2008-04-01 3-C SubmittalCity of Alameda
Inter-department Memorandum
T~: Honorable Mayor and Councilmembers
FRGM; Lara weisiger, City Clerk
DATE: March 31, 2008
SUBJECT; APRIL ~, X008 COUNCIL MEETING PRESENTATI -
GN #3 C
Attached are materials provided by T'Hud Weber re ardin the '
g g Light Brown Apple Moth
presentation. A binder of additional materials was also submitted and is on f a
ile ~n the City Clerk s
office. Please feel free to contact me with any uestions. Thank ou.
q y
cc: City Manager
City Attorney
Assistant City Manager
RE: Aerial Pesticide Spray of the Light Brawn Apple Moth and the Citizens of the City of
Alameda
Dear Members of the Alameda City Council,
I am a very concerned citizen of Alameda opposed to the planned aerial spraying of pesticides in the
Bay area. 1 feel there is a lot of misinformation currently being distributed by the California
Department of Food and Agriculture and would like to present same information offering a
contrasting point of view.
Please find enclosed:
General information:
one-page summary of the issue
Dne-page summary of why LBAM is not an emergency
Two health documents:
Executive summary of the report of 643 health complaints filed in Monterey and Santa Cruz counties
A lawyer's letter to the Santa Cruz health agency detailing health issues with the spray and lack of
infrastructure for reporting of health complaints
Three documents about the need for and effectiveness of the spray;
• Testimony of entomologist Dr, James Carey, UC Davis, to the Assembly Agriculture Committee in
which he reports that LBAM has likely been here 30-50 years and cannot be eradicated
• Report by botanist and UC Santa Cruz Arboretum Executive Director Dr. Dan Harder on LBAM in
New Zealand in which he reports that LBAM does no significant damage to crops or native plants and
is 80-90% controlled by natural predators in NZ and that those same natural predators are present in
CA.
• Dr. Daniel Harder and Jeff Rosendale, authors of "Integrated Pest Management Practr'ces for the Lrg~tt
Brown Apple Moth in New Zealand.' ~mplicatxons for California," responding to comments on their
report by California Department of Food and Agriculture ~CDFA}Primary Entomologist Sevin
Hoffman and Max Suckling of New Zealand Hort Research.
Sample Resolution
• Resolution similar to one used by Albany City Council
with all due respect, it will be difficult for members of the public to respond effectively to the CDFA's lengthy
presentation when they only have 3 minutes each of rebuttal time, At the next meeting I would like to ask the
council to entertain a presentation of equal length to that by the CDFA, by members of the public who have
researched the safety, effectiveness, and need for the spray sa that the council can get a balanced understanding
of the issue.
l appreciate your tame and hope that you will take my concerns into consideration.
Please feel free to contact me with any questions you may have.
' kind ~ ds,
~.
T~ . ud eber, citizen o Alameda
ZZ 1 Pacific Ave. Apt # 1
Alameda, CA 945x1
pixie 1 uscious~a,~mail.com
Q~~i
Tel, 510-Z$Z-4319
Light Brown Apple Moth Aerial Pesticide Spray/Eradication Program
What is the LRAM Eradication Program?
The California Department of Food and Agriculture (CDFA) plans to resume "emergency" aerial
pesticide spraying for the Light Brown Apple Moth LBAM} in summer 200$. The program
began in 2007 in Santa Cruz and Monterey counties using apheromone-based pesticide dispersed
from low-flying planes in microscopic plastic capsules. In 2048, CDFA plans to spray the Central
Coast again along with the San Francisco Bay Area. The spray is planned to repeat monthly for
up to 5 years or indefinitely until LBAM is eradicated. The LBAM eradication program also
involves other treatments, including painting of telephone poles with permethrin, a carcinogenic
and neurotoxic pesticide that is also toxic to honeybees and aquatic species. CDFA has not
Completed an Environmental impact Report on the spray program.
What are the Health Risks of the Spray?
More than 600 in Santa Cruz and Monterey County reported adverse health reactions following
the spraying in 2007. The active ingredient in the spray, a synthetic math pheromone, has not
been tested for long-term human toxicity. Dther ingredients in the spray are carcinogenic,
mutagenic, reproductive effectors linked to birth defects, liver toxins, dermal irritants, unsafe to
inhale, and toxic to aquatic species. The microscopic plastic capsules in which the pesticide is
sprayed break down over 30 days, releasing the pesticide. They are small enough ~~~ 0 microns}
to be inhaled into the deep lung where they cannot be expelled. The aerial spray poses particular
risk to sensitive populations: children, the elderly, pregnant women, and those with chronic
disease, as well as to those in the homeless population who do not have access to shelter and
those who work outdoors.
The Moth Does 1Vot Threaten Agriculture ar dative Plants
CDFA has repeatedly stated publicly that LBAM has done no documented crop damage in
California. Entomologists have testif ed that, based on its range, LBAM has likely been in
California for 30-50 years. A recent scientif c report on LBAM in New Zealand states that LBAM
there "is considered a minor pest that does not cause economically significant crop damage or
have detrimental effect on native flora" and that LBAM is $0-90% controlled by natural predators
in New Zealand, and the same predators are present in California, including birds, spiders, wasps,
flies, beetles, lacewings, and earwigs. These facts, taken together, indicate that there is no
"emergency" and likely no need to use pesticides to control LBAM.
Eradication willlVot Work
Even if LBAM posed a problem in the state, scientists say that eradication has no chance of
success given the range aver which LBAM is established and the fact that pheromone spray has
never been used successfully to eradicate a pest.
What E,f~ forts are Under Way to Stop the Spray?
Seven State Assembly bills and resolutions (AB 2892, AB 2763, AB 2760, AB 2765, AB 2764,
SCR 87, ACR 117}, two pending lawsuits with more expected, numerous local governments and
organizations taking official stands opposing the spray, and a number of other activities at the
local, state, and federal levels.
Where Can I het More Information?
More information, including scientif c reports and other background documents, is available from
several sources, including: StoptheSpray.QRG, www.pesticidewatch.or~
eastba info sto thes ra .or info sto then ra marin.or sfcontact cassonline.or
VVhy is LBAM not an Emergency?
Dr. James Carey, entomologist and invasive species expert at UC Davis, recently testified before the
California Assembly Agriculture Committee that LBAM could not have spread to its present range in
California unless it had been in the state for 34-50 years.
The California Department of Food and Agriculture (CDFA} has repeatedly stated that no crop damage
has been attributed to LBAM in the state.
If LBAM has been present here for decades and no damage has been observed, there is little justification
far claiming that LBAM poses a threat to crops and native flora.
Dr. Daniel Harder, botanist and Executive Director of the UCSC Arboretum, recently released a report
that documents that "LBAM is considered a minor pest that does not cause economically significant crop
damage or have detrimental effect on native flora" in New Zealand where it has been an established
exotic species for more than 100 years.
The Harder report also notes that LBAM in New Zealand is SO-90% controlled by natural predators --the
same generalist ~i.e., not specifically co-evolved only to prey on LBAM} natural predators of LBAM that
exist in California, including birds, spiders, trichogramma wasps, lacewings, and several others.
Putting together Dr. Corey's analysis of LBAM's tenure in California with Dr. Harder's research on the
lack of damage from LBAM in New Zealand and the presence of natural predators far LBAM in
California, it seems clear that California's ecosystems and natural predators have likely already adapted to
LBAM and we may well have been cohabiting with it for decades without noticeable effect.
Thus, there is no justif cation for an emergency campaign of aerial spraying against LBAM.
V~ith regard to the State's claim, based on a set of unreviewed CDFA trapping data from 2005 in which
na LBAM were reportedly detected, that LBAM has not had time to damage crops because LBAM
arrived in the state only last year, Dr. Corey's Agriculture Committee testimony states:
The argument that LBAM is a recent invader because no populations were detected by the CDFA in
2005 cannot be reconciled with LBAM's current widespread distribution. This recent invader
argument is simply not credible. For the `recent invader' argument to be valid, the assumption would
have to be made that the pest is capable of spreading 4,000 to 8,000 square miles annually or,
alternatively, from 50 to i00 miles outward per year. However, there is no precedent far this rate of
spread for any insect. Not even close.
contact; Nan Wishner, Chair
City of Albany integrated Pest Management Task Force'
510-524-5185p.k
' Dr. Corey's testimony is available on Assemblymember John Laird's website at:
z ttP :Ildemo crass.assembly. ca, govlmembersla271moth. htrn
Dr. Harrier's paper Integrated Pest Management of the Light Brown Apple Moth rn ~'ew Zealand.• Implications for
California is available on Assemblymember Jahn Laixd's website at:
http:lldemocrats.assembly.ca.govlmembersla271moth.htm
COMPLAINTS OF ADVERSE REACTIONS TO AERIAL
SPRAYING IN MONTEREY AND SANTA CRUZ COUNTIES
Mike Lynberg
P.D. Box 1612, Pebble Beach CA 93953
David Dilworth
Helping Our Peninsula's Environment HOPE}
P.O. Box 1495, Carmel CA 93921
~dditionar Support by. -
CaliforniaAlliance to Stop the Spray
Coalition for Sustainable Action
Pesticide Watch Education Fund
January 3, 2005
E~ECUTYVE SUMMARY
A Review of 643 Documented Complaints of Adverse Reactions
Following the CDFA's Aerial Spraying of two Pesticides based on
Pheromones over Densely Populated Neighborhoods in Santa Cruz and
Monterey Counties in September, Dctober, and November 2007
Full report online at htto:Ilwww.lhope.orglchkmate.htm sunder "Pesticide Harm Overview"}
As of December 20, 2007 various governmental agencies and citizen groups have
received 643 documented complaints from Monterey and Santa Cruz area citizens who
believe they suffered adverse short-term reactions following the aerial spraying of
pesticides pheromones on their cities in September, October, and November 2007.
Of the 643 complaints, 509 are reported here for the first time, along with the
original 134 citizen complaints of adverse reactions following the aerial spraying of the
Monterey area in September which released to state agencies and the press in October.1
Summary of the Complaints
Citizens complained of a variety of adverse reactions immediately and soon after
the aerial spraying, including:
o Asthma attacks
o Bronchial irritation
o Lung congestion and
o Difficulty breathing and
shortness of breath
o Coughing or "wheezing"
soreness
' The total number of complaints reported in the press in September and October grew to more than 200 as
governmental representatives, referring to the adverse reactions, likely added complaints they had received
directly to the count, and referred to these in their communications (see "Laird Response to Sec.
Kawamura," dated October 16, 2007, page 4, which referenced 204 complaints}. These extra complaints
are not included in the tally of 643 referenced in this report; only the 134 complaints received through
R.eactiontc~Spra~~g~Nyahoo.com last fall, and forms sent to the related P.O. Box.
o Skin rashes (sometimes o Dizziness
severe) o Muscle aches
o Vision blurred o Body tremors
o Eye irritation
o Sore throats o Intestinal pain and diarrhea
o Nasal congestion o Nausea
o Sinus bleeding o Swollen glands and lymph
nodes in neck and under arms
o Chest pains and tightness o Feelings of lethargy and
o Heart arrhythmia and malaise
tachycardia (irregular and o Menstrual cramping, an
rapid heartbeat) interruption to menstrual
o Headaches (sometimes cycles, and in some cases a
debilitating) recommencement of
o An inability to concentrate menstrual cycles after
and focus menopause
Several people reported severe reactions, and others have required emergency
roam visits. Some said the effects of the spraying were debilitating and made it
impossible for them to focus, work, and take part in their normal activities. Many report
they have never had any similar symptoms previously.
People with less severe reactions generally said they went on with their day-to-
day responsibilities, although with diminished capacity, and did not call or visit their
doctors because they did not want to take the time or incur the expense, or could not get a
short-term appointment.
A number of people said they had left their homes during the spraying and
experienced symptoms immediately upon returning. A tourist visiting Monterey from
Pennsylvania said her symptoms appeared as soon as she got near the area after driving
north on Highway One from the Hearst Castle in San Simeon.
Some reported that several members of their families experienced unusual
symptoms at nearly the same time shortly after the spraying. Several said their domestic
animals also experienced adverse reactions. Two pets died after developing symptoms
similar to those reported by humans.
Compiaint Sources
Today's report cites 317 complaints of adverse reactions received directly by the
CDFA since the spraying began, 52 of which were detailed illness reports. It also cites
3b reports of illnesses sent by doctors to the Santa Cruz County Agriculture
Commissioner's off ce. Public interest groups received 2~0 complaints, which are
documented in the report.
Potential Complaint Duplication
Because there is no single agency and no single well publicized system for
tracking and investigating adverse reactions to the aerial sprayings, there is likely some
overlap in the 643 complaints, if people filed complaints with more than one entity.
Underreporting Breadth of Illnesses And Symptoms
The report explains why the official numbers under-report the numbers of people
with illnesses and symptoms and how complaints inherently cannot include potential
long-term adverse health effects,
Sometimes a single complaint was submitted for several members of the same family,
and on one occasion, one complaint was submitted for a family of six, all of whom
got sick.
There is evidence some people could not afford the time or expense of a doctor visit,
or could not get an appointment, while others did not know how to register
complaints of adverse reactions. Meanwhile, some health care providers were not
prepared to recognize and report possible pesticide-related illnesses or were not aware
of state law requiring them to report suspected pesticide poisonings within 24 hours.
"Midway through the aerial sprayings, the CDFA stated that the only way
complaints of illness would be taken seriously is if they were validated by a
doctor. However, I have patients who told me that other doctors refused to file a
report on their reactions, even though it is required by law."
-Randy Baker, MD, a family physician practicing environmental medicine in
Soquel
The present tally of 643 complaints does not include complaints that have been made
directly to the offices of Governor Schwarzenegger and other elected officials.
Citizen groups have asked the Governor's office to disclose this information. They
also continue to gather illness complaints through various channels, including an
email address, ReactiontoS ra in c~ ahoo.com. The number of documented
complaints count should rise as the Governor's office, city governments, and
governmental representatives pass along complaints they have received directly from
citizens. There is no law requiring these offices to forward pesticide harm complaints.
Putting Health and Safety First
Despite assurances by the CDFA that the spraying would be safe, many
community leaders remain concerned after learning of the larger scale of documented
complaints.
"While California's agriculture business is vitally important, no one, including the
Governor, I think, wants to sacrifice the health of children and other vulnerable
citizens for produce. That's why the spraying needs to stop so we can have a
thorough public process including an Environmental Impact Report."
--Tony Madrigal, Santa Cruz City Council
"The science establishing the safety of the spraying simply is not there. In effect,
this has been an experiment on a grand scale. The Nuremberg Code, which is
adhered to by the National Institutes of Health, prohibits medical experimentation
on human subjects without their informed consent. I believe the same code of
ethics should be adhered to in this situation."
Dr. Doug Hulstedt, pediatrician, Monterey
"The number of people who have reported adverse reactions is alarming, and I
believe further spraying must be halted until we can be certain it is safe."
-~ Emily Reilly, Santa Cruz City Council member
"Protecting those who are most vulnerable is a hallmark of our society, and while
the aerial spraying might not adversely impact everyone, there is reason to believe
it is harming some people, including those with chemical sensitivities, impaired
immune systems, and asthma and other respiratory ailments. The rights of these
citizens need to be protected."
-Jeff Haferman, ~Vlonterey City Council member
"Article One of the California Constitution clearly states that all people have a
right to pursue and obtain safety, and the aerial spraying of synthetic pheromones
and other chemicals on neighborhoods, playgrounds and schools could be in
violation of this right."
-Mike Lynberg of Concerned Citizens Against Aerial Spraying.
"we, as elected off vials, have a responsibility in matters of public safety to make
sure that decision-making process is transparent to the citizenry, Thus far, the
state has not lived up this standard."
-- Ryan Coonerty, Santa Cruz Nlayor
"Far more effective non-spraying alternatives exist. Aerial spraying has been
called the `least effective' way to control the light brown apple moth because at
least 99 percent of the spray has no effect on the widely dispersed moths at all. A
more effective and less costly solution is targeted, pheromone-scented sticky
traps2, which the state has used to trap essentially all the 9,00o moths they've
caught in California so far."
-David Dilworth, Executive Director, Helping Qur p'eninsula's Environment
~H~~E)
~ Targeted pheromone-baited Sticky Traps are the only solution to catch and kill the LBA moths.
Twist ties and aerial spraying do not catch or kill the LBA moths. "Targeted" sticky traps are used only
where the moths are found. This is in sharp contrast to saturation trapping to cover an entire region. For
more detailed information on this effective and less expensive solution please see ~hope.orglcheckmate
"Given the number and seriousness of the health complaints, and the heavy
presence of the Checkmate LBAM F capsules in the river and along Cowell
Beach after the spraying, I think there is reason to believe that a line has been
crossed and that the aerial spraying is not environmentally responsible, possibly
violating the authority under which it was initiated.
- Ed Porter, Member of the Santa Cruz City Council
"CDFA has undertaken aerial spraying under the pretext of an emergency. Clearly
there is no emergency in the legal sense. An emergency is a sudden and
unexpected occurrence threatening life and property. There is no way in law that
the LBAM situation can be considered an emergency."
- Ed Porter
"Unfortunately, many people did not know how to register complaints of adverse
reactions, and primary care health providers were not adequately instructed how
to recognize and report possible pesticide-related illnesses among their patients.
Also, citizens and health practitioners were assured by the CDFA that the
spraying would not make anyone sick, so it's possible that many attributed their
adverse reaction to other causes.
Randy Baker, MD, a family physician who practices environmental medicine in
Soquel
"Midway through the aerial sprayings, the CDFA stated that the only way
complaints of illness would be taken seriously is if they were validated by a
doctor. However, I have patients who told me that other doctors refused to file a
report on their reactions, even though it is required bylaw."
-Randy Baker, MD
"Unfortunately, there is very little in the way of objective testing doctors can do
to tell if a complaint actually is related to chemical exposures. And many people
could not afford the time or expense of going to a doctor, or could not get a timely
appointment. Should their complaints be ignored?"
- Randy B aker, MD
METHODOLOGY: HOW THE COMPLAINTS WERE COMPILED
Mike Lynberg, a husband and father of two in Pacific Grove, who is also a bestselling
author and business writer, was concerned about the safety of spraying untested
pesticides on large urban populations and started Concerned Citizens against Aerial
Spraying in September 2007. Then, when some of his friends and neighbors had adverse
reactions to the aerial spraying, he began to collect and compile their complaints, and to
seek records of complaints from other sources.
Collected and compiled by Lynberg, this report includes or makes reference to;
317 citizen complaints submitted by citizens directly to the CDFA; 52 of them in
the form of detailed illness reports, and 265 in the form of phone calls, email
messages and other correspondence. These 317 complaints, disclosed to Lynberg
by the CDFA on December 20, 2007, are the total received so far by the CDFA
following all three rounds of spraying in Monterey and Santa Cruz Counties.
294 citizen complaints of illnesses have so far been received by public interest
groups, including via a dedicated email address, ReactiontoSpraying~c~~yahoo.coin,
a dedicated P.D. Box, and two citizen petitions. Qf the complaints, l34 followed
the first round of spraying in the Monterey area in September, and 156 of them
followed the second round of spraying in the Monterey area in October and the
first round of spraying in the Santa Cruz area in November.
36 complaints submitted by local physicians to the Santa Cruz County Agriculture
Commissioner's office following the November spraying in that county,
consistent with a law that requires physicians to report illnesses that could be
pesticide-related. These reports of illnesses are being investigated by Sean Fields,
an inspector in that office, and will be forwarded by it to the appropriate state
agencies at a later time.
While care has been taken to delete duplicate complaints in this report, there could be
some overlap ~i.e., some people might have reported their adverse reactions to more than
one entity. That overlap, to a significant degree, results from the lack of a single, well
planned and managed system for tracking and investigating adverse reactions, established
and funded by the state, and ideally undertaken by a reliable and trusted third party, and
peer reviewed by experts in the area ofpesticide-related illnesses.
