­­­­­
Forwarded
by
Hodayah
Finman/
DC/
USEPA/
US
on
09/
09/
02
01:
18
PM
­­­­
­
MTAUKUM@
aol.
com
09/
06/
02
12:
22
PM
To:
Bromide
Methyl@
EPA,
murphylee@
inforum.
net
cc:
wausk@
glcc.
com,
jivancovich@
trical.
com,
clelmore@
vegmail.
ucdavis.
edu,
jgerik@
fresno.
ars.
usda.
gov,
mamellano@
mellano.
com,
tnell@
mail.
ifas.
ufl.
edu,
norton.
jack@
worldnet.
att.
net,
Ssiri10@
aol.
com,
ccfc@
ccfc.
org
Subject:
CUE
­
California
Cut
Flower
Commission
I
have
attached
an
electronic
file
containing
a
report
from
the
California
Cut
Flower
Commission
regarding
a
critical
use
exemption
for
the
continued
use
of
methyl
bromide
on
cut
flowers
in
California
after
January
2005.
A
hard
copy
containing
the
references
has
been
sent
via
FedEx
to
the
address
given
on
the
application
form.
Please
address
all
questions
to
the
person
listed
below:
A.
R.
Chase
Chase
Research
Gardens,
Inc.
8031
Mt.
Aukum
Rd.,
Suite
F
Mt.
Aukum,
CA
95656­
0529
(
530)
620­
1624
(
phone/
FAX)
MTAUKUM@
aol.
com
METHYL
BROMIDE
USE
IN
CALIFORNIA
CUT
FLOWERS
­
A
PROGRESS
REPORT
FOR
CRITICAL
USE
EXEMPTION
A.
R.
Chase
President
and
Plant
Pathologist
Chase
Research
Gardens,
Inc.
8031
Mt.
Aukum
Rd.,
Suite
F
Mt.
Aukum,
CA
95656­
0529
(
530)
620­
1624
(
phone/
FAX)
MTAUKUM@
aol.
com
For
the
California
Cut
Flower
Commission
P.
O.
Box
4003
Aromas,
CA
95004­
4003
(
831)
728­
7333
The
California
Cut
Flower
Commission
(
CCFC)
has
been
very
concerned
with
the
impending
loss
of
methyl
bromide
for
more
than
10
years.
CCFC
has
rigorously
pursued
alternatives
for
methyl
bromide
to
the
extent
of
the
funding
available.
They
have
successfully
obtained
additional
funding
via
USDA
and
IR­
4
contacts
such
as
Jack
Norton.
For
the
past
year
I
have
been
working
with
them
on
research
as
starting
the
process
of
filing
a
CUE
on
their
behalf.
Although
much
progress
has
been
made
we
do
not
feel
that
we
are
currently
in
a
position
to
submit
a
complete
document
to
assist
EPA
scientist's
review
of
our
unique
and
very
challenging
industry.

We
have
therefore
chosen,
at
this
time,
to
file
this
document
in
place
of
a
complete
CUE
to
assure
EPA,
USDA
and
other
parties
of
the
seriousness
with
which
we
have
approached
the
loss
of
methyl
bromide
in
the
California
cut
flower
industry.
We
anticipate
filing
a
formal
CUE
in
2003
encompassing
all
cut
flower
production
in
the
US
with
complete
biological
and
economic
profiles.

Our
failure
to
submit
the
complete
CUE
at
this
time
is
due
to
several
factors.
First
the,
relatively,
short
time
frame
allowed
for
development
of
the
package
limited
out
ability
to
comply.
This
is
partially
due
to
limited
funding
available
to
address
economic
data
required.
We
chose
to
expend
the
bulk
of
the
available
funding
on
new
research
trials
as
we
feel
that
is
the
best
avenue
for
solving
the
loss
of
this
integral
product
in
the
California
cut
flower
industry.

Second,
our
industry
is
diverse,
complex
and
small
in
the
big
picture
of
agriculture.
This
is
easily
seen
in
the
following
listing
of
crops
produced
(
Table
1)
as
well
as
a
recent
article
(
Miller,
2002).
It
is
not
economically
feasible
for
our
producers
to
specialize
since
the
market
calls
for
a
wide
and
ever
changing
product
mix.
This
creates
problems
when
trying
to
decide
what
are
the
specific
targets
of
methyl
bromide
since
it
has
been
used
for
many
years
in
so
many
ways
that
few
are
even
documented.
We
refer
you
to
the
attachments
by
University
of
California
scientists
(
Farnham
and
McCain,
1982,
McCain
and
Paulus,
1981,
and
McCain,
1982).
These
grower
guides
clearly
show
the
complexity
of
the
disease
spectrum
for
a
few
of
the
most
widely
grown
crops
(
gladiolus,
larkspur
and
stock
 
Matthiola).
This
picture
is
minimal
compared
to
the
number
of
crops
produced
and
their
accompanying
pests.

Table
1.
Partial
listing
of
cut
flower
crops
produced
in
California.

Crop
%
Producers
1998
%
Producers
2000
Achillea
(
yarrow)
10
10
Alstroemeria
12
13
Anemone
6
5
Antirrhinum
(
snapdragon)
20
17
Aster
11
12
Banksia
8
10
Calla
lily
13
12
Campanula
3
5
Carnation
(
standard
and
mini­
carns)
16
16
Chrysanthemum
(
Cushion)
10
9
Chrysanthemum
(
Football)
6
8
Delphinium
16
14
Daffodil
(
Narcissus)
6
5
Freesia
9
10
Gerbera
9
9
Gladiolus
7
9
Godetia
(
Clarkia)
7
8
Gypsophila
13
13
Helianthus
28
26
Hypericum
5
5
Iris
(
Dutch)
15
16
Larkspur
21
18
Liatris
spicata
7
3
Lilium
(
Oriental,
Asiatic)
10
12
Limonium
spp.
21
15
Lisianthus
16
12
Peony
1
3
Protea
12
12
Ranunculus
9
10
Rose
18
15
Solidaster
8
8
Stock
(
Matthiola)
15
16
Strelitzia
(
Bird­
of­
Paradise)
18
10
Tulip
9
12
(
from
­
Prince
&
Prince,
Inc.,
Columbus
Ohio
 
in
"
California
Cut­
Flower
Production
and
Industry
Trends
­
2000.
There
were
191
(
1998)
and
172
(
2000)
respondents.)
Third,
most
of
our
production
lies
in
Coastal
California
(
see
Table
2
for
distribution
and
farm
size)
where
we
are
in
direct
competition
for
methyl
bromide
alternative
products
with
very
large
industries
such
as
strawberry
production
(
Table
3).
The
availability
of
methyl
bromide
has
already
been
impacted
by
this
key
competitor
as
they
can
financially
withstand
higher
input
costs.
In
addition,
use
of
a
key
alternative
 
1,
3­
D
(
Telone)
is
severely
affected
by
township
caps
that
will
be
met
by
the
strawberry
industry
leaving
little
if
any
product
available
for
cut
flowers
(
Carpenter,
Lynch
and
Trout,
2001).
The
political
atmosphere
in
California
is
such
that
serious
delays
will
probably
be
experienced
in
registrations
of
all
new
materials
(
Trout,
2001­
appendix
1).
Continued
use
of
standards
such
as
chloropicrin
is
also
in
doubt.

