A monthly report on pesticides and related environmental issues

Issue No. 142, February 1998

Open Forum:
In an attempt to promote free and open discussion of issues, The Agrichemical and Environmental News encourages letters and articles with differing views. To discuss submission of an article, please contact Dr. Allan Felsot at 509-372-7365 or afelsot@tricity.wsu.edu; Dr. Catherine Daniels at 509-372-7495 or cdaniels@tricity.wsu.edu; or Dr. Carol Weisskopf at 509-372-7464. The newsletter is available also in hardcopy version for a $15 yearly subscription charge. Please contact Dr. Catherine Daniels at 509-372-7495, cdaniels@tricity.wsu.edu for details.

Note: Based on instructions from WSU CAHE administration, information in this newsletter not originating from WSU contains a headline in the same color as the word "Note" at the beginning of this paragraph. This is to help ensure that readers can readily identify material obtained from a source outside WSU.

In This Issue

News and Notes Reregistration Notification Network
Reorganization Planned for EPA PNN Update
Update on Metals in Fertilizer State Issues
WSU Offers Recertification, Pre-licensing Short Courses for 1998 Federal Issues
You Can't Tell the Players Without a Score Card Tolerance Information
The National Organic Program: Proposed Rules
for Implementing the Organic Foods Production Act
of 1990
Position Announcement
WSDA's Pesticide Management
Revisits Pesticide Recertification

Note: The animated spider graphic appearing at this site is used with permission. Copyright and use information may be obtained at http://www.inscot.demon.co.uk

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Thank you!

As mentioned elsewhere in the newsletter, costs of future issues of the AENews will be covered through institution of paid subscriptions. This and the next issue are coming to you free. We are able to do this because of the generous support of Bryan Alford of Alford Farms, Inc., and Bud Mercer of Mercer Ranches, Inc. The faculty, staff, and students of FEQL would like to take this opportunity to thank these donors, and we are pleased that they have graciously extended their assistance to help cover printing and mailing of these issues.


We want your opinion on the AENews

Please return the questionnaire on the Agrichemical and Environmental News that was mailed to subscribers in December. This is your chance to tell us if we are serving your needs and to make suggestions. We hope to hear from all our subscribers, so please take a moment to answer the short questionnaire and drop it in the return mail today.

News and Notes

Note: The AENews is accessible from the World Wide Web via http://picol.cahe.wsu.edu
Enter this address carefully, paying close attention to punctuation and spacing (no spaces between parts of the address). Some readers may experience difficulties accessing the site. These are believed to be related to the Internet and to on-line services, not the web site. If you are having a problem accessing the web page, please inform Dr. Catherine Daniels at 509-372-7495, cdaniels@tricity.wsu.edu

A new look for the AENews

As you browse through this issue of the AENews, you may notice more changes than just the paper and ink color. We are taking advantage of the new year and some staffing rearrangements to revamp many features; we hope most will make the newsletter more useful to you. There have been three major changes to the newsletter itself (aside from the color).

First, reports on tolerances and sections 24(c), 3, and 18 are being omitted from the paper copy of the newsletter. These will, however, be included in the copy published on the web [http://picol.cahe.wsu.edu]. Second, a subscription charge is being instituted. The success of the newsletter has brought its circulation to nearly 1,600 issues per month, and it has become difficult to cover the cost of its printing and mailing. Third, we are committed to establishing a regular schedule of newsletter production. This is the February 1998 issue. There has been some slippage, and we are catching up with the calendar. Our new schedule should bring the newsletter to you a few days before the first of each month; the web copy will be available at the same time.

This issue was assembled before many newsletter surveys were received. Format and content will probably change over the next few months as suggestions are implemented. The survey is the easiest way to get your opinions to us; if you have not yet done so, please send it in. We always welcome comments; you can send them to the attention of Catherine Daniels or Eric Bechtel (address below) or FAX them to us at (509) 372-7460. We are interested in your thoughts regarding the newsletter, even if you are not intending to subscribe.

This issue and the next will be sent to all on our mailing list. To continue receiving a hard copy of the AENews, you will need to subscribe. The subscription cost is $15 for one year. Subscription requests should be mailed to Catherine Daniels' attention. Please make checks payable to the Pesticide Information Center, and include your name and mailing address.

Pesticide Information Center
1710 University Drive
Richland, WA 99352-1671

Ag census to arrive in mail

The 1997 Census of Agriculture is coming to a mailbox near you. Take the time to fill out your report form and return it by February 2, 1998; it's the law. All information you provide is, by law, kept completely confidential.

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Reorganization planned for EPA

Dr. Lynn R. Goldman, assistant administrator at EPA, issued two memos December 9, 1997, to the Office of Pesticide Programs (OPP) and the Office of Prevention, Pesticides, and Toxic Substances (OPPTS) staff. The first memo, to OPP staff, announced that Marcia Mulkey, who has served as the regional legal council for EPA Region 10 since 1989, will take over as director of OPP on February 2, 1998. She replaces acting Director Steve Johnson, who will continue as deputy office director in the short term.