Despite possible duplicate complaints, HOPE believes the known complaints are likely
just a fraction of the total illnesses linked to the spraying for the reasons described above.
Moreover, in late October, the CDFA began to say publicly that the only way citizens'
complaints of illnesses would be taken seriously is if they were validated by a doctor.
"What about people who could not afford the time or expense of going to a doctor, or
who couldn't get an appointment?" asks Lynberg. "Are their complaints not worth taking
seriously?"
Finally, the total number of complaints in this report is likely to be much lower than the
actual number of people who believed they suffered adverse reactions to the aerial
spraying because the complaints reported herein do not include;
• Complaints of illnesses received by Governor Schwarzenegger's office
• Complaints of illnesses and adverse reactions received by other elected officials
such as state and federal representatives
• Calls, messages and letters sent by people who believe they got sick to the mayors
of the city clerks of the many cities sprayed
• Complaints of illnesses received directly by the Monterey and Santa Cruz County
Health Off cers
Working with other public interest groups, Lynberg is presently working to obtain this
information so it can be publicly disclosed. In time, the total number of citizen
complaints of adverse reactions related to the aerial spraying of urban populations in
California in late 2007 could grow.
CDFA Could Spray Continuously through 200
The California Department of Food and Agriculture (CDFA} agency declared an
emergency and obtained a permit from the US-EPA to spray urban populations through
2410, as often as every 30 days, and to do so without any advance testing of the
pesticide's health harm to humans.
Three rounds of aerial pesticide spraying using two different pesticides3 occurred
late last year beginning on the Manterey Peninsula and then expanding to Santa Cruz
County. Each round involved airplanes spraying untested pesticides at high-speedo
largely over densely populated areas from 500 - S00 feet above the grounds. At that
altitude there is considerable sideways drift of the pesticides, potentially miles from the
release location.
The pesticide ingredients and concentrations are a closely held secret. Two days
after an LA Times editorial the Governor released a few of the names of ingredients of
only one of the two pesticides. The disclosed ingredients include a synthetic pheromone
3 Checkmate QLR-F and Checkmate LBAM
4160 mph.
s Crop dusting normally takes place anly a few yards above the ground and at speeds below 100 mph.
as the active ingredient, and variety of so-called "inert" ingredients. Some of the
disclosed ingredients are known to be hazardous at certain levels. Concentrations of the
ingredients and chemical residues of the manufacturing process were not disclosed. US-
EPAhas explicitly refused to disclose that information on an expedited basis.
The tiny light brown apple moth has been widely across California from Los
Angeles to Napa, including highly populated areas such as San Francisco, Berkeley and
Marin County. The LB~4 moth does not caase physical harm to people which is in sharp
contrast to the West file Virus.
6 Pesticides almost always contain chemicals that are secrets, misnamed inerts, "Despite their harmless
sounding name, many so-called inerts are dangerous chem2cals that can cause cancer, reproductive
harm, nervous system damage and other health effects." (NCAP Report "Toxic Secrets"}
RECUMMENDAT~QNS & ALTERNATIVE SULUT~UNS
There are three broad questions related to the recent aerial spraying of pesticides usin
g
pheromones and potentially toxic "inert" ingredients by the State of California on
hundreds of thousands of its citizens:
Is it necessary?
Can it be effective?
Is it safe?
Experts have expressed opposing viewpoints on whether the aerial spraying is
necessary or effective. For example, Jim Carey, a professor of entomology at the
University ofCalifornia-Davis and a respected Invasion Biology expert, has cast doubt
on whether the aerial spraying can be effective, saying the pest is too established to be
eradicated. "This thing is so widespread that there is no way that they're going to
eradicate it," said Carey m a 1Vlonterey Herald interview in December. When a pest is
not eradicatable, we can only try to control it. Pest control requires dramatically less
urgency and less draconian measures than eradication.
While the first two questions are critical, and while some experts believe the spraying is
neither necessary nor effective, this report is primarily focused on complaints of adverse
reactions to the spraying.
Dut of a deep concern for the health and safety of our families, friends and
neighbors, HQPE and those supporting this report strongly and respectfully
recommend that
I .The State of California immediately stop further aerial spraying to eradicate the light
brown apple moth, given the evidence the spraying may significantly harm human health
and 1s therefore not being done in an "environmentally responsible" way, as described in
Senate Bill 556.
2. our governmental representatives vigorously defend and uphold every citizen's
constitutional right to pursue and obtain safety, as established in the California State
Constitution, Article Qne, Section One.
3. The State of California abide by international codes of ethics pertaining to
experimentation on human subjects without their informed consent such as the
Nuremberg Code adhered to by the National Institutes of Health}, since the chemical
mixtures being sprayed have not, prior to the wholesale spraying of large urban
populations, been tested for their health effects on human beings.
4. The health complaints received so far be thoroughly investigated by an objective and
trusted thrrdparty -not by an agency or organization that serves or supports agriculture
and related interests -- and peer reviewed by panel of experts in the fields of toxicology,
environmental medicine and other appropriate disciplines. The California Dept of Public
Health may be a good start.
5. The ingredients in the products being sprayed on unwitting populations be thoroughly
disclosed, including their relative concentrations and the residues that result from their
reaction, and this data be studied by an objective and trusted third party -- nat an agency
with a clear conflict of interest and loyalty to agricultural and economic interests such as
CDFA and DPR, and peer reviewed by an appropriate panel of independent toxicologists,
physicians and other specialists.
6. The State of California prepare a thorough Environmental impact Report that includes
the findings of the investigations into the spray's ingredients and the adverse health
effects among the population, and objectively and thoroughly evaluates non~spraying
alternatives.
7. The CDFA implement non-spraying solutions to eradicate or control the light brown
apple moth, such as the targeted pheromone-scented sticky traps it has used successfully
to trap essentially all the 9,000 LBA moths found in California so far, instead of
measures that put people at risk and possibly sacrifice their health and safety for the
interests of others.
California Alliance to Stop the Spray ~CASS}
Santa Cruz, CA
December 31, 2007
Introduction
The California Alliance to Stop the Spray ~CASS} consists of organizations, health
professionals, and individuals who share the same common goal of opposing the spraying
of residential communities with pesticides without representation and consent. our
collective concern has arisen out of the fact that the LBAM eradication program utilizes a
aerosol pheromone-pesticide spray that has not undergone formal safety testing by either
federal or state agencies, that the spray has never been sprayed on humans before, that the
end goal of eradication will likely not be accomplished, and of particular concern, are the
current lack of monitoring and oversight of potential acute and long-term adverse effects
due to the spray. This communication is supported by the assigned organizations and
individuals.
Organizational Supporters
Citizens For Health LBAMSpray.org Pesticide watch
Soquel, CA Santa Cruz, CA Education Fund
Sacramento, CA
Stopthespray.org
Carmel, CA
Medical Advisors
Randy Baker, MD Sara M. Lackner, MD Art Presser, PharmD
Pacific Center for Integral Soquel, CA Professor of Pharmacy
Health University of Southern
Soquel, CA California
Los Angeles, CA
Legal Advisors
Mark Briscoe, Esq Zelda M. Lackner, Esq
Santa Cruz, CA Aptos, CA
LASS: Health Action Team Santa Cruz County Health Services Agency 1
To; Rama Khalsa
Health Services Agency Administrator
Santa Cruz County January 2, 2008
Dear Dr. Khalsa,
The individuals and organizations represented on this communication are writing
in regards to the Light Brown Apple Moth (LBAM) eradication program initiated by the
California Department of Food and Agriculture (CDFA). We are specifically concerned
that Santa Cruz County Health Services Agency (HSA) lacks any process for a formal
post spray-related adverse effects data collection system. It is also our belief that Santa
Cruz County health care providers should be better informed of the potential for adverse
effects of the pesticide-pheromone spray. We feel that a formal process for collecting
data. and educating the public, as well as health care providers is especially important for
the reasons stated below. For your consideration, we have provided documentation
supporting our reasoning.
1. The spray being administered was exempted from formal safety evaluations by the
Environmental Protection Agency (EPA} and was only approved for use under an
agricultural emergency declaration in the State of California; neither short- or
long-term safety of this aerosol pheromone-pesticide spray has been sufficiently
established';
2. There is data establishing that the disclosed ingredients in the LBAM spray are
potentially carcinogenic, mutagenic, teratogenic, hepatotoxic, and tumorigenic
even at dilute concentrations (see supporting data attached)";
3. A complete listing of the ingredients of the spray solution, and the concentrations
to which residents will be chronically exposed has not been fully disclosed making
an independent assessment of safety impossible;
4. A large percentage of the post-spray adverse effects reported by individuals in
Monterey and Santa Cruz Counties are consistent with the known adverse effects
associated with the spray or its ingredients"' (see supporting petition and comments
attached};
5. Santa Cruz county residents will be chronically exposed to the LBAM spray
solution continually for a minimum period of 2 years and aState-projected period
o f from 3 -10 years;
6. The contents of the spray are designed to last from 30-90 days and spraying will
continue every 30 days. This process will result in greater and greater overlapping
concentrations of pesticide solution and continued exposure that is greater than the
individual exposures estimated by the State;
7. No data exist of the potential adverse effects of acute or chronic exposure of this
spray on pregnant women and children in schools and day care centers within the
spray zones;
CASS: Health Action Team Santa Cruz County Health Services Agency 2
8. County physicians are not sufficiently aware that this spray solution has never
been applied to residential areas, that formal safety studies were not conducted,
and that the solution consists of potentially toxic compounds in addition to the
pheromones, which many believe are benign.
The CDFA began this program on September 9t" of this year by spraying
residential areas of Monterey County with the pheromone-pesticide Checkmate LBAM'~
see attached}. After the first two sprays, there were more than 200 reported cases of
adverse health reactions to the spray in Monterey County. To date, there have been more
than 650 adverse effects reported for residents in Monterey and Santa Cruz Counties.
Underreporting of any adverse event is typical among populations. In medicine, for
example, it has been estimated that as few as 10% of adverse effects to prescription
medicines experienced are reported by physicians. The Department of Pesticide
Regulation's own Consensus statement attached} similarly states;
"DPR's surveillance system, like others, under detects pesticide illnesses for
various reasons, including that pesticide illnesses may mimic other illnesses
ad that physicians and patients may not ascribe symptoms to pesticide
exposure."
Moreover, relatively minor, transient symptoms triggered by the spray would
similarly go underreported. Therefore, the actual number of adverse events experienced
by residents is undoubtedly significantly higher.
while the CDFA has stated that the formula Checkmate LBAM is safe for human
contact, the CDFA based this determination on a review conducted by the EPA, who in
turn based their determination on data obtained from New Zealand. This pheromone-
pesticide solution has never been sprayed over residential areas in New Zealand, or any
other country, making any extrapolation of safety from New Zealand data inappropriate
and irrelevant. Neither the CDFA nor the EPA conducted any independent safety
evaluation. A formal, independent safety review is usually required by EPA but was
exempted under the declaration of emergency. Most of the CDFA's communications
regarding the safety of this material are focused only on the safety of the pheromone
portion of the spray solution, not the complete solution that is being applied to residential
areas. Also, varying compositions of this solution are used making any extrapolation
from any other data completely irrelevant. Some of the non-active ingredients listed as
"other" or "inert" are ranked by the Hazardous Materials Identification System ~HMZS}
and National Fire Protection Association ~NFPA} as category 3 hazards ~"major injury
likely unless prompt action is taken and medical treatment is given."} See Appendix 2},
This does not appear to be common knowledge among health officials or health care
providers.
The State has declared that the concentrations of the spray to which residents
would be exposed are suff ciently dilute so as not to represent a public health risk.
However, as the supporting data provided shows, toxicity of some of the compounds in
the spray can occur even in dilute quantities, and for some, the degradation compounds
are more toxic than the parent compounds. Still other of the compounds can become
toxic over time. As previously noted, the exact concentrations of compounds within the
LASS: Health Action Team Santa Cruz County Health Services Agency 3
LBAM spray are proprietary information and so the actual concentrations delivered in the
spray solution cannot be assessed, nor their safety independently evaluated.
In addition to the potential for toxicity directly associated with the Checkmate
portion of the LBAM spray, there are unknown safety consequences potentially
associated with the delivery system, the safety of which has not been evaluated at all. Of
greatest concern is the lack of safety data on one class of carriers used in the spray known
as microcapsules and surfactants. Regarding the microcapsules, a group of researchers at
the University of California at Davis recently published a study the conclusion of which
revealed that the microcapsules in the LBAM formula range in size of from 10-190
microns ~V~erner et al 2007}y'. The American Lung Association considers aerosol
particles of 10 microns in size as particulate pollution known as PM 10~ that contribute
to a host of adverse health conditions, mostly, but not exclusively, respiratory in nature.
The majority of adverse effects currently reported for the Checkmate aerial spray were
respiratory or mucus membrane related see attached DPR consensus. The CDFA in
their Consensus Statement on the Human Health Aspects" of the microencapsulated
spray estimated the size of the microcapsules at a minimum of 25 micron, and because of
this, performed no safety or toxicity studies on the potential for the spray to cause
respiratory effects. The same document reports that respiratory symptoms are plausible,
even at their mistaken estimates of the 25 micron particle size, suggesting that the
incidence of respiratory disturbances will be much greater than estimated by CDFA.
Regardless of whether or not one personally believes that pheromone-pesticides
are safe, the fact that this particular pheromone-pesticide solution has never been sprayed
on residential areas before now, should raise substantial concerns for caunty health
officials. Monterey and Santa Cruz Counties are testing grounds for this material, and
there is currently no program in place to monitor adverse reactions if they were to occur.
In addition, many city and county physicians have been lulled into a false sense of
safety in the belief that the pheromone portion of the spray presents no harm, while being
completely unaware of the potential adverse effects that can be associated with other
compounds in Checkmate and in the delivery system, Residents experiencing post~spray
symptoms have reported meeting with physicians who have been unwilling to fill out the
proper adverse effects reporting forms because these physicians were apparently unaware
that the Checkmate aerial spray contains anything other than pheromones. Under these
circumstances, we concur with the opinion of the Department of Pesticide Regulations
who in their communication of November 16, 2007"', stated:
"A series of actions to ensure proper collection, review, and
coordination of health complaints is also recommended. Air sampling
should be considered to investigate the contribution of the aerially released
microcapsule particles to the overall ambient air particulate load. Awell-
designed, formalized study and tracking program that looks at a number of
factors including, but not limited to, both long- and short-term health
outcomes, exposed and unexposed persons, the potential effects of stress,
and outreach methods on illness complaints would be needed to begin to
properly address the question of causality."
CASS: Health Action Team Santa Cruz County Health Services Agency 4
0f additional concern are the surfactants that are present in the LBAM solution
~e.g, tricaprylyl methyl ammonium chloride}. Surfactants are substances similar to
detergents and soaps used to reduce the surface tension of liquids and, in the LBAM
solution, are present to ensure a smooth flow of spray through the spray nozzles. The
lungs are especially affected by surfactants as pulmonary surfactant is an inherent part of
normal respiration. However, the lungs must maintain a normal balance between
pulmonary surfactant and surface tension. Surfactants were associated with the death of
hundreds of seabirds, which occurred immediately after the Santa Cruz spray. The
association of surfactants with the dead birds is likely causative as many of the birds were
found to be stripped of their oils, which led to their drowning. While the contribution of
the surfactants and the dead birds is different than what would likely be experienced in
humans, the stripping of the oil in the dead birds strongly suggests exposure to
surfactants at concentrations that are great enough to influence the delicate balance of the
human respiratory system. This can result in a two-fold problem; endogenous systemic
effects in individuals susceptible to minor changes in respiratory surface tension and
greater absorption of exogenous particles that can trigger allergic responses in susceptible
individuals. Despite these associations, state and federal agencies have yet to perform a
single respiratory toxicity study, and currently have stated there is no intention to do so.
Df equal importance, the County of Santa Cruz is attempting to document any
Checkmate LBAM related illnesses for its impending court case and request for a
temporary restraining order against future sprayings, at least until an Environmental
impact Review can be conducted. Without a formal program in place within HSA, this
cannot be done. We believe HSA should work in cooperation with the city and county
governments who are working to safeguard the public's health.
As citizens concerned about our health, we believe that any material that is to be
aerially sprayed on residential areas needs to be shown to be safe before application. We
find it incredulous that the State of California would require citizens to carry the burden
of proof in showing this material to be potentially harmful. Rather, we believe it is the
responsibility of State andlor Federal agencies to prove this material, in the complete
form in which it will be dispensed, is safe prior to the spraying of residents, including
children, pregnant women, and the elderly. We believe it is the responsibility of State
andlor Federal agencies to prove this material, in the complete form in which it will be
dispensed, is safe prior to the spraying of areas such as playgrounds, backyards, parks,
etc. where people will inevitably come into direct contact with the pesticide. We also
believe it is the responsibility of HSA to question and review the assertions of the safety
of such materials rather than defer this to others whose primary focus may be incongruent
with the mission of HSA.
We respectfully ask that you please recognize that the concerns we raise are
legitimate, and that a focused program is needed to ensure that the public's health is truly
being protected through the monitoring and tracking of potential post-spray adverse
effects. The State needs this level of feedback in order to honestly assess the safety of
what they are doing. Moreover, we feel that it is important for county physicians to be
made aware that the material being sprayed is not simply a pheromone, as has been
widely represented, but that it contains other compounds of unknown safety, and
microcapsules whose particle size may result in an increase in respiratory complaints,
especially during times of spraying. Physicians and county health providers should also
CASS: Health Action Team Santa Cruz County Health Services Agency 5
be made aware that, in point of fact, this material has never been sprayed on residential
populations and that formal safety evaluations that would have normally been conducted
by EPA were obviated due to the declaration of emergency. This background knowledge
may make physicians more aware of the potential for spray-related adverse effects, and
more likely to report them.
Ms. Khalsa, we believe that you and Santa Cruz County HSA are committed to
doing everything in your power to make sure that the people, whom you are entrusted
with caring for, are indeed cared for. The mission statement far HSA illustrates this
commitment and we include it here in hopes that we may partner in its fulfillment.
"The Santa Cruz County Health Services Agency exists to protect the
public health of Santa Cruz County and to help assure residents access to
medical care and treatment. The ultimate goal of the Health Services
Agency (HSA) is healthy people living in healthy communities. HSA is
responsible for promoting community health in the public and private
sectors....
HSA is committed to protecting public health in the following ways...
Advocacy for expanding health coverage and environmental protection
and securing the resources for HSA and other health providers to carry
out the mission. "
We believe the assertions we have made accurately reflect the state of the
scientific data and justify the recommendations put forth. 4n behalf of the individuals
and organizations that support the submission of this communication, we respectfully ask
that you please respond to the questions below so we may know what programs are to be
put in place and where adequate programs are lacking.
We have also enclosed a copy of a petition that was signed by more than two
thousand residents of Monterey and Santa Cruz Counties. We respectfully request that
you read all of the comments in the petition, as well as the other enclosures we have
provided. Please take the time to review the data provided. We believe that if you do
this sincerely, you will reach the same conclusions that we have and will agree that it is
appropriate to have a mechanism for monitoring and tracking potential post-spray
adverse effects, and that local health care providers need to be better informed.
Cltxzens Health Concerns
Concerned citizens of Santa Cruz County respectfully request that HSA respond to the
following questions:
1. What plan does HSA have to notify Santa Cruz residents of the impending spray?
CASS: Health Action Team Santa Cruz County Health Services Agency 6
2. What plan does HSA have to caution Santa Cruz residents of potential adverse
effects of the spray?
3. What plan does HSA have to advise Santa Cruz residents what to do and where to
go in the event that they have an adverse reaction to the spray?
4. What plan does HSA have to do outreach to county health care providers so they
will know how to identify, treat, and document potential adverse effects due to the
spray?
5. What plan does HSA have to ensure that all Santa Cruz residents- even those who
do not qualify far county health care, but are too poor to afford adequate health
insurance -will be treated if harmed, and that their experiences will be
appropriately documented?