Table
2.
Primary
Counties
in
California
where
cut
flowers
are
produced
and
farm
sizes.
Counties
%
Respondents
2000
%
Respondents
1998
Monterey
17
14
San
Diego
27
28
Santa
Barbara
15
10
Santa
Clara
9
7
Santa
Cruz
5
9
Ventura
8
6
Remainder
19
26
Reported
farm
size
Under
10
acres
54
58
10­
49
acres
30
27
50
acres
or
more
16
15
These
data
were
obtained
from
Prince
&
Prince,
Inc.,
Columbus
Ohio
 
in
"
California
Cut­
Flower
Production
and
Industry
Trends
 
2000".
The
total
acreage
in
1998
was
reported
as
5205
and
for
2000
as
5084.
Only
44%
of
surveys
were
returned.

Table
3.
Methyl
bromide
use
in
California
in
1996­
99
(
Dr.
Tom
Trout
­
adapted
from
CA
Division
of
Pesticide
Regulation
Pesticide
Use
Reports)

Crop
MeBr
use
(
lbs)
Portion
of
crop
treated
(%)
Strawberry
4,800,000
94%
Sweet
potato
600,000
42%
Peppers
400,000
9%
Melons
500,000
7%
Other
annual
vegetables
and
fruits
1,200,000
­­­­­
Vineyards
1,700,000
20%
Peach
orchards
(
all
stone
fruit)
1,000,000
35%
Walnut
500,000
32%
Almond
800,000
14%
Nurseries
1,600,000
­­­­­
Cut
flowers
500,000
­­­­­
Structural
fumigation
400,000
­­­­­
Fourth,
the
diversity
of
crops
is
accompanied
by
a
diversity
of
pest
species.
Although
many
herbicides
(
and
fungicides)
have
been
evaluated
for
use
on
cut
flowers
or
their
pests
a
safe
and
effective
alternative
is
not
always
available.
Table
4
is
a
summary
of
the
research
trials
I
have
run
over
the
past
22
years
on
fungicides
for
Fusarium.
There
are
no
acceptable
alternatives
since
even
in
a
pot
these
products
provide
only
moderate
control
of
Fusarium
wilt.
Some
of
our
most
critical
crops
are
hosts
of
various
Fusarium
wilt
fungi
including
mini­
carnations,
Lisianthus,
gladiolus
and
Dutch
iris.
Killing
the
contaminated
crop
residues
is
especially
critical
for
these
crops
and
methyl
bromide
has
been
the
key
product
used
for
this
over
the
past
45
years
(
Carpenter
and
Gammon,
1955,
and
Wolcan
et.
Al,
2001).

Table
4.
Fungicide
trials
for
control
of
Fusarium
diseases
on
ornamentals.

Fungicide
Active
ingredient
Degree
of
control
Chipco
26GT
Iprodione
Very
good
for
stem
rot
or
leaf
spot
None
for
wilt
Cleary
3336
Thiophanate
methyl
Some
to
very
good
of
stem
rot
Poor
to
some
for
wilt
Compass
Trifloxystrobin
Very
good
to
excellent
for
leaf
spot
None
for
wilt
Daconil
Chlorothalonil
Excellent
for
leaf
spot
Cannot
be
used
as
a
drench
for
wilt
or
stem
rot
Heritage
Azoxystrobin
Good
to
very
good
for
leaf
spot
Good
for
wilt
(
effective
rates
are
above
those
labeled)
Medallion
Fludioxinil
Very
good
for
stem
rot
Good
for
wilt
Phyton
27
Copper
pentahydrate
None
to
very
good
for
wilt
PlantShield
Trichoderma
harzinianum
None
Terraguard
Triflumizole
Very
good
for
leaf
spot
Good
for
wilt
University
of
Florida,
Central
Florida
Research
and
Education
Center
(
1979­
1993)
and
Chase
Research
Gardens,
California
(
1994­
2002)

Another
serious
and
common
set
of
problems
on
certain
cut
flower
crops
(
i.
e.
Ranunculus,
stock
and
zinnia)
are
seed­
borne
bacterial
diseases
(
Azad
et.
al,
1996
and
McCain,
1982).
Xanthomonas
diseases
are
commonly
seed­
borne
and
although
they
are
easily
eliminated
with
a
heated­
bleach
treatment,
the
seed
producers
do
not
address
the
problem
and
continue
to
supply
badly
infested
seed
lots
each
year.
These
diseases
are
poorly
if
at
all
controlled
with
the
copper
bactericides
currently
available
even
when
the
entire
plant
can
be
protected
(
greenhouse
production).
These
disease
are
often
carried
from
one
production
cycle
to
the
next
via
crop
debris
(
McCain,
1982).
The
number
of
weed
species
and
crops
produced
makes
weed
control
in
the
fieldgrown
cut
flower
industry
critical
and
difficult.
Table
4
and
5
summarize
years
of
research
at
the
University
of
California.
They
illustrate
the
complexity
of
the
problem
faced
with
the
loss
of
methyl
bromide.
Note
that
the
first
weeds
listed
in
Table
4
are
the
remnants
of
previous
crops.
They
are
a
serious
problem
since
our
industry
routinely
practices
crop
rotation
and
infected
debris
from
an
earlier
crop
can
reduce
profit
margins
significantly.
It
is
not
possible
to
spray
many
of
these
crops
with
a
selective
herbicide
once
the
new
crop
is
planted.

Table
5.
Weed
species
as
major
problems
in
field­
grown
ornamental
propagation
(
Dr.
Clyde
Elmore,
Weed
Extension
Specialist,
University
of
California
Davis).

Class
One
­
Species
that
are
necessary
to
control
before
or
at
planting
to
reduce
further
invasion
into
growing
areas.
Common
Name
Scientific
Name
Gladioli
cormlets,
cormels
and
corms
Calla
lily
tubers
and
rhizomes
Iris
bulbs
and
Ranunculus
tubers
Little
mallow
Malva
parviflora
Clovers
Melilotus
sp.,
Medicago
sp.,
Trifolium
sp.
Common
sow
thistle
Sonchus
oleracea
Yellow
creeping
field
cress
Rorippa
sylvestris
Dwarf
nettle
Urtica
urens
Yellow
nutsedge
Cyperus
esculentus
Red
sorrel
Rumex
acetosella
Class
Two
­
Species
that
are
commonly
found
and
are
major
problems
in
some
fields
requiring
additional
hand
hoeing
and
cultivation
to
manage
the
weed.
Common
Name
Scientific
Name
Cudweed
Gnaphalium
sp.
Common
purslane
Portulaca
oleracea
Prostrate
spurge
Chamacycae
maculata
Creeping
spurge
Chamacycae
serpens
Common
groundsel
Senecio
vulgaris
Shepherds
purse
Capsella
bursa­
pastoris
Common
chickweed
Stellaria
media
Wild
mustard
Brassica
sp.
Dead
nettle
Lamium
amplexicaule
Toad
rush
Juncus
bufonius
Class
Three
­
Species
that
are
commonly
found
and
are
generally
controlled
in
normal
cultural
management
practices­
can
become
difficult
competitors
with
the
flower
crop
and
reduce
flower
production
or
quality.
Common
Name
Scientific
Name
Annual
bluegrass
Poa
annua
Corn
spurry
Spurgula
arvensis
Red
maids
Calandrinia
ciliate
Rough
pigweed
Amaranthus
retroflexus
Prostrate
pigweed
Amaranthus
blitoides
Table
6.
Weed
Susceptibility
to
Herbicides
Preemergence
Herbicides
DCPA
Isoxaben
Metol
.
Naprop.
Oryzalin
Oxadiazon
Oxyf.
Pendi.
Prodi.
Trif.