The second memo, to OPPTS staff, announced Dr. Goldman's proposal to reorganize OPPTS. Currently, OPPTS has two offices - the Office of Pollution Prevention and Toxics (OPPT) and OPP. A third office - the Office of Science Coordination and Policy - has already been proposed and is being established under the guidance of Penny Fenner-Crisp. Goldman also proposes the creation of a fourth office - the Office of Consumer Safety and Right-to-Know.

Proposed primary functions of each office are as follows:

OPPTS Immediate Office
Communications coordination, special assistance to the assistant administrator, Office of Program Management & Operations, policy coordination for OPPTS, regulatory blueprints and coordination, reinvention activities, preparing documents for Federal Register publication, policy coordination on international chemicals related activities, Pollution Prevention Policy staff, and Senior Budget Office.

Office of Consumer Safety and Right-to-Know
All OPPTS right-to-know programs, including TRI(EPCRA 313), worker protection, Food Quality Protection Act (FQPA) food safety pamphlets, consumer product registration and reregistration, antimicrobial product registration and reregistration, consumer labeling, worker protection, assessment of worker and residential exposure to pesticides and chemicals, surveillance of human poisoning incidents from toxic chemicals and pesticides, reports of adverse human health effects of chemicals and pesticides, OPPT and OPP state and tribal program coordination, and OPPT and OPP regional programs.

Office of Science Coordination and Policy
Science policy throughout the OPPTS and the primary liaison point regarding OPPTS science issues within EPA, domestically outside EPA, and internationally, policy issues which cross pesticides and toxics issues such as coordination of development of test guidelines for chemicals and pesticides, harmonization of classification, and labeling, etc.

Office of Pollution Prevention and Toxics
Pollution prevention, new chemicals, existing chemicals testing, risk management and Toxic Substances Control Act (TSCA) reporting, design for the environment, national program chemicals control (lead, PCBs asbestos, etc.), and TSCA docket.

Office of Pesticide Programs
Active ingredient registration and reregistration (except antimicrobial and consumer products), special review of pesticides (except antimicrobials and consumer products), and benefits assessment, product registration and regegistration (except antimicrobials and consumer products), FQPA implementation, including food safety issues and tolerance reassessment, ecological risk issues, Federal Insecticide Fungicide and Rodenticide Act (FIFRA) docket, minor use program, biopesticides, pesticide environmental stewardship program.

Dr. Goldman plans to place this reorganization package into EPA's approval process within six months. Upon approval, Steve Johnson will serve as office director of the Office of Consumer Safety and Right-to-Know; Susie Hazen will serve as deputy office director. Bill Sanders and Joe Carra will continue as director and deputy director of OPPT.

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An update on metals in fertilizer:

Do we also have to worry about dioxins?

By Dr. Allan S. Felsot

Dr. Felsot is an environmental toxicologist at the Washington State University Food and Environmental Quality Laboratory.

In between the periodic appearance of newspaper articles about problems with contaminated fertilizers, the governor-appointed Fertilizer Advisory Work Group hammered out a draft of legislation designed to set standards for heavy metals in fertilizers. In a January 8, 1998, press release, the Department of Ecology unveiled the text of the proposed legislation. At the same time, a summary was compiled of results from monitoring heavy metal and dioxin content of commercial fertilizers with recycled industrial by-products.

The proposed legislation, if passed, would make Washington one of the first states in the nation to adopt standards for fertilizers that are related to "tag along" metals. The proposed legislation has four objectives:

One surprise issued with the press release was the finding of dioxin in fertilizer by-products. This information was not in the draft report, "Screening Survey of Metals in Industrial By-Products and Fertilizers in Washington State", sent out by the departments of Ecology, Agriculture, and Health for peer review. Most of the past controversy had been focused on metals like cadmium, arsenic, and lead. Ironically, a natural product like wood ash, derived from burning untreated wood for fuel, when added to soil at recommended rates, would cause the highest levels of arsenic, lead, and dioxin contamination. Wood ash was recently listed as an approved nonsynthetic soil amendment under proposed National Organic Program rules in the Organic Foods Production Act.

Finding dioxins in recycled fertilizer by-products is not unusual. Dioxins refer to a group of 75 chemicals of varying toxicities known by chemists as polychlorinated dibenzo-para-dioxins. Each of the various forms of the chemicals are called congeners, and are characterized by differing amounts of chlorine atoms in the molecule. The most infamous and acutely toxic of the dioxins, 2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD) was an inadvertent contaminant of the herbicide Silvex, whose active ingredient, 2,4,-5-T was a major component in Agent Orange, the herbicide used extensively during the Vietnam War. The concentration of dioxins is expressed as the sum of the concentrations of the individual congeners adjusted for their toxicity relative to TCDD.

