The Pesticide Key to Pesticide Safety Label and Education January–March 2010 REGULATORY UPDATES TABLE OF CONTENTS Special Local Needs (SLN) NEW PRODUCTS Regulatory Updates ................................... 1 For growers of pineapple—use of the pesticide Re- House Mouse (recertification) ................. 2 Tain® (Valent BioSciences, EPA Reg. No. 73049– 45)—requires having a copy of HI–100001, valid Gloves (recertification) ............................ 6 1/14/10–1/13/15—some notes: ● do not apply more than 45 pouches (2250 grams a.i.) per acre per crop Supervising Noncertified Applicators cycle. ● keep spray away from flowering or fruiting (recertification) .................................... 12 plants. ● REI 12 h. A Sea Change on Inerts (recertification) 17 For growers of field corn and seed corn—use of Arsenic Use Cancellations ....................... 19 the pesticide Provado® 1.6 Flowable Insecticide (Bayer CropScience LP, EPA Reg. No. 264-763)— Birth of an Herbicide ................................ 20 requires having a copy of HI–100002, valid Ontario’s Cosmetic Pesticides Ban .......... 22 3/9/2010–3/8/2015—some notes: ● only for use by authorized Bayer personnel. ●no part(s) of the crop Proposed Spray Drift Labeling ................. 23 treated with this product shall be used as food for human or animal consumption. ● PHI 15 days. ● Illustrated Glossary .................................. 24 minimum interval between applications 7 days. ● do Previous Recertification Articles .............. 26 not apply where bees actively foraging. The Pesticide Label Archives .................. 26 Updated packet item, “Hawaii Pesticide Laws and Regulations” (January 2010) is the updated version of an older study guide included in pesti- NOTE: To navigate to an article from the cide study packets that many of you purchased. It Table of Contents, just left-click on its title. can be downloaded free of charge from http://pestworld.stjohn.hawaii.edu/studypackets/HI_Pes ticide_Laws_Regs_100122.pdf It replaces the older version titled “Pesticide Laws and Regulations”. Cooperative EXTENSION SERVICE, UNIVERSITY OF HAWAII AT MANOA, COLLEGE OF TROPICAL AGRICULTURE AND HUMAN RE- SOURCES, 3050 MAILE WAY, HONOLULU, HAWAII 96822. The UH-CTAHR Cooperative Extension Service and the U.S. Department of Agriculture cooperate in presenting t the people of Hawaii programs and services without regard to race, sex, age, religion, color, national origin, ancestry, disability, marital status, arrest and court record, sexual orientation, or veteran status. The University is an equal opportunity, affirmative action institution. HOUSE MOUSE (recertification) Ecology RECERTIFICATION CREDITS may be earned by certi- The house mouse (Mus musculus, Mus domesticus) is a recog- fied applicators that score at least 70% on the set of nized ―mighty mouse‖. It is the most widespread species of comprehension evaluation questions about the "recerti- fication" articles in this newsletter. These articles have mammal, along with humans, and occurs in all the same envi- a title which ends with "(recertification)". However, cre- ronments. This small rodent (20 g or 0.7 oz) is capable of jump- dits may not necessarily be applicable for the following categories: Private 2, Private 3, Commercial 7f, and ing almost a half-meter and squeezing through a hole just 6 mm Commercial 11. The question sets (quizzes) are written in diameter. It is a true, short-lived r-selected species (see side- and administered by the Hawaii Department of Agricul- bar), with a lifespan of about one year. The female is capable of ture (HDOA) staff. Ask about earning recertification credits at one of these HDOA offices: Kauai 274-3069, 4 to 6 litters per year, each litter containing 4 to 7 young. New- Oahu 973-9424/9409, Maui 873-3960, Hawaii 974- born mice mature in just three weeks and are quickly able to re- 4143. The area code for all offices is 808. produce. In one experiment, 20 mice were placed in an enclosure with ample food and water and their population reached 2,000 in 8 months. House mice live in groups called demes and usually stay within small areas, from a few square meters to 100 m2. These nocturnal animals have a strong sense of touch and ―muscle memory‖ and, together with the use of pheromones, can return home in total r- and K-selected species darkness after extensive travel. In ecology, the r/K selection theory Mice can survive extreme conditions and though they are mainly concerns the selection of characte- grass and seed eaters, they can eat almost anything. Unlike rats, ristics which promote survival in mice eat small but frequent meals, consuming 10 to 20 percent of different environments. It is derived their body weight each day. This explains the large number of from work on island biogeography droppings that often betray their presence, since mice are rarely and hypothesizes that selective pres- seen. Mice, unlike rats, do not need water to drink, but can get it sures drive evolution in one of two from their food. generalized directions: r- or K- selection. Typically, r-selected House mice that are closely associated with humans are not as species take advantage of less- competitive as wild house mice, those that are not associated crowded habitats and produce many with humans. The latter have larger home areas and actively de- offspring with a relatively low fend their territory. Wild house mice are seasonal breeders and probability of survival. In contrast, K-selected species are strong undergo large changes in population density. Their populations competitors in crowded habitats and are determined mainly by rainfall and seed availability. A 1994 have fewer offspring with a study on Mauna Kea, Hawaii, found that wild house mice mainly relatively high probability of ate insects (caterpillars), seeds, stems and flower stalks. They survival. were not eating bird eggs, the concern that stimulated the re- search, but were being eaten by feral cats. Conversely, this pre- dation helped control the population of wild house mice and de- creased the cats‘ tendency to prey on bird eggs and chicks. As part of the ecosystem, wild house mice recycle nutrients, dis- perse seeds and are prey for many larger animals. The Pesticide Label Page 2 One of the most important economic impacts caused by house mice is feeding on and contaminating stored food. They can also be a nuisance indoors because of their noise, odor and droppings. Mice will gnaw on insulated electrical wiring and can cause fi- nancial loss due to interrupted communications. An even greater Photo courtesy of James Cook University problem is the danger of house fires from exposed or damaged wiring. House mice are susceptible to many diseases and internal para- sites and can carry leptospirosis, plague and salmonella. They can transmit these diseases and others to humans, pets and lives- tock. Management Physical control. As with most pests, a combination of methods is the best approach to managing mouse populations. Since it is so difficult to keep these small mammals out of buildings, an important first step in their control is good sanitation. This means reducing places mice can shelter and