once a product lands on the IR-4
priority list it will take between four and six years, and sometimes longer,
before a label is obtained. While the process takes a long time it also
ensures that our food supply is safe and it prevents food safety scares from
labeled products such as aminotriazole on cranberries in 1959 or Alar on apples
in 1989.
I hear periodically of growers using pesticides that are not registered for
their crops, but which are apparently safe for the crop and do a good job of
controlling the target pest. This practice is at best dangerous and at
worst it is illegal and puts at risk your farming operation and all other berry
growers in the state. If an illegal residue is found on your crop the FDA
will quarantine your crop and not allow it to be marketed and it will more than
likely levy major fines in addition to potential jail time. Please don’t
use unregistered products on your farm even if you know they work. The
risk to you and the industry simply isn’t worth it.
If there is a crisis or emergency there is a process to obtain the use of a
specific pesticide to control a specific pest for a short period of time,
usually one growing season. However, a food tolerance must have been
issued for that pesticide for that crop. These are known as Section 18
exemptions. Strawberry and cranberry growers have had these in the past
(e.g. Spartan for the last two years).
The good news is that there are several products in the pipeline for fruit
growers. Hopefully labels will be issued for these crops in the
foreseeable future. In the meantime I hope this helps you understand the
process of registering pesticides better. Yes, it takes a long time, but
in the end the process protects you, your customers, and the environment.