U.S. EPA Proposed Changes to Rodenticide Labels for Agricultural Use: Opportunity for Public Comment

By Roger A. Baldwin, Professor of Cooperative Extension, UC Davis and Niamh Quinn, Cooperative Extension Advisor, UC South Coast Research and Extension Center

Rodents cause substantial damage and health risks in agricultural productions systems through direct consumption of fruit, nuts, and vegetative material; damage to the plant (e.g., girdling of stems and trunks); by providing a food safety hazard from contamination; damage to irrigation infrastructure; damage to farm equipment; burrow systems posing a hazard to farm laborers; posing a health risk through potential disease transmission; and increased soil erosion by water channeling down burrow systems, among other potential damage outcomes. They also cause substantial damage and food contamination risks in livestock holding facilities, food processing facilities, barns, and other agricultural-related structures. As such, effective management is needed to minimize these risks. The use of rodenticides is often considered the most efficacious and cost-effective tool for managing rodent pests, and as such, it is often included in Integrated Pest Management (IPM) programs designed to mitigate rodent damage and health risks. Given the significance of rodenticides in managing rodent pests, it is important to know that the U.S. EPA has recently released a list of Proposed Interim Decisions (PIDs) for public comment that, if approved, will substantially alter if and how rodenticides may be used to manage rodent pests in the near future. As such, we felt it was important to inform California’s agricultural producers as to the extent of these proposed changes, and if you are so inclined, we have provided a link for you to provide public comment on the PIDs, as well as links to contact your Senate and Congressional representatives to ensure your opinion is heard.

All rodenticides are currently under review. These include first-generation anticoagulants (FGARs; chlorophacinone, diphacinone, and warfarin), second-generation anticoagulants (SGARs; brodifacoum, bromadiolone, difethialone, and difenacoum), zinc phosphide, strychnine, bromethalin, and cholecalciferol. Of these, only FGARs, zinc phosphide, and strychnine have labels for use against field rodents (e.g., ground squirrels, pocket gophers, voles, rats, and mice found in agricultural fields), but not all of these active ingredients can be used for all rodent species. As always, it is imperative to fully read a rodenticide’s label before determining if it is appropriate for use against a particular species and in a specific situation. That said, the following are some significant changes that have been proposed that you should be aware of. Other potential changes have been proposed as well, so please check out the PIDs for additional details (linked at the end of this document).

1. All rodenticides for field applications will become restricted-use products. This means that applicators will need to be certified to use restricted-use products in these settings. They will also have increased reporting requirements for their use.
2. Above ground applications would be eliminated in rangeland, pastureland, and fallow land. This is a substantial deviation, as many/most applications in these areas have traditionally been through broadcast applications or spot treatments. This change would leave only bait stations for ground squirrels and voles.
3. Within-burrow applications of FGARs will generally not be allowed in croplands during the growing season. This would eliminate FGAR application for pocket gophers for much of the year, and would eliminate it for all uses in some crops (e.g., citrus and alfalfa in certain areas of the state).
4. Carcass searches will be required every day or every two days (starting 3-4 days after the initial application), depending on the product used and where applied, for at least two weeks after the last application of the rodenticide. When carcasses are found, they must be disposed of properly. Any non-target mortalities must be reported to the U.S. EPA. Collectively, this will require a major increase in labor, potentially making rodenticide applications impractical in many settings.
5. Extensive endangered species designations are anticipated that will limit or eliminate the potential to apply rodenticides. This could have large-scale impacts, although the full extent is not known at this time.
6. New labels will require the use of a PF10 respirator and chemical resistant gloves during application. This is a substantial change for some rodenticide labels, requiring fit testing for all applicators, with the requirement of respirators ultimately making rodenticide application more physically challenging.

Additional details on these proposed changes can be found at the following websites:

1. Anticoagulant PID: https://www.regulations.gov/document/EPA-HQ-OPP-2015-0778-0094
2. Zinc phosphide PID: https://www.regulations.gov/document/EPA-HQ-OPP-2016-0140-0031
3. Strychnine PID: https://www.regulations.gov/document/EPA-HQ-OPP-2015-0754-0025
4. Bromethalin and cholecalciferol PID: https://www.regulations.gov/document/EPA-HQ-OPP-2016-0077-0024

As mentioned previously, these proposed changes are likely to have a substantial impact on the use of rodenticides in agricultural settings. However, these changes are currently open for public comment. If you would like to comment on these proposed changes, the required links and useful guidance can be found at the following website: https://responsiblerodenticides.org/.