breed, as well as have access to food supplies. Snap traps are effective and have been used for many years to catch rodents, but they are not usually practical on a large scale. Some people prefer live traps, followed by releasing the mice in another area. State agencies are regulating this process carefully, however, as the mice can cause similar problems in the new area, including the transmission of disease. Some cats are good ―mousers‖, but they mainly feed on the sur- plus and do not reduce the core population. Mice can jump over glue boards, and repellents may only be effective in small areas. Chemical control. The most effective measures for house mouse control are probably chemical rodenticides. Most are formulated as food baits, but in situations where there is already plenty of food (granaries, around livestock), liquid baits and tracking powders may be more effective. The earlier, or first generation anticoagulants (e.g., warfarin, diphacinone) were de- veloped in the 1940s, have a relatively low toxicity and take sev- eral feedings before rodents are killed. The second generation of anticoagulants was introduced in the 1970s when genetic resis- tance began to develop against the first generation of anticoagu- lants. These newer rodenticides (e.g., bromadiolone, brodifa- coum, chlorophacinone) are more lethal, though some resistance The Pesticide Label Page 3 to them has also been reported. Zinc phosphide is a chemical toxic to most vertebrates and is often used in rotation with anti- coagulants to delay the development of resistance. Zinc phos- phide releases a toxic gas in the rodent‘s gut and they will often become sick and stop eating before consuming a lethal dose. This has been called ―bait shyness‖ as the mice usually won‘t approach the bait a second time. One way to avoid bait shyness is to first use another non-anticoagulant toxicant (e.g. cholecalci- ferol, bromethalin) before using zinc phosphide bait. In Hawaii, there are Special Local Needs labels for three roden- ticides: Ramik Mini Bars (diphacinone) for use in forests, off- shore islands and macadamia nut orchards; Rozol Mini Blocks and Pellets (chlorophacinone) for agricultural uses; and Prozap (zinc phosphide) for use in rural non-crop sites (e.g. around buildings), and on range or pasture lands. All of these products must be applied in bait stations (see sidebar). These devices pro- Mouse and rat baits must be used tect the bait from moisture and contamination, provide a safe in a bait station. These stations 1) place to feed, limit access to non-target animals, reduce spillage, keep the bait clean and dry, 2) and make it easier to monitor the amount of bait consumed by a reduce spilling, 3) give rodents a population. There are several other rodenticides registered in protected place to feed, 4)exclude Hawaii, though some are restricted use pesticides. The active pets and other non-target ani- ingredients in these products include sulfuryl fluoride, methyl mals, 5) and make it easier to bromide, aluminum phosphide and difethialone, a second gen- monitor the bait eaten. eration anticoagulant rodenticide. Problems with rodenticides include primary and secondary poi- soning and bioaccumulation of residues. Primary poisoning oc- curs when a non-target organism, such as a dog or deer, feeds on the bait. Secondary poisoning refers to an animal being poisoned by feeding on an animal poisoned by the bait, for example a hawk or owl eating a poisoned rodent. Most rodenticides are formulated with very low dosages of anticoagulant, so secondary poisoning is not as likely as it seems. However, a diet of poi- soned rodents can lead to bioaccumulation of the poison in the predator. House mouse outbreaks Massive increases in house mouse populations regularly occur. They have been commonly recorded in Australia and the U.S., including Hawaii. According to a review article on house mice by USDA researchers, the outbreaks are most severe and most thoroughly studied in Australia. They are closely correlated with heavy rainfall and vegetation growth when it follows several The Pesticide Label Page 4 drought years. Mouse populations increase with the abundant 1. What are some of the reasons the food source and move into crop fields, causing significant losses. house mouse is considered a After harvest, mice invade grain storage areas and create further pest? reductions in yield. In Australia, management is assisted by pre- dictive models based mainly on rainfall. 2. Why are they so difficult to con- trol? House mice on islands Islands that lack predators are ideal for seabirds that nest on the 3. What might be some of the ele- ground. If house mice are introduced, the defenseless eggs, ments of a good IPM plan to con- chicks and young birds are at risk. The extinction of many native trol house mice? island vertebrates have been caused by introduced rodents. 4. What is the mode of action for There have been about 20 successful eradications of established the most commonly used rodenti- rodent populations on islands. They mainly relied on anticoagu- cides? lant baits (brodifacoum) either broadcast or in bait stations placed in a grid pattern. As mentioned earlier, eradication of the 5. Primary and secondary poisoning rodent population can shift the diet of predators (e.g., cats, the are problems associated with ro- mongoose) from the absent rodents to native birds. On the other denticides. What do these terms hand, introduced predators like the feral cat can also be killed by mean and how might they be mi- ―toxic prey-loading‖ as they consume rodents that have ingested nimized? anticoagulant baits. According to the Global Invasive Species Database http://www.issg.org/database/welcome/ Mus musculus is among 100 of the ―World‘s Worst‖ invasive alien species. House mice will continue to be a control problem as long as humans exist to References feed, shelter, and accidentally transport them to new areas. Re- Hawaii Pesticide Information Retrieval System. 2009. NPIRS, Purdue Uni- search has shown that rodent problems are not all the same, versity. Viewed on 10 Sep 09 at however, and their management needs to take into account the http://state.ceris.purdue.edu/htbin/stw eb.com history, unique conditions, and driving forces of the invasion. In U.S. EPA. Final risk mitigation decision the near future, anticoagulants will probably remain the most for ten rodenticides, May 28, 2008. effective approach to large-scale rodent management. Research Viewed on 10 September 2009 at http://www.epa.gov/pesticides/reregist into species-specific diseases, endoparasites, and fertility control ra- agents also show promise. Perhaps more effective repellents and tion/rodenticides/finalriskdecision.htm . lures to enhance trapping could take advantage of the curiosity of Witmer, G. and Jojola, S. 2006. What‘s house mice. The continuous pest pressure of our interactive envi- up with house mice: A review. ronment demands that we protect ourselves by continuing the Viewed on 8 September 2009 at search for sustainable methods of pest management. http://www.aphis.usda.gov/wildlife_d amage/nwrc/publications/06pubs/wit mer063.pdf The Pesticide Label Page 5 