Great amounts of money have been spent studying the environmental chemistry and health effects of dioxin. The issue of whether dioxin has any long-term effects on humans exposed to environmental levels, which occur in the parts per trillion and quadrillion range, is still undecided and scientists are far from reaching a consensus. On the other hand, we now know a lot more about the environmental chemistry of dioxin, especially how it is formed. Combustion processes, including incineration of municipal and medical waste, biomass burning, steel and copper mill emissions, and cement kiln emissions are now known to be the major sources of dioxin emissions. Recent evidence reported in Environmental Science and Technology (ES&T) (Juttner et al., 1997 vol. 31, p. 806) indicates that dioxins have been accumulating in the environment since long before the 1900s, perhaps as a result of fossil fuel burning associated with industrialization dating to the 18th century.

The fact that dioxins are ubiquitous, and thus exposure is inevitable regardless of what is in fertilizer, was shown by an earlier study reported in ES&T (Berry et al. 1993, vol. 27, p. 1164). In this study, the dioxin content of everyday household products was compared to bleached paper, another known source of dioxin contaminants. The highest dioxin concentrations were found in plastic packaging, clothes dryer lint, vacuum cleaner dust, room air filters, car air filters, and house furnace filter dust.

The legislation to regulate fertilizer by setting standards for metals and dioxins is pending. The cat is out of the bag concerning the levels of contaminants, and surely much will be made about the dioxin content in industrial by-product fertilizers. However, no information was released about the possibility that dioxins may also occur in non by-product fertilizers. Certainly, the scientific literature indicates that dioxins are everywhere, and residues depositing from the air as a result of numerous combustion processes are the main sources of exposure. According to recent studies, exposures to various kinds of dioxins have been occurring for at least several hundred years. Concerns about dioxins in fertilizer and calls for their regulation seem premature, given the current knowledge about their environmental chemistry.

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Position Announcement

Agrichemical and Environmental Specialist

Agrichemical and Environmental Specialist: Asst./Assoc. Prof. (Res.(25%)/Ext.75%); tenure track, 12-mo. Appt.). Starting date July 1, 1998. Location Central Washington (Prosser or Tricities Campus). Develop a recognized extension and research program in crop protection technologies. A PhD is required. Desired areas of expertise include a plant protection discipline or related specialty. An ability to communicate well, both orally and in writing, strong organizational skills, experience working with commodity groups, experience conducting field plot investigations involving agrichemicals, and an ability to effectively use electronic communications and computer applications is desired. Salary competitive and commensurate with training and experience. For add'l info. contact, John D. Stark, Search Committee Chair, Washington State University, Puyallup Research and Extension Center, Puyallup, WA 98371, starkj@wsu.edu, Phone (253) 445-4519, Fax (253) 445-4569. Send a letter expressing your qualifications and interest in the position and program, a CV, academic transcripts, and a list of the names, addresses, and telephone numbers of three references to Dr. John J. Brown, Chair, Department of Entomology, Washington State University, Pullman WA 99164-6382. Appl. accepted through April 1, 1998 or until position is filled.

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WSU offers recertification,
pre-licensing short courses for 1998

Carol Ramsay and Carrie Foss of Washington State University are sponsoring the following WSU Pre-licensing and Recertification Short Courses for 1998.

Recertification requirements

For private applicators, 20 recertification credits are required in five years, with no more than 8 allowed per calendar year. All other applicators need 40 credits in five years, with no more than 15 allowed per calendar year. Applicators may retest after five years in all categories in which they are currently working.


Washington State University annually conducts pre-license training for pesticide applicators, consultants, and dealers. Washington State Department of Agriculture offers all exam categories at the end of the training. Anyone preparing for pesticide licensing exams will benefit from the training programs offered; however, this training will be most useful to those preparing for the following licensing exams:

Locations and dates for 1998 WSU pre-license short courses
Eastern Washington Western Washington
Yakima Jan. 27-29, 1998 Mount Vernon Feb. 3-5, 1998
Wenatchee Feb. 3-5, 1998 Tacoma Feb. 23-25, 1998
Spokane Feb. 17-19, 1998    


1988 Integrated plant
health management workshop
Dealer management meeting
A four-day integrated plant health management course, worth 20 credits, will be Feb. 9-12 at the WSU Puyallup Allmendinger Center, 7612 Pioneer Way East, Puyallup. Cost is $150. Class size is limited to 60. Up to 6 recertification credits will be available from a dealer management meeting planned for Feb. 6 from 8:15 a.m. - 4 p.m. at the WSU Tri-Cities campus auditorium. Contact WSU Cooperative Extension Conferences at (509) 335-2830 for more information.