Annual
weeds
Annual
bluegrass
C
N
C
C
c
c
P
C
c
c
Barnyardgrass
C
N
C
C
c
c
P
C
c
c
Bittercress,
lesserseeded
P
C
P
P
p
c
C
P
p
p
Burclover,
California
N
C
N
N
n
n
C
N
n
n
Cheeseweed
P
C
N
P
p
p
C
P
p
p
Corn
spurry
P
C
C
C
c
n
P
C
c
c
Chickweed,
common
C
C
C
C
c
n
P
C
c
c
Crabgrass
C
N
C
C
c
c
N
C
c
c
Cudweed
N
C
N
P
n
c
C
N
n
n
Fleabane
N
P
N
N
n
p
P
N
n
n
Filaree
P
C
N
C
p
c
C
N
n
n
Goosefoot,
nettleleaf
C
C
P
C
c
c
C
C
c
c
Grounsel,
common
N
C
N
C
p
p
C
N
n
n
Henbit
P
C
N
N
c
c
C
C
c
c
Horseweed
N
P
N
P
n
p
P
N
n
n
Junglerice
C
N
C
C
c
c
P
C
c
c
Lambsquarter
C
C
P
C
c
c
C
C
c
c
London
rocket
P
C
N
C
n
c
C
N
n
n
Mustard
P
C
N
P
n
c
C
N
n
n
Nightshade,
black
P
C
C
N
n
c
C
N
n
n
Nightshade,
hairy
P
C
C
N
n
c
C
N
n
n
Pearlwort
P
C
P
C
c
n
P
C
c
c
Prickly
lettuce
N
C
N
C
p
p
C
N
n
n
Pigweed
c
C
C
C
c
c
C
C
c
c
Purslane
c
C
C
C
c
c
C
C
c
c
Radish,
wild
n
C
N
N
n
c
C
N
n
n
Shepherds
purse
n
C
P
P
n
c
C
N
n
n
Sowthistle,
common
p
C
P
C
n
c
C
N
n
n
Sprangletop
c
N
C
C
c
p
N
C
c
c
Spurge,
prostrate
p
C
N
N
c
c
C
C
c
c
Stinging
nettle
p
C
C
P
p
c
C
P
p
p
Willowherb
n
P
N
N
p
p
C
N
n
n
Biennial
weeds
Bristly
ox­
tongue
n
N
N
N
n
n
N
N
n
n
Perennial
weeds
Bermudagrass
(
per)
n
N
N
N
n
n
N
N
n
n
Bermudagrass
(
seed)
c
N
C
C
c
p
N
C
c
c
Bindweed,
field
(
per)
n
N
N
N
n
p
N
N
n
n
Bindweed,
field
(
seed)
n
N
N
N
p
c
C
P
p
c
Buttercup,
yellow
n
N
N
N
n
n
N
N
n
n
Johnsongrass
(
per)
n
N
N
N
n
n
N
N
n
n
Johnsongrass
(
seed)
p
N
C
C
c
n
N
P
c
c
Nutsedge,
yellow
n
N
P
P
n
n
N
N
n
n
Nutsedge,
purple
n
N
P
N
n
n
N
N
n
n
Woodsorrel,
creeping
(
per)
n
N
N
N
n
n
N
N
n
n
Woodsorrel,
creeping
(
seed)
c
C
N
N
c
c
C
C
c
c
N
=
not
susceptible,
C
=
controlled
at
the
recommended
rate
Per
=
perennial
form,
Seed
=
germination
stage
DCPA,
isoxaben
(
Gallery),
metolachlor
(
Pennent),
napropamide
(
Devrinol),
oryzalin
(
surflan),
oxadiazon
(
Treflan),
clethodim
(
Envoy),
diquat
(
Reward),
fluazifop
(
Fusilade),
glufosinate
(
Finale),
glyphosate
(
Roundup,
sulfosate
=
Touchdown),
pelargonic
acid
(
Sycthe),
sthoxydim
(
Poast)

Post
Emergence
Herbicides
Cleth.
Diquat
Fluaz.
Glufos.
Glyphos
Pelargonic
Sethox
Annual
weeds
Annual
bluegrass
C
C
N
c
C
C
n
Barnyardgrass
C
C
C
c
C
C
c
Bittercress,
lesserseeded
N
P
N
c
C
P
n
Burclover,
California
N
P
N
c
C
P
n
Cheeseweed
N
N
N
p
P
N
n
Corn
spurry
N
P
N
c
C
P
n
Chickweed,
common
N
C
N
c
C
C
n
Crabgrass
C
P
C
c
C
P
c
Cudweed
N
P
N
c
C
P
n
Fleabane
N
N
N
c
C
N
n
Filaree
N
N
N
c
P
N
n
Goosefoot,
nettleleaf
N
N
N
c
C
N
n
Grounsel,
common
N
N
N
c
C
N
n
Henbit
N
N
N
c
C
N
n
Horseweed
N
N
N
c
C
N
n
Junglerice
C
P
C
c
C
P
c
Lambsquarter
N
P
N
c
C
P
n
London
rocket
N
N
N
c
C
N
n
Mustard
N
P
N
c
C
P
n
Nightshade,
black
N
P
N
c
C
P
n
Nightshade,
hairy
N
P
N
c
C
P
n
Pearlwort
N
N
N
c
C
N
n
Prickly
lettuce
N
N
N
c
C
N
n
Pigweed
N
P
N
c
C
P
n
Purslane
N
C
N
c
C
C
n
Radish,
wild
N
C
N
c
C
C
n
Shepherds
purse
N
P
N
c
C
P
n
Sowthistle,
common
N
P
N
c
C
P
n
Sprangletop
N
N
N
c
C
N
n
Spurge,
prostrate
N
C
N
c
C
C
n
Stinging
nettle
N
P
N
c
C
P
n
Willowherb
N
P
N
c
C
P
n
Biennial
weeds
Bristly
ox­
tongue
N
N
N
p
C
N
n
Perennial
weeds
Bermudagrass
(
per)
C
N
P
p
C
N
p
Bermudagrass
(
seed)
C
C
C
c
C
C
c
Bindweed,
field
(
per)
N
N
N
p
P
N
n
Bindweed,
field
(
seed)
N
C
N
c
C
P
n
Buttercup,
yellow
N
N
N
p
C
N
n
Johnsongrass
(
per)
C
N
P
p
C
N
p
Johnsongrass
(
seed)
C
C
C
c
C
C
c
Nutsedge,
yellow
N
N
N
n
P
N
n
Nutsedge,
purple
N
N
N
n
P
N
n
Woodsorrel,
creeping
(
per)
N
N
N
p
C
N
n
Woodsorrel,
creeping
(
seed)
N
C
N
c
C
C
n
N
=
not
susceptible,
C
=
controlled
at
the
recommended
rate
Per
=
perennial
form,
Seed
=
germination
stage
DCPA,
isoxaben
(
Gallery),
metolachlor
(
Pennent),
napropamide
(
Devrinol),
oryzalin
(
surflan),
oxadiazon
(
Treflan),
clethodim
(
Envoy),
diquat
(
Reward),
fluazifop
(
Fusilade),
glufosinate
(
Finale),
glyphosate
(
Roundup,
sulfosate
=
Touchdown),
pelargonic
acid
(
Sycthe),
sthoxydim
(
Poast)

These
tables
are
summaries
provided
by
Dr.
Clyde
Elmore,
Weed
Extension
Specialist
at
the
University
of
California
at
Davis,
CA.