6. How may Santa Cruz residents assist HSA in fulfilling its mission in this regard?
As the next spray is tentatively scheduled for late February or early March, time is
of the essence. We therefore would appreciate a response by January 15, 200$ or sooner.
Sincerely,
Zelda M. Lackner, Esq.
CASS: Health Action Team Santa Cruz County Health Services Agency 7
' Appendix 1: EPA Grants Emergency Approval of Checkmate: no formal safety studies
conducted.
"Appendix 2: Safety Concerns of Checkmate Ingredients. Material Safety Data Sheets
(MSDS} & Review of MSDS.
"' Appendix 3: Review of Post-Spray Adverse Effects in Monterey and Santa Cruz
Counties: Petitions and Comments.
'" Appendix 4: Label of Checkmate LBAM-F and Ingredients of Checkmate OLR-F.
Appendix 5: Heeley et al, 2001. Prescription-Event Monitoring and Reporting of
Adverse Drug Reactions. lancet. 358: 1873-73.
~' Appendix 6: Werner I, Deanovic LA, Markiewicz D. 2007. Toxicity of checkmate
LBAM-F and ~piphyas postvittana pheromone to Ceriodaphnia dubia and fathead
minnow ~Pimephales promelas} larvae. Aquatic toxicology laboratory. University of
California, Davis.
~" Appendix 7: Department of Pesticide Regulation; Consensus Statement on Human
Health Aspects of the Aerial Application of Microencapsulated Pheromones to Cambat
the Light Brown Apple Moth. October 31, 2x07.
y"' Appendix $: Department of Pesticide Regulation; Communication Nov 16, 2007.
CASS: Health Action Team Santa Cruz County Health Services Agency 8
Invasion Biology of the Light Brown Apple Moth
James R. Carey (UC Davis)
Presentation to Assembly California Legislature
Committee on Agriculture
Room 4202 State Capital
March 12, 2008
Thank Madam Chair for inviting me to testify to this committee.
I am James Carey, entomologist at UC Davis with specialties in invasion biology, insect
demography, and population dynamics. I served on the CDFA medfly scientific advisory panel from 1987 to
1994 and also testified on the medfly crisis in the state to the California Legislature Committee of the
Whole 17 years ago.
The question regarding the LBAM invasion is not whether we want it eradicated~f course we do.
Rather the question is whether it is passible to actually eradicate it.
Although I am not speaking for anyone other than myself, I have talked to eight different UC
entomologists about the LBAM problem. Some of these are highly statured scientists within the UC System.
Nat one of these entomologists believes that the light brown apple moth can be eradicated. Nor do any of
them believe that this is a recent invader. Vat one. But none of these entomologists is willing to speak out
because either of fear of retribution from the agencies andlar industry with regard to their research support
or out of a feeling that supporting eradication efforts seven if blindly} shows their allegiance to agriculture
mission. But given the extent of the LBAM infestation and the lack of control tools, I seriously doubt that
there is any entomologist in the country who truly believes that eradicating this pest is possible at this stage.
I would like to first offer my scientific views of the LBAM problem and then make specific
suggestions for actionable steps for both the short and long term.
The current distribution of the Light Brawn Apple Moth LBAM} in California, covering 10
counties with a combined area of more than $,000 to 10,000 square miles (i.e., the size of Connecticut}
suggests that this pest is not a recent introduction but has been in the state for many years, perhaps 30 to 50
years or longer. For perspective, the gypsy moth took mare than 10 years to spread from the point of
introduction in an amateur naturalist's back yard to his neighbor's yard, and over 30 more years to spread to
three counties in Massachusetts. The argument that LBAM is a recent invader because no populations were
detected by the CDFA in 2005 cannot be reconciled with LBAM's current widespread distribution. This
recent invader argument is simply not credible. For the "recent invader" argument to be valid, the
assumption would have to be made that the pest is capable of spreading 4,000 to 8,000 square miles
annually or, alternatively, from 50 to 100 miles outward per year. However, there is no precedent for this
rate of spread far any insect. Not even close.
Likewise the model of LBAM population growth contained in the declaration by CDFA that was
signed actaber 31, 2007 by Dr. Kevin Hoffman not just lacks credibility, it is demographically incredulous.
As the author of three books on demography including one on insect demography that is considered by
many entomologists in the country as the go-to book for demography, as well as the associate editor of
several scientific journals including one on demography, the population growth model presented by CDFA
would not be taken seriously by any editor of any entomology or ecology journal in the world. The CDFA
model has LBAM growing at a demographic speed of light with one math producing two thousand trillion
moths in 5 generations. This is the equivalent of 50 myths per square inch in Berkeley. As a demographer
using actual per generation growth rates of LBAM published in one of the most elite ecology journal in the
world ~J. Anim. Ecol}, my estimates for population growth would not be two thousand trillion moths but
from 50 to 100 moths.
The history of eradication programs in which an exotic insect is as widespread as LBAM is in
2
California suggests that we have little if any chance of success because several key preconditions for
conducting a successful eradication program are unmet. These include having:
1. An effective eradication tool. Mating disruption pheromone is a "control" tool and not an eradication
tool. There are huge problems even with the use as a control tool. Never in the history of insect
eradication has a pheromone ever been used for any eradication program, much less been successful in
eradicating any insect population.
2. A monitoring system for delineating the full extent of the infestation at the beginning of the program as
well as for identifying small populations in scattered pockets at advanced stages.
3. Strang public support so that ground crews deploying controls can have full access to private property
over a sustained period,
Even under the best of circumstances eradication is difficult to achieve for the same reason that cases
of advanced metastatic cancer are Jiff cult to cure. That is, there is not one LBAM population but tens of
thousands of populations infesting backyards, parks, fields and roadsides. Thus anything short of 100°/Q
effectiveness for each of these population packets must be considered "control" and not "eradication" This
because any of a number of residual packets of LBAM can regenerate the original populations spread over a
wide area.
Recommendations:
1. Do a reali check. This pest is so widespread, the control and monitoring tools so ineffective, and
public support in urban areas so weak cif not hostile} that eradication is simply not an option. The US
Forest Service tried to use DDT in the 1 gbOs to eradicate the gypsy moth spread over an area not much
larger than the area occupied by LBAM in California. The program failed, not because of lack of effort
but because eradication is so incredibly difficult when pests are widespread, even with effective control
tools.
Z. Sto considerin exotic est situations as dichotomous----either eradicate or manage. fin. fact, there are
any number of intermediate concepts including containment. Thus we should be considering creating a
first rate program of containment of the LBAM rather than launching an eradication program that has no
chance of success. Model after the `slow the spread' program against the gypsy moth on the east coast
and Midwest. Explore the concept of `math free zones' similar to what is used for fruit flies whereby if
moths not captured in region with accepted monitoring protocols, then considered risk free and can ship
commodities.
3. Revisit trade olio .Right now the biologists and entomologists at CDFA and USDA have to shoulder
the lion's share of the burden for dealing with pests. However, just as some mountains cannot be moved
and some cancers cannot be cured, many pests simply cannot be eradicated. Thus need to consider more
realistic trade policy consider non-zero risk. It is in the interest of all trading partners since really comes
down to an agreement of risk between a buyer and a seller. The same group who is buying today is
selling tomorrow and they too may have to deal with reciprocal quarantines if they demand zero risk at
every turn.
4. het Universi of California involved. UC is the research arm of our state yet the only input UC writ
large has to invasive pests is after the fact and picking up the pieces. To have token UC scientists on
each panel amounts to little because there can be little independent thought on these panels. Everyone
knows that the panel has its marching orders and, because these are technical advisory panels, the input
is technical and not strategic. There are 150 ecologists just at UC Davis alone. There are probably 1,000
ecologists across UC system, many of whom are NAS members and elite scientists. This braintrust can
be tapped and engaged in helping to deal with exotic pest problems from agriculture and forestry to
marine and freshwater systems. UC involvement would provide amuch-needed degree of scientific
input that is independent and objective and in an early stage of decision making ~e.g. before the decision
3
to launch an eradication program.
5. Hel create disci line of `invasion science'. I consider invasion biology at the same stage now as what
conservation biology was 30 years ago----mostly anecdotes and protocol-driven policy rather than policy
based on a set of unifying principles. For example, fisheries and wildlife used to be mostly case-studies.
Now it has evolved into a more coherent science of conservation biology where many of the same
principles for protecting endangered butterflies also apply to endangered elephants. Likewise, right now
forest entomologists do not even communicate with crop entomologists about eradication concepts.
V~hat needs to evolve and where California can take the lead is to in taking steps for developing a
coherent discipline of invasion science where the invasion biology, the monitoring, the trade policies
and risk, and exclusion concepts, and intervention tactics are brought together into a more cohesive
whole.
In closing, I will note that because I disengaged from invasion biology research and panel
membership over 10 years ago, I can see this LBAM problems with both fresh eyes as well as from the
perspective of having served on the CDFA medfly panel for 7-8 years, Broadly speaking, virtually nothing
has changed operationally since I joined a panel in 1987. The only things that have changed is that
emergencies are mare frequent and pests the state has been dealing with for 20 or more years are more
entrenched and widespread. It is clearly a time to take a hard look at our approach to exotic pests in the state
and consider changing the way we do business.
Thank you.
integrated Pest Management Practices for the Light Brown Apple Mvth in New
Zealand: ~mplicatians for California
Daniel Harder, Ph.D. Executive Director
The Arboretum, University of California at Santa Cruz
Jeff Rosendale, Grower, Horticultural Consultant
Watsonville CA
March 6, 2005
ABSTRACT
The Light Brown Apple Moth, Epiphyas postvittana ~LBAM} has been an established
exotic species in New Zealand for more than 100 years. The authors conducted a
three-week, 3,004-kilometer fact-finding study in New Zealand's two major
agricultural regions to assess integrated pest management IPM} of LRAM and
applicable strategies for California. LBAM was considered a problem pest in New
Zealand orchards during the 1980s when regular, calendar applications of broad-
spectrum organophosphate pesticides had eliminated the beneficial insects that prey
on LBAM. However, since elimination of organophosphate treatments in 2001 and
subsequent restoration of populations of benef vial insects and other organisms,
LBAM is considered a minor pest that does not cause economically signif cant crop
damage or have detrimental effect on native flora. Today, LBAM is effectively
controlled almost exclusively by natural predators in both agricultural settings and
wild lands in New Zealand. There is no evidence of biological or environmental
threat from LBAM in New Zealand. Because of United States' zero-tolerance
quarantine requirements for LBAM, New Zealand horticultu.rallagricultural
professionals use pheromone sticky traps to monitor LRAM populations and, based
on monitoring data, timed ground applications of insect growth regulators ~IGRs} are
used in select agricultural settings to prevent shipments from being rejected far export
to the U.S. The success of New Zealand agriculture and horticulture professionals in
controlling LBAM and other leaf~roller pests using IPM techniques and few or no
chemical applications is a model of best IPM practices that can be readily adopted in
California to control LBAM, particularly because many of the natural LBAM
predators that are present in New Zealand are also found in California. Adopting
IPM best practices would include suspending planned aerial and ground treatments
for LBAM in California and monitoring to determine extent to which LBAM
populations are being parasitized or destroyed by predators. United States
Department of Agriculture (USDA} classification of LBAM as an actionable
quarantine pest should be reviewed and revised based on current, relevant, science-
based information. The negative impact of organophosphate use on benef cial
predator species in New Zealand, along with the known health and environmental
dangers of these chemicals, suggests that current requirements for organophosphate
controls for LBAM in nurseries and elsewhere in the U.S. should be abandoned.
Introduction
This report describes results of a January 2005 fact-finding study on integrated pest
management of the Light Brown Apple Moth ~LBAM} in New Zealand. The study was
undertaken to understand the extent of LBAM's effect on New Zealand's agriculture and
natural environment and the methods of managing LBAM, with the goal of
understanding potential impacts of and best management practices for LBAM in
California. The authors focused on understanding best management practices for control
of LBAM and how these strategies impact the cultivation of plants in botanical
collections in gardens and arboreta as well as in cammercial nursery and agricultural
cropping systems.
New Zealand was chosen for this research because its climate and crops are similar to
California's coastal farming areas and because LBAM was introduced to New Zealand
from Tasmania and first reported in New Zealand in 159I ~Thomas,1957, HortNet
http:Ilwww.hortnet.co.nzlkeylkeyslinfoldistribllba-dist.htm} and thus has been an
established exotic in New Zealand for more than 100 years.
The remainder of this report describes the study's research methods and presents findings
and discussion on LBAM biology and behavior, hosts, populations, damage, and control
in New Zealand, as well as LBAM's role in global trade of New Zealand agricultural
products.
Methodology
The authors traveled and conducted interviews with government, agricultural, and
horticultural entomologists and researchers of LBAM and insect pests as well as
wholesale and retail agricultural and horticultural producers and plant conservationists.
They also conducted field searches for LBAM presence and damage in commercial
agricultural fields, orchards, native habitats including Abel Tasman National Park, and
along roadsides. The research was carried out over a period of three weeks, January 4 -
29, 2005, which is mid-summer in New Zealand when LBAM would be expected to be
active in all life stages and readily observable. The goals of the research were to learn
from agriculture, integrated pest management IPM}, entomology, and conservation
experts about LBAM in New Zealand and to identify IPM strategies that would be
effective against LBAM in California.
The authors focused on the two main agricultural production areas of New Zealand; on
the North Island, the Hawke's Bay region, known as the "fruit basket " of New Zealand
where the mayor produce is apples, nectarines, kiwis, wine-grapes and assorted row-
crops; and on the South Island, the Nelson agricultural region, which is a mayor
production area for apples, currants, hops and wine-grapes. See Figure 1.
2
Both the Hawke's Bay (Napier and Nelson areas are similar in terrain and mixed forest
areas to California's Monterey Bay and Santa Cruz areas where the California LBAM
presence is most dense. The Hawke's Bay region is a bit warmer and moister than
Monterey Bay, making it an ideal climate and study area for LBAM. These agricultural
regions also have a long history of studying and controlling LBAM and have developed
technologies to best protect craps. As shown in Table 1, Nelson and Napier have
climates very similar to California's Central Coast.
Comparhon of Temperature Itanges, Average Mean Temperaturs and Pretipitatlon in Monterey, California and Napler, New Zealand In 2x07.
Months have been aligned to season.
2007
]anus Februa Mareh A I Ma ]une ]u Au ust Se tember October November ~evember
Sunte Cru:, Caiiforni
Temperature Range (f) 39 J fil 41 / 63 42 J 65 43 J 68 4fi J 71 q9 / 74 51 J 76 52 / 76 50 / 77 47 / 74 43 / fib 36 J 64
nverege Temperature {F) 48 52 54 53 55 58 62 62 63 59 56 51
Precipltadpn (inches) 6.4 5.5 4,5 2.2 0.7 D,2 O.i 0.1 0,3 1.3 3.5 0.69
]ul Au ust Se ber October November decemher ]anus Februa Mereh A rit Ma ]une
Napier, New Zealand
Temperature Range {F) 36 J 65 35 J 66 33 / 67 34 J 77 43 J 83 48 J 83 45 J 89 47 J SG 4b J 85 38 / 75 30 J 72 31 / 69
Average temperature {F) SO 5D 52 58 58 64 66 64 65 54 55 49
Pnecipltatlgn (Inches) 3.3 3,2 2.1 2.2 1.6 Z.9 1.8 2,2 2.7 Z5 D.14 3.6
Table 1. Comparison of Santa Cruz, CA and Napier, NZ Temperatures and Rainfall
3
Figure ~ . New Zealand map
The southernmost area of New Zealand was not visited because its colder, harsher climate is
both less hospitable to LBAM than the warmer climate farther north and dissimilar to the
climate of areas where LBAM is presently found in California.
In addition, New Zealand cultivates hundreds of thousands of hectares of Monterey pine
~Pinus radiata} and has planted many Californian species including vintage Monterey
cypresses (Cupressus macroearpa},giant sequoias ~Sequoiadendron giganteum},coastal
redwoods Sequoia sempervirens}, as well as native New Zealand conifers.
Results and Discussion
The subsections below present findings related to LBAM, its biology, behavior, enemies
~bene~cial control agents}, populations, damage, control in New Zealand, and role in
New Zealand agricultural trade.
Piology and Pehavior of LBA~I
LBAM is a tartricid ~Tortricidae} moth and a member of the leaf-roller moth family in
the order Lepidoptera. Each LBAM individual exhibits four life stages: egg, olarva,
pupa, adult moth}. LBAM is polyphagous, meaning that it is not host specific but rather
feeds on a variety of plant species. A superficial feeder as a larva see Figure 2}, LBAM
typically causes cosmetic damage to the surface of leaves and fruit and only rarely
penetrates a host fruit. LBAM does not defoliate plants. Defoliation is contrary to leaf
rollers' biological need for leaves that, with the help of thread material, the larvae roll
around themselves for protection. The rolled leaves provide protection from predators
and the ideal conditions for growth and development. Like all leaf rollers, LBAM is
subject to natural predation and parasitism. Major predators and parasites in New
Zealand include: birds, spiders, wasps, flies, beetles, lacewings, and earwigs to name only
a few. A full listing of enemies to LBAM can be found at:
h :llwww,hortnet.co.nzlke Istonelinfolenerniesllba-enem.htm
LBAM may mate up to three tomes during its 1- to 1.5-week lifespan in New Zealand.
Female moths typically lay 34-54 eggs per egg mass. The majority of the eggs are
sub ject to environmental pressures including predation or parasitism before reaching
adulthood and thus da not mature ~HortNet ~Vebsite at
httpalwww.hortnet.co.nzlpublicationslproceedingslifaamlifoam69.htm}
Adult LBAM travel an average of approximately 140 meters from their hatching sites
during their lifetimes and are not necessarily particular about where oviposition ~egg-
laying} occurs. The larvae can travel mostly downwaxd by silken threads. Any larva that
falls ar loses contact with its food sourcelhost plant have little chance of survival, so the
larvae stay connected to the plant by the silken thread. Adults move the greatest
distances for dispersal of the populations}. LBAM does not form a central colony that
can spread and cause detrimental effects in an agricultural field. Because it is
polyphagous, LBAM can disperse and survive without concentrating and adversely
affecting all plants in a concentrated area.
4
Figure 2. Superf vial leaf damage from LRAM larva
LB~Nf.~fosts and ~'opulations in dew Zealand
Although LBAM is considered by New Zealand HortResearch, the government
agricultural and horticultural research agency, to be "comman" in orchards throughout
New Zealand and "less common, rare, or even absent" in areas of New Zealand still
covered in native forest ~HartResearch 2008
ht :llwww.hortnet.co.nzlke Ike slinfoldistribllba-dist.htm},
LBAM is, in fact, Jiff cult to find in New Zealand. Eighty to ninety percent of LRAM
larvae are parasitized by natural predators before maturation Shaw, 20x8}. According to
New Zealand Ministry of Agriculture and Fovd (MAF} and Department of Conservation
~D~C}experts, LBAM does not buildup in any one host in the wild and has never posed
a threat to native forests. Natural predators keep LBAM in check, and it is so rare in the
wild that it requires a true expert and meticulous searching to even find any sign of it.
For meeting U.S. quarantine requirements, LBAM populations in New Zealand are
estimated and monitored using pheromone traps.
LBAM is not an insect of significance in Monterey pine plantations in New Zealand.
LBAN~ is a leaf roller moth that requires flat-surfaced leaves to protect larvae while they
mature. Clearwater X2008} notes that LBAM clearly does not have a preference for
gymnosperms and is not considered a pest of these plants in New Zealand.
5
Shaw X2005}reports that gorse is a preferred LBAM host plant in New Zealand;
however, the authors found no LBAM larvae on gorse in a wide variety of regions in the
North Island and the main agricultural regions of the South Island. In fact, the authors'
extensive search for LBAM in native New Zealand habitats during the three-week, 3,000-
km extent of this research trip revealed only a few larvae, one on an exotic planting in a
hotel garden, as well as a few tortricid moths flying around porch lights in the evening.
