PPDC AZM Transition Issues Workgroup 

March 6, 2007 MEETING SUMMARY

Introductions 

Co-chairs:	Rick Keigwin, Director, Biological and Economic Analysis
Division (BEAD), Office of Pesticide Programs (OPP), EPA

Al Jennings, Director, Office of Pest Management Policy (OPMP), USDA

Designated Federal Official:  Linda “Pineapple” Murray, EPA/OPP/BEAD

Members of the AZM Transition Issues Workgroup

Rick Keigwin and Al Jennings started the meeting with introductions of
the workgroup members present in Potomac Yard and on the phone.  Linda
Murray gave an overview of the FACA requirements for this workgroup. 
She informed the group that the meeting summary will be docketed.

Rick Keigwin noted that the meeting summary will be posted to OPP’s
PPDC website and the meeting summary and attendance list will be posted
to AZM docket [located at   HYPERLINK "http://www.regulations.gov" 
http://www.regulations.gov  under docket number EPA-HQ-OPP-2005-0061].

Rick Keigwin also noted that litigation on the AZM decision has been
reinstated.  He informed the group that the purpose of the meeting was
not to discuss the merits of the decision or the lawsuit.  The purpose
of the meeting is to come together to work on transition.  The workgroup
will discuss new products, trade issues, Codex, and ways to ensure that
there are MRLs in key export markets, as well as to discuss technical
barriers to an effective transition.  EPA is in the process of doing a
chemical / crop matrix for the workgroup.

Discussion on the purpose of the meeting was opened by Larry Elworth of
the Center for Agricultural Partnerships.  He said that the purpose
should be to transition to something that works, not necessarily away
from AZM.  He said that the transition should be to a specific
destination, and that we should have a picture in mind of what the
destination will look like.  

Carol Dansereau of the Farm Worker Pesticide Project said that she has a
similar perspective as Larry Elworth.  She works with workers that are
exposed to AZM, and would like to know what workers will be exposed to
instead of AZM. 

Rebeckah Adcock of the American Farm Bureau noted that the definition of
“transition” and “alternative” should be clear and that the
definitions may differ depending on point of view.  EPA views certain
products as alternatives.  In practice for growers these products do not
work well and thus are not viable alternatives.  She noted that if some
of the alternatives listed do not work well, they are not real
alternatives from the perspective of farm communities.  She also noted
that it is not intentional on EPA’s part that alternatives to AZM are
also on the chopping block.  

Mark Whalon of Michigan State University advocated for the importance of
transition tools for cherries, apples, and peaches.  Tart cherries have
a larger problem than other fruits, and if EPA moves ahead as is now
planned, tart cherries will not have alternatives.  Plum curculio is the
main pest for tart cherries and there are no transition pesticides for
tart cherries.  Apples (in Michigan) are in better shape with regards to
alternatives, but growers will need some help.  There are more new
pesticidal tools coming downstream for the Lepidoptera pests. 

Michael Fry of the American Bird Conservancy said that the transition
away from nonspecific highly toxic pesticides was an important aspect of
FQPA.  It has been 11 years since FQPA was enacted and it is unfortunate
that there are not alternatives.  He asked the group, “Should the
transition be to more pest-specific pesticides?”  He said that the
transition away from nonspecific pesticides was an important aspect of
this workgroup, and this should be the way industry transitions from
other broad-spectrum pesticides.  He said that alternatives to
broad-spectrum pesticides are needed, but that the group should look
into natural predator populations as a control method also.  

Barbara VanTil, Strategic Agriculture Initiative, EPA Region 5 said that
the transition should be towards strategies instead of specific
chemicals.  The group should look at whole systems and not just consider
the situation chemical by chemical.  

Co-chair of the committee, Al Jennings of USDA/OPMP asked, “How do you
rebuild ag systems that were built on AZM?  What are the alternative
systems?  This is not a situation of losing chemical A, and substituting
chemical B.”  

Paula Paul of DuPont Crop Protection mentioned that the more specific a
chemical is to certain pests, the more likely it is to have resistance
problems.  