What
have
we
been
doing?

The
University
of
California,
USDA­
ARS
and
CCFC
have
focused
on
as
many
different
alternatives
as
funding
allowed
over
the
past
10
years
(
Appendix
2).
The
section
below
is
an
example
of
an
effort
to
improve
efficacy
of
solarization.
Due
to
the
location
of
our
industry
(
coastal),
it
is
rare
that
the
number
of
degree
days
required
for
effective
solar
treatment
occurs.
This
work
was
performed
by
Elmore
and
Roncoroni
in
1999.

"
Soil
solarization
has
been
conducted
in
the
Middle
East
and
California
for
several
years.
It
is
effective
when
applied
during
a
period
of
high
radiation
(
during
the
mid­
and
late­
summer
in
the
central
valley
of
California).
One
of
the
major
disadvantages
has
been
than
the
area
has
to
be
out
of
production
for
6
weeks
during
a
major
cropping
time.
A
method
that
would
increase
the
interest
in
this
practice
would
be
to
shorten
the
duration
of
solarization
from
4
to
6
weeks
to
2
weeks.
This
could
be
done
if
1)
temperature
could
be
increased
significantly
over
the
normal
temperatures
of
solarization
2)
add
a
reduced
rate
of
a
fumigant
such
as
metam
or
3)
to
use
a
process
of
bio­
fumigation
with
a
product
from
the
Brassicaceae
(
mustard)
family.
This
later
method
would
be
using
natural
products
within
the
plant
that
will
affect
pest
populations
in
the
soil.
In
1999,
two
experiments
were
established
using
field
cut
and
chopped
broccoli
incorporated
into
the
top
of
beds
by
shovel
(
2­
3
inches).
At
one
location
the
primary
weeds
were
annuals.
At
the
other
location
the
weeds
were
rhizomes
of
Calla
lily.
Table
7.
Weed
control
with
soil
applied
materials
and
soil
solarization­
Watsonville,
CA.
The
site
was
100
yards
from
the
ocean.

Treatment
Total
Weeds
%
reduction
No.
calla
shoots
Composted
chicken
manure
(
8T/
A)
43.5
38
38.5
a
Chicken
manure
+
4
weeks
solar
9.1
97
34.5
a
Solarization
4
weeks
18.4
74
41.5
a
Corn
Gluten
meal
+
4
weeks
solar
2.9
96
14.5
b
Chopped
broccoli
(
5T/
A)
+
solar
0.5
99
32.8
a
Metam
50
GPA
+
solar
5.5
92
0.5
c
Untreated
70.0
0
36.0
a
These
results
show
that
additives
such
as
corn
gluten
meal,
metam
sodium
and
chopped
broccoli
can
improve
control
of
certain
weeds
and
crop
debris."

Table
8
lists
the
MBTOC
approved
alternatives.
The
other
columns
relate
the
efforts
made
by
University
of
California,
ARS/
USDA,
IR­
4
and
independent
scientists
to
evaluate
these
and
many
other
alternatives
under
our
unique
political,
environmental
and
biological
conditions.
We
have
include
a
review
of
the
specific
trials
planned
or
in
place
(
complete
with
treatment
lists)
in
Appendix
3.

Table
8.
Alternatives
to
Pre­
Plant
Uses
of
Methyl
Bromide
 
Ornamentals.

MBTOC
selected
CCFC
2001
CCFC
2002
1,
3­
Dichloropropene
(
1,3­
D,
Telone)
X
X
1,
3­
D,
brush
burning
1,
3­
D,
Chloropicrin
X
X
X
1,
3­
D,
Chloropicrin,
Metam
sodium
(
Vapam)
X
X
1,
3­
D,
Chloropicrin,
Pebulate
1,
3­
D,
Metam
sodium
(
Vapam)
X
X
X
Basamid
(
Dazomet)
Chloropicrin
X
X
X
Sodium
tetrathiocarbonate
(
Enzone)
Metam
sodium
(
Vapam)
X
X
X
Metam
sodium,
Chloropicrin
X
X
Metam
sodium,
Crop
rotation
X
Metam
sodium,
Solarization
Nematicides
Solarization,
fungicides
Acetic
acid
X
X
Furfural
(
Multiguard)
X
X
Iodomethane
(
Midas)
X
X
Sodium
azide
(
Agri­
zide
and
CX­
100)
X
X
CONCLUSIONS
We
hope
this
has
helped
in
some
small
way
to
illustrate
our
plight
and
assure
the
EPA,
USDA
and
other
interested
parties
of
our
continued
need
for
methyl
bromide
or
suitable
replacement
in
the
cut
flower
industry.
We
are
well
on
our
way
to
becoming
organized
nationally
in
order
to
prepare
a
complete
CUE
at
our
next
opportunity.
Please
feel
free
to
contact
the
author
with
any
questions
regarding
this
position
statement.

References
attached
in
hard
copy
1.
Azad,
H.
R.,
M.
Vilchez,
A.
O.
Paulus,
and
D.
A.
Cooksey.
1996.
A
new
Ranunculus
disease
caused
by
Xanthomonas
campestris.
Plant
Disease
80:
126­
130.

2.
Carpenter,
T.
R.
and
E.
R.
Gammon.
1955.
Methyl
bromide
gas
treatment
of
dormant
gladiolus
corms
and
sclerotia
of
Sclerotium
rolfsii.
Phytopathology
45:
520­
521.

3.
Carpenter,
J,
L.
Lynch
and
T.
Trout.
2001.
Township
caps
on
1,3­
D
will
impact
adjustment
to
methyl
bromide
phase­
out.
California
Agriculture
55(
3):
12­
18.

4.
Chase,
A.
R.
2002.
Methyl
bromide
on
use
in
field
and
greenhouse=­
grown
cut
flowers.
Power
Point
chart.

5.
Elmore,
Clyde
L.
and
J.
Roncoroni.
2001.
Alternatives
to
Methyl
Bromide
in
fieldgrown
cut
flowers
­
2001.
University
of
California,
Davis,
CA.

6.
Elmore,
Clyde.
2002.
Trial
results
for
Methyl
Bromide
Alternatives
2001­
2002
studies
on
field­
grown
cut
flowers.
University
of
California,
Davis,
CA.