GLOVES (recertification) Over 95 percent of exposure to pesticides during spray applica- tion is through the skin. The right gloves can protect you from much of this exposure, but not if you don‘t wear them. You or your employees may hesitate to use gloves if they are hard to get on or off, too hot or uncomfortable, clumsy to work in, or never handy when you need them. Choosing the ―right‖ gloves, as you will see in this article, entails a series of compromises. Categories The ―Precautionary Statements‖ section of the pesticide label gives specific information on personal protective clothing and Choosing the “right” gloves calls equipment to be worn while mixing, loading, and applying the for a series of compromises. You product. This includes EPA chemical-resistant categories, from may need several kinds of gloves. A to H. These categories refer to the carrier solvent and its con- centration in the pesticide formulation (see Table). A. Any dry or water-based pesticide formulation B. Any pesticide with acetate as the carrier solvent C. Any pesticide with alcohol as the carrier solvent D. Any pesticide with halogenated hydrocarbons as the carrier solvent E. Any pesticide with ketones (e.g. acetone) as the carrier sol- vent F. Any pesticide with ketone and aromatic petroleum distillates mixture as the carrier solvent G. Any pesticide with aliphatic petroleum distillates (e.g. kero- sene, petroleum oil, mineral oil) as the carrier solvent H. Any pesticide that has aromatic petroleum distillates (e.g. xy- lene) as the carrier solvent Materials EPA ranks personal protective materials according to their resis- tance to chemical solvents. There are a number of glove mate- rials available within each carrier solvent category (see Table). Check the label for glove material recommended for each pesti- cide. The following evaluations are from the University of Illinois. Prices are listed only for their comparative values. Photos are courtesy of the University of Florida IFAS Extension Publication #Pl-120. The Pesticide Label Page 6 barrier laminate (foil type): the most chemically resistant but uncomfortable; poor dexterity due to design ($7/pair) barrier laminate ≥ means “greater than or equal to” butyl rubber ≥ 14 mils (i.e. greater than or equal to 14 mils): a synthetic rubber; resistant to gas and water vapors; good dexterity ($20/pair) butyl rubber natural rubber ≥ 14 mils: for dry or water-based formulations ($12-19/pair) natural rubber nitrile rubber ≥ 14 mils: resists puncture better than other materials; good dexterity, slip-proof grip; comes in range of lengths, thicknesses ($3-9/pair) nitrile rubber The Pesticide Label Page 7 neoprene rubber ≥ 14 mils: synthetic rubber; good dexterity; stays flexible at low tempera- tures ($2-3/pair) neoprene rubber polyethylene: limited pesticide uses ($1- 10/pair) polyethylene PVC ≥ 14 mils: limited pesticide uses ($4/pair) polyvinyl chloride Viton ≥ 14 mils: the most chemically resistant ―rubber‖ glove available; thick but very flexible and comfortable to wear ($150-175/pair) viton The Pesticide Label Page 8 Resistance to chemicals Gloves offer varying levels of protection and their chemical re- sistance and longevity are referred to as High, Moderate, Slight, and None (see Table). When testing gloves, the comparative measure of chemical resistance for the glove material is called ―break-through‖ time. This is the time it takes for a specific pure chemical to soak through the glove. The longer the time, the bet- ter the protection, but an 8-hour break-through time is common. Highly resistant gloves should be cleaned or replaced at the end of each day‘s work; rinse off all pesticides at rest breaks. Moderately resistant gloves may need to be cleaned or re- placed within an hour or two of contact. Slightly resistant gloves may need cleaning or replacement within 10 minutes of contact. None says this glove is not resistant to the chemical in this category. Do not wear personal protective clothing or equipment made from this material if contact with the pesti- cide is possible. Table. EPA rating of personal protective materials for each carrier solvent category (see p. 6). Selection Category Barrier Butyl Nitrile Rub- Neoprene Natural Poly- Polyvinly Viton Listed on Pesticide Laminate Rubber ber ≥ 14 Rubber Rubber ethylene Chloride ≥14 mils Label based on carrier ≥ 14 mils ≥14 mils ≥14 mils (PVC) solvent mils ≥14 mils A (dry & water based HIGH HIGH HIGH HIGH HIGH HIGH HIGH HIGH foundations) B HIGH HIGH SLIGHT SLIGHT NONE SLIGHT SLIGHT SLIGHT C HIGH HIGH HIGH HIGH MOD MOD HIGH HIGH D HIGH HIGH MOD MOD NONE NONE NONE SLIGHT E HIGH SLIGHT HIGH HIGH SLIGHT NONE MOD HIGH F HIGH HIGH HIGH MOD SLIGHT NONE SLIGHT HIGH G HIGH SLIGHT SLIGHT SLIGHT NONE NONE NONE HIGH H HIGH SLIGHT SLIGHT SLIGHT NONE NONE NONE HIGH Only unlined gloves or gloves with separable liners may be used. Design Gloves are made by two methods, handprint and molded. Handprint gloves are made from layers of material die-cut in the outline of a hand and heat-sealed together. Those made from a hand-shaped mold dipped into a polymer solution are called molded gloves. Handprint gloves fit either hand loosely and tend The Pesticide Label Page 9 to be thin, slick, and stiff. The highly resistant barrier laminate gloves are made this way. Molded gloves are usually more com- 1. What are some issues to consider when selecting the ―right‖ glove? fortable to wear and easier to work in, but thumb placement and finger length are variable. Some brands may offer a better fit 2. If a particular glove type is rec- than others, so try before you buy. ommended on a pesticide label, where would you find it? Fit If gloves fit properly, they feel less awkward and more comfort- 3. Which personal protective cloth- ing material, including gloves, is able. If they fit too tight, they will be harder to get on and off and the least resistant to chemical sol- your hands may tire faster. If gloves are too big, you lose agility vents? and there is a greater chance of catching them in machinery. To find your glove size (7 to 12), measure around your open hand. If 4. What signs may indicate the need it measures 10 inches, you are a size 10. Some gloves are sized to replace your gloves? Do the S-M-L and XL, men‘s and women‘s, or one size fits all. In this same apply when using highly case, try them on. toxic chemicals? Thickness 5. Should your shirt sleeves be inside or outside the gloves when spray- Glove thickness is measured in mils or gauge and bigger num- ing a pesticide? bers usually mean thicker gloves and more chemical protection. For example, one barrier laminate glove, Silver Shield® is 0.004- inch (4 mil) and a particular Viton® design is 0.036-inch (36 mil) in thickness. Both are resistant to most solvents (see table). As a comparison, ―surgeon‘s‖ gloves of natural rubber are 4 mil to 9 mil thick (1 mil = 0.001 inch) and are not durable enough for use with most pesticides. Uniform thickness is difficult to manufac- ture, however, and thinner areas will wear out first. Though thicker gloves may offer more protection from chemicals, tear- ing, and puncture, they are more bulky and clumsy. Thinner gloves are easier