1
UNITED
STATES
ENVIRONMENTAL
PROTECTION
AGENCY
WASHINGTON,
D.
C.
20460
OFFICE
OF
PREVENTION,
PESTICIDES
AND
TOXIC
SUBSTANCES
MEMORANDUM
SUBJECT:
Assessment
of
stakeholder
requests
to
retain
use
of
azinphos­
methyl
in
crops
where
its
registration
will
expire
in
2005
FROM:
Nikhil
Mallampalli
Bill
Chism
William
Gross
Biologists
Biological
Analysis
Branch
Stephen
Smearman
Economist
Economic
Analysis
Branch
Biological
and
Economic
Analysis
Division
(
7503C)

THRU:
Arnet
Jones,
Chief
Biological
Analysis
Branch
David
Widawsky,
Chief
Economic
Analysis
Branch
TO:
Diane
Isbell,
Chemical
Review
Manager
Margaret
Rice,
Chief
Reregistration
Branch
2
Special
review
and
Reregistration
Division
(
7508C)

BEAD
Product
Review
Panel
date:
March
30,
2005
INTRODUCTION
As
a
result
of
the
interim
Reregistration
Eligibility
Decision
(
iRED)
for
azinphosmethyl
(
AZM)
in
2001,
EPA
categorized
those
crops
whose
growers
were
allowed
to
continue
to
use
this
insecticide
into
three
groups.
"
Group
1"
comprised
crops
for
which
2
AZM
use
was
voluntarily
cancelled
by
the
registrant
(
Bayer).
"
Group
2"
uses
comprise
those
crops
that
are
slated
to
have
their
AZM
labels
expire
in
2005.
"
Group
3"
uses
are
those
crops
for
which
EPA
agreed
to
re­
examine
both
risks
and
benefits
prior
to
making
a
final
decision
on
their
continued
use
of
AZM.
As
part
of
the
process
of
canceling
the
"
group
2"
uses,
SRRD
recently
published
a
6(
f)
notice
in
the
Federal
Register,
inviting
stakeholder
comment
as
to
any
continued
need
for
AZM
in
any
of
the
crops
involved.

Crop
sites
in
this
group
are
as
follows:
cotton,
cranberries,
peaches
and
nectarines,
potatoes,
southern
pine
seed
orchards,
and
caneberries
(
raspberries
and
blackberries).
SRRD
requested
BEAD
to
evaluate
stakeholder
concerns
and
use
them
to
determine
whether
or
not
the
benefits
assessments
done
in
2001
require
significant
changes,
and
whether
or
not
this
is
feasible
based
on
available
information.
In
this
context,
the
reader
should
note
that,
in
2001,
BEAD
explicitly
evaluated
only
the
effect
of
extending
re­
entry
intervals
(
REIs)
for
AZM
for
most
crops.

Analyses
are
presented
below
for
each
crop
separately.
Each
analysis
begins
with
a
brief
description
of
BEAD's
2001
benefits
assessment,
a
summary
of
the
stakeholder
comments
regarding
AZM
elimination,
and
ends
with
BEAD's
assessment
of
these
comments
and
whether
or
not
the
benefits
of
AZM
use
have
changed
substantially
since
2001.
Comments
were
received
for
caneberries,
cranberries,
peaches,
potatoes,
and
southern
pine
seed
orchards,
so
these
will
be
the
only
crops
discussed
in
this
document.

EVALUATION
OF
STAKEHOLDER
COMMENTS
Caneberries
(
blackberries
and
raspberries)

Summary
of
BEAD's
2001
assessment
In
2001
BEAD
evaluated
the
benefits
impact
of
extending
REIs
for
AZM
in
caneberry
production.
Caneberries
is
the
general
term
for
Rubus
spp.,
which
are
commonly
called
raspberries
and
blackberries.
Caneberries
are
a
high­
value
perennial
crop
with
approximately
25,000
acres
grown
in
Washington,
Oregon,
and
California
(
the
major
production
areas).
In
2001,
a
critical
use
of
AZM
was
in
Oregon
for
control
of
the
raspberry
crown
borer
(
RCB),
Pennisetia
marginata
Harris,
in
blackberries.
All
other
pests
that
AZM
is
used
on
have
alternative
products
available.
RCB
is
a
clear­
winged
moth
with
a
two
year
life­
cycle.
While
not
widespread,
it
can
be
a
devastating
pest,
causing
losses
of
up
to
50
%
of
the
plant
in
heavily
infested
fields
in
the
absence
of
a
targeted
control
program
(
communication
with
local
experts).
The
only
reported
use
of
AZM
was
on
11
%
of
blackberries
in
1997
in
Oregon
(
USDA
1999).
Use
of
AZM
ranked
fourth
among
control
alternatives
for
Oregon
blackberry
growers
in
1999
with
approximately
300
total
pounds
applied.
At
that
time,
BEAD
believed
that
limited
impact
would
result
from
extending
the
restricted
entry
intervals
on
AZM
for
caneberries.
Diazinon
is
an
efficacious
alternative
and
is
readily
available
(
although
pest
resistance
could
develop
in
the
future).
BEAD
believed
that
the
most
likely
outcome
resulting
from
extending
the
restricted
entry
intervals
is
that
growers
would
switch
to
diazinon.
3
Summary
of
stakeholder
comments
or
concerns
regarding
cancellation
of
AZM
registration
Information
from
Oregon
crop
extension
service
staff
indicates
that
diazinon
is
the
only
effective
alternative
to
AZM
currently
available
for
blackberries,
in
particular.
Because
of
recent
label
changes
(
in
2003­
2004),
diazinon
can
only
be
used
once
per
season
for
control
of
RCB,
and
growers
would
like
to
use
it
later
in
the
season
for
the
western
raspberry
fruitworm
(
Byturus
bakeri)
instead
of
as
a
dormant
spray
for
the
raspberry
crown
borer.
Fruitworm
adults
emerge
from
the
soil
during
April
and
May
to
lay
eggs;
hatched
larvae
feed
within
developing
fruit.
Stakeholders
claim
that
diazinon
is
the
only
effective
pesticide
for
control
of
this
insect.

The
Michigan
Farm
Bureau
also
mentioned
caneberries
as
a
crop
needing
AZM
in
that
region.
However,
their
statements
were
generically
framed
and
focused
on
the
utility
of
AZM
as
a
rotational
tool
to
slow
resistance
development
and
as
a
reasonably
priced
material
for
a
number
of
crops,
of
which
caneberries
were
just
one
member.

