AZM Transition Workgroup Conference Call - September 24, 2007

Rick Keigwin, Al Jennings, Carol Dansereau, Mike Willett, Mark Whalon, Mike Shaw, Dan Sonke, Jim Cranney, Gabrielle Ludwig, Andrew Bayak, Marilyn Dykstra, Ephi Gur, Rebeckah Adcock, Lori Berger, Rufus Issacs, Shelley Davis, Ken Campbell, Linda Murray, Pat Cimino, Margaret Rice, Steve Jarboe, Tim Kiely, Skee Jones, Steve Smearman, Katie Hall, Diane Simms

Rick Keigwin opened the call by saying that the main purpose of the call was to prepare for the full PPDC meeting scheduled for October 17 and 18. The AZM Transition Workgroup has been asked to provide an update on its activities, particularly on the status of the two transition case studies – Washington apples and Ohio parsley. During this call we will talk about the update and how the group wants to present its update to the PPDC.
Mr. Keigwin also said that the group would discuss the data matrices for registration status, tolerances/MRL tracking tables, and pest management tools. There has been lots of email discussion on what should be included in the matrices.
Mr. Keigwin informed the committee that at a recent meeting of the NAFTA Technical Working Group (TWG) on Pesticides, EPA and PMRA agreed to work jointly on AZM transition issues. PMRA has been participating in person or by phone in EPA meetings on AZM transition. EPA and PMRA will formalize this group and develop milestones for a North American strategy. Once the project sheet is approved by the NAFTA Executive Board, it will be distributed to the workgroup so that they can see it. Mr. Keigwin asked the group if there was anything else that needed to be discussed during the call.
Mike Willett told the group that he would like to speak first because he had someone waiting on him to finish the call.
Rebeckah Adcock said that the representative of California Almonds needed to speak early in the call regarding to import-export issues and AZM.
Gabrielle Ludwig, representing California almonds, said that the European Union (EU) has put in place special measures for alflatoxin. The EU is testing more frequently. As of September 1, 2007, every lot from the US has to be tested to ensure compliance with limits. The EU is the largest market for almond exports.
Mr. Willett told the group that he is prepared to make a report to the full PPDC on the WA apple transition strategy. Mr. Willett told the group that Jay Brunner was unable to make the conference call because he was out of the country. Mr. Willett said that they are making progress with the transition project; they are putting together an executive team and advisory committee. The WA apple transition group will have representation from industry, farm labor, Washington State Department of Agriculture and Washington Fish and Wildlife folks. The advisory committee will steer progress for the next 2 years or so. The goal is that alternatives are sufficiently tested for efficacy and that they know the pitfalls of each alternative. Mr. Willett will also go to Washington for the October PPDC meeting.
Carol Dansereau asked about the advisory committee for the WA apple transition project. Ms. Dansereau had inquired about the committee and had requested to be involved, but she has not heard back from the advisory committee organizers. Ms. Dansereau asked what the plans are to tap into the farm labor point of view.
Mr. Willett said that farm workers will participate on the committee. Mr. Willett said that he is a committee member and is not sure how the members were selected. He knows the committee chairs have identified individuals from different organizations.
Ms. Dansereau said that she would like more information on who will represent the farm workers in the state process. Have Mr. Willett or Mr. Brunner been in contact with Shelly Davis regarding the apple case study for the EPA advisory process? Ms. Davis wanted to participate in the EPA Transition Committee apple case study development process.
Mr. Keigwin said that Mr. Willett developed the WA apples transition plan and circulated it to the PPDC sub-group for comment last spring.
Mr. Willett added that Ms. Davis was in on all of the emails that were sent back to the AZM transition workgroup committee. Mr. Willett said that if Ms. Dansereau or Ms. Davis have items for discussion, that they should contact Mr. Brunner or himself directly.
Ms. Dansereau said that she had contacted Mr. Willett directly but had not received a response. Ms. Davis was the original volunteer, but has not been involved.
Mr. Willett said that he had not seen those comments and had not heard from Ms. Davis. He will talk with Mr. Brunner when he returns about this.