to work in, but are also damaged more easily. Removal and cleaning After use, try washing the outsides of your gloves in running Do your hands get hot and sweaty water, and soap if possible, while you are still wearing them. wearing unlined gloves? Read the Next, remove one glove by grasping it near the cuff, without note at the end of the article and touching your skin, then peel it off. Hold the inside-out glove in work in comfort. your bare hand while you slip your ungloved finger under the cuff of the other glove, peeling it off. Put both gloves, now in- side-out, in a clean one-gallon zip-lock bag until they can be properly washed or disposed of. If you want to reuse a pair of gloves wash them the same day, as follows: 1) remove free pesticide and other material from the outside of the gloves with running water; 2) use a strong deter- The Pesticide Label Page 10 gent to remove remaining chemical residue; 3) rinse well in run- ning water; 4) hang by the fingertips with a clothespin to dry. Never put gloves in an automatic dryer. Disposal The usefulness of most gloves is short-lived. It may be time to replace them if you notice any of these signs: staining or color change inside or outside of the glove; softening, swelling, or bubbling; stiffening, cracking, or surface change; dissolving or becoming jelly-like; or leaking at any time. Even in the absence of these signs, pesticides can soak through or contaminate glove materials without changing the glove‘s ap- pearance or texture. So replace gloves when there is: direct glove contact with highly toxic chemicals for a short time, or repeated contact over a longer period. A routine replacement schedule may be useful, depending on the type of chemical exposure and amount of use. Cut gloves up so they cannot be reused and dispose of them as solid waste. Final tips Keep one set of gloves for mixing concentrates. Wash gloves after each use to reduce exposure time and lengthen glove life. Allow gloves to dry before storing. Manufacturers label packages, not gloves; write material type on cuffs with a permanent marker. Place sleeves outside of gloves if most of your spraying is at or below waist level (see sidebar 1). Place sleeves inside gloves if most of your spraying is over- head; make a 1- to 2-inch cuff to catch pesticide that runs down the glove (see sidebar 2). If spraying both above and below waist level, close your gloves tightly outside of your sleeves and secure with heavy- duty tape or an elastic band (see sidebar 3). Do not use flocked or lined gloves; they can absorb pesticide Natl. Pest. Applicator Cert. Core Manual (see the following note). The Pesticide Label Page 11 Note: On 1 September 2004, EPA amended the Worker Protection Standard‘s prohibition of using separable liners (e.g. References thin cotton gloves) in chemical-resistant gloves. The decision to EPA. 2004. Federal Register Vol. 69, No. use separable glove liners is now at the discretion of the pesti- 169. http://www.epa.gov/oppfead1/safety/work cide user: chemical-resistant gloves can continue to be used ers/fr-gloves.pdf without liners. EPA‘s new regulations contain restrictions to as- Fishel, F. 2006. Glove selection for working sure that contaminated liners will not remain in use. To assure with pesticides. that contaminated liners will not be reused, all separable liners http://edis.ifas.ufl.edu/PI157 Paulsrud, B. and Nixon, P. 2001. Choose the will have to be discarded immediately after 10 hours of use with- proper gloves when handling pesticides. in any 24-hour period; separable liners cannot be laundered and http://ipm.illinois.edu/bulletin/pastpest/arti reused. Separable glove liners that come into contact with pesti- cles/200111.html cides must be discarded immediately and replaced with new lin- Stone, J. 1996. Keep gloves handy for ers. Discarding separable glove liners immediately is necessary pesticide work. to ensure that gloves are not contaminated and reused, acciden- http://www.extension.iastate.edu/Publicati tally or otherwise. ons/PM1518E.pdf SUPERVISING NONCERTIFIED APPLICA- TORS OF RESTRICTED USE PESTICIDES (Recertification) State of Hawaii and federal laws and regulations allow a noncer- tified pesticide applicator to use a restricted use pesticide (RUP) if he or she is under the direct supervision of a certified pesti- A restricted use pesticide (RUP) is cide applicator and has written instructions from the certified a chemical product that requires applicator. If you are a certified applicator and you make a RUP regulatory controls in addition to available to a noncertified applicator, you must: 1) select a com- the rules for controlling the mi- petent person, 2) provide written instructions and adequate train- suse of pesticides. ing, 3) be available if and when needed, 4) be sure required re- cordkeeping is completed, and 5) be responsible for any viola- tions of the Hawaii Pesticides Law. Choosing a noncertified applicator A critical part of direct supervision is that RUPs only be applied A competent applicator is one by a competent person. A person is competent if he or she is who is able and qualified to do a able and qualified to perform a particular function in pesticide specific pesticide application task. application. For example, if calculating the square footage of an area is necessary to perform the function, then a competent per- The Pesticide Label Page 12 son must be able to do the calculation. And if using a respirator is necessary to perform the function, then the competent person must be qualified to use a respirator. It might be better to do the complex tasks yourself and leave the simple ones for the noncer- tified applicator. Further, the direct supervision policy of the U.S. EPA requires the certified applicator to judge competency by asking appropriate questions to ensure the noncertified appli- cator understands the instructions. Another facet of direct supervision is having the noncertified applicator under the instructions and control of the certified ap- plicator. If the ―supervising‖ certified applicator is not present during the application of a RUP, it may not count as direct su- pervision. This opinion came from a court decision related to Mr. C. Nagamine by the Hawaii Department of Agriculture‘s Pesti- cide Programs manager. The case involved the application of pesticides by aircraft. The certified applicator worked for a spray service during the prior year, but had since begun work at a bank. The certified applicator was retained as a consultant and was available for consultation by telephone. It was ruled that direct supervision was not provided because the certified appli- Photo by USDA, Bugwood Archives cator did not provide instructions or control. Control was defined as the exercise of a restraint, directing or regulating influence; or supervision which involves careful watching and responsible care. The judge concluded that the retention of a consultant in this capacity was an effort to circumvent statutory and regulatory requirements. A fine of $10,000 was assessed. Being available when needed For most RUPs, the certified applicator need not always be phys- ically present at the time and place the