The mad scientist in me says we should to do something like what researchers did with the tsetse fly or grass carp. GMO a northern or european honeybee or bumblebee species to have a kill gene or release with tripoloidy and immunity to -nicotinoids and -pyrethroids. Improve vigor with genes from african killer bees. Make the kill gene something like the smell of bubblegum.
The commercial grade group 4 (neonicotinoid) insecticides are far more concentrated than the group 28 (e.g. Spinosad) and hence have lower annual dosage limitations. The frequencies are also lower but are individual between them, so for example I’m allowed up to 3 annual applications of group 4A plus another 3 annual applications of group 4D. The requirements for production Citrus are 4 applications per year each of soil drench systemic and foliar psyllid insecticide. Nevermind that the primary native host for ACP is Curry Leaf which grows in many a home garden and is never treated!
I had to call up a legal friend to double check what I suspected. The EPA is expressly forbidden from requiring pesticide applicators to report how they how they use synthetic chemicals due to the FIFRA (Federal Insecticide, Fungicide, and Rodenticide Act). The federal government only collects information at the aggregate level. It is up to the state level department of agriculture to enforce (if at all). That said, the government as a whole doesn’t keep track of synthetic or non-synthetic pesticides on organic or individual industrial farms.
The only hard regulation is at the post-harvest level when foods enter commercial trade. The EPA has set limits on pesticide residues. The recommended application limits are provided for any pesticide are designed to stay well within these guidelines.
That said, with many organics insecticides, it’s much easier to stay within EPA guidelines even with over application beyond recommended rates because they are prone to extremely low-half lives, poor UV/light-stability, and poor plant uptake. For commercial organic production, the farmer just needs to demonstrate to the certifying organic agency they’ve reasonably exhausted other options before spraying. So in a high pressure season, this may indeed involve spraying beyond what the label recommends, but it still results in food complaint with EPA guidelines and still eligible for organic certification.
On the otherhand, I believe APHIS has access to all the application data they want.
APHIS is a good resource for pest researchers. I think some of my old computer models pulled from their database. As far as I know, this data is only monitoring use. They don’t have any statutory powers for enforcement. Meat, poultry, eggs are under FSIS under USDA. EPA is responsible for everything else.
The Food and Drug Administration is responsible for enforcing the EPA tolerances for domestic foods shipped in interstate commerce and foods offered for import into the U.S., except for meat, poultry, catfish, and certain egg products that are regulated by the U.S. Department of Agriculture.
link
They sure do if you are in a federal quarantine zone, of which I’m in a few.
Not concerning produce as far as I’m aware?
Enforcement would have to concern be indigenous wildlife/ fauna, domestic animals, aquatic life, seed, etc… Animal quarantine is their bread and butter though.
Produce and nursery stock under certain quarantine/eradication conditions.
Interesting. I know CA has some pretty strict requirements for many things related to produce. I learned something new for ACP. 
It seems that neonicotinoid application is not required for commercial citrus production.
As I expected, it’s not EPA, APHIS or any federal level oversight. It’s under the CDFA, state-level, which makes complete sense.
CA has a mandatory assessment of citrus fruit for ACP and HLB per the state level Citrus Pest and Disease Prevention Program. Even if you have 1 fruit tree and take it to sell sell at a farmer’s market, you must meet these requirements. This is fully administered by the California Department of Food and Agriculture (CDFA).
To more effectively protect California citrus from Huanglongbing, a regional Asian citrus psyllid quarantine for movement of bulk citrus and nursery stock went into effect on Jan. 1, 2018.
This declaration form is what growers have to fill out to sell citrus as ACP-free complaint per the ACP-growers info.
Spray and harvest is but one option. In the case of commercial organic production, manual cleaning, and post harvest treatment are also available options. However, no doubt much costlier. This makes much more sense. Neonicotinoids are simply just the most economical, lowest logistical investment that would fulfill the criteria set out by CDFA.
You make a point that has been eating at me for 25 years- that was when it became apparent to me how hard it would be to grow organic fruit in NY after enjoying the relatively easy fruit growing climate of S. CA as a young man.
