As you are all aware, mancozeb is one of the backbone fungicides for our grape spray programs. EPA is already making changes to captan labels, and though some of these changes will be onerous, they have no impact on our ability to grow grapes in Georgia as compared to the complete removal of mancozeb labels from the grape market. I consider this an EMERGENCY for our industry, and I suggest that each of you write a letter to EPA concerning this potential action (see below for instructions). Also, note the survey that has been developed as well. The deadline for comments is 16 September. Mancozeb is a critical fungicide for downy mildew, black rot and other diseases of grape. It is also a critical resistance management tool, and without it, we will have major issues with resistance development in the fungicides that remain. I do not mean to sound alarmist, but I truly do not know that production of Vinifera and hybrid grapes will be possible in our environment if mancozeb is removed from the market. The situation is that serious in my estimation.
The below information was just released by the National Grape Research Alliance in the newsletter developed by Donnell Brown. I hope many of you will have received this already, but in particular, the below article by Katie Gold (Cornell University) describes in perfect detail what is happening, why it is happening, and the actions that you should take immediately to let EPA know your concerns and the impact that this will have on your vineyard operation. The turnaround time is short, but please act now.
EPA Considers Delisting Mancozeb for Use in Grape By Katie Gold, Cornell Grape Pathology
| The US Environmental Protection Agency (EPA) has proposed to cancel the use of mancozeb, a multi-site fungicide commonly used to control Phomopsis, downy mildew and black rot, in grape due to potential post-application worker exposure hazards. The public comment period on this proposed interim registration review decision (PID) closes on September 16, 2024. If this change concerns you, you’re encouraged to click to submit comments to the EPA.(See more about comments below.) Cornell Grape Pathology is conducting a survey to better understand grape grower habits around the activities EPA cites as risk factors in its decision. All US grape growers are encouraged to weigh in on the survey by September 6, 2024. Why is the EPA re-registering mancozeb? The Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) is the Federal statute that governs the registration, distribution, sale and use of pesticides in the United States. Recently the EPA announced its intention to come into compliance with the endangered species act, which has led to a FIFRA re-registration review of many multi-site fungicides, including ziram, thiram, febram, captan and now mancozeb. Why grape but not other fruit crops? The EPA is proposing to cancel mancozeb in grape because of potential post-application worker health hazards. There are specific activities in grapevine production that yield post-application hazards above the EPA’s acceptable threshold after a single mancozeb application (at maximum single application rate of 3.2 lb AI/acre). They include tying/training, hand-harvesting and leaf-pulling up to 45 days, and girdling and turning-up for 72 days post application. The EPA has decided that imposing a restricted-entry interval (REI) of such length would preclude the use of mancozeb because it would impede growers’ ability to conduct other production activities. A lower single application rate (e.g., 2.5lb AI/acre) would still result in risks that could not be addressed with a feasible REI. Other orchard crops do not conduct these activities and are thus able to accommodate the mitigation practices (4-day REI and ban on hand-thinning) the EPA deems necessary to sufficiently reduce post-application worker health hazards from mancozeb. How did the EPA come to this decision? The EPA is by mandate required to do a cost-benefit “BEAD” analysis. The Biological and Economic Analysis Division (BEAD) methodology for mancozeb involves assessing the benefits of its use at the acre level and reflecting how growers make pest control decisions. This analysis includes reviewing mancozeb usage data, identifying use patterns, target pests and the attributes that make it valuable for pest control. BEAD also evaluates the biological and economic impacts of using alternative pest control strategies if mancozeb were unavailable, considering factors like cost, resistance management, and crop yield or quality. The methodology relies on data from university extension services, USDA, grower surveys, public comments and professional knowledge, with pesticide usage data provided by sources like Kynetec USA Inc. Does the EPA understand the impacts of banning mancozeb in grape? In its BEAD analysis, the EPA cites the following anticipated impacts: “With the loss of mancozeb in grape production, BEAD anticipates that at a minimum, grape growers east of the Rocky Mountains will experience an increased cost of pest control as growers will need to integrate more single-site fungicides. The growers would have to rely primarily on captan to control Phomopsis disease and downy mildew and single-site fungicides (e.g., myclobutanil) for effective control of black rot increasing the risk of resistance. Further, single-site fungicides are generally more expensive than mancozeb (Kynetec, 2021a), resulting in additional costs of fungicide treatment.” What happens now? The EPA is accepting public comment on its proposed interim decision until September 16, 2024. If you wish to contribute a comment to the EPA, you can type it in online or upload a formatted letter* here. And if mancozeb is delisted… What other products are available to control phomopsis, downy mildew and black rot in lieu of mancozeb? Dave Combs, a research support specialist inthe Grape Sensing, Pathology and Extension lab at Cornell AgriTech,published this guide to what grape disease management will look like in a post-broad-spectrum world earlier this year. Dr. Kaitlin (Katie) Gold is an Assistant Professor of Grape Pathology at Cornell University. She holds the primary research and extension responsibilities for grape disease management for New York State and leads the Grape Sensing, Pathology and Extension lab at Cornell AgriTech (GrapeSPEC). This article is an excerpt of Katie’s longer piece; read it here. *Editor’s note: For inspiration on what to write in your own formal comments to the EPA, consider this sample letter. (Click and a Word file will download.) There’s also more guidance in the full text of Katie’s article. See also this excellent report from The Ohio State University Extension Fruit Pathologist Melanie Lewis Ivey. |