Comments in Response to the Notice of Availability of Certain Ethylenebisdithiocarbamates (EBDCs) and Ethylene Thiourea (ETU); Risk Assessments and Preliminary Risk Reduction Options (With Comments from Hawaii Farm Bureau Federation)
Date: February 18, 2005
To: Rick Melnicoe, WIPMC Director
From: Cathy Tarutani
American-affiliated Pacific Islands (API) Comment Coordinator
University of Hawaii
Honolulu, HI 96822
Re: Comments in Response to the Notice of Availability of Certain Ethylenebisdithiocarbamates EBDCs) and Ethylene Thiourea (ETU); Risk Assessments and Preliminary Risk Reduction Options Docket OPP-2004-0078
As indicated in the attached letter from the Hawaii Farm Bureau Federation, the EBDC fungicides are important in Hawaii for the economic viability of food crops (tomatoes, cucumbers, asparagus, field and seed corn, onions, watermelon, potatoes, melons (honeydew and cantaloupe), papayas and bananas). The EBDC fungicides are also important to the production of ornamentals, most importantly Dendrobium orchids and also other orchids, cut foliage, roses, poinsettias and a number of lei flower crops. EBDC fungicides are also used by the landscape industry and on golf courses.
Microsoft Word document (12 pages)
Comments submitted by:
Dr. Michael Kawate
Phone: (808) 956-6008
Cathy Tarutani
Phone: (808) 956-2004
Department of Plant and Environmental Protection Sciences
3190 Maile Way, St John 307
University of Hawaii
Honolulu, HI 96822
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Phone: (808) 848-2074 • Neighbor-Islands: (800) 482-1272 Fax: (808) 848-1921 • Email: hfbf@hfbf.org |
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February 11, 2005 The Hawaiian Islands are blessed with year round sunshine, subtropical temperatures and rainfall which allow many different types of organisms to exist year round. This makes for a climate where produce production can occur for 365 days a year. It also is a climate that favors the proliferation of many different types of pathogenic organisms, especially fungal diseases. EBDC products are critical to the continued successful production of the crops for which it is labeled. The range of diseases controlled by EBDC products includes: powdery mildew, late blight, early blight, anthracnose, Alternaria leaf spot, Cercospora leaf spot, downy mildew, leaf mold, Septoria leaf spot, gummy stem blight, Helminthosporium leaf blight, Botrytis leaf blight, neck rot, purple blotch, and rust. Crops grown in Hawaii which rely on EBDC products are tomatoes, cucumbers, asparagus, field and seed corn, onions, watermelon, potatoes, melons (honeydew and cantaloupe, and bananas. Total acreage treated with EBDC products annually in Hawaii exceeds 8,000 acres (Hawaii Agricultural Statistics Service, 2003). Because of the year round disease pressure, the loss of EBDC products for crop production would increase resistance pressure on the remaining fungicides registered on crop plants. Hawaii Farm Bureau Federation understands the risks associated with the use of all pesticides but we feel that if the products are used in a manner consistent with the pesticide label then risk to applicators and workers is minimal. We support the continued registration of EBDC products for crop production in Hawaii. |