You may also comment on these proposed changes to your Senate and Congressional representatives. If you are unsure who they are or how to contact them, check out: https://www.congress.gov/contact-us.

The deadline for making comments to the U.S. EPA is unfortunately short, with a final deadline of February 13, 2023. Therefore, you will need to provide your comments in short order.

California Ag Today2023-02-09T11:05:06-08:00February 9th, 2023|

Action Needed to Amend SB1

Urge your Representatives to AMEND SB 1

From California Citrus Mutual

This week the Assembly will consider Senate Bill 1 by Senate Pro Tem Toni Atkins.

SB 1 proposes dangerous changes to how the state implements the Endangered Species Act (ESA) and will have devastating impacts on how water is managed in California.

The bill seeks to preserve environmental regulations against perceived rollbacks by the Trump Administration by empowering state agencies to immediately adopt the “baseline” standard in place before January 19, 2017 (the day before President Trump was inaugurated).

As currently written, SB 1 would lock in the existing biological opinions that determine how much water must flow out of the Delta to protect native fish species. This directly influences how much water is available to ALL water users south of the Delta.

The State and Federal agencies are currently in the process of updating the biological opinions, which will result in lower flows and more water for communities and agriculture. But, by locking in the existing biological opinions, SB 1 prohibits State from using the best available science to manage how water moves through the Delta.

Recent amendments do not go far enough to address the ESA provisions.

California Citrus Mutual and many other agricultural and business-sector groups have proposed constructive amendments to address these concerns. The Pro Tem’s office, however, did not make substantive changes to the bill before it was passed out of the Assembly Appropriations Committee on Friday despite pressure from the Governor’s Office.

The Legislature will adjourn next Friday and it is imperative that SB 1 be amended THIS WEEK.

We are calling on our Assembly Members and Senators to urge the Senate Pro Tem to accept amendments to the ESA section.

Please click on the link below to send a letter to your representatives asking them to support amendments to the ESA section in SB 1.

California Citrus Mutual Action Center

California Ag Today2021-05-12T11:05:02-07:00September 4th, 2019|

CCM Statement on Chlorpyrifos Ban

Flawed Data Forcing Cancellation

News Release From California Citrus Mutual

Recently, the California Environmental Protection Agency (CalEPA) and the California Department of Pesticide Regulation (DPR) announced that they are going to begin the cancellation process of chlorpyrifos. The statement cites scientific findings that chlorpyrifos poses serious public health and environmental risks to vulnerable communities.

“The decision to ban chlorpyrifos is not surprising given the significant pressure from anti-pesticide groups, active legislative proposals, regulatory proceedings, and ongoing court battles,” said CCM President Casey Creamer. “However, this decision relies heavily on an evaluation that was significantly flawed and based upon unrealistic modeling scenarios that are not verifiable by actual results in DPR’s own air monitoring network.”

“California Citrus Mutual and our member growers stand by science that is sound, that properly evaluates risks and puts forward appropriate safeguards to protect ourselves, our employees, and our surrounding communities. We are committed to safe and effective use of chlorpyrifos and other crop protection tools.”

“The process for which this chemical was evaluated was purposely exaggerated to achieve the desired outcome and jeopardizes the scientific credibility of the Department of Pesticide Regulation. This decision sets a terrible precedent for future evaluations and creates a chilling effect on companies planning on making significant investments to bring new products to the market in California.”

“The citrus industry is fighting feverishly to protect itself from the deadly citrus disease, Huanglongbing,” Creamer continued. “In order to do so, we must have the necessary tools in the toolbox for an effective Integrated Pest Management program.”

“The once mighty citrus-producing state of Florida has lost 70% of its production due to this disease, which is expanding exponentially in residential citrus trees in Southern California at this very moment. While our commercial growers will remain vigilant, it is vital that our policymakers recognize the seriousness of the threat and ensure sound scientific procedures are followed.”