Jim Cranney of the US Apple Association said that FQPA was more about
the process by which chemicals are reviewed.  He noted that we are not
here today to remove any specific chemistry from the lineup of
pesticides.  

Rick Keigwin stated that FQPA was about ensuring safety and reassessing
tolerances and does not say specifically that certain classes of
chemicals need to go away.  

Lori Berger of the California Minor Crop Council said that on the
research side, the cooperative extension service really needs to take
new information to the field and make it usable on a field level.  She
said that the group would need to look at the infrastructure needed to
support transition by extension, research, consultants, and grower
groups.  She also said that the group should consider alternatives that
work for both small growers and for “main-stream” agriculture.  

Larry Elworth spoke of a specific use for AZM in tree fruit programs in
Pennsylvania.  Half rates of AZM applied in alternate row sprays
provided insect control and preserved beneficial species that helped
control European red mites.  He asked about the methodology for the
transition in general.  

Rick Keigwin noted in response to this question that the chairs had
asked themselves, should we focus first on process, then AZM, or AZM and
then process?  Lessons learned from this group can be applied to other
chemicals.  This group will look first at AZM specifically, and then
look at how the processes reached with this group can be applied to
other chemicals. 

Carol Dansereau mentioned that when laying out objectives of the
workgroup, the members only mentioned helping the user community and
that she hopes that mitigation, e.g., buffer zones and ratcheting down
rates, will also be discussed.  She would like to talk about how and
when these mitigation measures will be implemented.  

Rick Keigwin responded that OPP will be working on mitigation
implementation and that the primary focus of this group is to talk about
user transition.  There may be opportunities to talk about other
mitigation measures in this group, and there are other opportunities to
talk about the mitigation measures also.  

Overview

Margaret Rice of EPA/OPP Special Review and Reregistration Division
(SRRD) gave the group an overview of the AZM Final Decision document
that was published on November 16, 2006.  She noted that most of what
she was to say is information also available in the AZM Fact Sheet,
which is available on the EPA website.  AZM has a long regulatory
history.  The 2001 AZM Interim Reregistration Eligibility Decision
(IRED) divided AZM uses into three different groups.  The first two
groups were comprised of uses that were phased out by 2006.  The uses in
the other group, group 3, were to be revisited.  These were uses that
posed high risk, and had high benefits to their use.  EPA issued a
proposed decision for these uses in June, and issued a final decision in
November.  Listening sessions were held with key members of the AZM
team, including OPPTS Assistant Administrator Jim Gulliford, and growers
and other stakeholders.  There were some key comments that contributed
to the risk management decision such as comments received on exposure to
residents, workers, and their families living in or near orchards,
particularly in the northwest.  Also, new information from the United
States Geological Society (USGS) showed continuing AZM detections in
surface water at levels exceeding the EPA Level of Concern (LOC) for
aquatic life.  

Benefits - some chemicals that had been in the pipeline as alternatives
to AZM had been registered by 2005.  However, even with these new
registrations, the percent crop treated with AZM hadn’t changed much
between 2001 and 2006.  This showed that growers had not been moving to
alternatives.  Comments from USDA and other stakeholders noted that
Maximum Residue Levels (MRLs) had not been established for alternatives
in key markets.  Historically, it has taken 6 years or longer to
establish MRLs.  There is a need to establish MRLs more quickly. 
Several commenters on the AZM decisions noted that the new alternatives
need to be applied on a more specific time frame than the older,
broad-spectrum pesticides and growers needed time to learn the
techniques associated with these new alternatives.

The AZM decision allows for a graduated phase-out.  Nursery stock and
Brussels sprouts will be phased out by September 2007.  Almonds,
pistachios, and walnuts will be phased out by October 2009.  Apples,
cherries, pears, blueberries, and parsley will be phased out by
September 2012.  The group to be phased out in 2012 is further
restricted by a graduated reduction in annual maximum application rates.
 The crop specific limitations were established to ensure that the phase
out is truly a phase out.  Growers told the Agency that they preferred a
limit on maximum annual application rates instead of maximum single
application rates, and the Agency was able to honor this preference.  In
addition, the AZM Decision called for larger buffer zones around water
bodies, buffers around houses and occupied structures, further
restriction on aerial applications, and a stewardship program to help
workers and their families reduce their exposure to AZM and other
pesticides.  New AZM labels will be in place for the 2008 use season.

