We need to tell EPA where more education and research are needed. This is very important to ag chemical manufacturers…

If there's something new or some progress being made in research, we want our fresh-market tomato and melon growers to know about it instead of waiting until after the season is completed and end-of-year reports are made.

Many of our efforts are in-season. Often a researcher works all year on a subject and then gets 20 minutes, once a year, to report on his work. We'd rather alert everyone to what's current so they know about it in real time.

We accomplish this with monthly newsletters to directors and to the Web sites for the California Tomato Commission and the California Melon Research Board.

While we keep the directors posted, we get an idea of how research is progressing, and at times I can attend a field day and report to the directors what was learned.

Keeping abreast of crop protection issues is important to development of pest management strategic plans for other minor crops in keeping with review of pesticides under the Food Quality Protection Act (FQPA).

The tomato and melon industries have been very proactive in telling the story of production agriculture to make certain the EPA and USDA understand what is critical to production of the commodities.

We meet with officials of the two agencies and also sit in on conference calls concerning chemicals under review under the FQPA.

Explain to regulators

The conference calls, 90 minutes in length, give us a chance to get on the line and explain to regulators why Diazanon, for example, is important to our industry and what alternatives are. If EPA requests additional information, we send it to them on a timely basis.

This gives the industry an essential representation. If EPA doesn't see or hear any factual material, they just assume it's not important.

One prime example of the importance of give-and-take for our California industries is that EPA officials may erroneously assume that top-of-the-label rates are being used the maximum allowed number of applications. This implies a vastly inflated amount of pesticide is being applied.

This is where our pesticide-use reporting data accumulated by the California Department of Pesticide Regulation has been very beneficial. We can reply, for example, that the DPR database shows that only 67 percent of the acreage was treated with a certain material for a certain pest. This is important because it shows a realistic, lower risk assessment than what might be assumed from maximum rates and applications. Unless EPA hears the documented facts it will make those assumptions.

Another hurdle we have in keeping the agencies informed is that maximum field size for California specialty crops is assumed to be 350 acres, as it is for Midwestern wheat or soybeans.

To be sure, no one plants a 350-acre field of fresh market tomatoes in California. We go to pest control advisors for their information on the average field size. They can talk about what is needed and viable alternatives.

Unless we can support our needs and the true risk assessment for materials, we face losing them. I've been contacted by agency officials who want to remove organophosphates and leave us the alternative of neem oil. I replied neem oil is only used on one percent of the acreage, and they wanted to know why we didn't use more of it.

That's why we need authoritative spokespeople to convince regulators why an alternative may not really be an alternative. In the case of neem oil, we have to tell them it is a contact spray, we use furrow irrigation and ground rigs can't get in wet fields to apply it, and flying it on makes it difficult to reach aphids or whiteflies on the undersides of leaves.

Better understanding

The more educated people we have who understand pest management problems and situations in the field, the better we can confront some of the issues that EPA poses. We need growers and PCAs to tell EPA why it is important we do not lose organophosphates.

EPA is attempting to cover all pesticides by 2006, and they may contact an industry in the middle of summer, the busiest season and give representatives 30 to 60 days to respond to an issue. If you miss the timeframe, you're out of luck. Unless you can tell the story, you are at the mercy of whatever EPA decides.

The pest management strategic plans are the next step. With these plans, we can propose a way to make a transition from organophosphates and advise EPA how it can help us in a regulatory way make the transition smoother.

We need to tell EPA where more education and research are needed. This is very important to ag chemical manufacturers so they know which chemicals are crucial to the crop. It's a win-win situation because all parties learn more about the industry.

For example, DuPont decided to stop manufacture of Benlate, and EPA responded by asking what would be done for an alternative. The industry can help by identifying the major diseases and pests of the crop.

The 10 crops with plans in progress are fresh market tomatoes, melons, pears, nectarines, plums, kiwifruit, avocados, table grapes, cherries and strawberries.

Commodity meetings

Growers, packers and PCAs for the 10 minor crops have to set up a day-and-a-half meeting for each commodity with EPA and USDA officials, farm advisors, and the research community. Almonds, wine grapes, and peaches have completed their meetings.

We want to complete this over the next 12 months. The objective is to come up with priorities and potential alternatives available to comply with the FQPA.

Each of the minor crop commodity groups needs volunteers to work on these projects, and growers and PCAs interested in taking part can contact their respective boards or commissions.

We want to identify problems and then propose solutions and seek help in getting the solutions. We need to fully disclose our story to regulatory agencies because if no suggestions for alternatives to organophosphates or carbamates are made, we will have to accept the consequences.

Real progress has been made because it appears we will be able to retain some products where we have no viable alternatives and we could show that suggested alternatives would not work under our situations.


John LeBoeuf is secretary of the California Minor Crops Council, which represents more than a dozen high-value crops in coordinating crop protection needs between growers, PCAs, researchers, regulatory agencies and manufacturers. He represents fresh market tomatoes and melons on the council.

A licensed PCA and a certified professional agronomist, he established AgriDataSensing, Inc. in Fresno in 1998.

As an independent contractor, he has coordinated research projects and grower education for the California Tomato Commission and the California Melon Research Board since 1999.

He has lived in Fresno since 1987 and has a bachelor's degree in plant science from Utah State University.