The media consistently attacks the environmental effects of agricultural pesticides with reckless abandon, often simply using the word “pesticides” or in the case of this article, throwing a blanket of condemnation over an entire class of pesticides as if they are are automatically as dangerous as the specific formulation for which there is evidence of concern.
The exception is organic pesticides, which the general media regards as being absolutely environmentally benign.
Meanwhile, the most demonstrably disruptive environmental poisons come from our cars and in the containers that hold our food. Many poisons that go into home and automobile construction are immune from media scrutiny and our laws are far more lax on evaluating their effects on the environment and our health.
My conspiracy theory is that this is generated by the power of advertising revenue. The big ag chem manufacturers really don’t care if the media endlessly celebrates organic food production, organic pest control is very expensive and assures an ever larger piece of the pie to the conglomerates who can manufacture and distribute whatever formulations of pesticides the markets demand.
However, our media rarely scrutinizes our excessive consumption of more and more stuff, much that we quickly throw away- plastic packaging, foam padding in furniture, batteries, electronic products that break quickly, plastic based clothing, building materials that contaminate for centuries for larger and larger homes…
The thing is, we have to eat and the less land we need to produce the necessary food the more wilderness buffer we can leave. In the areas with adequate rain for normal agricultural production, pest pressure tends to be high. The dry west is incapable of producing enough food to feed the entire country, let alone the world, but that’s where organic crop production is most feasible and reasonably productive.
You do have to pick your poison, but sometimes we seem to be choosing more out of emotion than logic.
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Agreed. This is getting side tracked, but I do think that, on balance, max application rates - organics insecticides are safer (for humans), despite research into their side effects being in its infancy and their sometimes extreme run off consequences for downstream ecosystems. (Rotenone would is the classic example of something OMRI certified but has definite bad human side effects, but this is more of an exception.) Whether that is a worthwhile trade, it’s not an easy choice, and I’d argue the justification is better made case by case.
There is a justification for organics, no spray, and or no -nicotinoids simply as a lifestyle choice; in the same way people often regard the slow food movement. Albeit inefficient from a production standpoint, some people go choose a specific method based on personal philosophy.
I think things are more interesting explained via a thought experiment. If I could guarantee every organic pesticides and fungicides were completely human and ecosystem safe, and could guarantee same yield and low costs of production as conventional, would anyone want conventional? No. Now change the equation. If I could only insure that organic was moderately safer for human consumption and the ecosystem, with lower yield 80% (being generous) and high costs of production (2x, being extremely generous), this would closer mirror the conundrum now. What if you take human health out of the equation completely? If one could prove that organics and conventional have the same impact on human health (not necessarily ecosystem), but one costs more and has lower yield, then organics would lose their appeal.
Let’s make it a clear cut benefit (for the sake of argument). What if I could guarantee the differential trade off of a lifetime of organic food vs conventional food is 5 years longer lifespan but the cost of living related to foodstuffs would be 4x greater for your entire life? Would you make the choice for organic? This means you are healthier but probably enjoy other facets of life less considering more resource investment. Maybe fewer vacations, fewer gadgets, less expensive or prestigious college, smaller house, cheaper car, smaller land to grow trees (:shudder: 
) etc… etc… What if the trade off was 10 years for 5x the cost? 20 years for 10x the cost? 10 years for 2x the cost?
Some people will always choose organics as a philosophical choice, even if there was nothing to benefit from a health standpoint. I think that should be respected. It’s not one based on explicit personal gain but more so an adherence to method of living. (Though, this doesn’t exactly translate to being more ecosystem safe.)
My rushed thought experiment is mostly my way of showing the valuation of alternative cost on the back of an envelope. Going full circle and bringing back to the topic of neonicotinoids (boy did we get off the track), these chemicals do have a human and ecological cost. However, the alternative valuation of not using these chemicals also have a huge human and ecological cost. Lower yields also translates into greater land and resource inputs. Sometimes there are no good choices. It’s just a matter of managing realistic goals.
I’d like to think conventional/intensive, organic/extensive, gmo, better training, better utilization of inputs, improved food preservation, etc… are all tools that we will need in combination to solve problems like produce pest management.
