Re: "natural" miticide -Reply

Ted Rogers (TROGERS@ars.usda.gov)
Tue, 07 Dec 1999 07:25:25 -0700

Sal, at present I do not think that this will impact your situation, these authorities already exist, the bill, as I currently understand it, is intended to streamline and clarify the authority and issues involved and is more aimed at invasive species and plant pests. We have a long history of creating pests by importing species either intentionally or by accident that get out side of their native habitat and run amuck.

There are also APHIS rules pending that speak to quality standards for bio-control agents. These are intended to assure that when you purchase any of these agents that they will arrive in a viable state and at least in theory will perform as expected if properly used. I will try to get on top of these issues and get back to you. We are working on so many pest management issues that the bio-control issues seem to take the back seat, though most of us recognize their importance to all of agriculture as well as the small organic community. Unfortunately, and I will leave it to you to rant on this one, in the U.S. very little is expended on bio-control research compared to Europe.

The natural essential oils that have been mentioned have I believe all been registered as active ingredients either individually or under a blanket registration by EPA. The problem comes with getting anyone with the capacity to deliver a technically standardized product with a legal EPA label to the market in quantity for a reasonable cost. The efficacy issue is a whole other problem and it is difficult to get demand till you demonstrate efficacy in a wide variety of applications and it is difficult to pay for such work unless you have a high potential demand.

Your nematode example, the encapsulated Bt issue, the Spinosad example that came up recently, and what we see coming with the reduced risk pesticides (where a great deal is being spent on research in this country) are a pet peeve of mine. They also define one of the poison pill issues that the perversion of the organic theory and philosophy to center on non-use of synthetic inputs in general and pesticides specifically has presented to the organic industry.

The 1/110 of 1% in the nematode formulation that has been rejected by the organic community is an anti-microbial and allowed the delivery of a dry medium with a high predatory nematode count that had a shelf life of several months, it was very easy to handle compared to a damp sponge with nematodes that has a shelf life of fifteen minutes to several days depending on handling. As Bart often says "go figure". As I often say "the organic community shoots them selves in the foot again" no news here. The other two are virtually the same issue. The encapsulated Bts are a Biotech product, at one time we thought that all the topical Bts would go this route. The Bt gene is spliced into another bacterium that is then vat-cultured, killed and the resultant Bt crystals encapsulated in the dead engineered bacterium are a technically superior method of delivering topically applied Bt toxin. Well the organic issue first appeared to center around the viability of the *dead* bacteria. T!
he conversation between myself and one of my colleagues at EPA was hysterical. As I remember, it went some thing like this: *Well how dead are these little buggers?*
* How dead do you want them to be Ted?*
*I asked first.*
*Is dead, dead, very damn dead, dead enough?*
*I hope so, but I doubt it.*
The rest is history, do all those bullets in your feet hurt or do you like the pain.

Well Spinosad looks great but the formulations have those nasty synthetic inert ingredients I suppose. As this next generation of low/reduced risk pesticides mostly synthetic or suspended in various synthetic inert ingredients come into use more and more in conventional production systems how do you separate your organic products from the conventional? You can*t legitimately claim that they are safer now, what do you do then? It may not be a problem though, most of you will have died from blood loss from all those foot wounds.

I will try to get back to you on the Bio-control issues, you probably won*t believe me anyway but we try to serve every body even if they don*t like us.

Best,

Ted

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