RUP is applied. But la- bels of a few RUPs specifically require the physical presence of the certified applicator, so be sure to check the pesticide label for any such product-specific requirement. Here are two examples, with words italicized for emphasis. • The Vikane® label says: When used for fumigation of enclosed spaces, such as houses and other structures…, two persons trained in the use of this product, at least one being an applica- tor that is licensed/ certified by the state, must be present during introduction of fumigant, reentry prior to aeration, and during the initiation of the initial aeration procedure. The Pesticide Label Page 13 • The label for Cheminova Methyl 4 EC says: Direct supervision for this product is defined as the certified applicator being phys- ically present during application, mixing, loading, repair and cleaning of application equipment. Both of these pesticides are labeled with the signal word DAN- GER, the skull & crossbones symbol, and the word POISON in red letters. In other cases, the required availability of the certified applicator is directly related to the hazard of the situation. EPA‘s interpreta- tion of this statement requires the physical presence of the certi- fied applicator when the use of a RUP poses a potentially serious hazard to people or the environment. In cases where physical presence is not required, the certified applicator must be availa- ble if and when needed. EPA interprets this statement to require, at a minimum, the availability of the certified applicator by tele- phone or radio immediately before, during, and after the noncer- tified applicator‘s use of a RUP. The certified applicator must also be able to get to the application site within a reasonable pe- riod of time if the need arises. When determining, ―a reasonable period of time‖, the potential or real consequences of a delay in arrival will be considered. Being on another island, for example, is not acceptable according to the Hawaii Department of Agri- culture. Written instructions and training Hawaii Department of Agriculture‘s Pesticide Regulations re- quires that a noncertified applicator who handles a RUP be given written instructions by the certified applicator that provides the pesticide. The written instructions must include: 1) directions for applying the RUP; 2) safety measures to be taken, including emergency procedures; and 3) contacting the certified applicator According to the Hawaii Depart- at any time during the application. To be more specific, the Ha- ment of Agriculture, if a noncerti- waii Department of Agriculture provides the following details, fied applicator is to handle an along with an example. RUP, the certified applicator must provide written instructions. Written instructions must include: 1. Information about the certified applicator a. Name of certified applicator b. Certification card number and expiration date c. Company name or employer name (suggested) 2. Specific instructions for application a. Brand (product) name of the RUP b. Specific rate of application The Pesticide Label Page 14 c. Site or crop, location, and method of application d. Total area to be treated e. Specific sprayer or device (pre-calibrated if necessary) to be used f. Amount and directions for preparing a pesticide spray mix- ture for the particular sprayer or device 3. Safety measures to be taken a. Specific personal protective equipment (PPE) to be worn b. How to respond to spills or leaks (taken from the pesticide label). List cleanup materials that should be available, on the truck or nearby, where the handling tasks are being performed. c. Other cautionary measures (taken from the Precautionary Statements section of the label) 4. Responses to pesticide exposure a. Telephone number for medical emergency b. Decontamination methods and other first aid procedures (taken from the Statement of Practical Treatment section of the label) 5. Means of contacting the certified applicator at any time dur- ing the application, such as the voice, cellular, or radio call phone number. 6. Whether a special pesticide labeling should be in the posses- sion of the applicator at the time of application, for exam- ple, a Special Local Need labeling. EPA policy also speci- fies that instructions be given at a level and in a language understood by the noncertified applicator. If a noncertified applicator will be applying several different RUPs at dif- ferent kinds of sites (or crops), the certified applicator is required to accompany the noncertified applicator to at least one site (or crop) for each different type of pesticide used. In cases where the noncertified applicator has not previously used the particular RUP, or where there is any doubt about the noncertified applicator‘s full understand- ing of instructions, the certified applicator is obligated to provide on-the-job-training and to observe the perfor- mance of the noncertified applicator before leaving the site. As explained above, however, the certified applicator may not leave the site if his or her physical presence is re- quired by the pesticide label or by the hazard of the situa- tion. Recordkeeping The Hawaii Department of Agriculture's "Pesticide Regulations" (also known as "Chapter 66") specifies recordkeeping require- ments for certified private and commercial applicators. Accord- ing to the requirements, the records must be kept for two years. Information about the items to record is available from two sources: The Pesticide Label Page 15 A consultation with a pesticide education specialist at the Hawaii Department of Agriculture's Pesticides Branch §4-66-62, in "Chapter 66" posted at http://pestworld.stjohn.hawaii.edu/studypackets/Chapter66_2 006.pdf Violations of pesticide laws Restricted use pesticides are not like ordinary pesticides sold at supermarkets and garden shops. They can cause serious prob- lems for people and wildlife if the applicators are not adequately trained and supervised. Suppose, for example, that you buy a RUP and allow a noncertified applicator to use it. Could you train and count on the applicator to do the following? Delay treatment if conditions are not right Figure and measure the proper amount Prepare the site for treatment Post signs or other information (required for some jobs) Protect any nearby workers and passers-by Choose and use personal protective equipment (PPE) Dilute the pesticide and load it into the application equip- ment Operate, adjust, and maintain the application equipment Control possible spray drift to nearby homes, schools and playgrounds Make and keep a record of each job Store the container properly Dispose of an ―empty‖ container properly Wash the safety gear and application equipment Change out of contaminated clothing; wash up These aspects of using any pesticide are subject to an inspec- tion or complaint investigation by Hawaii‘s pesticide regulato- References Hawaii Pesticide Law, Pesticide Regula- ry agency. And for a RUP that you provide to someone else to tion (condensed), available at apply, you would be responsible for any violations whether http://pestworld.stjohn.hawaii.edu/stu you were involved in applying it or not. Consider this too: The dypackets/Ch149A_Condensed.pdf Federal Insecticide Fungicide and Ro- list of tasks could be longer if the pesticide label required spe- denticide Act, available at cial hardware, experience, or judgment. For example, a struc- http://www.epa.gov/oecaagct/lfra.htm l tural fumigation treatment requires specialized air sampling Food Agriculture Conservation and devices and respirators that must be tested and maintained. Trade Act of 1990, available at Soil, weather and other treatment site conditions must be rec- http://www.ers.usda.gov/publications/ aib624/ ognized and factored into calculations for dosage and treat- FIFRA Compliance Program Policy No. ment time. Another layer of complexity is possible if the non- 2.3, April 5, 1985 (U.S. Environmen- tal Protection Agency). certified applicator was instructed to treat different sites at different times. Finally, if you made more than one RUP product available to the noncertified applicator, would they The Pesticide Label Page 16 choose the right one? This article is from the January-March and April-June 2004 is- sues of The Pesticide Label. Past and present issues of our new- sletter are available in PDF for free viewing or download at http://pestworld.stjohn.hawaii.edu/pat/Newsletter_main.html A “SEA CHANGE” ON INERTS (Recertification) According to a September 30, 2009 announcement from the U.S. EPA, the Agency, ―. . . intends to make a sea change in how inert ingredient information is made available to the public‖. The an- nouncement was in response to two petitions, dated August 1, 2006, for a ruling on disclosure of hazardous inert ingredients in pesticide products. Currently, EPA only requires the active in- gredient(s) in the product be listed on pesticide labels. This ar- ticle defines active and inert ingredients and then summarizes the 2006 proposals and EPA‘s response. Definitions An active ingredient is defined by EPA as, ―one that prevents, destroys, repels or mitigates a pest, or is a plant regulator, defoliant, desiccant or nitrogen stabilizer. By law, the active ingredient must be identified by name on the label together with its percentage by weight [author‘s emphasis]‖. An inert ingredient (inert) is defined as, ―any substance (or group of structurally similar substances if designated by the Agency), other than an active ingredient, which is intentionally included in a pesticide product.‖ Inert ingredients play a key role in the effectiveness of a pesticidal product. For example, inert ingredients may serve as a solvent, allowing the pesticide's active ingredient to penetrate a plant's outer surface. In some instances, inert ingredients are added to extend the pesticide product's shelf-life or to protect the pesticide from degradation due to The Pesticide Label Page 17 exposure to sunlight. Pesticide products can contain more than one inert ingredient, but federal law does not require that these ingredients be identified by name or percentage on the label [author‘s emphasis]. Only the total percentage of inerts is required to be on the pesticide product label‖. The State petition was a request from 14 states and the U.S. Virgin Islands that EPA amend its regulations governing certain chemicals already determined by EPA to be hazardous, toxic, or hazardous to man or the environment under the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) to require that those chemicals be listed as ―Hazardous Inert Ingredients‖ on the label of any pesticide product that contains them. The Northwest Coalition for Alternatives to Pesticides (NCAP) and 21 co-signing organizations also seek an amendment to the labeling regulations for inert ingredients. The NCAP wants a required listing on product labels of any inert ingredient(s) that EPA regulates as a hazardous chemical. If EPA cannot do this The term “inert ingredients” im- within current statutes, they would like a determination, section- plies “inactive, without effect”, by-section, on the 350 inert pesticide ingredients listed in their which most inerts are not. For petition, or if that is not possible an individual determination of this reason many people favor the each chemical, as to whether it should be identified on the term “other ingredients”. pesticide product label. They also request that EPA require labeling of inert ingredients listed in the Hazardous Substances Data Bank. EPA Response In their 30 September 2009 response http://www.epa.gov/opprd001/inerts/index.htm , EPA agreed that ―… increased transparency could lead to better informed deci- sion-making and to better informed pesticide use‖. They believe, in general, that formulations with hazardous inert ingredients have a less favorable cost/benefit ratio than formulations that work the same but do not contain the hazardous inerts. There- fore, EPA will start a rulemaking process that would increase availability to the public of inerts in specific pesticide formula- tions. It would include disclosure of all inerts, not just those listed as hazardous. This rulemaking process will begin with an Advance Notice of Proposed Rulemaking being submitted to the Office of Manage- ment and Budget. EPA states that there are many complex issues involved and all stakeholders should be given a chance to re- The Pesticide Label Page 18 spond. The Agency believes that the request of the petitioners— ―issuing determinations for that [sic] the specific substances listed in the petitions must be disclosed on product labels‖— would bring many challenges for certain products. The progress of the Office of Management and Budget deliberations can be located at http://www.reginfo.gov/public/do/eoPackageMain ARSENIC USE CANCELLATIONS At the request of the manufacturers, EPA is announcing cancel- lations for certain uses of pesticides containing organic arseni- cals, followed by their termination dates. The organic arsenicals include monosodium methanearsonate (MSMA), disodium me- thanearsonate (DSMA), calcium acid methanearsonate (CAMA), and cacodylic acid and its sodium salt. The requests terminate the following uses of MSMA: residential; forestry; non-bearing fruit and nuts; citrus, bearing and non- bearing; bluegrass, fescue and ryegrass grown for seed; drainage ditch banks; railroad, pipeline, and utility rights of way; fence rows; storage yards; and similar non-crop areas. These voluntary cancellations for MSMA-containing products do not terminate all of its uses in the U.S. The requests, however, do terminate distribution and use of all products containing DSMA, CAMA, cacodylic acid (CA) and its sodium salt (CAS). Existing stocks of these organic arsenates are those registered pesticides currently in the U.S. and which were packaged, la- beled, and released for shipment prior to the effective date of the cancellation. For existing stocks of these products and their can- cellation dates, refer to the following Table of Cancellations and Terminations of Uses of pesticides Containing Organic Arseni- cals and the EPA website at http://www.epa.gov/fedrgstr/EPA- PEST/2009/September/Day-30/p23319.pdf. The Pesticide Label Page 19 Table of Cancellations and Terminations of Uses of Pesticides Containing Organic Arsenicals. 