Ms. Dansereau said that there is a benefit to communicating with the farmworker community on this issue so that everyone can join forces and communicate transition to the state. She added as a process point for EPA that when people volunteer to be on the team, they should be included.
Al Jennings noted that the first opportunity any one had for input was on the draft that was circulated to the team.
Ms. Dansereau noted that the draft was circulated to the entire EPA transition committee without previous input from Ms. Davis although she was part of the team of three (along with Mr. Willett and Mr. Brunner) who was to develop the case study.
Mr. Willett noted that the goal of the AZM Transition Workgroup is to meet the phase out deadlines for AZM. Only two “acceptable” alternatives were presented by Ms. Dansereau.
Ms. Dansereau said that her comments were being misrepresented. She said that her input was on the process for analyzing alternatives.
Mr. Willett said that their responsibility is to find alternatives to AZM. He said that others should not find fault with the efforts that the state of Washington has put into this process.
Mr. Keigwin said that he thinks Adam Sharp will be in town to give the update on the Ohio parsley transition case study.
Mr. Jennings had an additional update on OH parsley. He said that the North Central Michigan IPM Center will fund a transition effort with OH parsley growers. Jim Nisniskey from Ohio State will work with all the fresh parsley growers in Ohio and the single parsley processor in Ohio. Jim Nisniskey thinks that one meeting is all that will be required to pull together basics of a transition plan.
Mr. Keigwin told the group that previously Barbara VanTil had been helping out with this transition. Barbara has moved on to a new position. EPA Strategic Agriculture Initiative coordinators are looking for someone to take Barbara’s place. So Adam Sharp is working on his own with Ohio growers.
Mr. Keigwin opened up a discussion on the matrices. Linda Murray has gathered comments from everyone. There have been some discussions about 1) the purpose of the matrices and the extent to which they should continue to be developed, and 2) what elements should be considered in the matrices. In the spring there was a discussion about adding or deleting elements of the matrices, but nothing further was decided. Today we can have the discussion of what should be included.
Ms. Murray said that there were comments from two viewpoints - one side thinks there should be more information on human health effects and ecological effects, and the other side thinks that the matrices are not that useful because they are not “go to” documents that growers would use anyway. It has been difficult to reach a consensus on should be included because of the diversity of opinions. The regulatory matrix is the one that EPA has committed to work on in order to consider what chemistries are in the pipeline and of MRLs.
Mark Whalon asked, “If there aren’t alternatives, is a transition workable?”
Mr. Jennings said that the real question is whether or not the established matrices are useful.
Shelley Davis said the point of the matrices is to present what alternatives are available. Since there are disagreements on efficacy, the decision for use will be made by the grower or crop advisor. The government should not recommend what people use, but say what is possible.
Ms. Adcock said that there is an in between point, between what is possible and what the results are. She said that there needs to be a threshold level of what is possible. There should be some criteria for putting an alternative on the list. She thinks that both the alternative matrix and the regulatory matrix are important.
Jim Cranney said that it is helpful to have a matrix that outlines tools in the pipleline, explains the strengths and weaknesses of the alternatives, and gives the timeline for registration. It would be helpful to keep a running list of countries for which MRLs are established. He said that this committee should not get into the details of pest management by regions, crop, etc., especially since there are experts working with growers on these issues.
Ms. Murray said that when this group was formed, the matrices were put together to kick off the discussion of what information was needed to build transition strategies. As we go beyond the two pilot cases, we need to maintain the information for each commodity and pest management strategy.
Ms. Davis said that she basically agrees with Ms. Murray and Mr. Cranney. Two “tiny” points she has are that 1) EPA should stay out of the business of efficacy since it’s not a part of the registration process. It would be valuable for each crop to show the percent crop treated with AZM by date to show how many farmers are using AZM, and importantly, how many are not using AZM. 2) It would be helpful to have both proposed and final MRLs.
Mr. Whalon said that it is also important to have percent crop treated by region.
Ms. Davis agreed to have percent crop treated by region. She said that it is a snapshot – a piece of useful information at a point in time.
Mr. Keigwin asked whether the group should discontinue the pest management tools matrix because the table oversimplifies the situation.
Ms. Adcock asked what the plan would be if we discontinued the matrix.