No evidence of LBAM eggs, larvae or adults was found in the 22,530hectare Abel
Tasman National Park on New Zealand's South Island. This national park has a mixture
of native and non-native plant species with amulti-story diverse habitat of broadleaves,
ferns and conifers.
Ag~iculturallhorticultural researchers in New Zealand noted that, because LBAM larvae
are often parasitized, finding a larva does not mean that a viable adult LBAM will hatch.
If a parasite has laid eggs in the larva, the parasite's adults, e.g., wasps, flies will hatch
rather than LBAM. Due to the need to understand natural controls for LBAM in
California and the similarity of types of organisms keeping LBAM under control in New
Zealand with those already present in California, monitoring of levels of parasitism of all
life stages should begin immediately for LBAM in California. As noted below in the
LBAM Con~rot in New Zealand section, researchers in New Zealand have developed a
monitoring protocol that allows them to determine the extent of parasitism of LBAM
populations to prevent unnecessary and costly control efforts based an observation of
larvae only. Similar parasitism of LBAM is likely occurring in the regions of California
where it is present. The Arboretum at the University of California, Santa Cruz has
initiated a survey of beneficial insects that may control LBAM. In eight larvae raised to
adults, two have been parasitized by natural predators.
LBA11 ~1 Damage in New Zeala~td
LBAM is currently considered a minor biological pest in New Zealand agriculture,
including apple, peachlnectarine, citrus, and vineyard crops. Codling moth ~"the worm in
the apple," also a tortricid~ and woolly apple aphids are much more significant pests in
apples, and thrips and mites are the pests of significance in New Zealand citrus ~~idean
2405}
Hawkes Bay horticultural researchers report that, with no monitoring ar ~eatments and if
LBAM were uncontrolled other than by naturally occurring trichogramma or other
beneficial insects and organisms, the maximum damage caused by LBAM would be one
percent or less of crops Walker 200$).
Reports of damage to crops prior to 2001 in Australia or New Zealand are from the era
when organophosphate pesticides were heavily used to control LBAM Ito comply with
USDA requirements that no trace of LBAM be found}. These pesticides eliminated
LBAM's natural predators. once organophosphate use stopped in 2001 and natural
predator populations rebounded, New Zealand's LBAM problem was greatly reduced to
its current, insignificant level.
6
New Zealand horticulture and agriculture professionals so successfully use IPM strategies
to manage LBAM that in mare than 3,000 U.S. shipments of pome (pip} fruit in 2006,
only six were rejected. Gne positive LBAM find can cause rejection of a single I S-ton
fruit order (Walker 2008}. Thanks to exceptional, modern New Zealand IPM practices,
leaf rollers ha~re limited economic impact on fruit or crop production other than
occasional shipments rejected by U.S. only because of zero tolerance for LBAM.
L~~~1 Control in ~Vew Zealand
Benef vial insects are considered the first and best line of defense against leaf rollers, and
insect growth regulators ~IGRs}, which are based on derivatives from natural sources, are
the primary insecticide used for leaf roller and codling moth control in New Zealand.
Growth regulators da not negatively affect beneficial insects to any significant degree.
Rather, IGRs are relativelytarget-specific and cause target larvae to mature faster than
normal before the larvae are physiologically ready and so die.
To control LBAM effectively with IGRs, it is important to target averwintering LBAM
populations. As cooler weather progresses, adult populations of LBAM drop; adults die
off, and larvae do not morph into adults. The lowest adult numbers occur in late winter.
IGRs are most effective when applied as eggs hatch and larvae begin to feed in warmer
summer weather. In California, IGRs should probably be applied in May, but the timing
needs to be verified by phenological monitoring using pheromone traps for adult males
Shaw 2405}.
Treatments with least~toxic IGRs for most other pests, particularly codling moth, which is
one of the top apple pests in New Zealand, generally act, along with beneficial insects, as
adequate LRAM controls. Biocontrols are effective against all LBAM life stages: eggs,
larvae, pupa, and adults. Biocontrols include native and introduced wasps and native
tachinid ~Tachinidae) flies. The key to effective control with predators and parasites is to
encourage a range of insects attacking all life stages.
In the Nelson area, roughly four to 10 percent of producers are organic. Because organic
systems encourage beneficial insect populations and da not negatively affect beneficial
organisms and insects with the use of harsh chemical controls, pests including LBAM}
are not signif cant problems for localized organic producers.
The leaf-roller complex, including LRAM and other native New Zealand species, is
readily monitored in the early tomid-spring with a pheromone sticky trap and regular
visual inspection. Based on monitoring results, a single IGR spray regime can be
effective for season-long control. Growers in the Hawke's Bay and Nelson regions do
not use mating disruption pheromones to control LBAM. They monitor in late spring
with pheromone traps specific to LBAM and codling moth. If the trap counts warrant, an
IGR is applied ~e.g, Intrepid, Conf rm: methoxyfenozide, tebufenozide}. This timed
treatment adequately suppresses LBAM and codling moth populations for the year
(walker 2008, Shaw ZOOS}.
7
Pyrethroids natural or synthetic} are effective controls for LBAM but also are
detrimental to beneficial insects and pollinators, making these products undesirable for
long-term IPM of LBAM. Pyrethroids are especially detrimental to native and
introduced (honeybee} bee populations essential for pollination and to mammals.
Histo of Or ono hos hate Control
During the late 19SOs and 1990x, organophosphatestyere applied regularly in New
Zealand orchards with no monitoring for insect populations. The effort was to create a
"sterile nursery" situation where there were no pests and no beneficial insects.
Organophosphatestyere used because of the zero tolerance for LRAM in produce to be
exported to the U.S. The chemicals were applied on a schedule rather than in response to
pest populations. Under the organophosphate spray regime, LBAM was a problem of
greater significance than it is today, and all pests were more difficult to control and
became increasingly hard to keep in check. Populations of insects, including LBAM
developed resistance to the organophosphate formulation.
Use of organophosphates was eliminated in New Zealand in 2001, HortResearch experts
report that once the use ofbroad-spectrum organophosphates was stopped and
agricultural professionals began monitoring fvr LBAM and timing IOR sprays, all of
which allowed beneficial insects to affect LBAM populations, the LBAM problem
reduced dramatically so that the moth is now considered a minor pest except for the
challenge posed by the U.S. Department of Agriculture quarantine}
http:Ilwww.hortnet.co.nzlkeylstonelinfolcontralllbacontrllr-chem.htm.
Organophosphatestyere destroying beneficial insects and creating resistant insects, and
orchards and vineyards were becoming LBAM breeding grounds.
Shaw X2005}reports that, at Nelsanl Matueka, "control trees with na insect or chemical
controls used have not recorded any damage from LBAM or other leaf rollers for more
than 10 years." HortResearch staff attempted to force LRAM infestation of these trees by
introducing LBAM eggs and larvae into the trees to no avail. Any infestation of these
trees by LBAM was quickly controlled by native predators without the need for IGRs.
"Once organophosphates were removed from the system and populations of benef clots
were left to develop naturally, complete control of LBAM was realized in less than 5
years" Shaw 2005}. when organophosphates were compared to natural controls in
consistent blocks of apples, control of LBAM was achieved with natural controls in less
than two years. Organophosphates never allowed effective control, and LBAM developed
resistance to them.
Zt is worth noting that in New Zealand, intercropping has been shown to promote
beneficial insect populations, resulting in near-complete LBAM population suppression
to below thresholds for use of control measures (Irvin et al. 2006, Begum et al. 2006}
Monitorin
Spring populations of LBAM in monitoring traps in total numbers per month is key to
deciding whether to use IGRs to control the population. Local monitoring of population
levels allows tracking of seasonal fluctuations Shaw 2005}.
Monitoring programs should assess levels of LBAM phenologically fat various life stages
and, by rearing Larvae and eggs from host plants, the degree of predation and parasitism
of LBAM. Parasites and beneficial controls may not be seen in early-stage occupation of
habitats by LBAM or other invading pests but will develop as the predators respond to
the presence of LBAM as a possible host.
A monitoring protocol has been developed that allows determination of the rate of
parasitism of LBAM larvae. Auckland HortResearch Insect Rearing Lab uses ageneral-
purposediet to rear LBAM larvae so that they can be observed to see if they axe
parasitized. Larvae are placed in a capped tube with cotton, allowed to develop at roam
temperatures, and observed to deternvne whether LBAM develops normally, parasites
hatch, or development is adversely affected by other potential control means.
The specifics of monitoring and thresholds for treatment are provided on the New
Zealand HortResearch website: http:llwww.hortnet.co.nzlkevl.
Eradication and Pheromone Use
V~'idespread LBAM eradication efforts have never been attempted in New Zealand.
Avery limited eradication program took place during the 1980s affecting two orchards
X200 hectares total} in the Nelson region where an insecticide-resistant LBAM strain had
appeared. Twist-tie pheromone strips X1000 per hectare} and ground-applied insecticides
were used to eradicate this resistant and localized LBAM population. Eradication is very
difficult unless a population is quite limited and well defined.
New Zealand researchers report that effective mating disruption using pheromones will
o~ work under the following s~eci~fiG conditions:
Extensive, even, and complete coverage of the pheromone
Uniform blocks of a single crop single canopy height}
Uniform topography ono slopes, hills or valleys}
Low population density of target pest knot too concentrated}
Under the above conditions, twist ties can be used for control under extensive coverage.
However, pheromones applied by any means cannot be effectively used across large
diverse areas with varying canopy heights, mixed species composition, and varying
terrain areas.
New Zealand researchers also note that aerial pheromone spraying interferes with
monitoring using pheromone traps, and monitoring is critical to successful control.
Moreover, use of broadcast pheromone spray to eradicate or control the moth is not
effective because female moths issue a more concentrated scent plume than the dispersed
pheromone scent of an aerial spray application, so male moths are able to find the
females Shaw 2008}.
Until tests reportedly carried out under a U.S. government contract in 2008 in southern
New Zealand forests ~"NZ Forest Provides Laboratory for Pheromone Trials" 2008
9
http:Ilnz.news.yahoo.com1080217131p140zs.html}, pheromones had never been aerially
applied in New Zealand, These trials are been undertaken within a Monterey Pine
plantation and does not involve applying the pheromone over urban areas. Pheromones
have never been used far widespread eradication anywhere in the world.
HartResearch stations on both islands agree that eradicating LBAM in California and
anywhere would require extensive, widespread use of IGRs with repeated applications to
address elusive, selected populations. These experts also question the eff racy of
bacillus thuringiensis ~Bt} against LBAM. Bt can also have a detrimental effect on
benef cial insects. They report that IGRs do not harm populations of beneficial insects
and that IGRs persist on foliage much more effectively than arganophasphatesdld.
Larvae emerging from eggs begin to perish as soon as they start feeding on the growth
regulators. Tests show IGRs are ovicidal as well as larvicidal and not toxic to
predatoryfbeneficial insects. The benef cial effects of the application of growth regulators
can be seen one to two days after application (walker 200$, Shaw 2008.
LRAM and Global Trade of dew Zealand Agricultural Products
LBAM is not of biological concern on either island in New Zealand but remains a pest of
concern only because it is a quarantine pest for exports. USDA considers LBAM an
"actionable quarantine pest" and has zero tolerance for LBAM finds in pre-inspection of
U.S.-bound fruit shipments. Consignments rejected because of any LBAM life stages are
sent to non-U.S. markets, e.g., Europe, which does not have phytosanitary restrictions for
LBAM. Today very few New Zealand fruit shipments are rejected by the U.S. walker
20x8}, which further suggests that New Zealand growers' LBAM controls relying vn
natural predators and IPM strategies are successful.
HortResearch experts say that when USDA announced during the late 1990s that the U.S.
would no longer accept fruit treated with organophosphatesbecouse of concerns far the
safety of fi uit handlers and consumers, this was the catalyst for abandonment of
organophosphates and the move to reliance an natural predators and IPM methods.
Implications far California
The information on LBAM and IPM in New Zealand reported in this report has
significant implications for addressing LBAM in California.
First, it is worth noting that, according to the National Museum of Natural History
Catalog of Type Specimens of Tortricidae
~www.sel.barc.usda.govllepltort types~list.html), California has SS native and localized
North American species of tortricid moths; none are problematic as a pest. All are kept in
check by natural biological controls, so there is conf deuce to believe that LBAM will
also be controlled by native natural predators or parasites. Preliminary studies by the
California Department of Faod and Agriculture report a high level of parasitization of
LBAM larvae by native California trichogramma wasps. Entomologists speculate that
LBAM may have been in California for as long as a decade already Garvey 2x07}, so it
is possible that LRAM is already being controlled by natural predators. Many LBAM
10
predator species in New Zealand are the same or closely related to California species
birds, earwigs, viruses, trichogramma and other wasps, tachinid flies, spiders, beetles,
etc.).
According to New Zealand information, the pheromone treatment currently proposed for
LBAM will most likely not eliminate nor control LBAM because none of the essential
conditions for successful pheromone use can be met. Use of the pheromone cannot be
complete ~e.g., it cannot be applied over sanctuary buffer zones and along
streamslwaterways), the pheromone will not be applied over a uniform block but rather
over mixed forests and native vegetation, houses, schools, roadways, craps, and
ornamental gardens. Moreover, topography of the California coast is highly varied and
diverse, and LBAM populations in these areas are dispersed and, in areas of high trapping
numbers, are too concentrated far effective use of mating disruption pheromones. In
addition, application of mating disruption pheromone alone without the addition of IGRs
would not allow for success.
Current CDFA requirements that commercial nurseries in California use the
organophosphate insecticide chlorpyrifos if LBAM larvae are found are in direct
contradiction to New Zealand findings that organophosphates destroy LBAM's natural
predators, resulting in resistance developing in LBAM populations. New Zealand experts
recommend use of IGRs in the control of LBAM in agricultural systems as much safer
and more effective.
Monitoring should be performed to assess level of predation on LBAM larvae, which
could reveal data indicating that less for nod intervention is required to control LBAM in
California.
Conclusions
The success of New Zealand agriculture and horticulture professionals in controlling
LBAM and other leaf roller pests using IPM techniques and few or no chemical
applications is a model of best IPM practices that can be readily adopted in California to
control LBAM, particularly because many of the natural LBAM predators that are
present in New Zealand are also found in California.
The finding that there is no evidence of biological or environmental threat from LBAM in
New Zealand, which has climate and crops much like California and where LBAM has
been an established exotic for more than a century, bodes well for the ability of California
agriculture and ecosystems to accommodate to LBAM's presence and suggests that
USDA classification of LBAM as an actionable quarantine pest should be reviewed and
revised. USDA's pest quarantine list needs to be re-evaluated based on current, relevant,
science-based information.
New Zealand researchers say that it will be very problematic to attempt to eradicate this
insect as it has now been firmly established over an extensive and diverse area. In
California, LBAM is found across more than 7040 square miles of varied terrain and
conditions, including within protected buffer zones and sensitive riparian corridors.
11
The negative impact of organophosphate use on beneficial predator species in New
Zealand, along with the known short- and long-term health and environmental dangers of
these chemicals, suggests that requirements for organophosphate controls for LBAM in
the U.S. should be abandoned. The requirement that California nurseries use
chlorpyriphos sets California up for failure oflong-term LBAM management and
management of future pests that would otherwise be controlled by natural predator
species that will be compromised or eliminated by chlorpyriphos use. This and other
highly toxic treatments need to be discouraged or prohibited in commercial nurseries.
The short- and long-term risks to exposure of organophosphates and the long-term
persistence of organophosphates in the environment make their continued use for control
of LBAM inadvisable.
A realistic assessment of LBAM populations and potential damage based on New
Zealand data must rely on recent studies published after the use of organophosphates
stopped. Drganophosphateose causes an unnatural situation to develop in which natural
predator populations are unable to function.
There may not be any need to introduce anon-native control for LBAM in California;
natural controls may already exist in the native fauna given the robust numbers of native
Tortricidae in California.
Summary of Recommendations
Based on the findings above, the key recommendations of this report are to:
* Suspend planned aerial and ground treatments for Light Brown Apple Moth
LBAM) in California and monitor to determine extent to which LBAM
populations are being parasitized or destroyed by predators.
• Adopt IPM best practices from New Zealand to control LBAM if necessary.
• Review USDA classification of LBAM as an actionable quarantine pest based on
current, relevant, science-based information.
• Eliminate requirements for organophosphate controls for LBAM in the U.S to
protect natural predator species that feed on LBAM and other pests.
• Realistically assess the potential impact of LBAM in California using New
Zealand data published since the use of organophosphates in New Zealand
stopped.
Sources
12
The information in this report comes from the authors' consultation with the fallowing
researchers and agricultural experts in New Zealand:
Jim Walker, PhD, Technical Research Scientist, New Zealand HortResearch
Mike Butcher PhD, Technical Manager, New Zealand PipFruit Association
Peter Shaw, PhD, Research Entomologist, Insect Science, New Zealand HortResearch
Paul Turner, Liner Plants New Zealand
Geoff Davidson, Oratia Native Plant Nursery, Oratia
Phil Smith, Owner, Taupo Native Plant Nursery, Taupo
Mark Dean, Owner, Naturally Native, Tauranga
Chris Green, Technical Support Off ter, Biodiversity Invertebrates and Biosecurity)
Department of Conservation
Phil Knightbridge, Department of Conservation, Botanist
John Clearwater PhD, Research and Consulting, Pheromone Technology, Organic
Growing Systems, Auckland
Ian Videan, Eskdale Orchard, Napier
REFERENCES
Begum et al. 2046. Using selective food plants to maximize biological control of vineyard
pests. Journal of Applied Ecology, 43: 547-554.
Garvey, K. K. 2007. "Entomologists Targeting Light Brown Apple Moth." University of
California News. http:Ilwww.universityafcalifornia.edulnewslartic1e19323
Irvin, N.A., S.L. Starrett, S.D. Wratten, C.M. Frampton, R. B. Chapman, and J.M.
Tylianakis 2006. The Effects of floral understoreys on parasitism of leafrollers
~Lepidoptera: Tortricidae) on apples in New Zealand. Agricultural and Farest
Entomology 8, 25-34.
"NZ forest provides laboratory for pheromone trials" 2117108;
http:llnz.news.yahoa.com1108021713140zs.html
Thomas, W.P.19S7. A Review of Biological Control of Invertebrate bests and Weeds in
11~ew Zealand X974 to 1987. Emerson, P.J., R.J. Hill, J. Bain, and W.P. Thomas.
Wallingford: CAB International.
13
About the Authors
Dr. Daniel Harder is the Director of the University of California at Santa Cruz
Arboretum and Adjunct Professor in the Department of Ecology and Evolutionary
Biology at UC Santa Cruz. The Arboretum maintains an extensive collection of
Australia, New Zealand, California natives, and southern hemisphere species within a
100 acre botanical garden on the UCSC campus. Dr. Harder is an expert on plants of
Asia and the Pacific Region, and Africa and has published papers on his research on the
floras of Central Africa and Viet Nam including works on the pharmaceutical
properties of plants, taxonomy, ethnobotany, and new species discoveries.
Jeff Rosendale is a grower and horticultural consultant in the Monterey and San
Francisco Bay Areas who specializes in the cultivation and uses of plants from
California, Australia, South Africa, New Zealand and Mediterranean Europe.
14
THE LIGHT BROWN APPLE MOTH ~N NEVI ZEALAND;
FACT vs, FICTION
March Z0, ZOOS
Dr. Daniel Harder and Jeff Rosendale, authors of "integrated Pest Management Practices for the Light
Brawn Apple 1~loth in New Zealand:l'mplications for California, "respond to comments on their report by
California Department of Food and Agriculture (CDFA~ Primary entomologist Kevin Hoffman and max
Suckling of New Zealand HortResearch.'
The intent of the Harder-Rosendale New Zealand report March 2008} was to make information publicly
available on integrated pest management IPM}practices in New Zealand that will likely be effective to
control the Light Brown Apple Mvth (LBAM} in California agriculture, The New Zealand report was
based on surveys of practices in New Zealand and interviews with LBAM experts in the New Zealand
government agricultural and horticultural research agency HortResearch.