Companies requested the opportunity to provide final comment on the
ecological risk assessment, and an internal meeting on the human health
hazard assessment.  The terms and conditions of the AZM label amendments
provided for at least one meeting prior to July 2011 to discuss whether
or not the necessary pieces are in place to ensure successful phase out,
including MRLs in key export markets.

Carol Dansereau asked Margaret Rice to comment more on the buffer zone
specifics.  Margaret Rice noted that the buffers around housing and
other occupied dwellings is 60 feet and will go into effect in 2008. 
Shelley Davis asked if the Agency placed value on impact on endangered
species and their habitat.  Margaret Rice noted that impact on
endangered species was not considered for the most recent AZM decision,
but that there is an endangered species assessment going on now for
litigation in the Pacific Northwest and elsewhere.  Shelley Davis
mentioned that it may take 6 years or more for MRLs to be established,
and asked how this was balanced in the decision.  She also asked what
EPA considered when balancing human health risks with benefits. 
Margaret Rice said that in the short term, EPA believed that benefits
outweighed risks, and this is explained in the decision document. 
Margaret Rice said that the purpose of this meeting is to ensure that
phase out occurs.  Shelley Davis said that some of the margins of
exposure (MOEs) for AZM are below 10, so there are specific examples of
acute neurotoxicity.  She asked what the criteria were for concluding
that the benefits outweighed the risks (for allowing continued use of
AZM) for the early stages of the phase-out.  Rick Keigwin indicated that
Shelley Davis had not heard the ground rules for the workgroup meeting. 
The group had discussed that they would not delve into rationale for the
Agency’s decision, but focus on transition.  Jim Cranney asked about
the meaning of an MOE in the low tens.  Margaret Rice responded that it
means there is approximately a 10 fold margin between expected exposure
and the no effect level.

	Al Jennings suggested that the group brainstorm ideas for paths forward
for the workgroup. Jay Brunner of Washington State University asked for
structure during the brainstorming, and suggested that the group
brainstorm by category.  It was decided that the group would first
brainstorm for categories.   

The group brainstormed many categories.  Barbara VanTil suggested that
one category should be the infrastructure to support growers- scouting,
training, etc.  

Jay Brunner said that the complexities of the systems should be
considered, as well as the effects on non-target bio-control agents and
disruption of those systems.  

Jerry Baron noted that just having alternatives available is important. 
He also said the group should consider the availability of alternatives,
as growers cannot transition to something that is not there.  

Rufus Isaacs asked about the evaluation of alternatives.  “How will
EPA determine by 2011 whether the alternatives we are aiming for are
working, i.e. effective alternatives to AZM?  There needs to be a
mechanism in place so that if they are not working, we can revisit the
phase-out plan.”  

Larry Olsen talked about risk analysis (risk-profiling) of the
alternatives for human health and environmental risk.  

Bob McClain said that we need to define what an alternative is and
determine if it is viable from not only a production standpoint, but
also how it fits into air and water quality and resistance management
considerations.  

Gabrielle Ludwig said that the water and air quality impacts of
alternatives are important considerations in California, and the
potential impact to mating disruption programs should be considered as
well.  Growers need to have a “hammer” type pesticide available to
use with pheromone mating disruption programs (in order to keep pest
populations at low enough levels for the pheromones to work).  

Lori Berger said that infrastructure should be expanded to extend from
research phase to the use of products.  She also asked about the role of
other agencies (such as National Resource Conservation Service (NRCS),
National Oceanic and Atmospheric Administration (NOAA), Interior
(Endangered Species, etc.) regarding alternatives.  