Mr. Keigwin said that as we go through process, it is important for the group to know how readily available alternatives are adopted. If efficacy issues are raised for the alternatives, it should be known. This could be a committee on gathering that information. Mr. Keigwin asked how active EPA should be in soliciting that information. Should user groups provide this information freely? Also, EPA should not oversimplify the alternative/efficacy information that comes in.
Ms. Davis said that no grower is going to use the matrix to make decisions. They will go to the experts.
Mr. Keigwin said that growers might want to know about how things are progressing i.e., what alternatives have become available.
Ms. Adock asked if regional experts would have access to EPA’s information.
Ms Davis asked if EPA was the right Agency to do this. She asked if this is an issue that extension should work on.
Mr. Whalon said that it would be possible to develop surveys from motivated growers. But again, it is important for growers to know what is in the tool box and what is coming down the line and what has been tested so that growers can transition.
Ms. Davis asked, “Who keeps track of this?”
Mr. Whalon said that entomologists across the country and private consultants do.
Mr. Jennings said that USDA doesn’t track field studies and that IR-4 tests specific commodities.
Ms. Davis said that the company developing the chemical would track its efficacy.
Mr. Whalon said that the land grant universities would also.
Mr. Jennings said that efficacy information is in scientific journals.
Mr. Whalon said that the Entomology Society of America publishes information on small plot trials.
Ms. Davis said that it is hard to find know where to find information on efficacy. Resources on the various alternatives would be good information to have.
Ms. Adcock said that it is difficult to find a clearing house of information on alternatives. In this case USDA and EPA should provide the information. USDA provides education component. EPA is the entity phasing AZM out, so they are assisting with this transition so that there is something to transition to. The information should be posted in a helpful manner.
Mr. Jennings said that posting a matrix is much different from helping an actual grower.
Ms. Davis said, “Can’t we agree that EPA is not going to provide the level of detailed information that would help a grower?”
Mr. Whalon said that what might be considered efficacious for some commodities may not be for another commodity because of different control standards.
Ms. Davis said that she would like a website where anyone could post information on efficacy issues – a space where people could post resources.
Ms. Adcock said that there should be a certain level of expertise required in order to post to such a site. She said that the group needs to find a way to assist growers over the long haul. EPA and USDA should both play a role.
Mr. Jennings said that as a country we have developed Land Grant schools as a system that works on a regional basis. Where is the system broken that this group could fix it?
Ms. Adcock said that she agreed with Mr. Jennings to some extent. However, the specialty crop community does not receive all of the information needed from the Land Grant process. Also, the system is not as strong as it used to be.
Mr. Jennings said that Ohio parsley is a good example of being able to respond when we know there is a problem. He said that he didn’t know that putting information on a website would help the Ohio growers.
Ms. Adcock said that people like her are caught in the middle. EPA and USDA dictated the transition, and are forcing the growers to deal with it. She said that’s what some people think.
Mr. Whalon said that it boils down to how the word “alternative” is used. Mr. Whalon said that an “alternative” should mean that there is a viable system that is ready to use. Tart cherries are not there yet. Mr. Whalon is a proponent of organic apple farming.
Ms. Davis said that she thinks Mr. Whalon has defined “alternative” to narrowly. EPA should list “potential alternatives.”
Mr. Whalon said that he’s trying to define alternative for people on the ground.
Ms. Davis said that she doesn’t agree, otherwise there wouldn’t be a six-year phase out. What useful information could be put on the website? She said that she thinks potential alternatives could be put on the website. Getting too specific would require local expertise and may not represent the national level. The people inquiring would have to find out what works for them.
Mr. Jennings said that they should put down alternatives that already exist or are in the pipeline. Mr. Jennings wanted to know who this information would help.
Ms. Davis said that she would like to know what is available on a crop by crop basis.
Mr. Jennings said that Pest Management Strategic Plans (PMSPs) are available on the web. Crop profiles are there too, but they are not as good for pest issues. The PMSPs were not developed with an AZM orientation.
Ms. Davis said that the point of the exercise is to identify AZM alternatives. The crop profiles were developed before AZM was going to be phased out.