7.
Farnham,
D.
S.
and
A.
H.
McCain.
1982.
Growing
Larkspur
as
a
cut
flower
crop.
Florist's
Review
January
21,
1982.

8.
McCain,
A.
H.
1982.
Stock
disease
control
guide.
University
of
California
Cooperative
Extension
Service,
Leaflet
2858.

9.
McCain,
A.
H.
and
A.
O.
Paulus.
1980.
Gladiolus
disease
control
guide.
University
of
California
Cooperative
Extension
Service,
Leaflet
2604.

10.
Miller,
M.
N.
2002.
Floriculture's
Changing
Face.
GrowerTalks
66(
3):
86,
88,
93­
96,
99­
108,
113­
114,
118­
120.

11.
Wolcan,
S,
G.
Lori
and
L.
Ronco.
2001.
First
report
of
Fusarium
solani
causing
stunt
on
Lisianthus.
Plant
Disease
Note
85:
443.
APPENDIX
1
California
Regulatory
Impacts
on
Adoption
of
MeBr
Alternative
Fumigants
Tom
Trout,
USDA­
ARS
Water
Management
Research
Laboratory,
Fresno,
CA
This
article
was
published
in
the
Methyl
Bromide
Alternatives
Newsletter
(
July,
2001)

From
1991
to
1999,
methyl
bromide
use
in
California
decreased
from
18.5
to
15
million
pounds,
while
use
of
alternative
registered
fumigants
increased
from
7.5
to
over
24
million
pounds.
Telone
(
1,3­
dichloropropene)
was
reintroduced
for
use
in
1994
and
about
3
million
pounds
was
used
in
1999,
mainly
on
orchards
and
vineyards
and
at
reduced
rates
on
annual
vegetables
(
carrot,
tomato,
and
sweet
potato).
Chloropicrin
use
has
gradually
increased
in
the
last
2
years
to
about
4
million
pounds
because
it
is
being
used
at
higher
ratios
in
methyl
bromide
mixtures
as
a
means
of
extending
the
limited
methyl
bromide
supplies.
Very
little
chloropicrin
is
used
as
a
stand­
alone
fumigant,
although
current
research
shows
it
has
potential
as
a
stand­
alone
fumigant
for
some
crops.
Over
70%
of
the
chloropicrin
use
is
on
strawberries.
Use
of
metam
sodium,
which
generates
the
fumigant
methyl
isothiocyanate
(
MITC),
has
increased
dramatically
to
over
17
million
pounds
and
has
now
surpassed
methyl
bromide
in
use.
It
is
primarily
used
on
annual
vegetable
crops
(
carrot,
tomato,
potato,
melons)
as
a
less
costly
alternative
to
other
fumigants.

These
increasing
use
patterns
appear
to
indicate
that
current
regulations
are
not
precluding
use
of
these
currently
available
alternatives.
However,
growers
and
applicators
are
quick
to
provide
examples
of
how
current
or
anticipated
regulations
will
limit
their
use.
This
is
especially
true
in
California
where
use
conditions
in
addition
to
those
on
the
United
States
Environmental
Protection
Agency
(
EPA)
label
are
often
imposed.
I
will
summarize
the
regulatory
procedures
in
California
and
the
impacts
of
these
current
and
anticipated
regulations
on
use
of
alternative
fumigants.

California
Fumigant
Regulatory
Process
California
fumigant
use
regulations
may
vary
from
those
in
other
states
in
three
ways
 
the
California
label,
State­
issued
permit
conditions,
and
specific
conditions
imposed
at
the
county
level
for
individual
applications.
The
California
Department
of
Pesticide
Regulation
(
DPR)
may
require
data
in
addition
to
that
required
by
EPA
before
it
will
register
and
allow
use
of
a
pesticide.
For
fumigants,
this
often
includes
efficacy
data
for
the
material
under
the
proposed
use
and
information
on
air
emissions,
transport,
and
fate.
Fumigant
registrants
may
work
simultaneously
with
EPA
and
DPR
so
that
their
registration
packages
meet
both
needs.
DPR's
current
intent
is
to
adopt
the
national
label
without
changes
and
to
impose
any
further
restrictions
they
feel
are
necessary
in
the
form
of
Suggested
Permit
Conditions.
These
permit
conditions
may
include
restrictions
on
application
rates,
buffer
zones
around
fumigated
fields,
worker
conditions,
environmental
conditions,
and
total
fumigant
use
in
an
area.

Suggested
Permit
Conditions
are
actually
recommendations
to
county
agricultural
commissioners
who
are
responsible
for
authorizing,
regulating,
and
accounting
for
all
fumigant
applications.
All
pesticide
applications
in
California
are
required
to
meet
the
intent
of
the
California
Environmental
Quality
Act
(
similar
to
the
federal
NEPA)
through
a
notice
and
permit
process
with
public
scrutiny.
Thus,
all
fumigant
applications
begin
with
a
"
Notice
Of
Intent"
filed
with
the
county
agriculture
commissioner's
office.
These
notices
include
the
field,
crop,
fumigant,
and
rate,
and
the
issued
Permit
will
note
use
conditions
and
restrictions
specific
to
the
fumigant
and
application.
County
agriculture
commissioners
(
appointed
by
the
county
board
of
supervisors)
must
answer
to
both
farmers
and
concerned
citizens
(
neighbors
and
other
residents
concerned
about
the
potential
dangers
of
pesticides).
They
usually
follow
DPR
issued
Suggested
Permit
Conditions,
but
may
also
(
and
sometimes
do)
further
restrict
use.
Although
county
restrictions
are
on
individual
applications,
they
may
be
printed
up
as
county
guidelines.
County
restrictions
may
be
based
as
much
on
nuisance
aspects
(
smell,
irritation)
and
perception
as
on
actual
risk.
County
inspectors
ensure
that
the
permit
conditions
are
met.

Regulatory
Impacts
on
Use
of
Telone
Telone
is
the
only
one
of
the
three
currently
registered
fumigants
to
have
completed
the
EPA
re­
registration
process.
It
has
also
completed
most
of
the
State's
risk
characterization
process.
Telone
is
also
the
most
restricted
of
the
three
currently.
Current
label
restrictions
include
300­
foot
buffers
around
occupied
residences
(
100
feet
for
drip
application
and
no
buffer
if
not
re­
fumigated
for
3
years),
35
gal/
acre
maximum
application
rates
(
except
for
nurseries),
5­
day
field
reentry
periods,
use
of
full
face
respirators
and
chemical
resistant
hats,
gloves,
boots,
and
aprons
for
workers
in
the
field,
and
moist
soil
requirements
during
application
and
a
soil
"
seal"
following
application
to
reduce
emissions.

Each
of
these
restrictions
can
limit
use
in
some
situations.
Three
hundred
foot
buffers
eliminate
fumigation
on
about
7
acres
of
surrounding
land;
100­
foot
buffers
affect
only
about
an
acre.
The
worker
personal
protective
equipment
(
PPE)
requirements
limit
the
ability
to
install
plastic
tarps
in
warm
climates.
Thirty­
five
gallons
per
acre
may
not
be
adequate
for
deep­
rooted
tree
and
vine
crops.
The
soil
moisture
requirements
in
most
years
are
difficult
and/
or
expensive
for
California
tree
and
vine
growers
to
achieve.