CDFA's comments on the New Zealand report do not alter the report's solid scientific findings that
LBAM is largely controlled by natural predators in New Zealand and is not a biological or environmental
threat there.
General comments
FICTION: Dr. Hoffman begins his analysis of the New Zealand report by stating that there are "f nancial
and environmental costs" associated with integrated pest management IPM}practices and then focuses
on only one IPM strategy, introduction ofnon-native predators, a strategy that the New Zealand report
does not recommend.
FACT: Dr. Hoffman overlooks the basic tenets of IPM: to first determine whether an identified pest
poses a problem that requires intervention and, if a problem is identified, to find a means to address it that
is least toxic and least disruptive to the natural ecosystem. To imply that there are financial and
environmental costs to the New Zealand paper's recommendation that CDFA determine to what extent
LBAM is being kept under control by natural predators already present in California diverts attention
from the real costs at issue in CDFA's current LBAM strategy: the costs to human health and the
environment of amulti-year or indefinite campaign of regular aerial spraying of populated areas.
FICTION: Dr. Hoffman claims the authors of the New Zealand report received suggested changes to
their paper from New Zealand HortResearch staff and did not incorporate these changes.
FACT: This is simply not true. The authors solicited review comments and corrections from
HortReserach and other LBAM experts mentioned in the report. To date, the authors have received only
a single, ane-word change from their New Zealand sources; this change was incorporated in the f nal draft
of the report. No other changes were suggested, and the authors have received no other comments from
peer reviewers aside from praise for the report. The report's conclusions accurately reflect the
information provided by the HortResearch staff and website.
FICTION: Dr, Hoffman believes the report overstates when it asserts that LBAM is largely kept under
control by IPM practices and natural enemies.
1 Same comments from Mr. Hoffman were editorial in nature andlor address production corrections. These are nat
addressed as they do not detract from the report's solid findings.
FACT: HortResearch personnel stated that LBAM is 80 - 94°/o controlled by natural enemies in
New Zealand. Some of these enemies were introduced to New Zealand from Australia and elsewhere,
Rare LBAM outbreaks are effectively controlled by the use of insect growth regulators ~IGRs} in
agricultural systems. Worthy of note is that LBAM was a greater problem in New Zealand when broad-
spectrum, organophosphatepwticide use had killed off the natural predators of LBAM, Once
organophosphate use stopped in New Zealand, the populations of LBAM's natural enemies rebounded
and these enemies are now the major control for LBAM.
FICTION: Dr. Hoffman states that "The introduction ofnon-native natural enemies has its pitfalls,"
implying that the report advocates introduction ofnon-native LBAM enemies to LBAM,
FACT; The report does not advocate intraducingnnn-native LBAM enemies. A wide variety of
potential enemies for control of LBAM are already present in California, including insectivorous birds,
small mammals, earwigs, ants, native Trichogramma wasps, ichnumen wasps, tachinid flies, spiders,
beetles, lacewings, and others, A full listing of the enemies to LBAM in New Zealand is available at;
ht :Ilwww,hortnet.co.nzlke Istonelinfolenemiesllba-encm.htm. The authors strongly support immediate
initiation as of a major study, supported by CDFA, of LBAM enemies in California,
FICTION: Dr, Hoffman states that the New Zealand report "focuses on applying the New Zealand
model to the currently infested area of California and ignores what might happen should the moth become
established in different environments where the required IPM practices might be less effective."
FACT: Venette et al, (2003}, a report that Dr. Hoffman quotes, makes clear that LBAM prefers the mild
climate of New Zealand and Coastal California; it does not reproduce well below 7.1 degrees C X45
degrees F) and or above 30.7 degrees C X87 degrees F}; thus, LBAM is unlikely to establish in other
types of environments. In addition, Dr. Hoffman underestimates the flexibility of IPM, which, by
definition, works with the local ecosystem to find the least environmentally disruptive solution to a pest
problem should such a problem arise, It is notable that LBAM is established in Europe and is not a
quarantine pest there,
FICTION: Dr. Hoffman questions the citing of expert sources in New Zealand as the basis for
information in the report,
FACT: observation of conditions and interviewing of expert sources in another country that has
comparable conditions to California's and where LBAM is also an introduced exotic are basic
background-gathering practices in scientific research, CDFA should have undertaken a study of this
type prior to launching a radical and risky eradication program involving chemicals of
questionable safety and effectiveness to achieve a goal that may not even be necessary.
Specific comments
FICTION: Dr. Hoffman says, "the report significantly understates the moth's fecundity."
FACT: CDFA's claims about LBAM's fecundity ignore the high DSO-90%} rate of parasitism and
predation of the moth's eggs in New Zealand that is likely also occurring in California.
FICTION; Dr. Hoffman takes issue with the use of the term "colony" for describing how LBAM
establishes itself in an agricultural f eld, noting that the term "colony" is not associated with Lepidopteran
insects,
FACT: The word "colony" was consciously chosen as a concept familiar to the public, "Colony" as an
entomological term refers to a closely related community of social insects such as honeybees, The
authors used the term to explain that LBAM does not buildup to significant numbers in a central location
but instead continues to disperse to other plants.
FICTION; Dr, Hoffman suggests that LBAM's capacity to feed on different plants is a negative feature,
"Polyphagy helps overcome host availability as a limiting factor, and therefore helps populations grow."
FACT: This statement oversimplifies insect biology, ignoring the fact that organisms adapted to a wide
range of food sources are highly unlikely to decimate a single food supply. Dr. Hoffman's statement also
ignores the impact of predators.
FICTION: Dr. Hoffman suggests that the photo of LBAM leaf damage in the New Zealand report was
staged.
FACT: The photo was not staged and shows feeding damage on the edge of the leaf consistent with
damage from LBAM larvae. The authors cannot verify with absolute certainty that the larva pictured is
LBAM as this requires DNA testing that was not available on site in New Zealand.
FICTION: Dr. Hoffman comments, "Neither of the authors are entomologists, so their assertion that they
had great cliff culty finding LBAM could just as easily be from their Zack of expertise... as from the
assumed lack of LBAM."
FACT: The authors have decades of experience working with plants and identifying insects and are very
skilled in finding LBAM.
FICTION: Dr, Hoffman criticizes the Tortricid moth larva parasitization study at UC Santa Cruz
arboretum.
FACT; Dr. Hoffman's criticism diverts attention from the real question: why isn't CDFA investigating
the extent to which LBAM larvae are being naturally parasitized? A basic tenet of IPM is to
determine the extent to which natural controls are working successfully in an ecosystem before
considering an intervention, especially a highly intrusive intervention such as aerial spraying. The point of
the small survey initiated at the UCSC Arboretum was to begin to enumerate the number of natural
enemies and the level of parasitism of Tortricid larvae, Understanding the level of predation by these
natural enemies to LBAM is critical to understanding what if any measures are needed to respond to the
moth's presence in the state. This important research work has not been part CDFA's effort to eradicate
this pest.
FICTION: Dr. Hoffman states that pheromone "trap shutdown is an indirect indication that the
pheromone disruption treatment is working."
FACT: VL~hen pheromone is dispersed into an environment, traps using the same pheromone to attract
male moths are considered "blinded" as the pheromone in the air negates the pheromone being emitted
from the traps, The males simply cannot find the traps so the number of males captured decreases,
Correspondence from New Zealand LBAM researcher John Clearwater who has more than 25 years of
working with LBAM} indicates that CDFA is correct in stating that the traps are blinded but the CDFA is
wrong that a lower trap count following treatment indicates that mating disruption is occurring and
successful. A considerable amount of work has been done on LBAM mating disruption in New Zealand.
Mating disruption pheromones are not in widespread use by apple or grape growers in New Zealand as
use of pheromones in the environment masks the ability to effectively monitor the populations of the
moth so important to IPM control of the pest,
FICTION: Dr. Hoffman states that "USDA uses aerial application of gypsy moth pheromone to
eradicate populations along the 1,200 mile leading edge of the infested area in the Eastern U. S. as part of
their Slow the Spread campaign." He cites this information as evidence that pheromones have been used
for eradication of a pest.
FACT: Dr. Hoffman appears to not understand the meaning of the word "eradication," which means
1~0°/o elimination of a population, as he uses the term here to describe an ongoing cycle of chemical
control, Activities to "'slow the spread" of a pest are not eradication. This use of "eradication" is not only
misleading but in direct contradiction to sound 1PM, which strives to reduce or eliminate use of chemical
controls and only uses a chemical control in the context of a specific plan for avoiding continuing or
repeated chemical use in the future. Applying chemicals repeatedly to control the same pest unnecessarily
subjects human populations and ecosystems to toxic, disruptive exposures and is not a sustainable
approach. The LBAM "eradication" is planned to be a three- to five-year or longer program of annual
chemical use; CDFA's history of repeated annual "eradication" programs for the same pests is a clear
precedent,
FICTION: Dr, Hoffman states that "the authors seem to be advocating the areawide ~i.e., aerial} use of
fGRs for LBAM eradication,"
FACT: The authors do not advocate the areawide certainly not aerial) use of IGRs for the control of
LBAM in any instance outside of agriculture. The New Zealand report presents the most effective tools
to control LBAM available anywhere. The exceptional research effort by expert HortResearch personnel
in developing an effective management and control tool for LBAM should be adopted where needed in
agricultural and horticultural production systems. The techniques of close monitoring and judicious use
of IGRs based on the results of monitoring have been shown to result in no evidence of LBAM on crops,
These techniques can be used to insure that crops from LBAM areas are free of the insect, allowing the
export of these products to countries with LBAM quarantine restrictions, The authors do not advocate the
aerial application of any substance over urban populations. These effective tools for control need to
remain within agriculture,
FICTION: Dr, Hoffman states that other Tortricid moth species in California "have insecticides as one of
the recommended treatments."
FACT: None of these species is the subject of an eradication program,
FICTION: Dr. Hoffman defends the use of chlorpyrifos in nurseries to treat far LBAM.
FACT: Dr. Hoffman ignores the fact that organophosphate insecticides like chlorpyrifos destroy the
beneficial insects that prey on LBAM and other pests,
In conclusion, the authors standby the factual findings presented in the New Zealand report, The factual
information and recommendations of the report remain intact, As yet, the State has not seriously pursued
any of the recommendations, which offer sound alternatives to the current eradication program.
4
RESOLUTION NUMBER #
UPDATED DRAFT MODIFIED FOR
City of Alameda
A RES4LUTIGN OF THE Alameda City Council OPPGSING THE
CALiF~RNIA DEPARTMENT 4F F~~D AND AGRICULTURE AERIAL
SPRAY PRGGRAM TG ERADICATE THE LIGHT BROWN APPLE MGTH
WHEREAS, the Light Brown Apple Moth LBAM} is a pest subject to Federal and
State quarantine and eradication orders; and
WHEREAS, there is a confirmed presence of Light Brown Apple Moths in the City of Alameda; and
WHEREAS, the California Department of Food and Agriculture ~CDFA} plans to
begin an LBAM aerial spraying program in the City of Alameda and surrounding areas in August
2008; and
WHEREAS, modern Integrated Pest Management IPM} relies on least-toxic,
Environmentally sensitive control methods; and
WHEREAS, least-toxic control options are available for LBAM, including
physical and cultural practices such as clean-up of plant debris where moth larvae over
winter; use of natural predators, parasites, and insect diseases; introduction of sterile
male moths; and use of pheromone sticky traps ;and
WHEREAS, aerial and other blanket pesticide applications have repeatedly
been shown in the past to upset natural ecosystem balance in unpredictable and often
catastrophic ways; and
WHEREAS, aerial and other blanket pesticide applications have repeatedly been
shown in the past to cause unintended, unpredictable, and often serious human health
effects; and
WHEREAS, the State has claimed an emergency exemption under the California
Environmental Quality Act (CEQA) in order to begin the LBAM aerial spraying program
without completing an environmental review; and
WHEREAS, the State began the spraying program in Monterey and Santa Cruz Counties in 2001
without completing an Environmental Impact Report and has confirmed that it will not complete an
Environmental Impact Report before the aerial spraying program continues in 2008; and
WHEREAS, blanket spraying of chemicals is expensive and inefficient; and
WHEREAS, biologists have testified that aerial pesticide spraying is extremely
unlikely to eradicate LBAM; and
WHEREAS, biologists have testified that the range over which LBAM has been
detected in California indicates that LRAM has been established in the state for decades; and
WHEREAS, CDFA has stated that no physical crop damage has been attributed to LBAM; and
WHEREAS, scientific study indicates that LBAM does no significant biological or environmental
damage to crops or wild land plants in New Zealand where LBAM has been an introduced exotic pest
for more than 100 years; and
WHEREAS, scientific study indicates that LBAM is 80-90% controlled by natural predators in ,New
Zealand and the same "generalist" natural predators are present in California; and
WHEREAS, the risk of economic damage alone does not~ustify the health and
environmental risks of aerial pesticide applications; and
WHEREAS, the State has relied almost entirely on its awn scientists to address public concerns about
the LRAM spray program and has not employed independent outside experts to evaluate and support
the program or and address issues in a direct and impartial manner; and
WHEREAS, the CDFA LBAM spraying program has used pesticides that both State and independent
toxicologists have stated have not been tested for long-term human exposure risk and toxicity; and
WHEREAS, the CDFA LBAM spraying program is relying on pesticides that contain ingredients that are
highly toxic to aquatic life; and
WHEREAS, the CDFA LBAM spraying program is relying on pesticides that
contain ingredien#s that are documented to be tumorigeniclcarcinogenic, mutagenic, reproductive
effectors linked to birth defects, liver toxins, dermal irritants, and unsafe to inhale; and
WHEREAS, the CDFA LBAM program sprays pesticides in microscopic plastic capsules that pose
unknown inhalation risks; and
WHEREAS, the CDFA LBAM program sprays pesticides in microscopic plastic
capsules that scientific study has shown will be 10 microns or smaller in size, which is small enough to
be inhaled to the deep lung and not expelled; and
WHEREAS, the California Department of Pesticide Regulation and Office of Environmental Health
Hazard Assessment Consensus Document on Health Risks of the LBAM Spray indicates that the S#ate
is relying on conclusions drawn from research that assumes that the pesticides to be used for LBAM
will be sprayed over agricultural rather than populated urban areas; and
WHEREAS, aerial spraying disproportionately affects vulnerable populations
such as those who work and play outdoors, those with the recognized disability multiple
chemical sensitivity, and those in the homeless population who have no option far protection from the
spray or receipt of written notification of spray dates; and
WHEREAS, the California Department of Pesticide Regulation and office of Environmental Health
Hazard Assessment Consensus Document on Health Risks of the LBAM Spray acknowledges that the
state cannot account for health effects of the pesticides on vulnerable populations such as children, the
elderly, and those with chronic diseases; and
WHEREAS, LBAM aerial spraying in the Santa Cruz and Monterey areas
resulted in the spraying of numerous residents and pets; and
WHEREAS, hundreds of reports of health effects were reported following the
LBAM aerial spraying in Santa Cruz and Monterey counties; and
WHEREAS, other environmental impacts were reported following the LBAM
aerial spraying in the Monterey and Santa Cruz areas;
NSW THEREFORE, BE IT RESOLVED AND ORDERED that the City of Alameda:
1 }Opposes the CDFA aerial spray program to eradicate LBAM, and will notify the Governor and other
relevant State and Federal officials of this opposition;
2} Requests that CDFA protect the health and welfare of the residents and natural environment of the
City of Alameda by immediately shifting its LBAM control methods to least-toxic Integrated Pest
Management methods that include monitoring to determine the true risk posed by LBAM;
3} Requests that CDFA shift its focus to educa#ing the USDA regarding the lack of crop damage done
by LBAM, and the need to use least-toxic pest control methods that do not expose populated areas to
aerial spraying
4} Supports, based on up-to-date science, downgrading of the current USDA classification of LBAM as
a quarantinable pest, removing the quarantine of areas where the moth has been found in California,
and notification of trading partners of this reclassification;
5} Requests that the State conduct along-term study of the health and environmental effects resulting
from the aerial spraying project that has been conducted to date in Monterey and Santa Cruz counties,
taking into account reports collected by citizens in the absence of an easily accessible method of
reporting to the State;
6 Supports passage of state legislation requiring explicit consent of affected residents before any aerial
spray, AB 2892 Swanson} as well as the package of other bills CAB 2760, AB 2763, AB 2764, AB
2755, SCR 87, and ACR 117} introduced calling for an immediate moratorium on aerial spray and for
other modifications to the State's aerial spray protocol, including completion of Environmental Impact
Report before spraying, disclosure of pesticide ingredients, invasive species advance planning, and
shifting responsibility to the Governor for declaring an emergency before State aerial spray can
proceed;
7} `Illill work with other Bay Area cities and counties to stop the aerial spraying, including exploring
joining regional legal action.
Signed
- Mayor, City of Alameda
References
California Department of Food and Agriculture. 2008. 2008-2009 Light Brown Apple Moth Action Plan.
Feb. 8. htt :Ilwww.cdfa.ca. ovIPHPPSI de Ilbamllbam main.html
California Department of Pesticide Regulation and California office of Environmental Health Hazard
Assessment. 2007. Consensus Statement on Human Health Aspects of the Aerial Application of
Microencapsulated Pheromones to Combat the Light Brown Apple Moth. 4c#ober 31.
httpllwww.cdfa.ca govlPHPPSIpdepllbamllbam main.html
Carey, James, PhD. 2007. Testimony Submitted in Edna V1lilliams, et al., v. California
Department of Food and Agriculture, A.G. Kawamura, et. al., Case No. 07-05587, U.S.
District Ct. for the Northern District of California. November 14.
Carey, James, PhD. 2008. Testimony Submitted to California Assembly Committee on Agriculture,
Sacramento CA. March 12. available at: http:lldemocrats.assembly.ca.govlmembers1aZ71moth.htm
Harder, Daniel, PhD. 2007. Testimony Submitted in County of Santa Cruz v. CDFA,
Superior Court of California, Santa Cruz County. October 31.
Harder, Daniel, PhD and Jeff Rosendale. 2008. Integrated Pest Management for the Light Brown
Apple Moth in New Zealand: Implications for California. March 6. available at:
http:lldemocrats.assembly.ca.~ovlmembersla271moth.htm
Material Safety Data Sheet. Butylated hydroxytoluene.
Material Safety Data Sheet. Polyvinyl alcohol.
Material Safety Data Sheet. Tricaprylmethylammonium Chloride
MDL information Systems, Registry of Toxic Effects of Chemical Substances: Butylated hydroxytoluene; 1,2-
Benzisvthiazol-3~2H~-one; Tricaprylmethylammonium Chloride
Philp, Richard B. PhD. 2007. Analysis of Toxicology Studies with LBAM and Related
Lepidopteran Pheromones. October.
Philp, Richard B. PhD. 2007. Testimony Submitted in County of Santa Cruz v. CDFA,
Superior Court of California, Santa Cruz County. October 31.
Werner I, Deanovic LA, Markiewicz D. 2007. Toxicity of checicmate~ LBAM-F and Epiphyas postvittana
pheromone tv Ceriodaphnia dubia and fathead minnow ~Pimephaies promelas} larvae. Aquatic toxicology
laboratory. University of California, Davis.