1 Cancellation Date Products Prohibited Except for the Following Labeled Uses (action, subject) January 1, 2010 MSMA Cotton, sod farms, golf courses, highway rights-of-way (sales and distribution by the manufacturer) DSMA, CAMA, CA, CAS All uses January 1, 2011 MSMA Cotton, sod farms, golf courses, highway rights-of-way (sales and distribution by persons other than DSMA, CAMA, CA, CAS All uses the manufacturer) January 1, 2011 MSMA Cotton, sod farms, golf courses, highway rights-of-way (purchased products can be used legally DSMA, CAMA, CA, CAS All uses until exhausted) January 1, 2013 MSMA All uses (sales and distribution by the manufacturer) December 31, 2013 MSMA All uses except cotton (purchased products can be used legally until exhausted) 1 MSMA=monosodium methanearsonate, DSMA=disodium methanearsonate, CAMA=calcium acid methanearsonate, CA=cacodylic acid, CAS=cacodylic acid and its sodium salt. BIRTH OF AN HERBICIDE Pesticide manufacturers are constantly searching for novel chem- icals with new modes of action. One good source of these com- pounds is allelochemicals, substances produced by some plants that are toxic to other plants. Though these compounds naturally affect other plants, they may need to be refined for agricultural use. For example, they may be 1) too complex to produce in economic amounts, 2) too weak and need too much product to be effective, 2) too toxic to non-target organisms, or 3) they may have other undesirable characteristics. Therefore, it is important to isolate relatively simple compounds and then change them chemically to produce a desired product. In 1977, a California biologist noticed that only a few weeds grew around his red bottle brush plants (Callistemon citrinus). maltawildplants.com He collected soil from under the plants and extracted allelochem- icals from it. Two of the five samples were allelopathic; they inhibited the growth of other plants. One of these was very active and was later named leptospermone. The Pesticide Label Page 20 A review of the literature showed that leptospermone was first reported in 1921 and since then has been extracted from many plants, but never before from bottle brush. The substance was purified and tested on a range of plants, both pre- and post- emergence. The unique symptom, a white bleaching of the leaves, interested the biologist and his company, Western Re- search Centre (formerly Stauffer Chemical, now Syngenta). The company synthesized and optimized the compound and eventually produced some very active products. Some were so toxic they killed 90 percent (LD90) of the test weeds at a dosage as low as 0.001 grams of active ingredient per 2.5 acres, com- pared to a 9,000-gram LD90 for leptospermone per 2.5 acres. However, these highly active chemicals had other characteristics Optimization steps from leptospermone to mesotrione that prevented their use, such as a long life in the soil, too broad a range of susceptible plants, or toxic effects to humans. After thousands of compounds were tested, mesotrione was discovered (see figure). Mesotrione (2-[4-(methylsulphonyl)-2-nitrobenoyl]-1,3- cyclohexadione) gives selective weed control in maize (corn). It is quickly taken up by leaves, shoots and roots and translocated throughout the plant. It can be used both pre- and post- emergence against many broadleaved and some grassy weeds, with excellent selectivity. Recommended rates of use are from 75 to 225 grams of active ingredient per 2.5 acres, about 100 times more powerful than leptospermone. Mesotrione‘s mode of action is the same as for leptospermone. It competitively blocks an enzyme that assists in the formation of carotenoids. These are orange pigments necessary for photosyn- thesis and the protection of chlorophyll and plant cell mem- branes during photosynthesis. In sensitive species, inhibition of this enzyme leads to bleaching of the aboveground parts of the plant and its eventual death. Maize is tolerant of mesotrione, breaking it down into inactive byproducts with very few symp- toms and no loss of yield. According to a recent article in the Journal of Agriculture and Food Chemistry, mesotrione applied to maize alone or together with atrazine can increase the level of carotenoids in sweet corn kernels by 15 percent. The two dietary carotenoids, lutein and zeaxanthin, are important in suppressing eye diseases caused by aging, such as macular degeneration, now affecting almost 2 million older Americans. The Pesticide Label Page 21 Mesotrione was introduced by Syngenta in the U.S. and Europe in 2000 under the brand name Callisto™ (from Callistemon). It reportedly has no significant risk to humans or other non-target References organisms or to the environment. It is quickly broken down in Cornes, D. 2005. Callisto: a very suc- cessful maize herbicide inspired by al- the soil and the threat of leaching into groundwater is slight. lelochemistry. http://www.regional.org.au/au/allelopa thy/2005/2/7/2636_cornesd.htm Kopsell, D.A., et al. 2009. Increase in nutritionally important sweet corn ker- nel carotenoids following mesotrione and atrazine applications. http://pubs.acs.org/stoken/presspac/pre sspac/full/10.1021/jf9013313 ONTARIO’S COSMETIC PESTICIDES BAN The Cosmetic Pesticides Ban Act of 2008 went into effect on Earth Day, 22 April 2009 in Ontario, Canada. Under this new act, ―Pesticides cannot be used for cosmetic purposes on lawns, vegetable and ornamental gardens, patios, driveways, cemeteries, and in parks and school yards.‖ For pest infestations in these areas, ―…lower risk pesticides, biopesticides and alternatives to pesticides exist‖. The Act bans the sale of more than 250 pesti- cide products and over 80 active ingredients for cosmetic use. There are few exceptions and these require prior approval. Opinions are divided on this pesticide ban. Here are a few com- ments and their sources on the internet: ―The McGuinty government believes the use of pesticides to control pesky weeds and insects for purely cosmetic reasons is an unnecessary risk to our families and pets, especially when you can have a healthier lawn and garden without chemicals.‖ Ontario Ministry of the Environment http://www.ene.gov.on.ca/en/land/pesticides/index.php ―Ontario's Lawncare Industry is over $1.26 billion a year, with $577 million spent on equipment and wages. There are 21000 full time [sic] employees whose jobs are now at risk.‖ The Landscape Management Newslet- ter at http://www.landscapemanagement.net/landscape/Green+Industry+ News/Lawn-care-spokesman-blasts-Ontario-pesticide- ban/ArticleStandard/Article/detail/585501 The Pesticide Label Page 22 ―Earth Day this year is a particularly good day for the envi- ronment, and Ontario families, especially children. By ban- ning the sale and use of cosmetic pesticides, we‘ve elimi- nated the unnecessary risk posed by cosmetic pesticides and made Ontario a healthier place.‖ – John Gerretsen, Minister of the Environment http://www.ene.gov.on.ca/en/news/2009/042201.php ―When a world-recognized expert, Dean M. Stanbridge says, ‗it‘s sad that science and common sense were pushed aside by scare tactics and emotion,‘ it certainly reinforces the posi- tion taken by the Ontario Federation of Agriculture on On- tario‘s pesticide ban.