California
Suggested
Permit
Conditions
imposed
300­
foot
buffers
until
this
summer
when
they
were
reduced
to
100
feet
to
match
the
new
EPA
drip­
applied
Telone
(
InLine
and
Telone
EC)
label.
Applications
are
also
restricted
in
the
San
Joaquin
Valley
in
December
and
January
when
air
inversions
are
common.

The
primary
restriction
in
current
California
Permit
Conditions
are
township
caps
on
Telone
applications.
Chronic
exposure
is
a
concern
with
Telone,
and
township
caps
are
designed
to
limit
air
concentrations
over
extended
time
periods
in
an
area.
California
township
caps
limit
Telone
applications
to
no
more
than
9,600
"
adjusted"
gallons
of
Telone
(
90,050
lb
1,3­
D)
in
any
36
square
mile
(
23,040
acre)
township.
Adjusted
pounds
are
the
actual
pounds
multiplied
by
an
application
factor
of
1.0
for
deep
(>
18
inch)
shank
applications
and
1.9
for
shallow
(>
12
inch)
shank
applications.
Township
caps
limit
applications
to
about
1
percent
of
the
land
for
a
typical
strawberry
or
orchard/
vineyard
fumigation
and
2
percent
of
the
land
for
a
typical
vegetable
fumigation.
As
Telone
use
has
increased,
township
caps
have
begun
to
limit
applications.
In
2000,
cap
limits
were
hit
in
four
townships
and
were
nearly
hit
in
nine
additional
townships.
As
methyl
bromide
is
phased
out
and
Telone
use
increases,
the
caps
will
be
more
constraining.
An
analysis
of
the
impacts
of
the
township
caps
on
potential
use
(
Carpenter
et
al.
2001,
Trout
2001)
showed
that
only
about
two­
thirds
of
the
land
presently
fumigated
with
either
Telone
or
methyl
bromide
would
be
able
to
use
Telone.

The
township
cap
impacts
varied
greatly
by
crop
and
region,
because
fumigated
crops
are
concentrated
in
particular
townships.
By
far
the
greatest
impact
is
on
strawberries.
Eighty­
five
percent
of
California
strawberries
are
grown
in
23
townships
and
only
about
one­
third
of
the
strawberry
land
could
be
fumigated
with
Telone.
Other
crops
affected
by
the
township
cap
are
crops
grown
in
the
same
coastal
townships
as
strawberries
(
flowers,
nurseries,
vegetables)
and
other
crops
grown
in
concentrated
areas
such
as
carrots
and
sweet
potatoes.
Impact
on
trees
and
vines
would
be
about
10
percent
statewide
because
these
fields
are
only
replanted,
and
thus
fumigated,
every
7
to
40
years.
Tomato
has
not
traditionally
used
methyl
bromide
but
is
beginning
to
use
Telone
over
wide
areas.
Because
of
the
large
number
of
acres
involved,
the
caps
will
limit
this
use.

Dow
Agro
Sciences
is
currently
working
with
DPR
to
determine
if
township
caps
can
be
raised
in
some
areas.
However,
because
strawberry
cropping
is
so
concentrated,
doubling
the
township
caps
will
only
raise
the
portion
of
the
land
currently
fumigated
with
Telone
or
methyl
bromide
that
can
use
the
product
from
67
percent
to
80
percent,
and
will
raise
the
portion
of
strawberries
that
can
be
fumigated
from
one­
third
to
one­
half.

Because
the
Telone
label
and
permit
conditions
are
restrictive,
county
agriculture
commissioners
seldom
impose
further
use
restrictions.

Dow
Agro
Sciences
was
issued
an
EPA
and
DPR
label
for
their
drip­
applied
emulsified
formulations
of
Telone
(
Inline
and
Telone
EC)
this
summer.
The
current
label
restricts
the
crops
(
strawberries,
vegetables,
melons)
and
application
methods
(
drip
under
plastic
(
HDPE)
mulch).
Applicators
are
not
required
to
wear
respirators
during
application
if
the
delivery
system
is
"
closed".
Drip
application
in
California
has
an
application
factor
for
township
cap
calculations
of
1.16.
The
formulation
is
not
labeled
for
perennials
or
ornamentals.

Regulatory
Impacts
on
Use
of
Chloropicrin
Current
chloropicrin
labels
are
not
restrictive
to
use.
There
are
no
buffer
or
crop
limitations,
allowable
rates
are
high,
respirators
are
not
required
unless
air
concentrations
exceed
0.1
ppm,
and
the
reentry
period
is
2
days.
Soil
surfaces
can
be
sealed
with
sprinkler
irrigation,
cultivation,
or
plastic
tarp.
One
label
(
TriClor)
includes
field
mixing
with
an
emulsifier
for
drip
application
at
up
to
300
lb/
acre.
The
TriClor
label
limits
drip
application
irrigation
amounts
to
1.5
inches
of
water,
which
is
inadequate
for
some
applications.

Because
chloropicrin
use
in
the
past
has
typically
been
in
combination
with
methyl
bromide,
DPR
has
not
issued
Suggested
Permit
Conditions
specifically
for
chloropicrin.
However,
in
anticipation
of
increased
use,
some
county
agriculture
commissioners
have
created
local
guidelines
for
chloropicrin
permits.
For
example,
Santa
Cruz
and
Monterey
counties
limit
application
rates
to
200
lb/
acre
(
inadequate
for
most
stand­
alone
uses),
and
requires
100­
foot
buffers
for
"
sensitive
sites"
(
occupied
residences
nearby).
When
DPR
completes
its
risk
assessment
for
chloropicrin,
there
will
likely
be
additional
use
restrictions.

Regulatory
Impacts
on
Use
of
Metam
Sodium
Current
metam
sodium
labels
allow
application
by
spray/
incorporation,
shank
injection,
drip,
sprinkler,
and
flood
irrigation
at
rates
up
to
75
gal/
acre.
The
soil
must
be
moist
(
between
50
percent
and
80
percent
of
field
capacity),
and
the
surface
can
be
sealed
by
tarps,
sprinkler
irrigation,
or
cultivation.
Respirators
are
not
required
unless
odors
are
strong.
Reentry
is
2
days.

The
Suggested
Permit
Conditions
for
metam
sodium
restrict
use
near
"
sensitive
sites"
when
rates
exceed
15
gal/
acre
(
most
uses).
Conditions
include
500­
foot
buffers,
hourly
field
monitoring
for
odors,
and
sprinkler
systems
in
place
if
odors
become
strong.
With
sprinkler
application,
a
"
water
cap
must
be
applied
immediately
following
application.
The
DPR
issued
guidelines
point
out
that
county
agriculture
commissioners
may
institute
more
restrictive
conditions,
which
many
do.
For
example,
in
Fresno
County,
the
Notice
of
Intent
to
fumigate
must
be
filed
96
hours
in
advance
and
must
map
all
occupied
structures
within
one­
half
mile
of
the
site.
If
the
site
is
in
a
sensitive
or
residential
area,
the
buffer
is
one­
half
mile
for
all
except
shank
applications.
The
Metam
Sodium
Task
Force
is
currently
working
with
the
DPR
to
develop
acceptable
Permit
Conditions,
including
buffers,
that
can
be
used
uniformly
by
counties.
Applications
will
likely
include
improved
soil
sealing
and
site
monitoring.