Mr. Jennings said that the group should look at the PMSP for Michigan cherries. Mr. Jennings will send the web address to Ms. Murray who will send it to the rest of the group.
Ms. Adcock asked if people from outside Washington DC feel like they have adequate information from national level.
Mr. Whalon said that he thinks that the MRL information would be useful. He knows situation in Michigan, but not other areas of country.
Lori Berger said that there are two levels of information. There’s information at the field level – commodities know that they have to investigate alternatives. If they identify a viable candidate, it is forwarded to the IR4 system. For MRLs, growers look to commodity groups to manage that information.
Mr. Keigwin said that the niche that EPA can fill is the MRL status of alternatives.
Ms. Davis asked why we are losing the piece on potential alternatives. The advocates would like to know what potential alternatives are available.
Ms. Berger said that info is available at a state and local level.
Ms. Davis said that non-experts could use some pointing in right direction. She would like to either have a list of potential alternatives or give them a list of websites where they could access that information.
Mr. Jennings said that alternatives can be anything from specific chemicals to cultural practices.
Ms. Davis said that the categories should be broad enough that non-experts can understand them. She doesn’t want EPA to make a judgment on what works and doesn’t. She just wants to know what potential universe of alternatives looks like.
Mr. Jennings said that the potential alternatives list would be huge.
Mr. Whalon said that the group is trying to make it useful and at the same time manageable. Mr. Whalon also said that it should not be overstated that small plot data is only a partial answer. There is no substitution for on-farm evaluation for conventional chemicals and organic systems. What matters if whether real producers under real conditions can make something work. The true measure is whether it works under actual conditions in the field.
Mr. Jennings asked if Ms. Davis would look at the matrix and see if it is what she is looking for.
Ms. Murray said that she would take the efficacy column out of the matrix and redistribute it to the group.
Ms. Davis asked if there was any controversy over the target pests.
Mr. Whalon said that the one tool/one target scenario doesn’t make much sense, especially for AZM, which kills lots of things. Mating disruption only takes care of one pest.
Ms. Davis requested that the group just list the potential alternatives.
Ken Campbell of the Pest Management Center in Canada said that doesn’t made sense to leave out the pest information. He said that we need to know what we’re dealing with.
Ms. Davis asked if percent crop treated would end up in the matrix? It provides information from a point in time. She would rather have an estimate for percent crop treated even if it is an imperfect estimate, than no estimate at all.
Mr. Keigwin said that we need to think about how that will be captured. Regional percent crop treated estimates are different from national percent crop treated estimates.
Ms. Davis said that if you could post national numbers, or you could post regional numbers if you have the time and resources. She doesn’t want the “excellent to be the enemy of the good.” She would like to have a starting point.
Mr. Keigwin asked if Ms. Davis would want the percent crop treated information updated on a periodic basis.
Ms. Davis answered yes, because it is a useful comparison point.
Mr. Keigwin said that there may be value to see how percent crop treated changes over time as AZM is phased out. The group discussed the frequency of the National Agricultural Statistics Service (NASS) crop surveys. NASS does not survey every year.
Mr. Keigwin said that EPA will track percent crop treated, regulatory status of alternatives and potential alternatives, both in terms of MRL status in U.S. and in key export markets. By and large we will remove efficacy considerations from the other matrix. Mr. Keigwin agrees with the sentiment that EPA should not distribute up to date information on efficacy and pest management information. It would be best to use the network that is already out there. The clearing house idea is something that we can come back to. Mr. Keigwin is not sure that he heard consensus on that topic.
Mr. Keigwin discussed the plans for the October PPDC meeting. Ms. Murray and Mr. Keigwin will work with Mr. Willett and Mr. Brunner on the WA apple case study, and will work with Adam Sharp on the Ohio parsley case study. They will try to have the case studies distributed before the meeting for comment by the group if possible. Folks can join us for the PPDC meeting if they want to. Mr. Keigwin noted that the AZM transition subgroup is only allotted half an hour at the PPDC meeting, so apples and parsley will take up most of that time.
Mr. Keigwin asked if there was anything else to discuss. Nothing was mentioned.

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AZM Transition Workgroup Conference Call - September 24, 2007

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