BEAD's
assessment
of
stakeholder
comments
and
changes
in
benefits
of
AZM
As
regards
the
situation
in
blackberries
in
the
PNW
states,
BEAD
has
communicated
with
regional
experts
and
has
determined
that
there
are
some
limitations
to
the
registered
alternatives.
Carbaryl
and
spinosad
(
a
"
reduced
risk"
chemical)
also
have
the
raspberry
fruitworm
listed
on
their
labels
for
caneberries,
and
thus
could
be
used
by
growers
against
that
pests
and
allow
them
to
substitute
diazinon
for
AZM
use
against
the
RCB.
However,
both
have
significant
limitations
that
BEAD
believes
will
inhibit
their
use
as
drop­
in
replacements
for
diazinon.
Carbaryl
is
more
toxic
to
bees
than
diazinon
and
tends
to
cause
mite
outbreaks
(
DeFrancesco,
personal
communication),
and
spinosad's
efficacy
against
this
pest
remains
unproven.
Evaluations
of
spinosad
efficacy
against
the
fruitworm
are
ongoing,
but
given
the
high
quality
standards
for
the
caneberry
crop
(
USDA
2003),
the
optimal
use
pattern
of
this
or
any
other
new
alternative
needs
time
for
Oregon
growers
to
effectively
adopt
in
a
commercial
setting.
However,
BEAD
notes
here
that
at
least
one
other
state
(
Virginia)
suggests
using
spinosad
as
the
only
insecticide
option
for
the
eastern
raspberry
fruitworm
(
B.
rubi),
an
insect
very
similar
in
biology
to
the
fruitworm
that
PNW
caneberry
growers
encounter
(
Pfeiffer
et
al.
2005).

In
this
context,
it
may
be
useful
to
note
that
other
recently
developed,
"
reducedrisk
or
"
OP­
alternative"
insecticides
may
also
hold
promise
for
controlling
either
the
raspberry
fruitworm
or
the
RCB.
Indoxacarb
and
novaluron,
while
not
presently
registered
for
caneberries,
have
shown
good
efficacy
against
other
pests
similar
to
the
raspberry
fruitworm
­
e.
g.,
cranberry
fruitworm,
leafrolling
caterpillars
(
e.
g.,
Wise
et
al.
2004).
As
compounds
active
against
Lepidoptera
in
particular,
they
may
also
have
some
efficacy
against
adult
RCB.
Preliminary
research
also
indicates
that
tebupirimphos
(
an
OP)
combined
with
cyfluthrin
(
a
pyrethroid)
applied
as
a
soil
drench
controls
RCB
larvae
as
well
as
diazinon
(
Johnson
and
Lewis
2002).
4
Therefore,
BEAD
suggests
that
researchers
and
regulators
include
these
materials
in
future
efforts
to
find
alternatives
to
both
AZM
and
diazinon
for
caneberries.
This
is
particularly
important
for
RCB
management,
because
even
with
alternatives
available
for
fruitworm
control,
reliance
on
diazinon
alone
for
RCB
control
may
increase
the
likelihood
of
resistance
developing
in
that
insect
over
the
longer
term.
BEAD
notes,
in
this
regard,
that
RCB
is
a
relatively
slow
growing
insect
(
with
two
years
needed
for
the
completion
of
a
single
generation),
a
factor
that
should
increase
the
time
needed
for
resistance
to
develop
fully.

Unfortunately,
an
accurate
estimation
of
the
losses
that
might
be
incurred
by
growers
who
face
both
the
RCB
and
the
fruitworm
depends
on
a
reliable
estimate
of
the
extent
of
such
an
overlap
in
these
pests'
distribution.
Stakeholders
have
not
supplied
this
information,
and
BEAD
has
been
unable
to
locate
it.
BEAD
concludes
that
some
growers
may
face
yield
losses
if
AZM
was
removed
as
a
pest
control
option
for
Pacific
North
West
caneberry
production,
since
either
the
borer
or
the
fruitworm
might
attack
their
fields
in
any
given
season.
Others
would
be
forced
to
increase
their
pesticide
use
to
control
mite
outbreaks
engendered
by
carbaryl
use.
However,
the
extent
of
these
worstcase
impacts
is,
arguably,
likely
to
be
no
more
than
the
area
treated
currently
with
AZM
 
approximately
1,000
acres
out
of
a
total
of
10,000
acres
of
blackberries
grown
in
2003
(
USDA/
NASS,
Agricultural
Chemical
Usage,
Fruit
Summaries
2003).

The
general
need
for
AZM
that
was
stated
by
the
Michigan
farm
bureau
for
caneberries
and
several
other
crops
is
very
difficult
for
BEAD
to
evaluate
quantitatively.
While
resistance
to
the
remaining
alternatives
could
theoretically
develop
faster
in
the
absence
of
AZM,
and
price
differences
between
AZM
and
the
alternatives
could
result
in
higher
production
costs
for
some
growers,
the
bureau
did
not
provide
any
estimates
of
the
likelihood
or
extent
for
these
potential
impacts
in
their
comments.
BEAD
examined
the
scientific
literature
and
extension
reports
for
the
region
to
attempt
an
evaluation
of
resistance
risk.
Resistance
to
alternatives
likely
to
be
used
(
carbaryl,
diazinon,
and
spinosad,
assuming
the
pest
spectrum
in
Michigan
is
similar
to
other
caneberry
growing
regions)
has
not
been
reported
or
scientifically
monitored
for
the
target
pests
in
that
region,
and
production
costs
for
the
crop
in
this
region
are
apparently
not
available.
BEAD
acknowledges
that
it
is
possible
that
an
unknown
number
of
Michigan
caneberry
growers
might
face
increased
production
costs,
or
resistance
problems
in
pests
in
the
long
term
future.
In
this
context,
it
may
be
useful
to
note
that
Michigan
produces
about
644
acres
of
caneberries,
out
of
about
30,088
acres
or
about
2%
produced
nationally
according
to
NASS.

Cranberries
Summary
of
BEAD's
2001
assessment
In
August
2001,
BEAD
evaluated
the
benefits
of
AZM
for
cranberry
production.
The
American
cranberry
(
Vaccinium
macrocarpon)
is
a
low­
growing
woody
perennial
shrub.
Cranberries
are
a
high­
value
crop
grown
in
five
states
on
approximately
37,000
5
acres.
A
critical
use
of
AZM
in
Wisconsin
is
for
control
of
blackheaded
fireworm,
cranberry
fruitworm
(
Acrobasis
vaccinii
Riley)
and
sparganothis
fruitworm
and
minor
pests
such
as
cranberry
tipworm.
The
most
recent
figures
available
in
2001
indicated
that
AZM
use
in
cranberries
had
declined
in
all
areas
except
Wisconsin.
Use
of
AZM
increased
slightly
in
Wisconsin
between
1996,
when
60%
of
the
crop
was
treated,
and
1998
(
the
latest
year
for
which
figures
were
available)
when
66%
of
the
crop
was
treated.

In
2001,
BEAD
believed
that
adequate
alternatives
were
both
available
and
efficacious.
BEAD
further
determined
that
the
most
likely
outcome
resulting
from
extending
the
restricted
entry
interval
was
that
growers
would
switch
to
alternative
pest
control
methods,
including
increased
usage
of
other
organophosphate
insecticides.