STATE CAPITOL
P.O. BOX 942$49
SACRAMENTO, CA 94249-0027
X916} 319.2027
FAX ri916} 319-2127
DISTRICT OFFICES
701 OCEAN STREET,
SUITE 31 $B
SANTA CRUZ, CA 9506p
x$31} 425-15p3
FAX: x$31} 425-257p
99 PACIFIC STREET
SUITE 555-D
MONTEREY, CA 9394p
($31 } 649-2$32
(4p$} 1$2.0647
I^AX: x$31 } 649-2935
March 24, 2008
~ssemhl~r
~lt~~ ~ ~~~x~~~~e
JOHN LAIRD
ASSEMB YMEMBER, TWENTY SEVENTH DI TRICT
Joan Denton, Director
Office of Environmental Health Hazard Assessment. O ~ f~ N A
1001 I Street, P.O. Box 2815
Sacramento, CA 95812
Mary-Ann Warmerdam, Director
. ~~~
California Department of Pesticide Regulation
1001 I Street, P.O. Box 4015
Sacramento, CA 95812
Mark Horton, Director
California Department of
1 15 Capitol Avenue, PD Box 997377
Sacramento, CA 95812W95S99
Dear Directors Denton, Warmerdam and Horton,
COMMITTEES
Chair, BUDGET
JUDICIARY
LABOR & EMPLOYMENT
NATURAL RESOURCES
I am writin to you today to re uest your attention and response regardin a number of
outstanding health-related matters associate wit t e a i ornia Department of Food &
Agriculture's CDFA 2007 and 2 i ht Brown A p e Moth LBAM}eradication
program. With CDFA's 2008 plans set to be implemented beginning in the next few
~-.
weeks -including new ground-based applications - I am requesting your urgent attention
to these matters.
What follows is background on the issue, as well as specif c matters of interest, including
health complaint evaluations, the need far independent analysis on likely health impacts,
and development of a reportingltracking program.
As you know, in early September 2007, after the CDFA completed the first round of
aerial spraying in Monterey County, numerous residents reported adverse health effects
such as irritated throats, shortness of breath, headaches and nausea. A few residents
visited their doctors, but most complaints were registered with concerned individuals,
primarily by e-mail. Many residents also raised these concerns directly with CDFA.
This document generated electronica!!y.
Re: Agenda Item #3-C
04.01.08 Council Meeting
Provided at meeting
Recognizing that many constituents might not have ready access to health care or may
not be knowledgeable about County-level clinics, I encouraged CDFA Secretary
Kawamura to create a dedicated LRAM telephone hotline. I felt it was vitally important
any complaints arising from the Department's LBAM program should be collected and
fully analyzed. CDFA assured me their existing hotline was equipped to log health
complaints and the "department's medical toxicologist [wasJ actively compiling and
analyzing the collected data" Letter from Secretary Kawamura, actober 4, 2005, p. 2}.
In the weeks leading up to the second round of spraying on the Central Coast, it became
apparent the process for following-up on complaints reported to CDFA's hotline was
counterproductive for two key reasons. First, CDFA's system was inconsistent with
California's established process for reporting known or suspected pesticide illnesses.
Second, on multiple occasions, CDFA's medical toxicologist publicly stated it was his
view the reported illnesses could not be caused by the pheromone spray, thus raising
concerns among residents as to whether the data was being objectively analyzed, or even
simply ignored.
At present, the number of health complaints that have been compiled by concerned
citizens is over 600. The CDFA, sn its February 2008 report to the Legislature,
acknowledged 330 health complaints. Df the 330, st is my understanding approximately
4o complaints were submitted by doctors. Yet to date, the only official response to the
health complaints has been the Consensus Statement published by 4ffsce of
Environmental Health Hazard Assessment ~4EHHA}and Department of Pesticide
Regulation tDPR} on Dctober 3I, 2007.
To the extent the Consensus Statement sought "to provide information on the toxicity of
microencapsulated pheromones and the potential far exposure, and to provide
recommendations," Ibelieve DEHHA and DPR have produced an informative document.
I also applaud aEHHA and DPR for recommends ng a tracking program that "looks at a
number of factors sncluding, but not limited to, both long- and short-term health
outcomes, exposed and unexposed persons, the potential effects of stress and outreach
methods on illness complaints [in order] to begin to properly address the question of
causality" t4EHHAIDPR Consensus Statement, October 3I, 2007, p. b and 7-S}.
However, the Consensus Statement was not a "human health rssk assessment or an
epidemiological study of exposed indsviduals." Further, the Statement acknowledged
that "because not all health effects can be predscted and because the general population
includes susceptible populations, such as children, the elderly and those with chronic
diseases, we cannot provide a definitive cause for their symptoms."
Furthermore, the US Environmental Protection Agency's conclusion cited in the
Consensus Statement} that "based on low toxicity in animal testing, and expected low
exposures to humans, no risk to human health is expected from the use of the
pheromones" refers "primarily to the pheromone active ingredients generally used in
This document generated e[ectronrcal[y.
emitter devises or aerial application over agricultural areas rather than aerial
application over populated areas {emphasis added}."
In a number of weeks, CDFA intends to begin ground-level bacteria application and
applying permethrin-laced moth attractant insecticide in conjunction with expanded use
of pheromone-treated twist ties and releasing stingless trichogramma wasps. The
Department is also conducting studies in New Zealand of several carrier methods for
aerial spraying, including microcapsules, paste-like droplets, and flakes. According to
the Department's 2008 Light Brown Apple Moth Program questions and Answers sheet,
the products are being evaluated for "efficacy, longevity and ease of application." The
Department intends to have results of its evaluations by April 2005 with the goal of aerial
applications resuming over the Monterey Bay area in June and the San Francisco Bay
area in August.
The list of unresolved questions and concerns about CDFA's LBAM program continues
to grow. Therefore, going forward, I respectfully request 4EHHA, DPR, DPH land any
other applicable state departments and agencies involved in the LBAM eradication effort)
to publish the following:
1. An evaluation of the health comps arisin from CDFA's 2007 aerial spraying.
~,~. 2. An analysis of the likelyhealth impacts of the CDFA's 2007, actions and its
2008 laps, including the new pheromone-based pesticide and its inert ingredients,
ground-level bacteria applications and applying permethrin-laced math attractant
insecticide on: healthy adults and children; those with compromised health systems;
those with asthma or other lung sensitivities who breathe in microcapsules; and, air
quality and particulate load.
Dr. Poki Nankung, the Santa Cruz County Public Health Officer, has offered a
detailed analysis and recommendations for the human health risk assessment. Dr.
Namkung recommends the human health risk assessment be conducted by OEHHA
and independent of the CEQA process. Consistent with my above request, the
assessment should consider all proposed methods vis-a-vis a comprehensive set of
parameters. In addition, aEHHA should utilize oversight by relevant experts and
subject their assessment t~ peer-review, including review by local public health
officials. Dr. Namkung's analysis and recommendations are attached, and should be
helpful in your efforts.
3. A formal plan that describes aEHHA's,re~ortingltrackin~,pro_~ram for health effects.
In addition to tracking new or unsuspected exposure-disease relationships, Dr.
Namkung recommends tracking existing health care utilization and health outcomes
data, as this may provide an additional approach to monitor population health effects.
She calls for a system that is more specific than the current Pesticide Illness
Reporting system, which would require training and funding for clinical and
laboratory care and diagnosis.
This document generated edectronical[y.
Further, I believe it is simply unrealistic to expect every person who suspects he or
she is experiencing health effects because of the LBAM program will have the
capacity to visit their doctor-though I fully concur that people should be strongly
encouraged to see their physician or go to a local clinic. With this in mind, an
anecdotal "complaint driven" system is needed, and as Dr. Namkung suggests, it
should be married to the monitoring system. In this regard, I do not believe relying
on CDFA's hotline to record complaints arising from the LBAM program is effective
for reasons stated above. It is critically important that any public reporting
mechanism for the tracking program be widely viewed as "credible and trusted," as
recommended in the Consensus Statement.
In closing, I have also asked CDFA whether it intends to adopt the Consensus
Statement's recommendation to undertake air sampling on particulate load, and I look
forward to learning what roles your departments may have in that effort.
As you know, CDFA intends to begin ground-level spraying using Bacillus thuringiensis
and Spinosad, and applying permethrin-laced, male moth attractant treatments within a
matter of weeks. The items addressed in this letter must be in place prior to ground-
based actions and aerial spraying, so your urgent attention to these recommendations is
vital.
I would be pleased to discuss these issues with you further, and I Iook forward to your
responses.
Sincerely,
~cl~u.. ~a.v,cP
V
JUHN LAIRD, Assemblymember
27`~ District
JL: cf
Attachment
cc: A. G. Kawamura, California Department of Food & Agriculture
Dr. Poki Namkung, Public Health Dfficer, Santa Cruz County
This docume~it generated e~eclronica[ly.
County of Santa Cruz
HEALTH SERVICES AGENCY
PAST OFFICE BOX 9fi2,1ofiD EMELINE AVE., SANTA CRUZ; CA 95Dfi1-09fi2
TELEPHONE: X831 } 454-4114 FAX: X831 ~ 454-5D49 TDD: X831 ~ 454-4123
Polo Stewart Namkung, M.D., M.P.H.
Health Ufficer
Public Health Division
March I5, 2005
The Honorable John Laird
Santa Cruz County District Office
701 Qcean St., 315 B
Santa Cruz, CA 95060
State Capitol Office
P.Q. Box 942849
Sacramento, CA 94249-0001
Re: Scope of the Proposed Environmental Impact Review of the, Light Brown Apple Moth
Dear Assemblymember Laird:
This letter provides my comments as the County of Santa Cruz Health Officer on the scope of the
Environmental Impact Report (EIR}for the California Department of Food and Agriculture ~CDFA)
2008-09 action plan for the eradicationlcontrol of the light brown apple math LBAM} focusing on
three aspects:
1. The otential health effects of any proposed eradicationlcontrol plan
2. The analysis of all available scientific evidence in order to assess the need for an
eradicationlcontrol plan for LBAM and the potential eff cacy of such a plan.
3. An anal sis of the impact of last year's aerials of S Cruz and Montere Counties
on LBAM reproduction and the essential elements of a health monitoring system that are
necessary given Santa Cruz County's experience with aerial spraying of a pesticide.
The County of Santa Cruz is a mix of urban, suburban, rural, agricultural, and natural settings on the
central coast of California. Agriculture represents a major industry for Santa Cruz County and 15% of
our fruits and vegetables are organically grown. Qur county is, by CDFA statistics, the most heavily
infested county in California with the newly identif ed quarantinable pest, the light brown apple moth.
Qur county and Monterey County experienced extensive aerial spraying last November, 2007 with a
chemical pheromone product resulting in over 600 recorded complaints from residents of adverse
health effects resulting from exposure to the spray. we are therefore highly interested that the potential
D
PublicHealth
Prevent. Promote. Protect.
Asseinblymemeberpohn Laird CDFA LBAM Letter
March 18, 2008
Page 2
health effects of whatever actions proposed for the eradicationlcontrol of LBAM be thoroughly
investigated prior to exposing our population to risks that are unknown at this time.
~Ve understand that the CDFA and USDA LBAM eradicationlcontrol plan is evolving and will involve
multiple control modalities, but currently includes plans to conduct aerial spraying of LBAM
pheromones over at least four counties, including ours, beginning in summer of Zoo8. The actual
specific commercial product to be used in this spraying has yet to be chosen, thus an official
toxicological review and a human health risk assessment have not been done,
There is growing public concern and opposition to aerial spraying. Cal EPA, the Office of
Environmental Health Hazard Assessment ~QEHHA}, and the Department of Pesticide Regulation
~DPR} have issued a consensus statement on "Human Health Aspects of the Aerial Application of
Microencapsulated Pheromones to Combat the Light Brown Apple Moth".~ The statement indicates
that reported symptoms such as eye, skin, ar respiratory irritation "could be consistent with inhalation
of a sufficient amount of the applied material" but that because the measured application rate was very
Iow, "it is likely that exposure occurred at levels below those that would be expected to result in health
effects. However, because not alI health effects can be predicted and because the general population
includes susceptible populations, such as children, the elderly, and those with chronic diseases, we
cannot provide a definitive cause for their symptoms."
VL~hile it is appreciated and understood that the selection of a pheromone for an eradicationlcontrol
program may be the least potentially toxic alternative, public concern is focused around the inert
ingredients involved, as well as its application by aerial spraying. Public Health officials in California
have been told that there are no long-term studies to determine the effects of chronic exposure nor have
these pheromone products ever been aerial sprayed over urban populations. V4~e do not believe that
any spraying should commence before completion of an EAR that includes a comprehensive human
health assessment. We also believe that a proposed eradicationlcontrol program should provide all
available scientific evidence and justification far the efficacy of control measures, including an
analysis of the effects of last year's aerial spraying of Santa Cruz and Monterey Counties.
There is also considerable disagreement among credible scientists about the threat that LBAM poses.
Experience in New Zealand has demonstrated that with strong integrated pest management, the
damage to crops or natural foliage is far less than what CDFA predicts. ~n major agricultural regions in
New Zealand, similar to California, LBAM is considered a minor pest. It does remain a pest of concern
because it is a quarantine pest for exports. However, because of highly effective integrated pest
management techniques, very few New Zealand fruit shipments are rejected by the U.S.~
Finally, once an eradicationl control program is formulated, it must include a robust monitoring
system for human health effects. This would include training healthcare providers to become
proficient at systematically examining patients and collecting necessary information to better assess the
possible effects of pesticidelchemical exposures. A fund or funding mechanism should be established
~ http:Ilwww.panna.orgldocumentsllbamPheromones20071116.pdf
z Harder, D, Rosendale, J; Integrated Pest management Practices for the sight Brown Apple Moth in IVew Zealand:
Irnplicarions for California; March 2008
Assemblymemeberpohn Laird CDFA LBAM Letter
March 18, ZD08
Page 3
to provide payment for medical evaluation and treatment. Continuation of an anecdotal complaint
driven system may still be necessary, however it should be married to a monitoring system that tracks
healthcare utilization and health outcomes data.
In summary, while we understand the CDFA's position that early and aggressive intervention has the
potential to eradicate LBAM in California, we also acknowledge that the proposed eradicationlcontrol
strategies involve new and untested technologies for which the risks and benefits to human health have
yet to be evaluated. ~Ve also acknowledge the great public concern about the risks of aerial spraying
and the growing skepticism about the need for such a program. We therefore ask that the following
issues be incorporated fully into the proposed EIR:
t. CDFA complete its environmental review before the implementation of any further
eradicationlcontrol plans.
2. Currently, CDFA is considering only one control plan in addition to the no-project alternative.
Given public controversy surrounding aerial application, CDFA should identify, consider, and
analyze other additional alternative programs of control that limit aerial application in urban
areas. All available scientific information, including an analysis of the efficacy of last year's
aerial spraying in Monterey and Santa Cruz Counties, should be used to formulate and justify
proposed efficacy of a program. The program description and alternatives should provide all
available evidence for the efficacy of contxol modalities in each of the geographical contexts
where CDFA anticipates using that modality. More specifically, given the limited history of
pheromone use in urban settings, CDFA should consider how factors specific to in urban
environments such as building heights, paved surfaces, limited vegetation, and urban canyons
might affect the efficacy of treatment modalities or influence choice of modalities.
3. The control alternative describes six control modalities but does not describe how CDFA will
utilize and blend control modalities in specific geographical contexts. The description of the
project and alternatives should describe the criteria CDFA will use to use or blend specific
control modalities in specific geographic contexts. CDFA should describe haw factors such as
climate, population density, building heights, or urbanization will be used to select specific
modalities.
4. CDFA proposed to conduct a human health risk assessment within the CEQA process. Given
that public controversy largely concerns human health risks, the risk assessment should be
conducted independent from the CEQA process by a qualified state agency. Vie recommend
that the State of California Environmental Protection Agency Office of Environmental Health
Hazard Assessment ~aEHHA~ conduct the risk assessment considering all modalities proposed
in the action plan, utilizing oversight by experts in relevant disciplines, and considering how
human health hazards may vary depending on context. CDFA should ensure that local public
health officials parrticipate in oversight and peer-review of the risk assessment. The EIR can
reference this risk assessment. The human health risk assessment should specifically consider:
a. Effects of the product, the active and inert ingredients, alone and in mixture;
b. Effects related to the microcapsule carrier ~e.g. respirability, toxicity}
c. Atmospheric behavior of the product dispersion patterns}
d. Persistence in the environment ~e.g., is the product biodegradable}
e. Cumulative effects on other regulated arhon-regulated pollutants
f. Potential routes of human exposure ~e.g., ingestion, inhalation, dermal absorption}
g. Anticipated concentrations in various environmental media-air, water, surface residues
' Assemblymemeber Sohn Laird CDFA LBAM Letter
March 1 S, 2Q08
Page 4
h. Development of risk quotients relating anticipated dose to a dose known to be toxic,
particularly in relation to chronic or cumulative exposure.
i. Variations in potential exposure due to geography, built environmental form, and
meteorology.
j. Existence of populations that may be particularly sensitive to the application
S. To respond to and mitigate public concerns, CDFA proposes to work with CDPH to
implement a monitoring program to pro-actively track potential health effects of control
measures. While complaint tracking is appropriate to identify new or unsuspected exposure-
disease relationships, the tracking of existing health care utilization and health outcomes data
may provide an additional approach to monitor population health effects. Types of data that
may be productively utilized include emergency room visits and school attendance.
6. Monitoring of human health effects must also include systemized collection of health data and
exposure data from health professionals that is mare specific than the current Pesticide Illness
Report system. This would necessarily involve training and outreach to health professionals to
be able to examine for and assess the potential exposure effects. A fund should be established
to provide payment for clinical care and laboratory diagnosis.
7. Environmental impacts should be assessed in conjunction with regional water quality control
boards and air quality management districts, the Bay Conservation and Development
Commission, the State Lands Commission, the State Coastal Commission, The Department of
Fish and dame, the U.S. FXSh and Wildlife Service, among others.
Sincerely,
Polo Namkung, MD, MPH
Health Dff i cer
cc: Susan A. Mauriello, County Administrative Officer
County Counsel
Light Brown Apple Moth Damage
Photos provided by HortResearch
Submitted by Dr. Bob Dowell at the
04.47.08 Council Meeting
Re: Agenda Item #3•C
L1~~1T BRfl~IN APPLE MATH
BAY APB
'osted 21~ 5108
(1 GUARA~IE REt~AI~ ~ DELIMITATIbN TRAPP~JC
~~~~] ~ ERADICATIONi ARF,0, ~ PROP4SE~ Z4DM7WI57TIE
(,~ ~ 2DD7.2008 TRAP PIND
_ ~ ERADICATION COMPLETED Q PROPOSED AERIAL TREATMENT
~ AERIAL TREATMENT 20D7 ~ PROPOSED WASP
Ag Secretary Protects Farmers, Environment
By: A.G. Kawamura, Secretary, California Department of Food and Agriculture
March 30, 2008
Excerpts below, for full view article please view htt :llwww.santacruzsentinel.comlci 8747687?IA.DID
As California's agriculture secretary, it is my duty to protect farmers and their crops from the damage that maybe done
by pests like the light brown apple moth, a recent arrival to our Central Coast and Bay Area regions. It is also my duty
to protect California's environment, and this pest is a bona f de threat to hundreds of native plant species. 4n those
grounds alone -- even if there is never a single dollar's worth of damage done to California's crops -- we should
eradicate this infestation while it is still possible to do so.
The moth is the latest invader to capture our attention, and there is no shortage of good reasons to eradicate this
dangerous pest from California. It is among the most serious new threats to our food supply and environment we have
seen in decades, so our trading partners are taking drastic actions. Canada and Mexico recently ratcheted up quarantines.
These two countries are among our leading trading partners, ranking second and fifth, respectively, among our
agricultural export destinations --combining to claim a $2.4 billion slice of our state's $9.6 billion in California's
agricultural exports. Make no mistake -- these restrictions are going to have a lasting impact on growers, on their
workers and suppliers, on their crops and on our communities.
Because of the appearance of the moth here, Canada and Mexico have tightened the screws on hundreds of California
growers who export their crops, making it more costly, more labor intensive and more time-consuming to prove their
crops are "free from" the moth and qualified for export. Even though Mexico has recently rolled back some of its newer
restrictions, the threat of increased costs to our agricultural producers remains..,
A common question is "What if you don't eradicate?" There is a misconception circulating on the Internet and elsewhere
that this is a paper pest, that maybe, just maybe, no damage would occur if we just turned our backs and hoped for the
best. "Let nature take care of herself," the argument goes.
Unfortunately, it wasn't nature that brought the moth here -- it very likely was people bringing plants into the state
without the proper inspection and clearance...