Locations and dates for 1998 WSU recertification short courses

Eastern Washington

Western Washington



Info / Registration




Info / Registration
Yakima (Convention Center) Jan. 28 & 29, 1998 Cooperative Extension, 128 N. 2nd St., Room 233, Yakima, WA 98901. Phone (509) 574-1600. 6 credits Silverdale (Island Lake Community Center) Jan. 27 & 28, 1998 Chris Smith, Ext. Agent, Kitsap Co. Coop. Ext., 614 Division MS-16, Port Orchard, WA 98366. Phone (360) 876-7157. 6 credits. Class sizes limited to 60.
Wenatchee (WestCoast Wenatchee Center) Feb. 4 & 5, 1998 Tim Smith, Area Agent, 400 Washington St., Wenatchee, WA 9801. Phone (509) 664-5540. 6 credits Bellingham Jan. 30, 1998 Craig MacConnell, Ext. Agent, Whatcom Co. Coop. Ext., 1000 N. Forest St., Ste. 201, Bellingham, WA 98225. Phone (360) 676-6736. 6 credits. Class size limited to 60.
Spokane (Cavanaugh's Inn at the Park) Feb. 18 & 19, 1998 Paul Peterson, Ext. Agent, 222 N. Havana, Spokane, WA 99202. Phone (509) 533-2048. 6 credits. Class size limited to 325 Mount Vernon Feb. 4 & 5, 1998 Dyvon Havens, Ext. Agent, 306 First St., Mt. Vernon, WA 98273. Phone (360) 428-4270. 6 credits. Class sizes limited to 275.
Bellevue Feb. 18 & 19, 1998 WSU Coop. Ext. Conferences, PO Box 646230, Pullman, WA 99164-6230. Phone (509) 335-2830. 6 credits.
Bellingham Feb. 20, 1998 Craig MacConnell, Ext. Agent, Whatcom Co. Coop. Ext., 1000 N. Forest St., Ste. 201, Bellingham, WA 98225. Phone (360) 676-6736. 6 credits. Class size limited to 60.
Tacoma Feb. 26 & 27, 1998 Jim Kropf, Ext. Agent, 3049 S. 36th St., Ste. 300, Tacoma, WA 98409. Phone (206) 591-7180. 6 credits.
Olympia March 3 & 4, 1998 Don Tapio, Ext. Agent, Grays Harbor Co. Coop. Ext., 102 W. Broadway, Room 108, Montesano, WA 98563. Phone (360) 249-4332. 6 credits.

More information on recertification, prelicensing, and other courses offered through WSU may be obtained through WSU Cooperative Extension Conferences at (509) 335-2830. Information on recertification and prelicensing courses is also available via the Internet at http://www.wsu.edu:8080/~ramsay/wsurec.html and http://www.wsu.edu:8080/~ramsay/wsuplt.html

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You can't tell the players without a score card

By Dr. Carol Weisskopf

Dr. Carol Weisskopf is an analytical chemist at the Washington State University Food and Environmental Quality Laboratory.

As many of you may be aware, Dr. Alan Schreiber is no longer with WSU. The university hopes to fill the vacancy before summer, but in the interim some of you may be wondering who will be handling various activities formerly the responsibility of Dr. Schreiber. In most cases, they will be the same folks who dealt with them in the past. To dispel some of the anonymity, it's time to review the field and the players on it, as well as some of the reorganization that has recently taken place in the Food and Environmental Quality Laboratory (FEQL) and the Pesticide Information Center (PIC).

Dr. Catherine Daniels, who has been managing activities within the PIC since 1990, has now also been named as the state liaison for the Pesticide Impact Assessment Program. She and her staff will continue to address pesticide information matters, as well as section 18 and 24(c) issues. If it's about agrichemical toxicity, residues, impacts, regulations, or the trivia likely to win you an office bet, the PIC is sure to know it. She is assisted by: Mark Antone (pesticide label and tolerance databases and PICOL guru); Jane Thomas (the pesticide notification network and minor crop production/protection information our specialty) and Lonny Waddle (how do we get the information from us to you?).

Besides wearing a larger hat for PIC, Catherine has also been named managing editor of the AENews, and is guiding content and scheduling. She was the unanimous choice, not only because of her knowledge of the field but because she is most likely to keep us all on schedule. She has been authorized to use all necessary coercion, up to and including blunt force trauma, to meet newsletter deadlines. Eric Bechtel remains editor, dealing with the nuts and bolts of newsletter assembly, spelling, and grammar. He continues to ably rescue those of us who are who/whom, between/among, that/which and affect/effect-challenged.

Dr. Allan Felsot continues his thought-provoking examinations of agricultural and environmental issues for the newsletter, and will also be including reviews and the addresses of pertinent, useful, or just plain weird Internet sites related to agriculture and the environment. Allan runs a laboratory based research program investigating pesticide transport and fate, and is assisted in the dirty work by Judy Ruppert and David Hanna. Allan is also a good source for FQPA and toxicological material, and his brain contains the most amazing conglomeration of odd but useful information you could imagine.