Future
Regulatory
Impacts
Fumigants
are
going
through
re­
registration
at
the
Federal
level
and
reevaluation
in
California.
The
state
process
involves
a
risk
assessment
of
the
compound
and
then
steps
to
mitigate
the
risks.
Mitigation
can
take
the
form
of
permit
conditions
or
State
regulations.
California
DPR
issues
a
monthly
Status
Report
for
Fumigant
Pesticides
where
information
on
the
fumigant
risk
assessment/
management
process
is
summarized
and
updated.

Of
the
three
registered
alternatives,
only
Telone
products
have
completed
this
reregistration
process.
Dow
Agro
Sciences
is
now
working
with
DPR
to
reassess
the
analysis
that
was
used
to
establish
the
Telone
township
caps
with
the
goal
to
increase
the
caps
in
some
areas.
A
draft
of
the
risk
assessment
document
for
metam
sodium
is
under
public
review.
Metam
sodium
has
been
placed
on
the
restricted
materials
list.
The
risk
assessment
for
chloropicrin
has
just
begun.
As
was
noted,
some
county
agriculture
commissioners
are
applying
permit
condition
restrictions
on
these
materials.

The
State
is
carrying
out
ambient
air
monitoring
of
fumigants
in
areas
of
heavy
use.
Monitoring
in
the
Watsonville
area
in
2000
indicated
methyl
bromide
levels
exceeded
target
seasonal
(
sub
chronic)
exposure
levels
(
1
ppb)
in
some
areas.
This
nearly
triggered
emergency
regulations
on
the
use
of
methyl
bromide
and
has
resulted
in
a
court­
ordered
temporary
restraining
order
on
methyl
bromide
applications
in
specific
areas.
This
summer
and
fall,
ambient
air
concentrations
of
methyl
bromide,
1,3­
D,
chloropicrin,
and
MITC
(
generated
from
metam
sodium)
are
being
monitored
in
two
regions.

California
fumigant
users
point
to
methyl
bromide
regulation
as
an
example
of
what
could
happen
to
other
soil
fumigants.
Restrictions
in
California
on
methyl
bromide
use
have
increased
dramatically
in
the
last
5
years.
A
recent
court
decision
requires
DPR
to
issue
use
regulations
instead
of
Suggested
Permit
Conditions.
These
regulations
include
a
complex
formula
to
calculate
buffers
depending
on
application
method
and
rates.
For
example,
for
a
10­
acre
orchard
fumigation,
the
buffer
would
be
840
feet
if
it
were
fumigated
at
one
time.
Multiple
applications
of
portions
of
the
field
are
often
required
to
reduce
buffers
to
acceptable
levels.
The
new
regulation
also
requires
extensive
prenotification
of
occupants
of
residences
within
300
feet
of
the
buffer,
and
limits
in­
field
workers
(
drivers,
copilots,
tarp
layers)
to
no
more
than
4
hours
per
day
in
the
field.
These
restrictions
have
resulted
in
both
legal
and
practical
limitations
where
methyl
bromide
can
be
used
and
increased
application
costs.

Conclusions
Fumigant
use
regulations
are
more
complex
and
restrictive
in
California
than
in
other
states.
Telone
township
caps
will
severely
restrict
use
in
some
areas.
County
applied
buffers
also
limit
uses.
Although
current
restrictions
on
alternative
fumigants
are
of
concern
to
growers,
of
more
concern
is
not
knowing
what
future
regulations
will
be.
As
long
as
the
rules
may
change,
it
is
precarious
to
invest
time
and
money
into
adopting
and
adapting
to
alternative
fumigants.

References
Carpenter,
Janet,
Lori
Lynch,
and
Tom
Trout.
2001.
Township
limits
on
1,3­
D
will
impact
adjustment
to
methyl
bromide
phase­
out.
California
Agriculture
55(
3):
12­
18.

Trout,
Tom.
2001.
Impact
of
township
caps
on
Telone
use
in
California.
The
Pink
Sheet,
published
by
the
California
Strawberry
Commission,
01(
9),
4
pp.
APPENDIX
2
California
Cut
Flower
Commission
(
Kee
Kitiyama
Foundation)
funding
for
Methyl
Bromide
Alternative
Research
(
1992
to
present)

Title
Researcher/
University
Funding
Period
Amount
Impacts
of
Crop
Protection
Chemicals
Regulations
on
the
Cut
Flower
Industry
in
California
Zilberman/
UC
Berkeley
Nov.
1992
 
Mar.
1995
$
20,000
Electronic
Heating
of
Soil
and
Growing
Media
to
Eliminate
Plant
Pathogens
MacDonald/
UC
Davis
Aug.
1993
 
Dec.
1994
Feb.
1995
­
Feb.
1995
$
20,000
$
11,500
Testing
of
Methyl
Iodide
as
a
Substitute
for
Methyl
Bromide
as
a
Soil
Fumigant
for
Cut
Flower
Production
Ohr
&
Sims/
UC
Riverside
Feb.
1995­
Feb.
1996
$
2,500
Soil
Heating
Technologies
as
Alternatives
to
Methyl
Bromide
for
Soil­
borne
Plant
Pathogens
MacDonald/
UC
Davis
Feb.
1996
­
Feb.
1997
$
10,000
Controlled
Atmospheres
as
an
Alternative
to
Methyl
Bromide
for
Disinfestation
of
Perishable
Commodities
Shelton/
Cal
Poly,
San
Luis
Obispo
Feb.
1996
­
Feb.
1997
$
4,000
Control
of
Problem
Weeds
in
Field
and
Greenhouse­
grown
Ornamentals
Elmore/
UC
Davis
Feb.
1997­
Feb.
1998
Feb.
1998
­
Feb.
1999
Feb.
1999
­
Feb.
2000
Feb.
2000
­
Feb.
2001
$
15,000
$
15,000
$
4,500
$
12,500
Alternatives
to
Methyl
Bromide
for
Control
of
Soil­
borne
Pathogens
MacDonald/
UC
Davis
Feb.
1997
­
Feb.
1998
$
8,000
Steaming
as
an
Alternative
to
Methyl
Bromide
for
the
Control
of
Fusarium
Wilt
of
Carnations
MacDonald/
UC
Davis
Feb.
1998
­
Feb.
1999
$
8,000
Yellow
Nut
sedge
Management
Systems
for
Field
Grown
Cut
Flowers
Wilen/
Coop.
Ext.,
San
Diego
Feb.
2000
­
Feb.
2001
$
10,036
Development
of
an
Integrated
Treatment
Approach
as
an
Alternative
to
Methyl
Bromide
Pre­
plant
Fumigation
for
Field
Grown
Cut
Flower
Production
Locke/
USDA,
ARS,
USNA,
FNPRU
Feb.
2001
­
Feb.
2002
$
6,500
Organization
and
evaluation
of
methyl
bromide
alternative
trials
and
CUE
preparation
(
limited
trial
work
funded
by
Arvesta)
Chase,
Chase
Research
Gardens,
CA
Jan.
2002
 