Quarantines like those imposed by Canada and Mexico are the most obvious consequence of failing to eradicate, but it
is important to also consider the additional pesticides that will be used far into the future by farmers, homeowners,
landscapers and others who will be motivated to protect their crops, yards and gardens. Eradicating this pest is as much
an enviranmental imperative as it is an act of agricultural protection.
So, what can we do about this infestation? Fortunately, we have an innovative solution that satisf es the dual
requirements of being both effective and environmentally benign. Pheromones are that solution. Unlike chemical
pesticides, pheromones do not kill or even harm anything --not even the moths. They simply distract the male moths so
they cannot find a mate, causing the colony to collapse from a lack of breeding.
For years, the environmental community has demanded that agriculture move toward such sustainable, cutting-edge
tools that provide safer alternatives to chemical pesticides. While conventional insecticides kill pests on contact or by
ingestion, pheromone products are inherently safer because they do no harm to the insect. Pheromones merely distract
the male moths so they can't find a female, and reproduction is curtailed. We can't sense or detect them, but these
pheromones are all around us every day, emitted by the moth as well as native moths and butterflies in our environment
I am proud to be able to offer this progressive, alternative approach to eradicating the light brown apple moth, and I
trust that once the facts are understood, Californians will support this forward-thinking approach to protecting the
Golden State's diverse resources.
###
~~
~ CALIFQRNIA ~EPARTMFNT 4F
~ ~ ~ FOOD 8 AGRICULTURE
Light Brown Apple Moth (LBAM)
FACT SHEET
SUMMARYlBACKGRQUND
The Light Brown Apple Moth LBAM} is an invasive pest that attacks over 250 crops examples: citrus, grapes
and fruit tree crops} and 2,000 host and ornamental plants examples: roses, jasmine and mums}.
In early 2007, LBAM's presence was first confirmed by California Department of Food and Agriculture CDFA}
and United States Department of Agriculture USDA}, and an emergency was declared.
o This is the first infestation of LBAM in the contiguous 48 states.
o The state legislature passed legislation stating that the infestation presented a "clear and present danger."
LBAM is currently infested hand quarantines are in place} in ten Bay Area and Central Coast counties Monterey,
Santa Cruz, Santa Clara, San Mateo, Contra Costa, Marin, San Francisco, Alameda, Solanv, and Santa Barbara}.
o Isolated detections last year in Los Angeles and Napa counties have already been eradicated fusing twist
ties that emit moth pheromone}, and in Sonoma County, where a single moth has been detected, intensive
trapping is underway to determine if there are more.
ERADICATION PRQGRAM
Protecting California's environment from invasive species is the goal, and eradication (via mating disruption} is
the strategy.
The eradication program was designed by the Technical Working Group ~TWG} and is under constant scientific
review.
o TWG is a group of global scientific experts appointed by the USDA to advise and evaluate California's
LBAM infestation. Their eradication program is based on published and peer-reviewed research, as well
as TWG's career and academic experiences.
Pheromone treatment is the primary means of eradication, which mimic female moths to break the moth's
breeding cycle by confusing the male moths. Anticipated methods are based on levels of infestation and include:
o Pheromone-infused twist ties applied by hand} to treat the "outlier infestations" few moths in isolated
areas}.
^ Currently being used in Alameda, Marin, San Mateo and Solano counties.
^ Planned for Treasure Island (San Francisco County} and Carpenteria Santa Barbara County} in
late March and April.
o A "male attractant technique" that combines the pheromone with a pesticide in a mixture applied in small
splotches on utility poles and trees for "intermediate infestations" ~a limited number of moths spread over
a fairly large area}.
o Aerial spraying with a TBD pheromone product to treat the heaviest infestations many moths in a large
area}.
o Additional methods include the release of tiny, stingless parasitic wasps that feed on the moths' eggs and
organic-approved biopesticides Bt or Spinosad to treat concentrations of LBAM larvae.
COMMUNITY OUTREACH
CDFA is reaching out to affected communities -including hearings, briefings, meetings, mailings, and earned
media -- to educate and explain the eradication program.
CDFA will continue to encourage citizens to subscribe to the email notif cation service, utilize the hotline and
visit the website for current information.
MORE INFORMATIQN IS AVAILABLE
CDFA - www.cdfa.ca.govllbam,
CDFA Pest Hotline: 800-491-1899
APHISIUSDA - www.a his.usda. ov
Page l of 1 Last Updated: 411105
6~
CAIiFORNlA DEPARTMENT OF Light BI"oIIVn Apple Moth
~. Fooo ~ AoRlCU~TUi~E
"Claims and Responses"
CLAIM: There's been "no demonstrated damage by the apple moth. This is the green age but
they're still doing things in the old toxic way. " (Dona spring, Bcrkclcy City Councilmcmbcr, The Dail Cali orniulr 2125108}
RESPONSE:
- The Light Brown Apple Moth ~LBAM} treatment with moth pheromone is the most
environmentally friendly pest eradication program in the history of the California
Department of Food and Agriculture CDFA}. Moth pheromone treatment is progressive and
dramatically different from treatments with conventional pesticides.
- The pheromone doesn't kill or even hurt the moth, Instead, it creates mating confusion and
disruption, which prevents moths from multiplying and results in the population dying out
naturally.
- If not eradicated, LBAM can cause damage to the environment and the food supply like it
does in Australia, where it is native, and in New Zealand, where it has been for more than
1.00 years. In California, damage to date has been minimal because the pest was detected early,
before significant damage occurred.
- The pheromone eradication technique was designed by a Technical Working Group
TWG} of international scientific experts. The T~VG believes the moth is a serious
environmental and agricultural threat to California. (source: APHIS~usDA
CLAIM: No one "outside the state of California has said the jaerial~ spraying is safe. "
Jane Brunner, Oakland City Councilmember, Tri-Valle Hera! 2125108}
RESPGNSE:
- Aerial treatments with moth pheromones have been ongoing around the world for more
than a decade.
- Illinois, Indiana, Ohio, Virginia and Wisconsin have sprayed the pheromone in residential
areas. (source; USDA)
- More than 3 million acres in the U.S. have been treated aerially with moth pheromone for
mating disruption of the gypsy moth, All of these treatments, like that in California, have been
with a product consisting of moth pheromone formulated with other ingredients.
- There is no indication that these treatments have harmed people, pets or plants. (Fur more
information see a e 14 of the USDA's Februa 2008 environmental assessment
CLAIM: Aerial spraying "doesn't work." Instead CDFA should be using "ground treatments "and
a "natural enemy, tike anon-stinging wasp. "
(Jared Blumenthal, Director of San Francisco's Department of the Environment, San Diego Union Tribune,211310$)
RESPONSE:
- CDFA and the U.S. Department of Agriculture USDA}are already utilizing ground
treatments as part of the varied approach suggested by the TWG. Ground treatments with
pheromone-infused twist ties are occurring in isolated areas with small infestations.
- ether ground-based approaches, such as the release of stingless parasitic wasps, are
anticipated.
- Aerial pheromone treatment should be the approach for heavy infestations spread over
large geographic areas, according to the TWG report. (Source: APHIS_IUSDA)
Page 1 of 3 Last updated 4.1.08
.. ..
r CALtFQRNtA DEPARTMENT of `~ h~ Brown A le Moth
FOLD $ AGRICIJITURE ~ ~~
"Clams and Responses"
CLAIM; Aerial spraying should be stopped until a "reliable outside independent source ver f es that
there are no health effects. " {Qakland City Council resolution, Ba~Ciry Neu7s, 316108)
RESPQNSE:
- The USDA is working with New Zealand agricultural officials. Together, they are testing
aerial pheromone products for use in 2x08.
- A complete battery of scientific tests is being conducted at the request of the federal and
state EPAs and by a private laboratory in Texas. These tests, known as the "six-pack," are for
oral toxicity, dermal toxicity, skin irritation, inhalation toxicity, eye irritation and dermal
sensitization,
- Before any spraying occurs, the U.S. EPA, the state Office of Environmental Health
Hazard Assessment ~UEHHA}, Department of Public Health ~DPH} and the state
Department of Pesticide Regulation ~DPR} all must review the test results to accept the
treatment aslow-toxicity.
CLAIM: The CDFA is spraying far `political reasons "and "demonstrates a full out press to keep
f the] USDA from slapping a quarantine on California]. "
(Steven Scholl-Buckwald, Pesticide Action Network, ~4BC7News.com, 2113108}
RESPONSE:
- We must eradicate LBAM to prevent significant environmental and economic damage to
California.
- The pest threatens more than 2,040 plants and mare than Z54 crops.
- If it is not eradicated, a statewide quarantine would be established. In order to meet the
quarantine requirements, California food producers could face delays and increased costs, which
could trickle down to consumers. The impacts could be felt from restaurants, to grocery stores,
to farmers' markets.
- The USDA estimates that, should the pest become established statewide, it could cause
billions of dollars worth of economic damage. (For more information, see pa~19 of the USDA's FcbNar~+ 2008
cnvironmcntal asscssmcnt )
CLAIM: LBAM can't be that devastating to thousands of species of plants, otherwise "both
Australia and ~Vew Zealand would be very barren countries, plantwise, and that isn't the case. "
(Richard Fagerlund, Sari Francisco Chronicle 2123108}
RESPONSE:
- Natural predators in Australia keep LBAM manageable there, along with other pest-control
practices.
- New Zealand has imported natural predators from Australia for LBAM.
- Those natural predators don't exist in California, according to California's Primary State
Entomologist, Dr. Kevin Hoffman. There is no guarantee that natural predators will evolve in
California, which, in any case, has a goal of eradication rather than pest control. {source. CDFA}
Page 2 of 3 Last updated 4.1.OS
{', CALIFORNIA DEPARTMENT OF Light Brown Apple Moth
cdfa FOOD & AGRICULTURE
X11-1 "Claims and Responses"
CLA1M: After the 2007 aerial sprayings in Santa Cruz and Monterey counties, over "60o reports of
eat pro ems emerged. (Traci Shcchan, Planning and Conservation League, Culrfor,ria Progress Report, 317108}
RESPONSE:
- oEHHA, DPR and DPH are reviewing the claims of illness. They will have a conclusive
report completed by early April 2008.
- It is unlikely the pheromone was used at exposure levels that would be expected to result in
health effects. Previously, a consensus statement by OEHHA and DPR, in consultation with
DPH, concluded that there was an extremely low application rate of the pheromone product used
last year - about a teaspoon per acre. (source: Consensus Statement}
CLAIM: I'he class cation of L~A1V1 "as an actionable quarantine pest" is based on outdated
classifications bythe United States Department of Agriculture (USDA} and "should be reviewed
and revised based on current, relevant, science-based information. "
(Integrated Pest Management Practices for the Light Brown Apple Moth in New Zealand: Implications for California, Report, 316108)
RESPONSE:
- A USDA review in 2003 determined that LBAM is "considered highly likely of becoming
established in the U.S.; the consequences of its establishment for U.S. agricultural and
natural ecosystems were judged to be high." This is current and relevant science. (source: osDA
"Mini Risk Assessment," September 2003}
CLAIM: The spray contains ingredients that are highly toxic to aquatic species. As well as
surfactants, that might have contributed to algae bloom fired tide) and the death of hundreds of
waterfowl. (A flyer at: h ;Ilwww.lbams ra .com100 Fl erslMarinFl er. df}
RESPOIVsE:
~ A UC Davis study that found the Checkmate pheromone product used last year was not
harmful to marine life. The study was completed in fall 2007, at the request of the
Monterey Bay National Marine Sanctuary. (source: Marine Lifc Study}
- A California Department of Fish and Game (DFG} study showed no traces of
Checkmate in dead waterfowl found last year in the central coast area. That study was
completed in March 2008. (Source: Fish and Gamc Study}
CLAIM; CDFA's aerial program "doesn't smelt right. If the problems are out there, why are they
just spraying the urban areas}? "(Jane Brunner, Oakland City Councilmember Source: Trr-tulle Herald 2125108}
RESPONSE:
- CDFA is treating infested areas.
- Most CDFA eradication programs, historically, have been in urban areas due to higher
population concentrations and a propensity for people to bring invasive species into
metropolitan areas.
- Urban areas are common locations for invasive species introductions.
Page 3 of 3 Last updated 4.1.08
"...we applaud CDFA's decision to use an
approach to the Light Brown Apple Moth that
relies on the principles of IPM [integrated pest
management] and that uses apheromone-based
approach instead of toxic insecticides."
GINA M. SOLOMON, M.D., ~III.P.H., SENIOR SCIENTIST
NATIONA! RESOURCES DEFENSE COUNCIL ~NRDC~
How do pheromones work?
Insect pheromones are signals that some insects release to
attract mating partners or trigger other behaviors. Humans
and other mammals do not respond or react to these insect
pheromones and cannot detect them. These pheromones
are present in our environment every day.
When we release the pheromone, the treatment works by
surrounding the male moths in the area with the phero-
mone, distracting them so they cannot locate mating
partners. The moths simply live out their natural life cycles
without being able to locate and mate with a female moth.
As breeding subsides, the colony collapses.
agriculture
Studies of the LBA1~ pheromone in particular and of the
interaction of pheromones and mammals in general have
shown no evidence for concern about exposure to phero-
mones, even at much higher levels than those present in the
aerial treatment approach. The Environmental Protection
Agency (EPA), the primary reviewer of pheromone prod-
ucts, does not perform long-term human testing for any
pesticide; however, animal studies Indicate a large margin
of safety for even the most sensitive groups. Based on low
toxicity in animal testing, and thus expected low exposure to
humans, no risk to human health is expected from the use
of these pheromones. During more than a decade of using
mofh pheromones to control LBAM infestations in Australia
and New Zealand, no adverse effects have been reported.
Pheromones' safety record has also prompted the EPA to
conclude that consumption of food containing pheromone
residues presents no risk. The USDA has also approved this
pheromone and others for use on organic crops.
"This really is a benign pest control agent. It is
much safer than commonly used home cleaning and
home pest control products. In fact, as humans, our
bodies are unable to recognize and/or even react to
pheromones produced by insects."
DR. CARL WINTER, TOXICOLOGIST AND DIRECTOR
UNIVERSITY OF CALIFORNIA, DAVIS FOODSAFE PROGRAM
of California's
environment,
Is aerial treatment the best option?
Alternatives including mass trapping, sterile insect technique
~SIT~, pheromone twist-ties and conventional pesticides were
all evaluated by a Technical Working Group of scientists.
Conventional pesticides: A number of conventional
pesticides, including some that are approved for use on or-
ganiccrops, would be effective against the LBAM. Unfortu-
nately, these products would also affect endangered insects,
Monarch butterflies and other beneficial insects such as
pollinators. The pheromone is specific to the LBAM species
and, since it is not toxic, it leaves these endangered and
beneficial insect populations unaffected.
Trapping or twist-ties: Traps are effective to detect
a pest and are a very valuable part of this program, but
deploying an array of traps or twist-ties dense enough to be
effective as an eradication tool would require thousands of
staff and millions of traps/ties, neither of which are avail-
able in sufficient quantities. Operationally, this approach is
not feasible over a large area or region.
Sterile Insect Technique: Australia and New Zealand
have begun developing the facilities, equipment, expertise
and technologies needed to conduct sterile insect releases
for LBAM. The theory of SIT is sound and the prospects
for LBAM are promising, but the project will take years to
develop. USDA is working with its international partners
to accelerate this process as much as possible so that this
option is available in the future.
What areas are infested?
Infestations have been found in California's Central
Coast and Bay Area communities including portions
of the counties of Alameda, Contra Costa, Morin,
Monterey, Napa, San Francisco, San Mateo, Santa
Clara and Solano.
A few of the 254+ plants threatened by
!~
Monterey Pine Almond Camellia Grape
The biology of the pest and the recent arrival of the infesta-
tion are the driving factors in the urgency of these treat-
ments. A national pest survey in 2405 confirmed that the
moths were not present in California at that point. The
survey relied on the same pheromone-based traps now in
use, and traps were set in several of the same areas now
known to be infested. The populations of LBAM are still
relatively small and are considered by an international
panel of expert scientists to be susceptible to eradication-
butonly if we take significant action promptly.
The LBAM infestation could grow exponentially with approx-
imatelyfive mating cycles per year and each female moth
laying hundreds of eggs per cycle. Failure to act quickly
invites substantial environmental and economic impacts.
The program's emergency status allows the eradication to
begin under a temporary exemption from environmental
analysis, with the understanding that a full environmental
assessment of the project, including these emergency treat-
ments, will be completed. That assessment will likely take
more than a year to complete, and the process has already
begun. If we were to wait that long to begin the eradica-
tion effort, experts agree that the infestation would be well
beyond reach, spreading over a larger area and multiply-
ing exponentially through several breeding cycles.
Do these pheromone applications affect
beneficial insects, endangered species
or Monarch butterflies?
Although moths and butterflies are similar insects, the
pheromones used by their separate species are different.
Monarch butterflies are not attracted to the light brown
apple moth pheromone and will not be confused or oth-
erwise affected by it. The pheromone treatment iswater-
based and contains no oils or other materials that would
pose a threat to the Monarch population.
As an alternative to conventional pesticides, the pheromone
has the distinct advantage of being highly specific to the
LBAM, so mammals and other organisms are not affected.
!n the pheromone-based traps used to detect LBAM, we
have trapped only limited numbers of five closely related
moth species, further indicating the highly specific nature
of this pheromone. Two of these other species are also
invasive pests, although they are not considered significant
threats because they do not share the LBAM's wide host
range and rapid reproductive cycle. Because these other
moths are permanently established in the region beyond
the limits of the LBAM treatment area, any reduction in
these populationswould be expected to rebound after
LBAM eradication treatments subside.
Brown Apple Moth:
Hibiscus
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The EPA has established that pheromone applications are
not toxic to fish or aquatic invertebrates because phero-
mones are insoluble in water. While the scientific data
strongly establishes that this product is not harmful to
aquatic life, we have also engaged local ecotoxicologists
with the University of California to conduct further study
to ensure that concerns raised by environmental groups
are thoroughly addressed. Early results show no harm to
aquatic life.
Toxicity aside, applying pheromones over water is unneces-
sary to eradicate the LBAM infestation because the moths
do not live, breed or feed there. The eradication project
can be successful without applying the pheromone over the
ocean and other bodies of water, so we have established
strict protocols including buffer zones to ensure that we are
applying the pheromone only over land.
How are the aerial treatments done?
Three King Air twin-turbine airplanes fly over the
treatment areas along parallel paths set by GPS
systems, The treatments are performed at night to
minimize the inconvenience to the community and
because there is less air traffic. The planes re-
lease the Checkmate LBAM-F pheromone product
through spray nozzles beneath the wings. The
planes typically return to the airport and reload
several times during the night.
Weather plays a significant role in any aerial
treatment. Typically, inclement weather or winds
of over 1 ~ miles per hour will cause a delay or
postponement, if the weather or winds subside,
treatment may resume the same night. If not,
treatment usually resumes on the next clear night.
During treatment periods, CDFA offers automatic
e-mail updates aboutthe treatment schedule and
any delays ar rescheduling--please sign up online
at www.cdfa.ca.gov/Ibam. Updates are also avail-
able bycalling the hotline at 1-500-491-1599.
During treatments, CDFA also communicates with
local officials and members of the media to pro-
vide updates if Mother Nature or any other factor
imposes a change in plans.
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How does the Light Brown Apple Moth
affect our local economy?
The current LBAM infestation has already caused the na-
tions of Canada and Mexico to impose onerous restrictions
on exports of crops and plants from the infested areas of
California. China also has begun the kind of information
gathering that frequently leads to such trade restrictions. As
businesses are forced to delay, reduce or abandon exports
to these nations, employment, investment and tax levels
are all adversely impacted. Internally, restrictions are also
imposed by CDFA and USDA on businesses such as plant
nurseries ~n the infested areas so that their counterparts
outside of the area can be protected from the infestation.