Summary
of
stakeholder
comments
or
concerns
regarding
expiry
of
AZM
registration
Wisconsin
and
the
Cranberry
Institute
have
requested
that
AZM
remain
available
for
the
control
of
the
fruitworm
complex
in
Wisconsin.
They
claim
that
alternative
control
measures
for
the
control
of
fruitworm
complex
such
as
phosmet
or
tebufenozide
are
not
effective.
One
effective
alternative,
methoxyfenozide
(
Intrepid
 
)
,
has
an
endangered
species
restriction
and
can
only
be
used
in
certain
counties
representing
less
than
half
the
cranberry
acreage.
Stakeholders
state
that
another
potential
alternative
diazinon
(
AG
600
water
based
formulation)
is
in
short
supply
because
of
the
transition
of
ownership
to
a
new
company.
Wisconsin
would
like
to
use
AZM
for
two
applications
in
the
summer
for
use
in
rotation
with
tebufenozide.
In
addition,
they
have
suggested
that
if
methoxyfenozide
were
available
they
would
not
need
AZM.

The
Michigan
Farm
Bureau
also
mentioned
cranberries
as
a
crop
needing
AZM
in
that
region.
However,
their
statements
were
generically
framed
and
focused
on
the
utility
of
AZM
as
a
rotational
tool
to
slow
resistance
development
and
as
a
reasonably
priced
material
for
a
number
of
crops,
of
which
cranberries
were
just
one
member.

BEAD's
assessment
of
stakeholder
comments
and
changes
in
benefits
of
AZM
BEAD
has
discussed
the
situation
with
regional
experts
in
conference
calls,
examined
Wisconsin
extension
service
pest
management
guides
(
Mahr
et
al.
2005)
and
results
of
efficacy
trials
on
a
number
of
insecticide
alternatives
submitted
by
stakeholders
(
Dittl
2000).
Based
on
these
sources
it
appears
that
the
AZM
alternatives,
tebufenozide,
diazinon,
methoxyfenozide,
and
phosmet
are
effective
and/
or
recommended
by
extension
services
for
control
of
both
fruitworm
pests
cited
by
the
Wisconsin
stakeholders.
Thus,
while
short­
term
shortages
of
diazinon
may
exist
(
BEAD
was
unable
to
confirm
or
refute
this),
other
alternatives
appear
to
exist.
60%
of
Wisconsin's
cranberry
acres
were
treated
with
AZM
in
2003,
according
to
the
Cranberry
Institute,
so
usage
of
the
material
does
appear
to
remain
high
in
this
region.
However,
AZM
is
recommended
for
use
against
a
suite
of
insect
pests
of
which
the
fruitworms
are
only
one
component;
for
example,
the
cranberry
tipworm
and
the
cranberry
girdler
(
Mahr
et
al.
2005).
It
is
therefore
not
clear
whether
or
not
the
fruitworms
are
the
chief
targets
of
AZM
in
Wisconsin.
6
Given
the
availability
of
effective
alternatives,
BEAD
believes
that
most
Wisconsin
growers
should
be
able
to
manage
most
fruitworm
infestations
without
AZM
in
the
near
future.
However,
an
unknown
number
of
growers
may
have
to
dedicate
use
of
the
alternatives
to
control
of
the
other
insects
(
mentioned
above),
and
without
both
AZM
and
methoxyfenozide,
these
producers
would
be
left
without
effective
fruitworm
control
materials.
In
this
context,
BEAD
also
notes
that
in
most
other
cranberry
growing
regions
(
e.
g.,
Massachusetts),
methoxyfenozide
is
the
standard
treatment
for
fruitworms,
based
on
its
effectiveness
on
egg
and
larval
stages
and
reduced
risk
status
(
e.
g.,
see
Anonymous
2004).
Thus,
BEAD
agrees
with
stakeholders
that
the
impact
of
the
removal
of
AZM
on
Wisconsin
cranberry
production
would
be
further
minimized
if
the
buffer
restrictions
on
methoxyfenozide
are
alleviated.

The
general
need
for
AZM
that
was
stated
by
the
Michigan
farm
bureau
for
cranberries
and
several
other
crops
is
very
difficult
for
BEAD
to
evaluate
quantitatively.
While
resistance
to
the
remaining
alternatives
could
theoretically
develop
faster
in
the
absence
of
AZM,
and
price
differences
between
AZM
and
the
alternatives
could
result
in
higher
production
costs
for
some
growers,
the
bureau
did
not
provide
any
estimates
of
the
likelihood
or
extent
for
these
potential
impacts
in
their
comments.

Resistance
to
alternatives
likely
to
be
used
(
tebufenozide,
diazinon,
and
methoxyfenozide,
assuming
the
pest
spectrum
in
Michigan
is
similar
to
the
Wisconsin
cranberry
growing
regions)
has
not
been
reported
or
scientifically
monitored
for
the
target
pests
in
that
region,
and
production
costs
for
the
crop
in
this
region
are
apparently
not
available.
BEAD
acknowledges
that
it
is
possible
that
an
unknown
number
of
Michigan
cranberry
growers
may
face
increased
production
costs,
or
resistance
problems
in
pests
in
the
long
term
future.
As
was
stated
in
the
discussion
of
caneberry
comments
(
above),
there
are
presently
unregistered
alternatives
that
have
shown
promise
against
fruitworms
or
other
caterpillar
pests,
such
as
indoxacarb
and
novaluron.
BEAD
urges
stakeholders
(
and
OPP's
Registration
Division)
to
pursue
the
development
of
these
insecticides
as
alternatives
for
the
longer
term.

Peaches
Summary
of
BEAD's
2001
assessment
The
critical
use
of
AZM
in
2001
was
to
control
plum
curculio,
Oriental
fruit
moth,
white
peach
scale,
San
Jose
scale,
peach
tree
borer,
lesser
peach
tree
borer
(
LPTB)
and
leafrollers.
AZM
provides
excellent
control
of
plum
curculio
and
scale
insects
¸
but
its
use
has
decreased
since
the
REI
was
increased
to
14
days,
which
prevents
use
during
the
thinning
period.
Phosmet
is
used
during
this
period.
Cost
effective
alternatives
to
both
AZM
and
phosmet
were
found
to
be
available
in
the
West.
40
%
of
the
U.
S.
peach
crop
acreage
was
treated
with
AZM,
mostly
in
Pennsylvania,
New
Jersey,
New
York,
and
Washington,
with
lesser
use
in
Michigan,
Texas,
North
Carolina,
and
South
Carolina.
However,
71%
of
U.
S.
peach
production
was
in
California
and,
(
nearly
all
processed
peaches
and
49%
of
fresh
market
peaches
were
grown
in
California
in1997).
7
Summary
of
stakeholder
comments
or
concerns
regarding
expiry
of
AZM
registration
For
southeastern
US
peaches
(
primarily
Georgia
and
South
Carolina),
stakeholders
claim
there
are
currently
two
critical
uses
for
AZM
 
"
clean­
up",
and
control
of
the
lesser
peachtree
borer,
Synanthedon
pictipes
(
LPTB),
a
clear­
winged
moth.
Stakeholders
claim
that
AZM
does
more
to
clean
up
outbreaks
from
a
wide
array
of
insects
than
any
other
peach
insecticide
(
including
currently
registered
materials
and
unregistered
reduced­
risk
materials
that
have
been
tested
in
this
region).