“California Citrus Mutual will continue to be actively engaged in the regulatory processes around the cancellation decision and will continue to explore all potential remedies to allow the safe and effective use of chlorpyrifos.”

California Ag Today2021-05-12T11:05:03-07:00May 14th, 2019|

Roger Isom: Probable Electric Rate Hikes Raise Concern for Ag

California Agriculture Concerned Over PG&E Increases, Overtime Rules

By Mikenzi Meyers, Associate Editor

Water, labor, and air quality issues in California keep growers’ plates full of challenges, but with probable PG&E rate increases in the future, it seems they can’t catch a break. Roger Isom, President and CEO of the Western Agriculture Processors Association and California Cotton Ginners and Growers Association, is among those wondering how the industry is going to compete.

“We’ve been paying for a lot of those safety upgrades. What happened? I mean, we’ve got to let the investigation take place, but to saddle rate payers with that amount of money, we just can’t do it,” Isom said of the threat of rate increases.

Roger Isom, president and CEO, Western Processors Association (source: LinkedIn)

At the same time, the industry is still battling the effects of the Brown administration’s ruling on overtime.

“There are farm workers in 45 states that could work 20 hours a day, seven days a week, and never trigger overtime. We have to compete with that, and that’s just unacceptable,” Isom said.

Isom is optimistic about new appointments in California administration, though.

“You’ve got Jared Blumenfeld, who’s the new CalEPA Secretary. He was actually extremely helpful over there when we were working on incentives for replacing pumps and tractors,” Isom explained.

Isom also gave credits to Wade Crowfoot, who was on the previous administration and helped with port shutdowns.

“He’s going to hit up resources, which obviously with the water situation is a very critical agency for us. Seeing somebody over there that could be helpful is important,” he said.

California Ag Today2019-02-28T15:59:04-08:00February 28th, 2019|

Temperance Flat Denied Funding

All Hope Dries Up

By Patrick Cavanaugh, Editor

Again, it came down to fish, specifically Chinook salmon, that forced the proposed Temperance Flat Dam out of the race for Proposition 1 funding for building new water storage projects.

Mario Santoyo and Temperance Flat Denied Funding

Mario Santoyo fought hard for Temperance Flat Dam funding.

For more than 20 years, the Temperance Flat Dam proposal was passionately advocated with unwavering support by Central Valley cities and the San Joaquin Valley Infrastructure Authority (SJVIA) who were behind the application. Temperance Flat came crumbling down Wednesday at the California Water Commission (CWC) meeting in Sacramento on the second day of discussion.

On Tuesday, CWC staff members assigned to crunch the Public Benefit Ratios for the project were solidly encased in concrete, refusing to grant the project any consideration for its ecosystem restoration benefits. The Dam would provide critical cold water to flow down the San Joaquin River, thus helping the salmon spawn.

CA Water Commission kills Temperance Flat funding

CA Water Commission denied funding for Temperance Flat Dam.

And while the official public benefit calculation came up short today, proponents already saw that the project was already on life support Tuesday, with a dire prognosis.

“Stunned is an understatement,” said Mario Santoyo, executive director of the SJVIA, who has worked for more than 18 years on the project. “Temperance Flat is the most critical water project ever proposed for the Central Valley, which is ground zero for significant water shortages that will not go away.”

It all boiled down to the Ecosystem Diagnosis and Treatment (EDT) model that was approved by Bureau of Reclamation and the California Department of Water Resources. Despite both approvals, that model did not jive with the Commission staff’s model, which undervalued the project’s public benefit ratio, killing the opportunity for Temperance Flat Dam to receive funding of more $1 billion for construction.

“We are working in an area of great uncertainty in professional judgment,” Bill Swanson, vice president, Water Resources Planning & Management for Stantec, a global planning and engineering firm, who presented data for the SJVIA. “We do not have fish in the river. We do not have empirical data. The only issue available to us is a comparison of how the system would respond to changes in flow, temperature and habitat,” Swanson said.