Dr. Carol Weisskopf (that's me), after a hiatus due to extended health problems, will return to these pages in my attempt to make toxicant residue analyses at least somewhat understandable. My research program deals with (what else?) the analytical chemistry of toxicants in food products and environmental and biological samples. I manage the laboratory facilities and equipment at FEQL and also supervise Rich Westberg, which means he gets to clean up any messes I make in the lab.

Ron Wight has been doing field projects for pesticide residues and efficacy for 23 years, the last four at FEQL. He has been named Field Research Director for IR-4 projects. He and sidekick Wilson Peng have been amazingly productive in the number of field trials they have been able to complete, although it means the rest of us only see them in the wintertime. They will be relocating to a new office in February, so their phone number will change at that time.

Finally, Doria Monter, administrative assistant extraordinaire, actually runs the place. If you can't figure out who to talk to (or if it's about money), start with her.

Contact list

Contact Phone (509) and E-mail (FAX number for all contacts is 372-7460)
Eric Bechtel 372-7378
Catherine Daniels 372-7495
Allan Felsot 372-7365
Doria Monter 372-7462
Carol Weisskopf 372-7464
E-mail via monter@tricity.wsu.edu
Ron Wight 372-7378

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The National Organic Program:
Proposed rules for implementing the Organic Foods Production Act of 1990

By Dr. Allan S. Felsot

Organic food may be generally considered "pesticide free," but the appellation organic actually applies to a whole system of agricultural and livestock production encompassing source materials, and prescribed practices for soil and crop management, and food handling and processing. Producers could label products "organic" if they were certified as complying with standards controlled by any one of the 11 state programs or 33 private organic certification agencies. Such a decentralized system, while highly democratic, has created problems in marketing organic products across the U.S. because standards for organic production vary among certifying agencies. Differences in use of seals, labels, and logos have confused consumers. Agreement has been lacking on appropriate labeling for foods with multiple ingredients, each assessed by different certifying agencies. The organic food industry has been unable to agree on an accepted list of substances permitted or prohibited for use in organic production and handling. A lack of national organic standards has inhibited an expansion in the availability of a greater variety of organic foods and has also reduced opportunities for export marketing.

Birth of the OFPA
The organic industry trade associations tried to establish a unified national voluntary organic certification program. Their failure, however, led to the petitioning of Congress for establishment of a mandatory National Organic Program (NOP). Thus, as part of the 1990 Farm Bill, Congress enacted the Organic Foods Production Act (OFPA) with three objectives: establish national standards governing the marketing of certain agricultural products as organically produced products; assure consumers that organically produced products meet a consistent standard; and facilitate commerce in fresh and processed food that is organically produced.

Congress mandated the USDA to implement the OFPA. USDA was authorized to appoint a 15-member National Organic Standards Board (NOSB) to assist in developing standards for the use of synthetic and nonsynthetic substances in organic food production. The NOSB also tackled other subjects related to organic production practices, and in 1994 it issued a report of its recommendations. The USDA Agricultural Marketing Service (AMS) was charged with preparing rules for implementing the OFPA, and in doing so considered all the recommendations of the NOSB. During December 1997, the AMS, garnering national press attention, released in the Federal Register its long-awaited proposed rules for the NOP.

Running nearly 500 pages long, the proposed NOP rules, Part 205 of Subchapter M of the OFPA, detail the hoops that producers and processors must jump through to be certified organic. The breadth of the NOP can be appreciated by the titles of its various sections, labeled as Subparts A through F: Definitions; Organic Crop and Livestock Production and Handling Requirements; Labels, Labeling, and Market Information; Certification; Accreditation of Certifying Agents; Additional Regulatory Functions.

NOP Defines Organic
The OFPA never defined specifically a system of organic farming and handling. To establish consistent national standards for organic production and handling, the principal objective of the Act, the AMS defined organic production to be "a system that is designed and managed to produce agricultural products by the use of methods and substances that maintain the integrity of organic agricultural products until they reach the consumer. This is accomplished by using, where possible, cultural, biological, and mechanical methods, as opposed to using substances, to fulfill any specific function within the system." The AMS further states that such a system will "maintain long-term soil fertility; increase soil biological activity; ensure effective pest management; recycle wastes to return nutrients to the land; provide attentive care for farm animals; and handle the agricultural products without the use of extraneous synthetic additives or processing."