Stakeholders
also
claim
that
LPTB
has
emerged
as
a
potentially
serious
pest
of
peaches
in
this
region
since
2001.
They
believe
this
change
in
pest
status
is
correlated
to
the
loss
of
use
of
methyl
parathion,
which
occurred
in
1999.
Historically,
the
impacts
of
LPTB
were
restricted
to
older
orchards
already
showing
visible
signs
of
aging
and
decline.
Growers
and
crop
experts
claim
that
in
recent
years,
orchards
as
young
as
8
years
of
age
have
been
taken
out
of
production
because
of
LPTB.
Normal
life
expectancy
for
peach
orchards
in
the
Southeast
is
12
to
14
years.
Orchards
typically
pay
for
themselves
in
their
6th
season.
Growers
also
state
that
AZM
use
has
become
widespread
in
recent
years.
The
use
of
1
to
3
sprays
is
claimed
to
provide
an
observable
improvement
in
slowing
development
of
debilitating
levels
of
LPTB
(
1
to
3
sprays
depending
on
the
season
of
ripening,
with
1
for
early
varieties
and
3
for
full
season
varieties).

According
to
crop
experts,
pheromone
mating
disruption
for
LPTB
has
promise,
but
it
is
not
ready
for
commercial
use
in
the
Southeast
(
Horton,
personal
communication).
Mating
disruption
works
well
on
peach
tree
borer
complex
further
north.
However,
several
years
of
work
in
Georgia
has
shown
that
even
elevated
application
rates
(
4
pheromone­
dispensing
ties
per
tree)
may
be
insufficient
against
heavy
infestations
of
LPTB
in
the
Southeast.
Further
research
on
LPTB
mating
disruption
is
planned
for
2005.
Researchers
and
growers
are
asking
for
an
extension
on
AZM
cancellation
while
tests
of
new
and
promising
alternatives
against
LPTB
proceed.

In
New
Jersey
peaches,
AZM
is
used
to
control
numerous
insect
pests
including
the
Oriental
fruit
moth,
tarnished
plant
bug,
various
species
of
stink
bugs,
leafrollers,
plum
curculio,
San
Jose
scale
and
white
peach
scale
and
borers.
NJ
growers
typically
apply
1­
1.25
lbs
of
product
per
acre
per
application,
and
point
out
that
these
rates
are
well
below
the
maximum
label
rate.
They
further
state
that,
since
most
mid­
Atlantic
growers
apply
sprays
using
the
alternate
 
row­
middle
technique,
only
0.5­
0.63
lbs
are
typically
applied
per
acre
per
spray.
Of
the
pests
listed
above,
the
San
Jose
scale
(
SJS),
Quadraspidiotus
perniciosus,
and
the
Oriental
fruit
moth
(
OFM),
Grapholitha
molesta,
are
the
critically
important
targets
mentioned
by
stakeholders
as
the
basis
for
their
request
for
AZM
retention.

Finally,
some
northwestern
US
growers
(
primarily
from
Oregon
and
Washington),
as
represented
by
the
Northwest
Horticultural
Council,
have
also
requested
AZM
be
retained
mainly
for
use
against
the
peach
twig
borer,
Anarsia
lineatella
(
PTW),
also
a
clear­
winged
moth.
8
BEAD's
assessment
of
stakeholder
comments
and
changes
in
benefits
of
AZM
For
southeastern
peaches,
BEAD
believes
that
some
growers
may
face
yield
losses
due
to
the
LPTB
in
the
absence
of
AZM
as
a
control
option.
The
extent
of
these
yield
losses
cannot
be
determined
reliably
at
the
present
time,
since
pest
populations
are
still
being
assessed,
and
alternatives
with
some
promise
against
similar
insects,
such
as
novaluron
and
thiamethoxam,
have
not
yet
been
evaluated
or
registered
for
peaches.
LPTB
can
be
controlled
to
some
extent
with
dormant­
season
applications
of
chlorpyrifos
or
growing­
season
applications
of
either
esfenvalerate
or
endosulfan
(
Brannen
et
al.
2005).
Chlorpyrifos
(
with
or
without
horticultural
oil)
will
probably
offer
good
control
of
overwintering
LPTB
larvae,
albeit
with
higher
costs
because
all
scaffold
limbs
(
and
not
just
the
trunk)
of
trees
will
have
to
be
treated.

Since
the
LPTB
has
multiple
generations
per
year
in
the
southeast,
damage
to
productive
tree
limbs
during
in­
season
will
probably
require
control
outside
the
dormant
season.
The
pest
management
goal
is
to
keep
the
LPTB
from
damaging
as
much
productive
peach
wood
(
flower
and
fruit
bud
producing
branches
for
the
following
season)
as
is
possible.
Orchards
that
have
high
populations
of
LPTB
in
the
previous
year
will
show
dead
and
dying
branches,
reduced
flower
buds,
and
a
reduction
in
fruit
number
and
size
in
the
following
summer.
Size
is
important
in
fresh
market
fruit;
the
greater
the
size,
the
greater
the
profit.

To
control
high
populations
of
LPTB
during
the
growing
season,
reliance
on
esfenvalerate
(
a
synthetic
pyrethroid)
probably
cannot
be
increased
significantly
without
increasing
the
risk
of
secondary
pest
outbreaks
(
of
scales
and
mites).
Increased
use
of
endosulfan
(
an
organochlorine
insecticide),
the
only
other
recommended
foliar
insecticide,
also
may
not
be
a
viable
option
due
to
grower
concerns
about
environmental
and
health
effects.
However,
given
the
lack
of
information
on
the
peach
acreage
sensitive
to
in­
season
damage
by
LPTB
and
the
uncertain
efficacy
of
dormant­
season
control
of
apparently
increasing
pest
populations,
BEAD
cannot
make
an
accurate
quantitative
assessment
of
the
impact
of
the
loss
of
AZM
as
a
potential
control
option
for
this
insect
in
the
southeast.

For
scale
insects
in
New
Jersey,
BEAD
believes
that
dormant
oil
and
newly
registered
materials,
including
pyriproxyfen
and
buprofezin,
are
adequate
substitutes
for
control
in
the
absence
of
AZM.
For
the
OFM
(
the
other
critical
northeastern
pest),
effective
alternatives
also
appear
to
exist.
These
include
mating
disruption
using
pheromone­
treated
ties
and
methoxyfenozide,
a
reduced
risk
pesticide
recently
registered
in
this
crop.
Indoxacarb
has
also
shown
good
efficacy,
and
its
registration
is
pending
for
peaches.