“That’s the reason we used the EDT model, the same model that the Bureau of Reclamation has used in their models of flow,” Swanson explained. “The SJVIA’s challenge was how to take the results of that model and analyze them to a level of detail that distinguishes the precision that we might want to have around the results,” said Swanson.

Stantec’s Bill Swanson advocated for Temperance Flat Dam funding.

“I’m very disappointed with the way they scored a great project that needed to be built,” noted Santoyo. “And I am not happy about one commissioner from Orange Cove who stabbed us in the back and scolded us on why we did not meet the Public Benefit Ratio. We did meet and exceed that ratio, but the CWC disagreed with our ecosystem restoration model that had been used by both the state and the feds.”

Several Water Commissioners publicly wrangled with their staff on how they could make the project work. They sought areas to increase the project’s cost-benefit evaluation to get it funded.

Commissioner Joe Del Bosque read the ballot text of Prop 1, approved by California voters by 67 percent in 2014. He reminded those present that voters expected a water storage project to be built, adding, “We need to find more certainty in order to get Temperance Flat built.”

Commissioner Daniel Curtain distinguished two parts to the discussion—physical and monetary. “Take a look and see if there is a physical benefit for ecosystem restoration. Finding a potential benefit and attaching a potential monetary benefit could be helpful,” he said.

The project was also short on points for recreation opportunities on what would be a new lake behind the 600-foot high dam east of Fresno, behind Friant Dam. Commissioner Joseph Byrne said he hoped for more thought given to the recreation cost benefit. “Intuitively, zero benefit does not make sense. We need a higher level of confidence in the estimated recreation cost-benefit,” he said.

CWC staff stipulated that while the newly created lake behind Temperance Flat Dam would accommodate boating activity, the lack of camping, hiking, and other activities within the existing San Joaquin River Gorge neutralized any recreation benefits.

If built, the Temperance Flat Reservoir would contain 1.26 million acre-feet of new water storage above Millerton Lake, northeast of Fresno. Temperance would have helped provide a more reliable supply of fresh drinking water for disadvantaged Valley communities. It would have enabled below-surface groundwater recharge, addressed extreme land subsidence and provided critical help to farmers facing severe groundwater restrictions due to the Sustainable Groundwater Management Act (SGMA).

Santoyo said the SJVWIA spent more than $2 million on the California Water Commission application, utilizing what he said were the most qualified engineers to develop the technical data required by Commission staff. The U.S. Bureau of Reclamation, which administers California’s Central Valley Project for the U.S. Department of the Interior, has invested more than $38 million in studying the project. Santoyo said those studies supported the finding that the selected Temperance Flat site is the most preferred location for such a crucial project.

California Ag Today2018-05-03T15:42:58-07:00May 3rd, 2018|

Chlorpyrifos Under More Scrutiny in California

California Regulators Pursuing Health Protections for Chlorpyrifos

News Release

The California Environmental Protection Agency (CalEPA) announced recently that both the California Department of Pesticide Regulations and the Office of Environmental Health Hazard Assessment are pursuing health protections on one of the most widely used agricultural pesticides in the nation, chlorpyrifos.

The Department of Pesticide Regulation (DPR) released an updated draft risk assessment for public comment. This action marks the start of a public and scientific review of the document, which could lead to increased restrictions on chlorpyrifos statewide. DPR is currently developing interim restrictions on use of the pesticide and recommendations will be made to county agricultural commissioners next month.

In addition, the Office of Environmental Health Hazard Assessment (OEHHA) is referring chlorpyrifos for potential listing as a developmental toxicant under Proposition 65. OEHHA recently posted an announcement that the state’s Developmental and Reproductive Toxicant Identification Committee will consider the listing of chlorpyrifos at its next public meeting.

“While chlorpyrifos has been protecting crops for more than 50 years, new information in the scientific community leads us to believe the level of risk it poses is greater than previously known,” said CalEPA Secretary Matthew Rodriquez. “We need to better understand the science to ensure our actions protect public health. The actions we are taking today reflect our commitment to the health and safety of all Californians, and the environment.”