Requirements for Organic Certification
Those already certified by a state agency or a private entity to market products as organic have probably already been following many of the proposed rules. For those now wanting to switch from "conventional" production and market with an organic label, a wait of three years will be mandatory along with a plethora of other requirements. First, a producer has to develop an organic plan that is then approved by an accredited certification agent, which could be an agent of a private organization or a State program. The organic plan is defined in the proposed NOP rules as "a plan of management of an organic farming or handling operation that has been agreed to by the producer or handler and the certifying agent and that includes written plans concerning all aspects of agricultural production or handling described in the Act [OFPA] and the regulation in subpart B [Organic Crop and Livestock Production and Handling Requirements], including crop rotation and other practices as required under the Act." After the organic plan is approved and before certification of organic production is granted, growers have to implement the plan for three years on any land having received unapproved synthetic fertilizer and pesticides.

Flexibility in Allowable Practices
The rules governing production and processing are performance based standards rather than prescriptive; they do not prescribe specific technologies or precise procedures for compliance. AMS built in flexibility by allowing a range of farming and handling practices. For example, a priority for pest management in organic production is to carry out cultural practices that will prevent the buildup of pest populations in the first place. Also, any practices must not degrade soil or water quality. Thus, cultivation to control weeds or insects must be practiced without enhancing soil erosion.

Disagreements in Allowable Practices
Despite the claim of performance-based standards for flexibility, the NOP rules have very definite bounds, especially regarding allowable substances for fertilization, pest control, and processing. The rules recognize that many organic growers will still need pesticides, and lists of approved substances had already been adopted by private and State certification programs. The NOP implements a National List which details what substances are allowed and prohibited in organic agriculture. The rules lay out criteria for inclusion of allowable synthetic substances in organic food production. For example, the substance must not be cytotoxic, which is defined as "having a toxic effect by means of interference with normal cell functions." The OFPA required no compilation of nonsynthetic (natural) substances, but did mandate prohibited nonsynthetic substances be listed. The NOSB made recommendations for the list, but in several cases the AMS disagreed. Thus, certain synthetic substances were placed on the allowable list despite NOSB recommendations, but no nonsynthetic substances were prohibited.

Three controversial areas the AMS wished to avoid before further public comment were whether to approve irradiation, genetically engineered organisms, and biosolids (the nutrient rich sludges derived from municipal wastewater treatment). The NOSB was against incorporation of all three, and newspaper accounts of the proposed rules tended to highlight this controversy.

The Organic Label
Other areas covered by the proposed rules include procedures for certification of organic food production and processing, how agents and State programs will be accredited, and labeling requirements. The labeling requirements are especially needed when non-organic ingredients are used with organic ingredients in processing a final product. The rules recognized that many times non-organic ingredients are the only commercially available processing agents. The benchmark for including organic on a package's principal display panel and how it is stated depends on the percentage composition of organically produced ingredients. Five percent of the weight of a finished processed product, excluding water and salt, can have non-organic ingredients that are included on the National List and still be labeled as "organic product" on the display panel. The USDA-approved organic seal may be used only on products in this category. Products with 50-90% by weight of organic ingredients may be labeled only as "made with certain organic ingredients" with no other references to organic on the display label. If a product contains less than 50% organic ingredients, the word "organic" is allowed to appear only in the product's ingredients listing.

Organic Doesn't Mean "Pesticide-free"
The final section of the proposed NOP rules contains interesting provisions about use of pesticides in emergency situations. Such use is permitted without losing the organic certification, but in the year of use the crop could not be marketed as organic. The NOP requires that organic products be tested periodically for prohibited substances, both at the farm and distributor level. The rules also recognize that plants will take up pesticide residues from past farming practices. The presence of a synthetic pesticide residue does not disqualify marketing a product as organic, as long as the concentration is below 5% of the tolerance level set for currently registered products or the Food and Drug Administration action level for banned products.

The NOP is a Bargain
Along with developing the proposed rules, the AMS was required to assess their regulatory impact. Monetary costs would be incurred by the fees that producers and processors will pay for certification and certification agents will pay for accreditation. Record keeping expenses comprise the largest costs. Nevertheless, the estimated combined fee and record keeping costs were less than $6 million, perhaps because the size of the organic food industry is tiny by comparison to agriculture as a whole. About 0.1% of the total 946 million acres of U.S. agricultural lands are certified as organic, according to a 1995 AMS report ("Organic Food and Fiber: An Analysis of 1994 Certified Production in the United States"). This land is managed by 4,050 certified crop and livestock producers. Approximately 500 handlers, including manufacturers, processors, distributors, and retailers, were certified organic in 1994. Considering that the estimated value of organic foods sales has risen from $78 million in 1980 to $3.5 billion in 1996, the NOP is a bargain.