The
pest
management
value
of
these
materials
as
part
of
a
larger
set
of
newer
insecticides
was
recently
demonstrated
by
a
study
funded
by
the
USDA
Risk
Avoidance
and
Mitigation
Program
(
RAMP).
This
study
was
conducted
in
2002­
2004,
under
the
directorship
of
Drs.
Peter
Shearer
and
A.
Atanassov
of
Rutgers
University.
Eight
peach
9
orchards
on
four
farms
were
used
each
year
to
study
the
implementation
of
reduced­
risk
arthropod
management
practices.

The
study
sites
were
approximately
10­
40
acres
in
size.
Each
study
site
was
divided
into
two
blocks
and
assigned
one
of
two
treatments;
1)
"
RAMP",
¸
in
which
pests
were
managed
with
reduced
risk
chemicals
(
such
as
Indoxacarb
and
methoxyfenozide)
and
mating
disruption
(
for
OFM,
PTB,
and
LPTB),
and
2)
"
conventional",
in
which
pests
were
managed
with
broad
spectrum
insecticides,
such
as
AZM,
phosmet,
and
esfenvalerate.
In
all
years
and
most
farms,
scale
and
OFM
damage
appeared
to
be
adequately
controlled
in
the
"
RAMP"
treatments.
However,
the
cost
of
the
products
used
to
control
arthropods
was
considerably
higher
for
the
RAMP
treatments
 
up
to
three
times
higher
than
the
conventional
treatments
in
some
farm/
year
combinations.

Thus,
while
effective
alternatives
exist
for
these
pests,
production
costs
will
probably
go
up
in
the
absence
of
AZM,
though
in
an
unpredictable
manner,
since
over
the
longer
term,
the
cost
of
most
insecticides
tends
to
decline,
and
growers
will
probably
not
need
to
control
all
target
insects
every
year.

For
northwestern
peach
growers
facing
the
PTW,
BEAD
has
identified
the
following
registered
alternatives:
carbaryl,
chlorpyrifos,
esfenvalerate,
horticultural
oil,
lambda­
and
gamma­
cyhalothrin,
malathion,
methidathion,
permethrin,
and
spinosad.
At
least
one
state
(
Oregon)
in
the
region
recommends
oil
mixed
with
either
diazinon
or
spinosad
as
the
main
control
options
for
PTW
(
Olsen
and
Pscheidt
2005).
Therefore,
as
in
2001,
BEAD
believes
that
growers
should
be
able
to
use
these
alternatives
in
place
of
AZM
for
control
of
this
insect.

Potatoes
Summary
of
BEAD's
2001
benefits
assessment
In
2001,
based
on
available
published
data
and
personal
communications
with
crop
experts,
BEAD
believed
that
the
impacts
resulting
from
extending
the
REIs
(
to
seven
days,
as
was
proposed)
on
potatoes
for
AZM
would
be
insignificant.
BEAD
analysts
arrived
at
this
conclusion
based
primarily
on
the
fact
that
worker
activities
were
not
likely
to
be
affected
by
the
extension
of
the
restricted
entry
intervals.
If
for
some
reason
grower
production
practices
were
significantly
impacted
by
an
extension
of
the
REIs,
BEAD
determined
that
they
would
be
replaced
with
one
of
several
efficacious
and
similarly
priced
alternatives.
Imidacloprid,
carbofuran,
permethrin,
and
phorate
were
available
and
apparently
preferred
by
many
growers
for
use
against
the
key
target
pest,
the
Colorado
potato
beetle
(
CPB).
While
AZM
was
used
against
some
other
insects,
particularly
flea
beetles,
leafhoppers,
and
aphids
(
various
species),
approximately
80
%
of
AZM
use
was
targeting
CPB.
BEAD
determined
that
insects
other
than
CPB
that
were
targeted
with
AZM
also
had
effective
alternatives,
including
imidacloprid,
methamidophos,
and
permethrin.
10
Summary
of
stakeholder
comments
or
concerns
regarding
expiry
of
AZM
registration
In
2001,
The
National
Potato
Council
asked
to
continue
use
of
AZM
on
potatoes.
In
this
context,
it
may
be
useful
to
note
that
this
use
was
originally
listed
in
Group
1
(
cancellation
without
a
phase­
out).
Because
of
comments
received
during
the
iRED
publication
phase,
potatoes
were
moved
to
Group
2
(
cancellation
with
a
4­
year
phaseout
The
current
label
allows
for
use
in
the
Columbia
River
Basin
or
Washington
state
only.
The
National
Potato
Council
has
requested
to
expand
the
use
to
include
Colorado
and
the
Mid
Atlantic
region.
A
recent
request
to
retain
the
AZM
potato
use
in
the
Columbia
River
Basin
has
also
been
received
from
the
Washington
State
Potato
Commission.
The
Potato
Council
claims
that
growers
need
AZM
to
control
Colorado
potato
beetles
(
CPB)
in
all
areas,
as
well
as
a
pest
new
to
the
northwest,
the
potato
tuber
moth,
Phthorimaea
operculella,
(
PTW).
In
this
context,
the
Potato
Council
also
claims
that
AZM
is
necessary
for
control
of
CPB
without
generating
mite
outbreaks
in
Pacific
Northwest
(
PNW)
potatoes,
where
the
beetle
has
not
yet
developed
resistance
to
organophosphates
(
OPs).

The
PTW
sporadically
damages
tubers
in
the
field
and
also
propagates
in
storage
bins
and
damages
harvested
tubers
there.
It
is
a
long
standing
pest
of
potatoes
in
South
America,
and
occasionally
becomes
a
serious
pest
in
California
as
well.
The
Potato
Council
indicated
that
they
are
not
certain
how
widespread
this
pest
is
in
PNW
potatoes,
nor
whether
AZM
is
the
most
efficacious
control
option
available.

BEAD's
assessment
of
stakeholder
comments
and
changes
in
benefits
of
AZM
As
in
its
2001
benefits
assessment,
BEAD
believes
that
CPB
can
be
effectively
controlled
with
a
number
of
other
products
already
available,
including
synthetic
pyrethroids
such
as
bifenthrin,
and
neonictonoids
such
as
imidacloprid.
Thiamethoxam,
a
newer
neonicotinoid
(
i.
e.,
the
same
chemistry
as
imidacloprid)
has
also
been
registered
on
potato
since
2001.
A
suite
of
OPs
and
carbamates,
all
with
CPB
listed
as
being
controlled
on
their
labels,
continue
to
be
registered
on
potatoes,
at
least
for
the
short
term.
These
include
aldicarb,
carbofuran,
endosulfan,
esfenvalerate,
methamidophos,
permethrin,
phorate,
and
methyl
parathion.
BEAD
believes
that
judicious
use
of
the
neonicotinoids,
along
with
OPs
still
available,
such
as
methamidophos,
and
cultural
controls
such
as
removal
of
refugia
and
crop
rotation
should
continue
to
provide
adequate
protection
against
CPB
for
potatoes
in
the
absence
of
AZM.