Department of Pesticide Regulation

DPR scientists believe chlorpyrifos may pose a public health risk as a toxic air contaminant based on its assessment of the latest studies in the scientific community. However, this new finding, indicated in the updated draft risk assessment has not been peer reviewed and must go through a public comment period and be independently evaluated by other scientists.

On September 15, DPR will hold a public workshop on the updated draft risk assessment at the Pesticide Registration and Evaluation Committee meeting in Sacramento.

After the 45-day written public comment period, which began August 18, DPR’s updated draft risk assessment will go before an independent panel of nine scientists known as the Scientific Review Panel (SRP ). The thorough review process, which may ultimately lead to more restrictions on use, may conclude in December 2018.

Next month, DPR will provide county agricultural commissioners with specific interim recommendations, including:

Increasing distances between sites where the chemical is applied and sensitive locations, such as homes and schools. These would be specific to each type of application method.
New restrictions on methods used to apply chlorpyrifos.

Office of Environmental Health Hazard Assessment

OEHHA will soon open a written public comment period on scientific materials that describe the evidence for the developmental toxicity of chlorpyrifos. OEHHA will provide the materials and the written public comments to the Developmental and Reproductive Toxicant Identification Committee. The committee is an independent panel of 10 scientific experts that determines whether chemicals are added to the Proposition 65 list as causing birth defects and other reproductive harm. The committee will also consider public comments presented at its November 29 meeting.

If the committee adds chlorpyrifos to the Proposition 65 list as a developmental toxicant, businesses that knowingly cause exposures above minimum levels must provide a Proposition 65 warning.

DPR’s updated draft risk assessment and other documents relating to chlorpyrifos are available at:http://www.cdpr.ca.gov/docs/whs/active_ingredient/chlorpyrifos.htm

OEHHA’s notice of the November 29 meeting of the Developmental and Reproductive Toxicant Identification Committee concerning chlorpyrifos is available at: www.oehha.ca.gov.

California Ag Today2021-05-12T11:05:16-07:00August 21st, 2017|

EPA Reviews Agricultural Pyrethroids

Pyrethroid Products Reviewed

By Brian German, Associate Broadcaster

Pyrethroids are synthetic chemical insecticides that are included in more than 3,500 registered products, with many of those being used in agriculture. Every 15 years, the Environmental Protection Agency is required by congress to review all registered pesticides. They received their first-ever review evaluating how they impact fish and aquatic plants.

John Cummings is the Registration and Regulatory Affairs Manager for FMC, a diversified chemical company that has been serving the agricultural community for over a century. “We are very concerned with the content of that risk assessment – that they have identified that there is high-risk concerns to certain aquatic organisms, not necessarily fish or anything like that, but small aquatic organisms,” Cummings said.

The underlying purpose of these kinds of reviews is to ensure public safety, especially when reviewing products used in ag production. “They’ve done a very high level, simple, cursory risk assessment that has identified these concerns,” Cummings said.

During the past decade, the use of pyrethroids has increased, as the use of organophosphate pesticides continues to decline. That is due to their higher toxicity to birds and mammals when compared to pyrethroids. Cummings expressed his concern regarding the data that the EPA bases their decision on. “There’s been other actions by EPA recently around the use of the best available data and the best science around risk assessment. … The EPA should be using the best science to make the right regulatory decisions while protecting the environment,” Cummings said.

Through their industry consortium, the Pyrethroid Working Group, FMC is in the process of putting data together that they hope the EPA will take into consideration. Cummings explained that their research will “make it more real world while still conservative and protecting the environment. It’s more real world and typical of how these products are used.”

Pyrethroids are a broad-spectrum insecticide that have shown tremendous success in controlling a variety of different insects considered to be economically important to the ag industry. “Pyrethroids are a very important element of both integrated pest management as well as resistance management. Growers today are facing very complex insect control problems, and it’s necessary to have many tools in the tool box,” Cummings said.

“I think EPA needs to understand how important it is to consider the benefit of these to production agriculture as well as society, in feeding the world,” Cummings concluded.

The public comment period for the EPA’s risk assessment has been extended to March 31st.