Food Quality and Safety is Not an Issue
The OFPA, and its implementation by the proposed NOP rules, is strictly oriented toward establishing national standards to protect consumers and the interests of organic producers and handlers. To date, no studies have shown organically produced food to be qualitatively different from non-organic food. Thus, the regulations are not designed to have any impact on food safety. Certainly, the goals of nondegradation of soil and water quality are commendable, but this ethic is today infused across all agricultural production, and growers nationwide are striving to implement as quickly as possible best management practices consistent with environmental stewardship. That the food supply is indeed safe, regardless of whether it is produced conventionally or organically, is expressed in an introductory statement in the proposed rules: "No distinctions should be made between organically and non-organically produced products in terms of quality, appearance, or safety."

The Future Looks Bright
The proposed NOP rules were not prompted by food safety issues, but rather a need to establish consistent standards for organic food production and handling. Their effect, should the rules be implemented and the AMS prove correct in its assessment that they will expand markets and give consumers more choice, appears to be a much brighter future for the organic foods industry.

(Editors Note: The full text of the proposed NOP rules, NOSB recommendations, and questions and answers can be accessed from the Internet at http://www.ams.usda.gov/nop. Comments about the rules can be submitted either electronically at the home page or via fax (202-690-4632). Written comments should be sent to Eileen Stommes, Deputy Administrator, USDA, AMS, TM, NOP, Room 4007-S, AgStop 0275, P. O. Box 96456, Washington, DC 20090-6456.)

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WSDA's Pesticide Management
revisits pesticide recertification

The Washington State Department of Agriculture (WSDA) in 1996 moved to review the department's pesticide license recertification requirements and, subsequently, the policy used to accredit pesticide continuing education courses. This process, which continued through the fall of 1997, involved obtaining comment on three questions:

The questions were asked through a formal review by a committee of pesticide industry representatives and by a pesticide licensee survey.

The Pesticide Recertification Committee
In 1996 the Department of Agriculture petitioned pesticide industry associations, Washington State University and its Cooperative Extension, and public agencies to participate in a formal review of the pesticide recertification program. That led to formation of The Pesticide Recertification Committee, which evaluated WSDA's current recertification program and proposed to the agency's director any changes or improvements.

The committee reviewed background materials including federal certification regulations (40 CFR Part 171), recertification requirements of other states, statistics relevant to Washington's pesticide license and recertification programs, and WSDA's Pesticide Licensee Survey. Each meeting included debate on pesticide licensing and recertification issues and agency representatives answering inquiries about WSDA's program.

The committee consensus is that the existing recertification program works well and serves the needs of most Washington pesticide licensees. The committee cited support for this position from user feedback and personal contact with committee members' constituents. The committee recommended that the recertification standard (RCW 17.21.128) remain as is. The standard encourages public confidence in the professionalism of those individuals involved in pesticide use. In addition, committee members expressed their belief that the present accreditation policy provides broad, flexible discretionary power that benefits sponsors and participants and allows changes to course programs when needed. The committee recognized a need to develop and provide increased opportunities for continuing education for small and/or isolated industry groups (i.e licensees for which there are limited or no courses because of category and to licensees residing and working in rural locations away from main urban centers).

The committee recommended the agency encourage the expansion of outreach to isolated constituents (i.e. Internet-based courses), increase Spanish language course opportunities, encourage sponsors to focus topics to customer needs, and develop a monitoring system to provide timely feedback to course sponsors.

Pesticide License Recertification Survey
In April 1997, WSDA engaged the services of the United States Department of Agriculture, Washington Agricultural Statistical Service, to administer the Pesticide License Recertification Survey. The survey asked participants to rate current WSDA requirements for recertification, including the recertification course accreditation policy. Demographic questions were included to help identify the types of people who responded. Two populations (from a total of more than 12,000 licensees) were sampled. One group consisted of only licensees classified as private applicators. The second group was of licensees randomly selected from all other license types (commercial applicators/operators, public operators, consultants, dealer-managers, research and demonstration, and private-commercial applicators).

Of the combined groups, 80% of the participants stated that recertification requirements are appropriate; 75% responded that the department's accreditation policy gives ample opportunities for continuing education. They commented that there was a need for more pesticide safety programs, more product information (changes in label, or directions on product use), and courses specific to work directly related to licensee category. Comments ranged from "Happy with the way things are presently done" to "Recert meetings...are a joke." A participant who wrote that pesticide recertification is a "necessary pain in the rear" represented the middle ground.

The Pesticide Recertification Committee work and results from the WSDA's Pesticide License Recertification Survey provided valuable and useful information that will help the department meet customer needs.

Copies of the survey and committee recommendations are available on request by writing to:

Hugh Watson, Pesticide Certification and Training,
Pesticide Management Division,
P.O. Box 42589 Olympia, Washington 98504-2589
Phone: (360) 902-2016, FAX: (360) 902-2093
E-mail: hwatson@agri.wa.gov

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Reregistration Notifications

The source of this information, the Reregistration Notification Network, is a cooperative effort of USDA-NAPIAP, Interregional Project No. 4 (IR-4), U.S. Environmental Protection Agency (USEPA), and the American Crop Protection Association (ACPA).