(Ok. Back to engineering my genetically modified super bee, immune to -nicotinoids and pyrethroids.)
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My go-to on all of this is dial down human population and most of these problems begin to go away. Somehow that just doesn’t seem to be in the public discussion much and, in fact, doesn’t even belong in the discussion here. So I will withdraw now.
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Good to know!
To be clear, are there any safer options that still work once PC have lain eggs in the fruit? Or is preventative spraying the only other option?
I really liked that I could wait till the problem occurred, but OTOH I do know PC will hit hard every year. I could start spraying earlier.
You’re referring to Citrus produce.
I believe this is covered in PC threads on this forum.
OMRI does not guarantee NOP qualification, nor organic in general. It just means that the manufacturer paid $50k+ to put the symbol on their label.
In CDFA monitoring, “organic produce” is 5 times more likely than conventional to contain above legal limits of pesticide residues.
I think we’re just throwing semantics. Anyone going for organic certification no matter the certifying organic agency must spray approved pesticides/insecticides. It’s not freedom to choose what you want to spray.
Yes. I was referring to citrus produce, and as I understood, so were you. It simply was a rebuttal. I was just trying to find the regulations that lay this out. Neonicotinoids are not a requirement. It’s one of several foliar options per CDFA regulations and of the ACP-free certification, spraying is one of three options.
Source? Sample size? EPA guidelines or CDFA guidelines?
Not with focus on comparing the safety aspects in detail. Unless I missed that thread out of the gazillions on PC, which is quite possible, lol.
If you can find a primary source, it would be much appreciated. I like reading research papers. All I could find was that CDFA only enforces EPA set guidelines. They have no additional/stricter thresholds.
According to the 2017 report by the CDFA, California’s Pesticide Residue Monitoring Program (CPRMP)
The CPRMP does not target organic produce but sometimes collects organic produce as encountered during routine sample collection. The California Department of Food & Agriculture (CDFA) administers the State Organic program. More detailed information about the State Organic Program.
Produce labeled as “organic” does not mean, “not treated with pesticides.” The U.S. Department of Agriculture allows certain pesticides for use in organic farming. In addition, certified organic produce may have residues of other pesticides at less than 5% of the U.S. EPA commodity tolerance (Code of Federal Regulations, Title 7, Part 205.671).
In 2017, the CPRMP collected 288 organic samples and 99% of those samples had legal or no residues detected. These samples represented 69 different commodities from 12 different countries. Seventy-five percent of the organics tested (215 of 288) were of domestic origins; 23% of the samples (67 of 288) were imported organic.
Although the CPRMP detected 42 organic samples with quantifiable residues, only three of those samples had illegal residues. Two of the illegal samples, lemon and lime, were imported from Mexico. The other sample was of kale grown in California. All three illegal residues were for pesticides that had no tolerance established for the commodity. Results for all organic samples were reported to the CDFA Organic Program for enforcement of state and federal organics standards.
Organic Produce Sample Results
Produce labeled as “organic” does not mean “not treated with pesticides.” The U.S. Department of Agriculture allows certain pesticides for use in organic farming. In addition, certified organic produce may have residues of other pesticides that are less than 5% of the U.S. EPA tolerance for that commodity (Code of Federal Regulations, Title 7, Part 205.671).
In 2016, 148 (4.1%) of the samples collected were labeled as organically grown. These samples represented 53 different types of commodities. 78% of these samples (116 of 148) were grown in the U.S. with the majority grown in California. The CDFA laboratory reported results for these samples to DPR and the CDFA Organic Program which is responsible for enforcement of state and federal organics standards. 1.4% (2 of 148) of organic samples tested had either an over tolerance or no tolerance established violation (Figure 5).
I’m in the CDFA, CDPR, and APHIS programs as a certified applicator, certified nursery, and registered site for both. I receive bulletins and legal requirements from these agencies and of course those and more is on their websites. My PCAs are plant pathologists at Crop Production Services in San Marcos who advise Durling’s among others. I feel I have all the bases covered.