Ag Stakeholders are urged to comment at http://www.defendbifenthrin.com

Patrick Cavanaugh2021-05-12T11:05:43-07:00February 26th, 2017|

Postcard Campaign to Stop Additional Pesticide Regulations Near Schools

Call to Growers: Join Postcard Campaign to Stop Additional Pesticide Regulations Near Schools before Friday, Dec. 9

By Brian German, Associate Broadcaster

Proposed DPR Regulations

“The proposed California Department of Pesticide Regulation (DPR) further restricting growers from applying crop protection products near schools is unnecessary,” noted Kelly Covello, president of the Almond Alliance of California, which advocates and lobbies for the almond industry.

“Basically, this proposed rule is going to add a layer of unnecessary regulation. It proposes restricting pesticide applications within a quarter mile of schools and daycare centers between Mondays and Fridays, 6am to 6pm,” said Covello. She noted there are already regulations in place to protect both the community and the applicator.

Likewise, Colleen Cecil, executive director, Butte County Farm Bureau, said, “We’re very confident in the regulation that currently exists and the responsibility that landowners take when it comes to spraying anywhere. There are rules in place and these rules work.”

“The environmental community has done a bang-em-up job at fear-mongering, period. They believe they can take pictures of kids next to fields and make the farmer the bad guy. Nothing can be further from the truth,” Cecil said.

“Nothing is more important than the health and safety of people,” noted Ceil. “As stewards of the land, farmers already do everything in their power to mitigate risks involved in agriculture and the application of pesticide is no exception.” Cecil added, “The puzzling part of the proposed regulation is that DPR have stated themselves that they were ‘unable to quantify the benefits’ and that ‘any health benefits of the prohibitions are unknown.'”

Postcard campaign to stop additional pesticide regulation near schools

Call for Growers to Take Action

“We have joined California Farm Bureau Federation (CFBF) and other organizations that are working on this issue,” said Covello. “One of the main calls to action for grower engagement with DPR is CFBF’s postcard campaign. If you would like postcards to share with your grower network, please email staff@almondalliance.org or simply print from the Postcard PDF document and mail directly to DPR (contact information is on the last page of the PDF document). A high volume of input will be critical.

Growers can also sign and share CFBF’s petition. Farm Bureau will deliver the petitions to DPR before the comment period closes on December 9.

“This [proposed regulation] really is unnecessary,” said Covello. “There is no science. There is no injury or illness that has sparked the need for new regulations. We are really hoping we can get our growers engaged by sending in a postcard or sending in comments. Again, growers can contact the Almond Alliance by email at staff@almondalliance.org and by phone at (209) 300-7140.

“We would be happy to get you a postcard,” Covello said. “We can also email it to anyone. So please help us in this fight to stop unnecessary regulation.”

Almond Alliance of California

Butte County Farm Bureau

California Department of Pesticide Regulation

California Farm Bureau Federation

California Ag Today2021-05-12T11:05:43-07:00December 5th, 2016|

Water Diversion Plan for Fish, Part 2

Grober: It Won’t Help to Vilify People

Part 2 of 2-part Series

By Patrick Cavanaugh, Farm News Director

California Ag Today conducted an extensive interview with Les Grober, assistant deputy director, State Water Resources Control Board (SWRCB, Water Board) Division of Water Rights. We published Part 1, “Water Board’s Point of View on Increasing San Joaquin River Flows,” on November 28, 2016.

http://yn2.000.myftpupload.com/increasing-san-joaquin-river-flows/

Grober explained the Water Board’s water diversion plan to adjust the flow objectives on the San Joaquin River to protect fish and wildlife. The plan, specifically, is to divert 40 percent of water flows from the Stanislaus, Tuolumne and Merced Rivers that flow into the lower San Joaquin River.

California Ag Today: We asked Mr. Grober to explain how the Federal Water users on the Westside of Fresno and Kings Counties were granted a mere 5 percent allocation this year, and why many did not receive their full 5 percent.

Grober: The 5 percent allocation is due to the junior water rights of those growers and to the interconnections of so many things — priority of right, hydrologic conditions, and minimal protections or fish and wildlife. Anyone who thinks it’s all due to fish is simplifying a very complex situation.