Carol Dansereau said that risk profiling needs to consider non-chemical
alternatives and that determining the safety of the alternatives needs
to go beyond acute effect considerations.  She said she would like to
know the full range of barriers that growers face such as insurance,
grading of apples, and other obstacles to transition.  Are there surveys
that have already identified these obstacles?  What is it that growers
themselves say?

Jeff Zellers said that the definition of alternative was key.  Many of
the alternatives researched include other OP’s or other chemicals with
risk.  He said that the group should define alternatives as “viable”
alternatives.  He also said that the group should look at infrastructure
– what does the group have to do to “elevate” research to make
sure they are identifying viable alternatives (in terms of efficacy,
MRLs, economics of use, etc.).  Paula Paul said that the ability of
alternatives to manage resistance should be considered.  She also
suggested that the Agency’s MRL spreadsheet should be expanded to
include the pest to be controlled.  She said that the groups should
identify which MRLs are in place and what the time frame is for
achieving MRLs.  Rick Keigwin indicated that EPA is working on the pest
matrix and will incorporate Paula’s suggestions.  He also told the
group that Lois Rossi, Director of the Registration Division in EPA’s
Office of Pesticide Programs asked him to tell the group that CODEX is
looking for candidates for MRLs.  This workgroup can identify chemicals
for prioritization within the CODEX MRL setting process.  

Rebeckah Adcock asked, “What is the Plan B?” What happens if
problems such as resistance occur, or if MRLs are not established?  She
asked about a scenario in which AZM is the only tool left and the
transition is not successful.  

Mike Willet told the group that the USDA - National Ag Statistics
Surveys (NASS) are being reduced or eliminated.  The NASS surveys are
the clearest sources of use information (for states that do not have
mandatory use reporting).   

Robin Spitko said that the group needs to address efficacy.  In New
England, neighbors don’t like the use of some chemicals and OP’s are
being phased out.  Damage is being observed with the use of some
alternatives and some alternatives are not performing as well as was
expected.  

Jim Cranney said that the economic component of transition is very
important and should be addressed.  He also noted that the topic of
transition has many issues; the group should recognize that AZM has been
in the pest management system for 30-40 years.  We do not know what is
going to happen when it is removed.  How are growers going to be
educated, funded, and what is the availability of resources to make the
transition happen?  Can EPA fast-track any AZM replacements in the
registration queue?  Jim Cranney said that resistance management was an
important part of the transition.  Additionally, Jim Cranney advocated
that the success of the transition be monitored.  He said that
scientific assessment of the transition is needed.  

Steve Balling of Del Monte Foods said that Codex is not always used as a
default for export markets.  Many countries have abandoned Codex in
favor of establishing their own residue limits.  He said that
infrastructure and research are eroding at the same time we are asking
growers to adopt products that are assumed to be less risky. 
Sustainability issues (water, air quality, biodiversity) are weighing
heavily on food processors and growers and they need to consider
sustainability while they are transitioning and remaining competitive in
the global marketplace.  Steve Balling would like to see metrics to
measure success or failure of the transition.  He said that we often
institute change and then never look back.  Barbara VanTil agreed that
metrics are important.  Shelley Davis suggested that the group explore
whether mitigation efforts are really protecting workers and their
families.  Biomonitoring and incident reporting could be measures of
this.  She also asked about the viability of moving to organic
production and measuring the number of producers that are growing
organically.  Larry Elworth said that the economics component of the
transition needs to be broad in scope – is the cost of alternatives
too high?  He also agreed that the transition should distinguish between
pests.  The transition should look at secondary pests as well because
they become more important as AZM is replaced.  Just having something
registered is different than knowing if it works.  Experimental Use
Permits (EUPs) are important for determining efficacy.