Rid-A-Bird, Inc. has entered an agreement with the USEPA to voluntarily cancel its product, Rid-A-Bird Perch 1100 Solution (fenthion), by 3/1/99. All use of the product is prohibited after 10/1/99, and the registrant has agreed to recall any leftover stocks from distributors and users by 12/1/99.

Rid-A-Bird Perch 1100 Solution is registered to control starlings, English sparrows, and pigeons that land or roost in and around agricultural buildings and structures.

The USEPA's concerns are based on evidence that this product poses a significant risk of poisoning to protected predatory birds that feed on the birds poisoned by Rid-A-Bird Perch 1100 Solution. To mitigate this risk, the manufacturer has agreed to make label changes to this product by 5/1/98 that prohibit its use in starling roosting areas. Other registered uses of fenthion (mosquito abatement and lice control on cattle and hogs) are unaffected by this action.

For Rid-A-Bird product information:

Mr. Keith Wilson
Rid-A-Bird Inc.
Phone 319-732-3970
Fax 319-732-3971

For additional fenthion information:

Dr. John Thornton
Bayer Corporation-Agricultural Division
Phone 816-242-2255
Fax 816-242-2738

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PNN Update

The information contained here is not to be construed as a substitute for obtaining and reading product labels. Always read the label before applying a pesticide.

The PNN is operated by WSU's Pesticide Information Center for the Washington State Commission on Pesticide Registration. The PNN system is designed to distribute pesticide registration and label change information to groups representing Washington's pesticide users. The information below (with the exception of the tolerance data) is a summary of what has been distributed on the PNN in the past month.

Our office operates a web page called PICOL (Pesticide Information Center On-Line). This provides a label database, status on registrations and other related information. PICOL can be accessed on URL http://picol.cahe.wsu.edu or call our office, (509) 372-7492, for more information.

State Issues

Section 24c Cancellations

Section 24c Revisions

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Federal Issues

Manufacturers' Use Deletions

Section 18 Specific Exemptions

Experimental Use Permits

Supplemental Labels

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Miscellaneous Regulatory Information

PNN Notification 1997-711, transmitted 12/18/97, announced that Novartis had issued a 2ee use recommendation providing directions for the use of its fungicide Orbit on peaches, nectarines, and cherries in Oregon, Utah, Michigan, and Washington. The main Orbit label was revised earlier this year (PNN Notification 1997-553, 10/3/97), and use directions for areas west of the Rocky Mountains were deleted, effectively disallowing all use of Orbit in Washington. WSDA holds the position that, because the federally registered label does not allow use of this product in Washington, the use cannot be recommended and is not allowed under a 2ee exemption from the label (Because there is no valid use under the federal label, there can be no valid use under a 2ee). Use under the 2ee recommendation issued by Novartis constitutes a use contrary to the label and is, therefore, prohibited. DO NOT use Orbit according to the 2ee recommendation issued by Novartis.

Note that Novartis has registered several other propiconazole products in Washington for use on various tree fruits. These are Break (45%), Banner (14.3%), Banner GL (41.8%), and Banner Maxx (14.3%). Read the labels to verify specific use restrictions.

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Tolerance Information

The following tolerances were granted by EPA since the last report (November/December 1997). These data do not mean that labels have been registered for these uses. These pesticides must not be used until labels are registered with EPA or a state department of agriculture.


A = adjuvant FA = feed additive I = insecticide VR= vertebrate repellent
D = desiccant FM = fumigant IN = inert N = nematicide
D/H = desiccant, herbicide G = growth regulator M= molluscicide P = pheromone
F = fungicide H = herbicide V = viricide R=rodenticide


Chemical* Petitioner Tolerance (ppm) Commodity (raw)

Primisufuron-methyl EPA 0.1(a) bluegrass hay
a = Time limited tolerance expires 10/31/1998

EPA has revoked tolerances for pesticide residues in or on livestock feed commodities that have been deleted from the list of significant livestock feed commodities in Table I of Pesticide Assessment Guideline 860.1000. In implementing the Federal Food, Drug, and Cosmetic Act (FFDCA), EPA does not require data on or set individual tolerance levels for minor, non-significant livestock feed commodities. EPA considers residues in minor, non-significant livestock feed commodities to be covered by the tolerances for the pesticide on the principal commodities of a crop.

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Contributors to the Agrichemical and Environmental News:

Allan Felsot, Catherine Daniels, Carol Weisskopf, Mark Antone, Eric Bechtel, Jane Thomas

Contributions, comments, and subscription inquiries may be directed to Dr. Catherine Daniels at the Food and Environmental Quality Laboratory, Washington State University, 2710 University Drive, Richland, WA 99352-1671, ph: 509-372-7495, fax: 509-372-7491, E-mail: cdaniels@tricity.wsu.edu

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