Further,
BEAD
notes
that
CPB
is
notorious
for
its
propensity
to
develop
resistance
to
OPs,
and
AZM
use
can
reasonably
be
said
to
be
limited
by
that
factor
alone.
While
CPB
populations
in
the
PNW
region
have
not
yet
developed
such
resistance,
alternatives
to
AZM
do
appear
to
currently
exist
and
of
these,
at­
plant
applications
of
neonictonoids
should
control
most
CPB
infestations
through
most
of
the
growing
season.
An
unknown
number
of
growers
may
need
to
make
additional
treatments
for
CPB
later
in
the
season.
Based
on
the
very
low
current
usage
of
AZM
in
the
region
(
see
below)
the
proportion
of
growers
thus
affected
is
arguably
low.
Indeed,
it
is
not
clear
to
BEAD
why
growers
outside
the
PNW
would
rely
on
AZM
given
that
most
of
the
U.
S.
potato
11
production
community
has
been
notified
by
University
extension
services
that
CPB
can
develop
OP
resistance
quickly.

In
this
context,
the
latest
figures
show
that
nationally
3,900
pounds
(
on
average)
of
AZM
are
applied
annually
to
the
entire
U.
S.
potato
crop.
The
proportion
of
the
crop
treated
with
AZM
ranges
from
2
­
3%
nationally.
There
has
been
a
modest
decline
since
2001,
in
terms
of
the
pounds
applied
annually.
In
the
PNW,
EPA
usage
data
indicate
that
less
than
1
%
of
the
potato
acreage
was
treated
in
2002
and
2003.

For
PTW,
BEAD
notes
that
foliar
insecticides
such
as
AZM
only
kill
the
adult
moths,
which
are
not
the
tuber
damaging
life
stage.
While
such
insecticides
may
reduce
damage
by
killing
female
moths
before
they
lay
eggs,
it
appears
that
growers
in
other
regions
where
this
insect
is
a
problem
rely
more
on
cultural
control,
such
as
destroying
culled
potatoes
and
volunteer
plants
in
fields
(
which
removes
overwintering
refugia),
or
using
sprinkler
irrigation
to
reduce
soil
cracking
(
Godfrey
et
al.
2003).
Soil
cracking
allows
moths
to
reach
tubers
more
easily,
and
furrow
irrigated
fields
are
much
more
vulnerable.
A
search
of
extension
service
materials
available
on
the
internet
for
both
U.
S.
and
South
American
potato
production
did
not
reveal
any
publications
or
researchers
specifically
recommending
AZM
as
an
effective
treatment
for
PTW.

The
University
of
California,
which
discusses
this
pest
at
some
length,
lists
methomyl,
methamidophos,
and
esfenvalerate
as
recommended
insecticide
options
for
suppressing
adult
PTW
(
Godfrey
et
al.
2003).
In
light
of
these
findings,
low
current
usage
of
AZM
in
the
PNW,
and
lacking
quantitative
evidence
to
the
contrary,
BEAD
does
not
believe
that
PTW
is
currently
a
compelling
need
for
retaining
AZM
use
in
potatoes.
BEAD
acknowledges
that
there
may
be
a
niche
for
AZM
use
among
some
growers
who
face
high
levels
of
multiple
pests
(
aphids,
CPB,
and
PTW)
throughout
the
season.
In
these
cases,
the
alternative
insecticides
available
may
be
assigned
in
such
a
way
as
to
create
a
situation
where
AZM
has
no
practical
replacement.
However,
the
number
of
growers
facing
such
a
situation
is
arguably
low,
given
the
very
low
current
usage
of
AZM
in
PNW
potatoes.
However,
for
the
longer
term,
BEAD
suggests
that
stakeholders
explore
efficacy
of
reduced
risk
materials
such
as
indoxacarb
and
novaluron,
as
well
as
registered
neonicotinoids
such
as
thiamethoxam,
since
these
have
shown
promise
against
other
caterpillar
pests
in
other
crops
(
e.
g.,
Wise
et
al.
2004,
Mangini
2003a,
b).

Southern
Pine
Seed
Orchards
Summary
of
BEAD's
2001
benefits
assessment
Based
on
expert
comment
and
published
research,
BEAD
concluded
that
there
would
be
significant
grower­
level
impacts,
impacts
on
the
seed
industry,
and
on
supplies
of
the
seeds
if
both
AZM
and
phosmet
(
the
best
alternative,
which
was
also
undergoing
registration
review
at
that
time)
were
simultaneously
removed
from
use.
The
key
pests
are
coneworms
(
four
species
of
moths
in
the
genus
Dioryctria)
and
seed
bugs
(
two
species
of
true
bugs,
order
Heteroptera).
Together,
these
insects
can
attack
the
flowers,
12
developing
cones,
or
mature
cones
(
Ebel
et
al.
1980).
Thus,
they
cause
both
direct
yield
reductions
and
reductions
in
the
quality
of
the
harvested
seed.
A
major
factor
driving
AZM
benefits
was
that
southern
pine
seed
was
estimated
to
be
worth
$
2,917
per
lb.
(
based
on
the
discounted
value
of
future
seed
and
trees
produced
from
these
seeds).
The
value
of
the
seed
has
remained
near
$
3,000
per
pound
since
2001
(
Mangini,
Byram,
and
Taylor,
personal
communication).

Impacts
to
national
gross
revenue
for
pine
seed
producers
were
estimated
to
range
from
$
105
million
to
$
245
million
annually.
This
estimate
was
based
on
the
assumptions
that
(
1)
southern
pine
seed
yield
losses
of
30­
70
%
are
realized
without
effective
control
of
the
key
pests
in
the
absence
of
AZM,
and
(
2)
replanting
costs
and
the
losses
due
to
the
lag
to
regenerate
production
are
not
included.

In
2001,
small­
scale
efficacy
tests
(
on
single
trees)
suggested
that
phosmet,
soon
to
be
registered
on
this
crop
at
that
time,
could
provide
acceptable
control
of
the
key
pests.
On
the
basis
of
these
tests,
BEAD
also
concluded
that
growers
might
not
face
the
negative
impacts
as
long
as
phosmet
was
available.
BEAD
also
estimated
that
(
assuming
equivalent
efficacy)
the
use
of
phosmet
instead
of
AZM
would
result
in
a
savings
of
approximately
$
10,000
in
control
costs
based
on
the
total
application
cost
difference
of
$
1/
acre
between
AZM
and
Phosmet.
BEAD
analysts
cautioned
that
this
was
a
tentative
scenario
since
the
effectiveness
of
phosmet
on
coneworms
and
seed
bugs
was
in
a
single
tree
treatment
and
large
scale
control
had
not
yet
been
definitively
evaluated.