California Ag Today: Regarding the water hearings that are scheduled over the next few months, is the Water Board trying to give information to farmers and others would be affected by the decreased water should the Water Board’s proposal go through?

Grober: The ultimate goal is to make people even more prepared to provide comments to the Board at the scheduled hearings. It’s part of a public process where, if we did not get our economic figures right, we want [accurate] information from the stakeholder to make it right.

We thought we did a good job in an economic analysis on how we thought the proposed taking of 40 percent water would affect the communities and farmers. We clearly heard from many people who thought we did not do a good job, and my response is: Good, show us why, make a proposal and take it to the Water Board hearings, and then we can adjust it.

California Ag today: The Water Board has a 3,100-page report all about saving the salmon.

Grober: The reason we have a big report is because we are making a proposal and we’ve shown our work. Although it is work for people to look at it and review it, we have tried to make it easy so that people can see if we have made mistakes, if there are things that are left out or if we have made an incorrect assumption. That’s why we’ve shared it with everybody and here’s your opportunity for setting us straight.

It won’t help to vilify different people who are making good use of the water or to vilify or disparage the implementation of our laws and what we are required to do. We have a great process I think, as hard as it is, a public process where we can work these things out in the open, just to use it and deal with each other professionally.

-Les Grober, assistant deputy director, State Water Resources Control Board (SWRCB, Water Board) Division of Water Rights

California Ag Today: We are sure you are getting a lot of information from farmers and city leaders about this not being a good use of the water.

Grober: These problems are not so simple that they could be reduced to a sound bite. I think we would have solved the salmon problems by now, but because we are in the drought situation, we are dealing with a precious resource, which is water. Everybody wants the water but there’s not enough to do all the things we would like to do with it.

California Ag Today: But there are many people in California who feel that more water for fish instead of farmers is reprehensible.

Citrus Tree devastated by drought.

Grober: It won’t help to vilify different people who are making good use of the water or to vilify or disparage the implementation of our laws and what we are required to do. We have a great process I think, as hard as it is, a public process where we can work these things out in the open, just to use it and deal with each other professionally.

California Ag Today: But we’ve heard from experts that have been studying this, that the increased flows have not really helped these species. Do you have proof that they have?

Grober: It’s hard to show proof one way or the other because recently we have not increased flows to see what effect it would have. That seems to be a notion that is out there, that we have somehow done something to increase flows in recent years, and that’s simply not the case.

If anything, flows have gone down. And in the recent drought years, as I said, even the minimal flows that were required were adjusted downward. You would have to show me that evidence that flows have gone up and there has been no response to those higher flows. I do not believe that there is any.

California Ag Today: So, the Water Board wants 40 percent of unimpaired flows?

Grober: When we say the requirement is 30 percent to 50 percent of unimpaired flows, it is 30 percent to 50 percent of that amount, which means just the opposite. It means that 50 to 70 percent of [flows] for February through June would be available for consumptive use.

That is frequently misunderstood and turned around. That is still from February through June, so it means more than 50 to 70 percent since other times of the year this water is available for consumptive use.

California Ag Today: Is the Water Board looking at the fact that if the water is needed for the species, it is going to force these growers to use more groundwater? That is a direction in which we do not want to go, especially in a region that has not yet had critical overdrafts. How does the Water Board look at that domino effect forced on these growers in order to survive, stay in business and produce the food in this major Ag production region?

Grober: Implementing that 30 to 50 percent of unimpaired flows would mean less surface water available for diversion. So our analysis of the potential environmental effects and overall effects of the program, based on recent drought information and other information, shows we would see increased groundwater pumping.

California Ag Today: Is the increased pumping weighted at all in the proposal, because overdraft groundwater pumping is not sustainable?

Grober: By our analysis, the area is already in overdraft.

California Ag Today: What? Why would there be overdraft pumping in an area that has great irrigation districts such as Modesto and Oakdale Irrigation Districts delivering surface water? We did not think growers in those districts would be overdrafting.

Grober: Sure. Within those irrigation districts themselves, they are not overdrafting. That’s why the analysis we do goes into that level of detail. The irrigation districts that already have a source of surface water actually apply much more water than they need just for the crop, so they are recharging groundwater within those districts, and even with this proposal, would continue to recharge groundwater. It is all those areas outside of those districts that don’t have access to surface water that are pumping groundwater.

