Rick Roush says he remembers coming out of the classroom when he was a graduate student at the University of California-Davis in the 1970s and finding the air filled with ash. “You could almost count on that at some point in the fall you would have all this ash just raining down on campus,” he says. “Of course, people began to realize that the ash was coming from burning straw in rice fields.”
In most cases like this, the public becomes concerned about the impact of such activities on air quality. Then, public interest groups begin to file lawsuits or seek legislation. And, finally, state agencies are forced to implement strict regulations aimed at heading off such practices.
“They still burn some of the straw, but the amount of rice acreage being burned off has been greatly reduced because of some regulatory efforts and voluntary actions on the part of the rice industry,” said Roush, director of the University of California’s Statewide Integrated Pest Management Program.
“It took a while to get there, and it took some compromise on the part of the rice industry itself, but we now have people plowing the stubble back into the water. At the same time, the industry is becoming known for its efforts to provide sustainable habitat for birds. “It’s a perfect example of turning a sow’s ear into a silk purse,” he said. “What had all the earmarks of a potential disaster is now being seen as an environmental plus for the industry.”
Roush says other segments of California agriculture should start deciding how they can get out ahead of another air quality issue – emissions of volatile organic compounds or VOCs – to avoid the potential loss of a number of important agricultural chemicals.
“The Department of Pesticide Regulation has made a key policy decision that is likely to affect access to a wide range of pesticides and even plant growth regulators across California,” he told members of the California Association of Pest Control Advisers (CAPCA) at their annual meeting in Reno, Nev.
“To meet regulatory demands, DPR is planning to require changes in many liquid formulations of agrochemicals, especially emulsifiable concentrates (ECs). In some cases, this may mean that registrations for some products will be dropped in California. PCAs can help reduce the impacts of these proposed changes.”
Roush admits to being a little biased in his belief that industry members can make a difference in regulatory matters. That comes from working in Australia for eight years before returning to California to lead the state’s IPM effort two-and-a-half years ago. “When I was in Australia, we approached regulatory issues somewhat differently than here in California,” he said. “A lot of Australians realize they don’t have a lot of political clout in agriculture anymore, if they ever did.
“The rice industry, the cotton industry, the vegetable industry, the citrus industry, the wine industry, they all have to try to anticipate what their environmental problems are going to be, find a solution and go to the government and propose regulations so they will adopt rules that will work and make sure the enforcement people are well schooled.”
Roush says volatile organic compounds are becoming an increasing concern because their emissions and nitrogen oxide react with sunlight to create ozone. The federal Clean Air Act requires California to reduce the emissions of VOCs in geographic areas (non-attainment areas) that do not meet ozone standards.
“Ozone is regulated under California’s State Implementation Plan because of the Clean Air Act,” says Roush. “If the SIP requirements are not met by deadlines, a Federal Implementation Plan could be imposed and California could lose federal highway funds.”
California’s Department of Pesticide Regulation has already been sued by one public interest coalition over VOC emissions levels in the San Joaquin Valley, which is currently classified as a non-attainment area.
Pesticides ranked sixth in the list of sources of volatile organic compounds in the San Joaquin Valley in 2004 (behind livestock waste, primarily dairy cattle, light and medium duty trucks, light duty passenger cars, prescribed burning and oil and gas production. But farm chemicals make an easy target for regulators.
“For some agrochemicals, the inert ingredients include VOCs,” said Roush. “This includes some EC formulations of pesticides, some plant growth regulators like gibberellins and some defoliants.”
These account for about 37 percent of the VOCs from pesticides in the San Joaquin Valley with about 49 percent of the remainder coming from fumigants.
Chlorpyrifos (Lorsban), avermectin, pyriproxyfen (Esteem), sethoxydim (Poast), fenarimol (Rubigan) and endosulfan (EC) products have emission potentials or EPs of 35 to 60 percent. (The latter is the fraction a product is assumed to contribute to VOCs.)
“There can be a wide range of emissions potentials among EC formulations of the same active ingredient,” Roush notes. “For many active ingredients, liquid concentrates, solutions or wettable powders have much lower EPs. Some gibberellic acid formulations have an EP of 94 percent, but others, soluble powder, liquid concentrates among them, have EPs of 6 percent or less.”
To achieve compliance in the San Joaquin Valley, DPR aims to require pesticide manufacturers to reduce the VOC content of liquid EC formulations of 20 to 30 percent. This includes products used anywhere in California, not just in the SJV.
“In other words, pesticides that have an emissions potential of more than 20 to 30 percent of their weight will either have to be reformulated or lose registration unless there are legitimate reasons why reformulation cannot be done,” he said. “This will likely affect hundreds of products.”
That’s where PCAs come in, says Roush.
“Given the broad implications for the many crops grown in California, it would be prudent to begin considering the impacts on production and investigating alternatives to EC formulations, including non-ECs with the same active ingredients,” he notes.
DPR will start the process with a mandatory data call-in for emission potential data for all “suspect” formulations. Using its re-evaluation authority, DPR will then work with registrants and pesticide users over the next four years to implement changes in product formulations.
“It may be possible to obtain exemptions where there is a specific need for economic, pest management or environmental reasons,” he said. “PCAs can help document these situations.”
They can also help in other ways.
Roush is working with researchers to conduct an economic analysis of the impact of the potential regulatory changes to help provide evidence for any arguments about changing policies to reduce the cost of the changes to growers.
Second, many suspect formulations may be replaced with others. Members of the citrus industry, for example, have indicated they can use non-EC formulations of Gibberellic acid and dispense with the high EP formulations. Other farmers may be able to change the timing of fumigant applications or reduce dependence on those products.
“Please contact me if you have concerns about particular products for specific pests and commodities,” said Roush. “Not only would it be very helpful to pass this kind of information along to me for further collation, you will be doing your growers a great service by recommending such substitutions whenever possible.
“You can help us identify crops and pests for which pesticide substitutions are either possible or risky and implement voluntary changes where possible.”
Roush provided CAPCA members with a lengthy list of products that might be subject to reformulation that don’t have E or EC in their names. More information can be obtained on the Statewide IPM Web site: www.ipm.ucdavis.edu.