Summary
of
stakeholder
comments
or
concerns
regarding
expiry
of
AZM
registration
Crop
experts
and
grower
groups
state
that
a
larger
scale
study
of
phosmet
failed
to
show
the
high
levels
of
efficacy
that
the
single
tree
studies
suggested
(
Mangini,
Byram,
and
Taylor,
personal
communication,
Mangini
2002).
This
study,
conducted
across
four
seed
orchards
in
the
southern
U.
S.,
showed
that
neither
phosmet
nor
bifenthrin
(
a
synthetic
pyrethroid)
improved
yield
in
terms
of
either
the
number
of
seeds
per
cone,
or
survival
of
mature
cones
(
ready
for
harvest)
significantly,
as
compared
to
the
untreated
control.
AZM
was
not
simultaneously
evaluated
in
that
study
(
Mangini
2002).

Currently,
orchard
managers
use
sequential
sprays
of
a
synthetic
pyrethroids
(
esfenvalerate
or
permethrin)
and
AZM
to
control
the
two
key
pests.
Multiple
insecticide
applications
are
claimed
to
be
necessary
because
both
key
pests
have
multiple
generations
per
year,
and
can
damage
all
stages
of
the
developing
cones
(
Barber
et
al.
1989).
Typically,
synthetic
pyrethroids
are
sprayed
only
once
to
minimize
their
disruption
of
beneficial
insect
populations
(
predators
and
parasitoids)
that
control
scale
insects.
AZM
applications
are
necessary
later
in
the
season.
Stakeholders
note
that,
since
2001,
they
have
been
successfully
using
AZM
at
a
lower
rate
and
fewer
applications
per
season.
Rates
are
now
at
1.5
lb
a.
i./
acre
(
vs.
3
lb/
acre
before
2001),
and
the
maximum
number
of
applications
are
three
per
season,
as
opposed
to
five
prior
to
2001.
13
BEAD's
assessment
of
stakeholder
comments
and
changes
in
benefits
of
AZM
Based
on
the
available
literature,
conference
calls
with
crop
experts,
and
an
examination
of
the
results
of
the
larger
scale
efficacy
study
of
phosmet
(
described
in
the
previous
section),
BEAD
believes
that
the
potential
for
a
significant
negative
impact
on
southern
pine
seed
production
continues
to
exist,
if
AZM
is
removed
from
this
crop
as
a
seed
pest
management
tool.
Phosmet
cannot
be
relied
upon
to
provide
the
same
level
of
efficacy
as
AZM,
and
increased
pyrethroid
use
cannot
be
substituted
for
AZM
indefinitely,
due
to
their
disruption
of
scale
insect
control,
lower
residual
efficacy,
and
the
inevitable
increase
in
resistance
to
these
insecticides.
In
the
near
future,
however,
pyrethroids
will
probably
control
the
target
pests.

Recent
efficacy
studies
conducted
on
multiple­
tree
plots
indicate
that
a
combination
of
tebufenozide
(
a
reduced
risk
insecticide,
sold
as
Mimic
TM)
and
esfenvalerate
(
Asana
TM)
provides
acceptable
control
of
coneworms
(
Mangini
2003a).
Similar
studies
showed
that
thiamethoxam
(
Actara
TM),
a
neonicotinoid,
provides
acceptable
control
of
seed
bugs,
and
indoxacarb
(
Steward
TM)
also
works
well
against
coneworms
(
Mangini
2003b).

Unfortunately,
none
of
these
materials
is
currently
registered
for
use
in
pine
seed
orchards,
and
apparently,
registrants
have
not
yet
expressed
interest
in
pursuing
registrations.
Unless
these
promising
alternatives
are
made
available
to
growers,
BEAD
believes
that
there
may
be
economic
losses
in
the
long
term
if
AZM
is
removed
as
a
pest
control
option
for
pine
seed
orchards.

CONCLUSION
BEAD
has
evaluated
the
main
stakeholder
comments
on
the
Group
2
uses
within
the
constraints
imposed
by
the
timeframe
for
AZM
cancellation
as
stated
in
the
iRED.
The
results
of
these
evaluations
indicate
that
in
the
absence
of
AZM,
growers
should
have
viable
alternatives
(
for
the
critical
target
pests
cited
in
stakeholder
comments)
in
all
crops,
at
least
in
the
near
term.
However,
important
caveats
should
be
mentioned
when
stating
this
conclusion
for
some
of
the
crops
involved.
In
caneberries
and
southern
pine
seeds,
growers
will
have
only
one
alternative
insecticide
or
class
of
chemistry
to
rely
on
without
AZM;
this
can
be
expected
to
increase
the
selection
pressure
for
resistance
to
develop
in
the
target
insects
to
an
unknown
extent.

In
peaches,
while
scale
and
OFM
have
effective
new
alternatives
as
well
as
viable
older
alternatives
available,
the
overall
cost
of
control
will
probably
go
up
in
the
absence
of
AZM.
The
LPTB
is
a
pest
that
is
apparently
increasing
its
numbers
and
damage
in
southeastern
peaches,
in
particular.
While
there
is
a
dormant­
season
control
(
chlorpyrifos)
and
a
few
in­
season
alternatives
(
esfenvalerate
and
endosulfan),
these
have
their
own
risk
concerns
or
pest
management
constraints
(
secondary
pest
outbreaks).
Thus,
while
in
the
short
term
these
alternatives
may
provide
some
control
of
LPTB,
the
loss
of
14
AZM
may
contribute
to
a
long
term
increase
in
yield
losses
due
to
this
insect
that
is
unsustainable
for
growers.

However,
given
the
lack
of
information
on
the
amount
of
acreage
affected
by
the
damage
inflicted
by
this
pest
or
on
efficacy
of
AZM
or
registered
and
potential
alternatives
as
in­
season
control
options,
BEAD
cannot
quantify
the
extent
of
negative
impacts
of
LPTB
in
the
absence
of
AZM.
Given
the
uncertainties
associated
with
these
crops,
BEAD
suggests
that
promising
alternatives
(
described
in
the
crop
discussions
above)
be
given
registration
priority
wherever
possible
to
minimize
pest
impacts
to
this
crop,
if
and
when
AZM
use
is
removed.

Finally,
for
cranberries,
while
other
adequate
alternatives
appear
to
be
available,
BEAD
notes
that
growers'
use
of
methoxyfenozide
(
which
may
be
the
most
practical
and
effective
option)
is
hampered
by
the
buffer
restriction
on
its
label.
In
potatoes,
while
the
arrival
of
the
potato
tuber
worm
in
the
PNW
does
not
currently
appear
to
be
a
compelling
reason
to
retain
AZM
use,
BEAD
recognizes
that
there
is
a
long
term
need
for
stakeholders
and
regulators
to
explore
the
efficacy
of
reduced
risk
alternatives,
as
well
as
pest
management
strategies
in
the
broader
sense.