California Ag Today: There is a lot more pumping of groundwater on the east side near the foothills.

Grober: Based on the information that we have, the total area — not just the districts that have access to surface water — but the total area, is already overdrafting groundwater. And there are many areas on the east side of these districts now, up into areas that were previously not irrigated, converting now to orchard crops. So with the information we have, there are large areas of production using water from the basin. The entire area is to some extent pumping more groundwater than there is recharge.

California Ag Today: We’ve been concern about this.

Grober: That’s why the Sustainable Groundwater Management Act (SGMA) is going to be good, because the local areas are going to have to get on top of that information and on top of the management.

California Ag Today2016-11-30T10:25:24-08:00November 29th, 2016|

Safe Food Alliance Helps Farmers Cope with MRL Disharmony

California Farmers Cope with MRL Disharmony

By Patrick Cavanaugh, Farm News Director

California farmers are careful with crop protection products because they know the importance of producing safe and wholesome food for their customers across the nation and in their export markets. “However, I think that there are some real challenges facing growers in California today,” said Thomas Jones, senior analytical services director for the Fresno-based Safe Food Alliance.

“As growers send their commodities around the world, they’re facing increasing challenges of knowing the right chemicals to apply and at what levels. We have our own strict regulations within California, if needed, [that govern] not only the application but also the maximum residue levels (MRL) or tolerances allowed for various crops,” said Jones.

Thomas Jones, senior analytical services director, Safe Food Alliance

“That’s also carried onto the federal level; we have very strict EPA regulations. But as we [export] into other countries, they may have entirely different regulations,” said Jones. He noted this could be confusing not only to farmers, but also to registrants of crop protection materials because there is a lack of standardization of MRLs in different countries.

“Historically, there was the CODEX system, a UN-based system geared towards a more international standard for pesticide residues. It was very thought out, and very scientifically based,” Jones said.

However, as Jones explained, many countries do not want to follow the important scientific standard. “Increasingly, we are seeing countries want to establish their own systems, their own tolerances. They may be responding to their own political pressures within their countries.”

“We are seeing a process called ‘deharmonization’ in which every country wants to establish its own positive list of what is allowed and what is not allowed in [farm] products. Sometimes, those are in agreement with U.S. regulations and California state regulations; sometimes they are not. So it is important that [our] growers know not only what is legal in this country and in our state, but also what is allowed in their target [export] markets.”

Jones commented it is now known that some of these marketers [apply] random low MRLs and keep other MRLs high on some of their own products in order to get a marketing edge. “Some of those MRLs may or may not be based on any scientific standards.”

“There are a number of great tools out there,” he said. “There are a number of great software programs. Obviously, anything that [information growers] can get out of the print media or any educational courses are really essential. It is important to work with your Pest Control Adviser (PCA), as well. It’s important that [farmers] know what they are up against, as far as growing these crops,” said Jones.

The Safe Food Alliance is available to growers to help them qualify to meet the standards in the U.S. and abroad. “We [provide] training twice a year on fumigation safety for the various processors of dried fruits and tree nuts. We focus particularly on commodity fumigations and on what treatments are allowed and not allowed. We also have a full-service pesticide-testing laboratory and are very aware of the requirements in these other countries, so we’re happy to help both processors and growers with our monitoring efforts,” noted Jones.

Featured Photo: For these California-grown peaches to be shippable to any out-of-state U.S. consumers or international export markets, they must meet scientific Maximum Residue Levels (MRLs).

C O D E X A L I M E N T A R I U S, the international food standards, guidelines and codes of practice contribute to the safety, quality and fairness of the international food trade. Begun in 1963, Codex standards are based on the best available science assisted by independent international risk assessment bodies or ad-hoc consultations organized by Food and Agricultural Organization of the United Nations (FAO) and World Health Organization (WHO). Consumers can trust the safety and quality of the food products they buy and importers can trust that the food they ordered will be in accordance with their specifications.

California Ag Today2021-05-12T11:05:44-07:00November 28th, 2016|

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