  

Mike Shaw of Dow AgroSciences said that trade is a necessary category. 
It is more complex than MRLs; getting a Codex MRL is not as useful as it
used to be.  Japan does not accept as many MRLs.  How can MRLs be
established for new or existing chemicals in a timely way?  He would
like to see a framework developed with USDA-Foreign Ag Service (FAS) to
do this.  Regarding organics, Steve Shaw said that international organic
standards differ.  A US organic label does not mean that something can
be sent to Japan or Europe as organic.  Mike Willett said that in the
markets where MRLs are not recognized, commodities might actually be
able to get into those markets faster than the six years it takes to get
an MRL.  Al Jennings indicated that USDA Deputy Secretary Conner has
laid out some goals for advancing specialty crop trade in the upcoming
Farm Bill.  Michael Fry said that funding for regional efficacy and IPM
studies is important.  He asked if there are any anticipated changes in
the standards for Section 18’s or 24C’s?  How cumbersome are the
regulatory constraints for Section 18’s and 24C’s?  Ephi Gur of MANA
said that some alternatives might not be registered in all U.S. states. 
Ann Pingitore mentioned that aflatoxin contamination could increase in
pistachios if alternatives do not adequately control worm pests.  

Larry Elworth asked about the registration status of AZM in Canada. 
Andrew Beyak of Canada’s Pest Management Regulatory Agency (PMRA) told
the group that AZM is registered on apples, crabapples, apricots,
blackberries, cherries, cranberry, grapes, pear, peaches, plums, prunes,
and raspberries.  Of those, apples, cherries, and pears are the most
important uses.  Some phase-outs are scheduled for 2007.  Alfalfa,
clover, rye, Brussels sprouts, and nursery plants, and some other uses
are already phased out.  Andrew Beyak said that one way to find
information on Canadian MRLs is to search for AZM MRL on the PMRA web
site.  Larry Elworth asked about the status of AZM in Mexico.  Jerry
Baron asked Andrew Beyak if there are still MRLs for parsley and
blueberries in Canada.  David Trinka said that economics is important,
and that application methods of AZM and alternatives are important. 
Michigan blueberries need aerial application for some pests.  IR-4 needs
to be funded to ensure that alternatives are available for smaller
crops.  Bob Elliot of the California DPR spoke to the group about
California’s experiences with transition grants and on infrastructure
and field testing.  He talked about smart sprayer technology and said
that there is a lot of interest in California for this technology.  Rick
Keigwin asked Bob Elliot to send him a fact sheet about their grant
programs for the workgroup.

Larry Elworth suggested that the group consolidate categories.  Mike
Shaw suggested some major categories – trade, pest management systems
(efficacy, alternatives, economics, strategy shifts), transition
metrics, and a generic category (registration, etc.), and said that
there may be other categories.  Mike Willet suggested four different
categories that would include all of the brainstormed items: (1)
Research and efficacy; (2) International MRL efforts; (3) Grower impact
assessment and tracking changes; and (4) Registration of alternatives
and risk profile of alternatives.

Lori Berger noted her interest in discussing the definition of
alternative.  Rick Keigwin noted that it is important to know what a
working definition of alternative is.  Barbara VanTil volunteered to
work with a smaller group to facilitate the consolidation of the
brainstorm list.  Larry Elworth suggested that EPA look for a previous
definition of alternative as developed by a TRAC committee.  Shelley
Davis suggested that the group not obsess over the word alternative.  Al
Jennings reminded the group that its purpose is to provide USDA and EPA
advice.  Lori Berger restated that it is important for this group to
establish definitions.  Rebeckah Adcock said that there may not be a
consensus by the workgroup on the definition of alternative, but she
would like a clear understanding of what EPA means by alternatives.  Mr.
Keigwin indicated that there are Canadian MRLs for AZM for blueberries
(2 ppm), cranberry (1 ppm), and strawberry (1 ppm).  

Lunch 

During lunch a smaller group of the AZM Transition team worked to
consolidate the brainstorming ideas into a workable list to break down
the transition process.

Afternoon

The smaller group reported back to the full workgroup.  The categories
decided upon include:

Trade

Regulatory Issues

Impact Assessment

Research and Implementation

A question was brought up about how to capture resistance management
issues.  Another question was brought up how performance will be
measured.