‖ Greenhouse Canada magazine at http://www.greenhousecanada.com/content/view/1636/38/ ―We‘re delighted to be involved in helping Ontarians achieve a pesticide-free landscape. Communities in Bloom is dedicated to promoting green spaces, especially in urban set- tings, and we‘re proud that our efforts are helping the envi- ronment.‖ – Lee Rozon, Executive Director, Communities in Bloom – Ontario http://www.ene.gov.on.ca/en/news/2009/042201.php PROPOSED PESTICIDE LABELING TO CONTROL SPRAY DRIFT The U.S. Environmental Protection Agency has rolled out pro- posed guidance for new pesticide labeling to reduce off-target spray and dust drift. The new instructions, when implemented, will improve the clarity and consistency of pesticide labels and help prevent harm from spray drift. The agency is also request- ing comment on a petition to evaluate children‘s exposure to pes- ticide drift. ―The new label statements will help reduce problems from pesti- cide drift,‖ said Steve Owens, the assistant administrator for EPA‘s Office of Prevention, Pesticides and Toxic Substances. ―The new labels will carry more uniform and specific directions The Pesticide Label Page 23 on restricting spray drift while giving pesticide applicators clear and workable instructions.‖ The new instructions will prohibit drift that could cause adverse health or environmental effects. Also, on a pesticide-by-pesticide basis, EPA will evaluate scientific information on risk and expo- sure based on individual product use patterns. These assessments will help the agency determine whether no-spray buffer zones or other measures – such as restrictions on droplet or particle size, nozzle height, or weather conditions – are needed to protect people, wildlife, water resources, schools and other sensitive sites from potential harm. More at http://www.epa.gov/pesticides/factsheets/spraydrift.htm ILLUSTRATED GLOSSARY Terms from Pesticide Labels Biopesticide. Biopesticides are certain types of pesticides derived from such natural materials as animals, plants, bacteria, and certain minerals. U.S. EPA divides these pesticides into three categories: 1) Microbial pesticides consist of a microorganism such as a bacterium, fungus, or protozoan; 2) Plant-incorporated Protectants, or PIPs, are pesticidal genetic material that have been added to plants; and 3) Biochemical pesticides are naturally occurring substances that control pests by non-toxic mechanisms. Label example: Integrate this biofungicide (see Microbial pes- ticides above) into an overall disease and pest management strategy whenever fungicide use is necessary. Gloves, chemical-resistant. Hand covers made of various mate- rials, such as rubber, neoprene, PVC, that protect the handler‘s hands from chemical contact; consult EPA chemical resistance category selection chart. Label example: Chemical-resistant gloves, such as barrier la- minate or viton. The Pesticide Label Page 24 Inert ingredient. Any substance (or group of structurally similar substances if designated by EPA), other than an active ingre- dient, which is intentionally included in a pesticide product (FIFRA). May also be listed in the ingredient statement as ―other ingredients‖. Label example: Inert ingredients … 60.0% Intertidal zone. Area of the shore that is exposed to air during low tide and covered with water at high tide. Area between high and low tides. Seashore, foreshore, littoral. Label example: Do not apply directly to water or to areas where surface water is present or to intertidal areas below the mean high water mark. Rodenticide. a substance used to kill rodents (rats, mice, voles, gophers, squirrels, etc.) Label example: Weather-resistant rodenticide for use in and around structures and in terrestrial nonfood/nonfeed areas to control commensal rats and mice … The definitions in this glossary are intended to help un- derstand the terms used on pesticide labels. Other defini- tions may be available for these terms. Mention of a trademark, company, or proprietary name is not an endorsement and does not imply a recommen- dation to the exclusion of other companies or products. The Pesticide Label Page 25 The Pesticide Label January—March 2010 PREVIOUS RECERTIFICATION ARTICLES October–December—Soil Fumigant Regulations: EPA Responds to Stakeholders (p. 2), Misbranding (p. 5), Her- bicide Flashback (p. 8) July–September 2009—Pesticide Adjuvants (p. 2), Herbicides (p. 5) April–June 2009—Invasive Snails and Slugs of Hawaii (p. 2), Temperature Effects of Storage on Greenhouse, Ornamental and Turf Pesticides (p. 9) January–March 2009—Disposal of Pesticides and Pesticide Containers (p. 2), Pesticide Resistance (p. 3), Poly Tanks (p. 8) July–December 2008—Gaseous Pesticide Formulations (p. 2), Fumigants (p. 5), EPA‘s New Regulations for Soil Fumigants (p. 10), Pesticide Shelf Life (p. 14) April–June 2008—Reducing Spray Drift: Windbreaks and Buffer Zones (p. 5) February–March 2008—Pesticide Labels (p. 4), Engineering Controls for Pesticide Exposure (p. 7) October 2007–January 2008—What is a Pesticide? (p. 3), Special Hazards of Restricted Use Pesticides (p. 5), Su- pervising Noncertified Applicators of Restricted Use Pesticides (p. 9) Archived issues of “The Pesticide Label” available for free download at http://pestworld.stjohn.hawaii.edu/pat/Newsletter_main.html Updated packet item, “Hawaii Pesticide Laws and Regulations” now available at http://pestworld.stjohn.hawaii.edu/studypackets/HI_Pesticide_Laws_Regs_100122.pdf This newsletter is published by the Extension Pesticide Programs. For Mention of a trademark, company, or proprietary name in this newsletter does information on pesticide programs, please contact: not constitute an endorsement, guarantee, or warranty by the University of Hawaii Cooperative Extension Service or its employees and does not imply Charles Nagamine recommendations to the exclusion of other suitable products or companies. Department of Plant and Environmental Sciences 3050 Maile Way, Gilmore 310 University of Hawaii at Manoa Caution: Pesticide use is governed by state and federal regulations. Pesticides Honolulu, HI 96822 and pesticide uses mentioned in this newsletter may not be approved for Ha- waii, and their mention is for information purposes only and should not be Telephone: (808) 956-6007 (Nagamine) considered a recommendation. Read the pesticide’s labeling to ensure that the E-mail: firstname.lastname@example.org intended use is included on it and follow all labeling directions. Web edition: http://pestworld.stjohn.hawaii.edu/pat/newsletter_main.htm Cooperative EXTENSION SERVICE, UNIVERSITY OF HAWAII AT MANOA, COLLEGE OF TROPICAL AGRICULTURE AND HUMAN RE- SOURCES, 3050 MAILE WAY, HONOLULU, HAWAII 96822. The UH-CTAHR Cooperative Extension Service and the U.S. Department of Agriculture cooperate in presenting t the people of Hawaii programs and services without regard to race, sex, age, religion, color, national origin, ancestry, disability, marital status, arrest and court record, sexual orientation, or veteran status. The University is an equal opportunity, affirmative action institution.
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