Dec.
2002
$
15,000
$
4,000
Methyl
bromide
alternative
research
for
the
California
Cut
Flower
Industry
Gerik,
USDA,
ARS,
Parlier,
CA
Sep.
2002
­
Sep.
2003
$
20,000
TOTAL
$
178,536
Appendix
3
California
trials
in
progress
for
2002­
2003
Dr.
Jim
Gerik
­
USDA
ARS,
Parlier,
CA
Pyramid
Flowers
­
Oxnard,
CA
Started
in
August
2002
Treatment
Rate
Midas
(
30%
Iodomethane/
70%
chloropicrin)
400
lb/
acre
Chloropicrin
300
lb/
acre
InLine
50
GPA
Sodium
azide
100
lb/
acre
Multiguard
Protect
and
metam
sodium
56
and
50
GPA
Multiguard
FAA
600
lb/
acre
Metam
sodium
100
GPA
Untreated
control
­­­­­

Dr.'
s
S.
Schneider,
J.
Gerik,
T.
Trout
Jackson
Perkins
Rose
Trial
Started
­
Fall
2001
Treatment
Rate
Untreated
control
­­­­­
Methyl
bromide:
chloropicrin
(
98:
2)
350
lb/
acre
Shanked
MIDAS
(
30%
Iodomethane/
70%
chloropicrin)
400
lb/
acre
Telone
C35,
with
tarp
48
GPA
Telone
C35,
no
tarp
48
GPA
Drip(
water
cap,
no
tarp)
InLine
50
GPA
Telone
II
EC
35
GPA
Chloropicrin
400
lb/
acre
Chloropicrin
200
lb/
acre
MIDAS
(
30/
70)
400
lb/
acre
MIDAS
(
50/
50)
300
lb/
acre
Chloropicrin,
split
application
200
lbs
+
200
lbs
7
days
later
Metam
sodium
75
GPA
Iota
(
a
biological
distributed
by
Central
Cal
Ag)
Dr.
Clyde
Elmore
and
John
Roncoroni
 
University
of
California
at
Davis
Davis,
CA
(
campus
trial)
Scheduled
for
Fall
2002
Treatments
Rate
Plastic
­
water
control
­­­­­
Sodium
azide
(
CX
100)
100
GPA
Sodium
azide
(
CX
100)
150
GPA
Sodium
azide
(
Agrizide)
100
GPA
Sodium
azide
(
Agrizide)
150
GPA
Multiguard
FF
56
GPA
Multiguard
FF
+
metam
sodium
56
+
50
GPA
Metam
sodium
50
GPA
Chloropicrin
400
lbs/
acre
InLine
(
50:
50)
300
lbs/
acre
Dr.
Clyde
Elmore,
John
Roncoroni
and
Ann
King
Ano
Nuevo
Flower
Gardens
­
Santa
Cruz,
CA
Started
June
2002
Treatments
("
Dry
Side")
Rate
Film
Iodomethane
+
chloropicrin
(
50­
50%)
100
lb/
acre
HD
tarp
Iodomethane
+
chloropicrin
(
50­
50%)
200
lb/
acre
HD
tarp
Iodomethane
+
chloropicrin
(
50­
50%)
300
lb/
acre
HD
tarp
Iodomethane
+
chloropicrin
(
50­
50%)
100
lb/
acre
VIF
tarp
Iodomethane
+
chloropicrin
(
50­
50%)
200
lb/
acre
VIF
tarp
Iodomethane
+
chloropicrin
(
50­
50%)
300
lb/
acre
VIF
tarp
Untreated
­­­­­
VIF
tarp
All
treatments
were
covered
with
HD
or
VIF
polyethylene
for
7
days.

Treatments
("
Wet
Side")
Rate
Metam
sodium
+
1,
3­
D/
chloropicrin
(
C35)
75
+
35
GPA
Metam
sodium
75
GPA
Dazomet
(
Basamid)
+
C­
35
200
lb/
acre
+
35
GPA
HD
tarp
Dazomet
200
lb/
acre
1,3­
D
+
chloropicrin
(
C­
35)
35
GPA
Untreated
+
tarp
­­­­­
Dr.
Clyde
Elmore
and
John
Roncoroni
 
University
of
California
at
Davis
Glad­
A­
Way
 
Santa
Maria,
CA
Started
July
2002
Treatments
("
dry
side")
Rate
Methyl
bromide/
chloropicrin
(
50:
50
mixture)
350
lb/
Iodomethane/
chloropicrin
(
67:
33%)
300
lb/
acre
Iodomethane/
chloropicrin
(
50:
50%)
300
lb/
acre
Iodomethane/
chloropicrin
(
33:
67%)
300
lb/
acre
Untreated/
tarped
control
­­­­­
Applied
through
shanks
and
covered
with
standard
HD
tarp.

Treatments
("
wet
side")
Rate
Metam
sodium
+
C­
35
75
gal
(
blade,
rototilled,
packed)
+
35
gal
(
shanked
and
tarped)
Dazomet
+
C­
35
200
lb
(
rototilled,
packed)
+
35
gal
(
shanked
and
tarped)
Metam
sodium
+
C­
35
50
gal
(
blade,
rototilled,
packed)
+
35
gal
(
shanked
and
tarped
Sodium
azide
(
Agrizide)
100
lb
(
bladed,
rototilled,
packed
and
tarped)
Untreated
­­­­­
(
tarped)
Tarps
remained
for
7
days
when
they
will
be
cut
and
opened
to
air
for
24­
48
hours
then
removed.

Dr.
Clyde
Elmore
and
John
Roncoroni
 
University
of
California
at
Davis
Mellano
Flower
Fields
 
Carlsbad,
CA
Planned
to
start
October
2002
Treatments
Rate
Metam
sodium
+
C­
35
75
GPA
(
incorporated
and
rolled)
+
35
GPA
(
shanked
and
tarped)
Metam
sodium
+
Telone
II
75
GPA
(
incorporated
and
rolled)
+
+
chloropicrin
200
GPA
+
15
GPA
(
shanked
and
tarped)
Metam
sodium
75
GPA
(
incorporated
and
rolled)
Dazomet
+
C­
35
200
lb/
acre
(
incorporated
and
rolled)
+
35
GPA
(
shanked
and
tarped)
Dazomet
+
Telone
II
+
chloropicrin
200
lb/
acre
(
incorporated
and
rolled)
+
200
GPA
+
15
GPA
(
shanked
and
tarped)
Check
­­­­­
(
tarped)
Dr.
Clyde
Elmore
and
John
Roncoroni
 
University
of
California
at
Davis
Mellano
Flower
Fields
 
Carlsbad,
CA
Planned
to
start
October
2002
Fumigation
plot
­
Ranunculus
on
North
side
Treatments
Rate
Methyl
bromide/
chloropicrin
(
50­
50)
350
lb/
acre
Iodomethane/
chloropicrin
(
50­
50)
300
lbs
Iodomethane/
chloropicrin
(
50­
50)
350
lbs
Check
­­­­­
(
tarped)