Rick Keigwin noted that some considerations cross over categories;
metrics applies to all categories and resistance relates to ‘Impact
Assessments’ and ‘Research and Implementation.’  

Barbara VanTil noted that progress needs to be measured over time so
that adjustments can be made while implementing transition plans.  

Rick Keigwin mentioned that the group needs a working definition of the
Research and Implementation category.  

Jerry Baron noted that infrastructure can fit into each of the
categories.  

Jay Brunner agrees, but said that the infrastructure need for
Implementation is a challenge.  

Lori Berger said that all of the categories are interconnected, the role
of every transition partner should be defined so that each is aware of
what they need to do.  

Carol Dansereau asked if barriers to organic production are included in
any of the categories.  

Al Jennings said that it is embedded in each of the categories, as are
barriers to any sort of change.  

Rick Keigwin said that an aspect of the trade category is what the tools
are to form MRLs in other countries.  

Larry Elworth asked if what the group wanted was a check list.

Mike Shaw noted that the workgroup had identified categories and will
work on the definition of what a successful transition would be.  He
said that the group should look at where we are now and identify where
there are gaps to getting to the goal of transition.  Then the group
should determine what is needed to get to the goal, and what it will
take to get from here to there.  Larry Elworth said that the group
should not only have a goal in mind, but have a check list of what it
needs to do to get there.  Shelley Davis noted that not only do we need
a check list of what needs to be done, but we need to list out who will
do these things.  What is it that the workgroup will do?  Rick Keigwin
said that the work group will help pull a framework for transition
together, and will also keep the Agency up-to-date on how the transition
is going.  

Jay Brunner said that the group needs a framework, and that the
framework would contain the implementation plan.  He hopes that the
workgroup will talk about the framework.  He suggested that the group
make recommendations on priorities, the reallocation of funding, etc. 
Rick Keigwin asked how folks wanted to proceed from here.  It was
suggested to pick a category and proceed.  Rebeckah Adcock asked if the
group was going to break into smaller groups.  She said that she works
with growers in the field.  Farming is already complicated. 
Transitioning at the grower level is difficult.  The ultimate matrices
are if we will have any agriculture left.  She has seen that by the time
changes in regulations come down to growers, they often don’t apply to
the growers situations.  

	The workgroup divided into two groups.  One break-out group addressed
what would fall under research and implementation and the other
break-out group addressed what would fall under trade and regulatory
issues.  The workgroup came back together to ‘report out’ on the
break-out discussions.

TRADE

MRLs for alternatives; time line for achieving the MRLs; and
non-pesticide issues (e.g., alfatoxin)

Quarantine pests

Organic certification (international)

REGULATORY ISSUES

Develop a better list of alternatives from the EPA spreadsheet provided
to include target pests and identify minor pests that might become
important.  Identify all export markets and gaps in MRLs.

Timeline for MRLs will be added when needs are identified.  

Section 18s – Plan B?

Identify where there are no good alternatives

Gaps in state registrations 

Registration timetable for new registrations

Resistance management – engage experts to ensure that there are
sufficient tools to manage resistance.

The group questioned the trade and regulatory break out group.  Jay
Brunner asked about the prioritization of crops by IR-4.  Are there
experimental use permits (EUPs) for large-scale testing before
registration?  Larry Elworth said that it would take a significant
change to use EUPs like this because the information, cost, and time
needed to obtain an EUP currently prevents EUPs from being a viable
option.  Jerry Baron said that IR-4 would give high priority to AZM
alternatives.  We would need to know if a chemical is likely to serve as
an AZM alternative in the necessary time frame.  Jim Cranney said that
the first couple years of use for new chemicals are part of the
experimentation process for growers.  This is when growers determine
whether the new materials are solving problems or whether they are not. 
Rebeckah Adcock asked, “What is the market reality of having a product
available for use as a Section 18?  Is it a real option as a plan B?” 
She said that crops with a small percentage of crop treated will be in
this position.  Pat Cimino of EPA/OPP said that tart cherries would be a
crop in that position.  Zero tolerance is the standard for some of these
pests.  Could the group talk to USDA about these standards?