INFORMATION
SOURCES
Anonymous.
2004.
Cranberry
Station
Newsletter,
December
2004.
A
publication
of
the
University
of
Massachusetts,
Amherst,
MA.
Available
on
the
web
at
http://
www.
umass.
edu/
cranberry.

Brannen,
P.,
Horton,
D.,
Bellinger,
B.,
and
Ritchie,
D.
(
editors).
2005.
Southeastern
Peach,
Nectarine,
and
Plum
Pest
Management
Guide.
Bulletin
#
1171
of
the
University
of
Georgia
Cooperative
Extension
Service.
Available
on
the
web
at:
http://
entomology.
ent.
uga.
edu/
peach/
peach_
guide/
title.
htm
Barber,
L.
R.,
Cordell,
C.
E.,
Anderson,
R.
L.,
Hoffard,
W.
H.,
Landis,
T.
D.,
Smith,
R.
S.,
and
Toko,
H.
V.
1989.
Seed
and
Cone
Insects.
In:
Forest
Nursery
Pests.
USDA
Forest
Service
Agriculture
Handbook
No.
680.
184
pp.

DeFrancesco,
J.
Personal
communications
via
e­
mail
to
EPA/
OPP/
BEAD,
March
1­
25,
2005.

Dittl,
T.
2000.
Fruitworm
Management:
Wisconsin
Insecticide
Trials.
2000.
PowerPoint
presentation
e­
mailed
to
Diane
Isbell,
EPA/
OPP/
SRRD.

Ebel,
B.
H.,
Flavell,
T.
H.,
Drake,
L.
E.,
Yates,
H.
O.,
and
DeBarr,
G.
L.
1980.
Seed
and
cone
insects
of
southern
pines.
U.
S.
DA
Forest
Service
Gen.
Tech.
Rep.
SE­
8,
revised.
43
pp.
15
Environmental
Protection
Agency.
2001.
Caneberry
Biological
and
Economic
Benefits
Assessment
for
Azinphos­
methyl.
W.
Chism
and
S.
Smearman.

Environmental
Protection
Agency.
2001.
Cranberry
Benefits
Assessment
for
Azinphosmethyl
and
Phosmet
Related
to
Proposed
Occupational
Risk
Mitigation.
W.
Chism
and
S.
Smearman.

Godfrey,
L.
D.,
and
Haviland,
D.
R.
2003.
UC
Pest
management
Guidelines:
Potato
tuberworm.
UC
ANR
Publication
#
3463.
Available
on
the
web
at
http://
www.
ipm.
ucdavis.
edu/
PMG/
selectnewpest.
potatoes.
html.

Horton.
D.
Professor,
Department
of
Entomology,
University
of
Georgia,
Athens,
GA.
Personal
communication
to
EPA/
OPP/
BEAD
via
telephone
and
e­
mail,
March
1
 
30,
2005.

Johnson,
D.
and
Lewis,
B.
A.
2002.
Insecticide
efficacy
trails
for
raspberry
crown
borer
on
blackberry.
Study
C2
in:
Arthropod
Management
Tests
2003.
Available
on
the
web
at
www.
entsoc.
org.

Mahr,
D.
L.,
Roper,
T.
R.,
McManus,
P.
S.,
and
Flashinski,
R.
A.
2005.
Cranberry
Pest
Mangement
in
Wisconsin.
Pub.
#
A3276
of
the
University
of
Wisconsin
Extension
Service.

Mangini,
A.
2002.
Southwide
Imidan
Eficay
Study.
Unpublished
data
summary,
communicated
via
e­
mail
from
A.
Mangini
to
EPA/
OPP/
BEAD
on
March
24,
2005.

Mangini,
A.
2003a.
A
pilot
test
of
tebufenozide
(
Mimic
TM
2LV)
combined
with
esfenvalerate
(
Asana
TM
XL)
for
control
of
seed
and
cone
insects
of
loblolly
pine;
includes
an
efficacy
test
of
thiamethoxam
(
Actara
TM).
Unpublished
manuscript
from
the
U.
S.
DA
Forest
Service,
Pineville,
LA.

Mangini,
A.
2003b.
A
pilot
test
of
tebufenozide
(
Mimic
TM
2LV)
and
indoxacarb
(
Steward
TM)
for
control
of
seed
and
cone
insects
of
loblolly
pine.
Unpublished
manuscript
from
the
U.
S.
DA
Forest
Service,
Pineville,
LA.

Mangini,
A.,
Byram,
T.
D.,
and
Taylor,
J.
Personal
communications
via
teleconference
and
e­
mail
to
EPA/
OPP/
BEAD,
March
1
­
22,
2005.

NASS,
2000.
Cranberries.
National
Agricultural
Statistics
Service,
Agricultural
Statistics
Board,
U.
S.
Department
of
Agriculture.

Olsen,
J.
L.
and
Pscheidt,
J.
W.
2005.
Peach
Pest
Management
Recommendations.
A
publication
of
the
Oregon
State
University
Extension
Service.
Available
on
the
web
at:
http://
eesc.
orst.
edu/
agcomwebfile/
edmat/
html/
EM/
EM8419/
EM8419.
html
16
Pfeiffer,
D.
G.,
Yoder,
K.
S.,
and
Bergh,
C.
2005.
Diseases
and
Insects.
Pp.
47­
66
In:
2005
Pest
Management
Guide:
Horticultural
and
Forest
Crops.
Publication
No.
456­
017
of
the
Virginia
Cooperative
Extension
Service.
Available
on
the
web
at:
http://
www.
ext.
vt.
edu/
pubs/
pmg/
index.
html
USDA.
1998.
Crop
Profile
for
Cranberries
in
Wisconsin.
K.
A.
Delahaut
and
S.
E.
R.
Mahr.
Available
on
the
web
at
http://
ipmcenters.
org.

USDA
1999.
Crop
Profiles
for
Raspberries
and
Blackberries
in
Oregon.
Prepared
by
P.
Thomson,
W.
Parrott,
and
J.
Jenkins.
Available
on
the
web
at
http://
ipmcenters.
org.

USDA
2003.
Pest
Management
Strategic
Plan
for
Pacific
Northwest
caneberries.
Available
on
the
web
at
http://
ipmcenters.
org.

Wise,
J.
C.,
Gut,
L.
J.,
Isaacs,
R.,
and
Schilder,
A.
2004.
Tree
and
Small
Fruits
Insecticide/
fungicide
Evaluation
Studies.
A
publication
of
the
Michigan
Agriculture
Experiment
Station,
Michigan
State
University,
East
Lansing,
MI.