Larry Elworth commented that for an alternative to be viable in 2012 it
really needs to be in the queue now.  Jerry Baron said that a project
started by IR-4 in 2007 would be submitted to the Agency in 2009.  Then
the project would have to wait for PRIA timeframes.  So there is a two
year minimum between residue trials and submission to EPA.  Barbara
VanTil said that grower and crop level impacts would need to be
assessed, as would resistance management.  The group should realize that
some crops are already on Plan B.  The group will need to decide what
impacts will be risked?  Worker risk or ecological risk?  Will we impact
systems – water and air quality?  She also asked, “When will this be
done and who is going to do it?  Need to establish baselines, what is
the time table?

What are some methods that have worked for transitions in the past?

RESEARCH AND IMPLEMENTATION

	Aspects of research and implementation identified by the break out
group are described below:

A matrix of pest, products that may be used on the pest, and geography
is needed.  Local solutions are important to capture.  

Grant funding:  Need continued funding for research relating to
efficacy, etc.  

NRCS funds for implementation, i.e. Environmental Quality Incentives
Program (EQIP).  Will help to look at ecosystem effects.

Education – Need continued presence of extension services.  Some areas
have better extension systems than others.  Who will be doing consulting
and scouting?  

Information dissemination – there is a database in development through
Interagency workgroup that will help disseminate some of the results of
research for federally funded projects.

Pull in processors.

How are products marketed?

Local focus, growers must be integrated into the process.  Make sure
growers are involved and that options have been run past them.  

IMPACT ASSESSMENT

Crop/Grower – Level Impacts

What if growers are already on “Plan B?”

Resistance management issues

Use Data

Yield impacts

Economics

Risk Impacts

Impacts to non-target species, especially endangered species

Ecosystem effects, including air and water quality impacts

Impacts to human health of workers

Find systems that work

Jay Brunner commented that alternatives come along and are assumed
“safe.”  If there is information that becomes available from
non-traditional sources, it should be included in the registration
process.  Jeff Zellers asked if something “drops out” of the matrix,
i.e. doesn’t meet all of the criteria for a real alternative, what is
Plan B?  Rick Keigwin said that the workgroup exists to help find the
answer to this question.  Shelley Davis said that it would be a good
first step to find out what is in pipeline.  She also suggested to talk
to people that have already switched and see if it is a workable system
for people who need to transition.  Larry Elworth said that we know what
time frame is available, and should be able to lay the steps out.  Al
Jennings said that the USDA has PMSPs, and that some have been done and
not published.  That may be a good starting point.  Larry Elworth said
that the PMSP is a good starting place, but we will need to narrow down
focus by specific pests.  

	Mike Shaw said that there is not a secret list of products that are in
pipeline.  He also said that the IR 4 list of alternatives may be
longer.  Jerry Baron of IR 4 said that there are some alternatives in
the pipeline in IR 4.  

	Lori Berger suggested that there be a case study for how the transition
will look.  She suggested parsley.  Shelley Davis requested to look at
apples first because it is the majority of the use.  Barbara VanTil said
that two case studies may make sense – apple and parsley.  Mike
Willett asked how we would assess whether sufficient progress is being
made as we go through the transition.  The case studies should identify
what is working and not working during transition.  Jim Cranney said
that regional issues need to be considered.  Barbara VanTil will work
with Jeff Zellers on a parsley case study.

	It was decided that Mike Willett, Jay Brunner, and Shelley Davis will
meet with Al Jennings on the apple case study.  Al Jennings said that he
would set up a meeting with the apple case study group within two weeks
of the meeting.  

Next Steps:

Distribute meeting summary in draft form to workgroup members.  Finalize
after workgroup comment, then post to the PPDC website.

Propose date for conference call – mid to late April.

Plan for PPDC (which is May 9 and 10) and meeting for workgroup on May
8.

USDA to draft outline for transition strategies.

EPA to develop alternatives matrix.

  

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