These businesses must comply with strict regulations that
limit or delay the companies' ability to export their plants
outside the area. If the infestation is not eradicated, these
regulations and trade restrictions would continue indefinite-
lyand other countries would likely adopt similar measures.
What can I do to help?
Invasive species such as the LBAM can arrive in California
in any number ofways, but the most common method is for
international travelers to bring in prohibited fruits, vegeta-
bles, plants, soil, seeds or related items, Please leave these
items in their native countries. If you think you have seen
or captured an invasive pest, CDFA also operates a toll
free pest hotline at $00-491-1899. Residents of LBAM
treatment areas are also welcome to use this hotline for
updates and information about the eradication project.
/ The LBAM is part of a family of
moths called "leafrollers" because
the caterpillar rails the edges of a ~ .,
leaf around itself for protection. r
Oak Redwood
What is the Light Brown Apple Moth?
The Light Brown Apple Moth LBAM} is a small ~~ ~ ~~'~~°.
E;r~~ ~
moth, approximately'/a inch in length, and is ~~ • ~j'~'
enerall tan with some darker markin s It is ,,;'
g Y 9
originally from Australia and has also infested ~ ~'
New Zealand, New Caledonia, Hawaii and the ~
r
Brltlsh Isles. It feeds on such a wide variety of ,
~,
plants that it is considered a significant threat to
the environment as well as to agricultural crops.
Other nations and territories understandably
want to keep it out, and they typically impose trade restric-
tions such as plant and crop prohibitions, inspections or
other requirements to do so. Now that LBAM has been
detected in California, officials in Canada and Mexico have
imposed such restrictions on the affected areas, complicat-
ing and curtailing agricultural exports for local growers.
What damage does the LBAM do?
Before it matures into an adult moth, the LBAM caterpil-
larfeeds on and damages the leaves and new growth of
plants. 0n some crops including grapes, apples, ci#rus and
avocado, LBAM larvae also feed directly on the fruit, ren-
dering it unmarketable. More than 250 kinds of plants are
Targeted by this pest including Monterey pine, cypress, oak,
roses and many common crops and ornamental plants.
Most any plant in the average garden or yard is on the list.
The centerpiece of the eradication project is aerial releases
of the moth pheromone Checkmate LBAM-F to confuse
male light brown apple moths and keep them from locat-
ing amate. As breeding subsides, the colony will collapse.
The pheromone is the most environmentally friendly alter-
native available to eradicate this infestation. The overall
program also relies on other elements such as insect trap-
ping, surveys, and inspection and treatment of plants and
crops to make sure the infestation does not spread.
"LBAM is a generalist defoliator with a long host
list including such important native conifers as
coast redwood, Douglas fir, grand fir, pine, spruce
and cypress species... In the absence of its
native predators and parasites, LBAM could easily
explode through California forests causing yet
another wave of dead trees and shrubs and the
associated casts."
RUTH COLEMAN, DIRECTOR
CAf.IFORNIA DEPARTJNENT OF PARKS AND RECREATION
The following agencies and organizations
consider the aerial pheromone treatment
approach for the eradication of LBAM to be
acceptable:
U.S. Environmental Protection Agency jEPA}
California Department of Pesticide Regulation ~DPR}
California Office of Environmental Health Haxard
Assessment ~OEHHA}
California Department of Parks and Recreation
California Department of Public Health ~DPH}
California Certified Organic Farmers ~CCOF}
Central Coast Regional Water Quality Control Board
U.S. Fish and Wildlife Service
Natural Resources Defense Council ~NRDC}
Monarch Watch
Otter Project (Monterey County)
CDPA PEST HOTLINE:
LBAM PROGRAM E-MAIL:
SIGN UP FOR E-MAIL UPDATES:
~] CALIFORNIA DEPARTMENT DF
(~ FOOD ~ AGRICULTURE
www.cdfa.ca.gov/I ba m
OCTOBER X007
,,
~DFA > Public Affairs > Press Release
News Release
~Al1FgRNYA UEFAR7MEh~T €3F F4~0~ A~~p A~G~I~UL~La~E
Media Contacts:
Sleeve Lyle, CDFA Public Affairs, X996} 654-0462
Larry Hawkins, USDA, ~996~ 930.5509
Page 1 of 3
~, ,
. ;:~.wr;~.~
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;•
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Arnold Schwarzenegger, Governor
A. G. Kawamura, Secretary
Light Brown Apple Moth Science
,~,,
Update Technical Working Group cdfa
Comments on Harder/Rosendale ~--~`
Release #08-018
Report
HarderlRosendale report ca[Ied un f aunded and scienti f rcal[y unjusfi f red
~~
SACRAMENTO, Tuesday, April 01, 2008 -The Technical Working Group ~TWG~ has provided written comments
to the HarderlRosendale report: Integrated Pest Management Practices for the Light Brown Apple Moth in New
Zealand: Implications for California.
The TWG response, available at www.c. fa.cat~ovllbam, states that the HarderlRosendale report offers a
narrow perspective and is scientifically unjustified in its recommendation that California should abandon the
Light Brown Apple Moth ~LBAMI eradication program. Among the findings:
• Until recently, LBAM was the plant pest of greatest impact in New Zealand.
• HarderlRosendale's "account of the LRAM situation in New Zealand fails to recognize the natural resistance
of New Zealand's native plants and bio-control program developments that have just recently resulted in the
reduction of this pest's impact on the country's agricultural sector."
o "Until the biocontrol organisms became established...producers relied heavily...on the use of insecticides as
the primary means of controlling the pest."
o "It is unlikely that the United States government would allow the entry and use of similar biological control
agents...that present a potential risk to native species.,."
• "...the timing of their field visit did not correspond with peak periods of LBAM activity.,."
• Their report asserts that New Zealand has never attempted widespread LRAM eradication efforts, but that is
because LBAM has been present in New zealand "...for over 100 years, and such area-wide pest detection and
eradication techniques were only developed more recently."
• The report is "unjustified" and their "approach is inadequate given the significant environmental and crop
production differences between New Tealand and California..."
• "The issue is not just with LBAM becoming established along California's central coast, it also involves its
potential establishment in other parts of California, and in other States."
,s
"California must eradicate the Light Brown Apple Moth because it poses a complex threat -not only to our
environment and habitats but also - to our local farms, nurseries and farmers' markets," said CDFA Secretary
A.G. Kawamura, "Nat only does this pest attack over 250 crops and 2000 host and ornamental plants, but a
statewide infestation could cost California billions of dollars annually."
http:Ilwww.cdfa.ca.govlegovlPress ReleaseslPress Release.asp?PRnum=OS-02S&nrint=vex 41117.~~R
CDFA > Public Affairs > Press Release
Page 2 of 3
More on the Technical Working Group ~T1NGy: Comprised of ~D scientists, the TWG was appointed by the U.S.
Department of Agriculture ~USDA~ to evaluate California's LBAM infestation. The USDAICDFA eradication
program washbased on the TWG's recommendations. Its members, from Australia, New Zealand, California and
the USDA, are considered the world's foremost experts in the biology of the pest. The scientists are:
Vic Mastro, USDA-APHIS-Plant Protection and Quarantine ~PPQ~-Chairman
Ken Bloem, USDA-APHIS-PPQ
Eckehard Brockerhoff, ENSIS, New Zealand
Ring Carrie, University of California
Marshall Johnson, University of California
Dave Lance, USDA-APHIS-PPQ
~,
Don McInnis, USDA-ARS
Bob Staten, USDA-APHIS-PPQ ~Ret. ~
Max Suckling, HortResearch, New Zealand
Bill Woods, Department of Agriculture and Food, Western Australia
Mare on the Light Brown Apple Moth ~LBAM~: is native to Australia and is found in New Zealand, the United
Kingdom and Hawaii. The range of host plants is broad with more than two-thousand plant species known to
be susceptible to attack by this pest, and more than 250 crops, It threatens California's environment by
V
destroying, stunting or deforming young seedlings and damaging new growth in the forest canopy. The math
also feeds on host plants favored by a number of endangered species; spoils the appearance of ornamental
plants; and injures citrus, grapes, and deciduous fruit tree crops.
A USDA study indicates that, if California becomes generally infested, the moth could cause billions of dollars
in damage annually. Additionally, it would hinder export opportunities and interstate commerce due to
quarantine restrictions, as demonstrated by quarantine restrictions in Mexico and Canada. California
agricultural exports to the two countries totaled more than $2.4 billion in 2006.
V
a cooperative eradication program run jointly by CDFA and the U.S. Department of Agriculture ~USDA~ is
currently underway to suppress and eradicate infestations in ten Bounties along California's Central Coast and
Bay Area. Since its detection in February 2007, the Light Brown Apple Moth has been found hand quarantines
have been enacted in the counties of Monterey, Santa Cruz, Santa Clara, San Mateo, Contra Casta, Marin, San
Francisco, Alameda, 5olano and Santa Barbara counties.
isolated detections last year in Los Angeles and Napa counties have already been eradicated, primarily using
u
twist ties that emit moth pheromone. In Sonoma County, where a single moth has been detected, intensive
trapping is underway to determine if there are more.
For more information on the Light Brown Apple Moth, please visit .cdf~.ca.~ov
http:llwww.cdfa.ca.~ovle~ovlPress ReleaseslPress Release.asn?PRnum=(~R-~7Rc4rnr;nt=vP~ 41~ I~nn~
CDFA > Public Affairs > Press Release
Page 3 of 3
The California Deportment of Fond and A~ricu[ture protects and promotes Ca[ifarnia's $31.8 billion
a~ricu[tura[ industry, Ca[ifarnia's farmers and ranchers produce a safe, secure supply of food, fiber and
shelter; marketed f airy f or a[[ Californians; and produced with responsible environmental stewardship,
California Department of Food and Agriculture Dffice of Public Affairs
Nancy Lungren, Deputy Secretary
1220 N St., Ste. 214, Sacramento, CA 95814
916.654-0462, www,cdfa.ca.gov
http:Ilwww.cdfa.ca,~ovle~ovlPress ReleaseslPress Release.asn?PRnum=~R-[~ZRr4rnrinf =CPC 41117f1~R
Technical Working Group
Light Brown Apple Moth
March 2008
Technical Working Group's comments regarding report entitled,
~• "Integrated Pest Management Practices for the Light drown Apple Moth
in ll~ew Zealand: Implications for California. "
Yntroduction
we are expressing concerns about the conclusions made in the report entitled, "Integrated
Pest Management Practices for the Light Brown Apple Moth in New Zealand:
Implications for California." Specifically, we find aspects of the report's analysis of
LBAM management in New Zealand to be unfounded and its assumption that the pest's
behavior and impact in California can be determined based upon the New Zealand and
Australia experience to be scientifically unjustified.
The report essentially concludes that New Zealand has found a way to manage crop
damage caused by LBAM using integrated pest management IPM} techniques, therefore,
California should too, Accordingly, the report's authors, Dr, Daniel Harder and Mr. Jeff
Rosendale, recommend that LBAM eradication in California should be abandoned,
However, the report's account of the LBAM situation in New Zealand fails to recognize
the natural resistance of New ZeaIand's native plants and the Long history of scientific
studies and biocontrol program development that have just recently resulted in the
reduction of this pest's impact on the country's agricultural sector. Until the biocontrol
organisms became established at a level to effectively control the LBAM infestations in
New Zealand, producers relied heavily for many years on the use of insecticides as the
primary means of controlling the pest. The report also overlooks the many fundamental
differences between New Zealand and California with respect to biogeography, endemic
and introduced flora, and ecology. Additionally, the report offers a narrow perspective
about options for managing LBAM infestations, especially as it relates to the assertion
that biocontrol is the best option for managing LBAM populations.
In conclusion, the findings and recommendations presented in the report are based upon
unjustified suppositions the authors make about what might occur in California based on
New Zealand's experience. This approach is inadequate given the signif cant
environmental and crop production differences between New Zealand and California and
the fact that, until recently, LBAM was New Zealand's most impactful plant pest. More
importantly, the authors' recommendation does not take into account broader issues
associated with LBAM, such as the potential for the pest to spread domestically beyond
California and the economic impact of actual or potential interstate and international
trade quarantines of California host products.
Posted ~f~t08
General Points of Contention
The TWG believes that the authors' report is based an several unsupported general
assumptions. These assumptions include:
LBAM Could be Managed in California as it is in New Zealand
LBAM was the country's primary horticultural fruit crop pest in the period leading up the
mid I990's. New Zealand has recently met with success in managing LBAM, but this
success only occurred due to years of substantial research, extensive biocontrol agent
introductions, and developments in IPM-based crop management practices throughout the
country's fruit production system.l These advancements were made at a considerable
cost over many years. Moreover, the cost associated with IPM management of LBAM in
New Zealand is now a routine cost of business for producers. It is uncertain that New
Zealand's approach to managing LBAM could be applied in the context of California's
horticultural systems and associated regulatory environment. While the potential
consequences of LBAM becoming established in California are not fully known, it is
certain .that the long term costs of developing an IPM strategy to manage the pest would
be substantial. ~
California and New Zealand are Comparable
We also f nd the report's conclusion that there is no evidence of a biological or
environmental threat from LBAM in New Zealand to be scientif cally unsubstantiated, as
is the report's assumption that New Zealand and California share similar climates and
plant species. New Zealand and California do not share native plants, It is well-
documented that many of New Zealand's native plants have a natural resistance to
LBAM, which, in concert with biological control and other IPM strategies, minimizes the
impact of this pest and other tortricid species on the countries forests and wild plants.
California's native plants and trees may not possess such a resistance; thus, they could
make comparatively good hosts for LBAM in contrast to those in New Zealand,
Biocontrol Mitigates LBAM
There is very little definitive data to attribute the decline of LBAM's impact on New
Zealand's main fruit production regions solely to the introduced biological control agents.
However, it is apparent that there has been a corresponding decline in the population of
'Suckling, D.M., Burnip, G.M., Walker, J.T.S., McLaren, G.F., Shaw, P.W., Howard, C.R., White, V., and
Fraser, J.1998. Abundance of leafrollers and their parasitoids on selected host plants in New Zealand. NZ.
JCrop & Hort Sci. 26:193-203.
~ The TWG has recommended that the ecology of LBAM in California undergo formal study.
3 Sing, P., Fenemore, P.G., Dugdale, J.S, and Russell, G.B., 1978. The insecticidal activity of foliage from
New Zealand conifers, Biochem. System. Ecol. 6:103-106.
GB Russell and GA Lane 1993. Insect Antifeedants - A New Zealand perspective. Proc. 46th NZ Plant
Prot. Conf.179-186, http:llwww.nzpps.orgljaurnaV
2
Paste 4f~ I~~
non-target, native tortricid species in these same fruit production regions.4 If this decline
in native, non-target species is attributable to the introduction of biocontrol agents for
LBAM, then this situation runs counter to what is now acceptable to New Zealand's
Hazardous Substances and New organisms Act of 1996, which regulates the introduction
of new exotic species for the purpose of biocontrol, It is unlikely that the United States
government would allow the entry and use of similar biological control agents ~T.
brevifacies, G. s~okesri, and X. rhopaloceros} that present a potential risk to native, non-
target species-such as lepidopteran fauna-if released into LBAM affected areas of
California.
No Significant Populations of L~BA~VI were Observed in ~Vew Zealand
In the report, it is noted that the authors did not observe signif cant LBAM activity during
their field visit to New Zealand fruit production areas. According to subject mater
experts in New Zealand, this is understandable considering the timing of visit did not
correspond well to LBAM's seasonal phenology. Pheromone trapping programs
demonstrate that this pest is typically still the most abundant tortricid species trapped in
fruit production sectors that are undergoing IPM monitoring and control systems. While
damage caused by LBAM larvae appears to be much less extensive in New Zealand
today, due to ongoing IPM-based production practices, they are still commonly found
among many non-native host ornamental and weedy plant species in home gardens and
other non-managed environments.
S ecif c Points of Contention
The report also contains statements that are either technically incorrect or down play the
significance of LBAM as a potentially important economic pest. While it is true that,
according to some studies, an average adult moth will travel about I00 meters in its
lifetime, the report did not reference studies in New Zealand that have found that
individual LBAM adults can fly as far as 2 kilometers and LBAM larvae can balloon
along air currents for a similar distance. It should also be noted that the photograph
included in your report of LBAM feeding damage is hardly a typical example of such
damage. Rather, damaged shoot-tips with rolled and webbed leaves are more
characteristic of LBAM feeding.
a Munro, V.M.W.1998. A record of releases and recoveries of the Australian parasitoids Xanthopimpla
rhopaloceros Krieger Hymenoptera; Ichneumonidae} and Trigonospila brevifacies Hardy (Diptera:
Tachinidae~ introduced into New Zealand for leafroller control. New Zealand Entomologist 21:81-92.
Munro, V.M.W.; Henderson, I.M. 2002, Nontarget effect of entomophagous biocontrol: Shared parasitism
between native lepidopteran parasitoids and the biocontrol agent Trigonospila brevifacies ~Diptera:
Tachinidae} in forest habitats.
Environmental Entomology 31:388-396.
Suckling, D. M., G. M. Burnip, A. R. Gibb, J. M, Daly, and K. F. Armstrong. 2001, Host and host plant
influences on the leafroller parasitoid Dolichogenidia tasmanica ~Braconidae}. Entomologia exp. & app.:
100: 253-260.
Posted 411!08
ether specific points of contention include:
"The southernmost area of New Zealand was not visited because its colder, harsher
climate is bath less hospitable to LBAM than the warmer climate farther north and
dissimilar to the climate of areas where LBAM is presently found in Califarnia." Page
4.
The authors missed an opportunity to visit Canterbury, which is located on the South
Island. This area of southern New Zealand, contrary to the authors' statement, has high
levels of LBAM infestation. Canterbury is arguably similar to California, although a
proper~climate match is needed.
"Any larva that falls or loses contact with its food source/host plant have little chance
of survival, so the larvae stay connected to the plant by the silken threaa~" Page 4.
In actuality, larvae engage in a process called "ballooning" where they use silk threads as
a parachute to drift through air currents to spread to other host plants. The silk does not
stay connected with the original plant. Because of LBAM's extensive host range, larvae
have a~relatively high likelihood of ballooning to another host plant.
"LBAMmay mate up to three times during its I- to ~.5-week lifespan in New Zealand.
Female moths typically lay 30-54 eggs per egg mass." Page 5.
The report omits the fact that mated females typically lay on average 300 eggs in their
lifetime, which can significantly exceed 1.5 weeks. Mated LBAM females have been
known to lay more than 1000 eggs in extreme situations. This statement also
underestimates the female's potential lifespan. These facts certainly emphasize the
strong and rapid reproductive ability of LBAM.
"Because it is polyphagous, LBAM can disperse and survive without concentrating
and adversely affecting all plants in a concentrated area." Page 5.
The ability of LBAM or any other polyphagous insect to survive in an area without
causing undue damage does not mean it will not cause damage in some or many
situations. Gypsy moth, Japanese beetle, and Mediterranean fruit fly are all polyphagous
and are among the most destructive plant pests.
"According to New Zealand Ministry of Agriculture and Food (MAF) and department
of Conservation ~~nC) experts, LBAM does not build up in any one bast in the wild
and has never posed a threat to native forests. " Page 6.
This is most likely due to the "biotic resistance" of New Zealand's forest rather than any
inherent weakness or inefficiency of the pest itself. The "biotic resistance" of New
4
Pasted 4;1 !D8
Zealand's forests are cited in published scientif c articles, which indicate that plant
compounds native to New Zealand are toxic to leafrollers,5
"Natural predators keep LBAM in check, and it is so rare in the wild that it requires a
true expert and meticulous searching to even find any sign of it. " Page 6.
The report's authors stated several times that they had difficulty finding LBAM adult and
larvae populations. However, LBAM is common in gardens and in wild areas such as
forests and waste lands, which collectively represent a significant area of New Zealand.
It is surprising that the authors failed to find and observe the insects, even if the timing of
their field visit did not correspond with peak periods of LBAM activity.
"Gnawers in the Hawke's Bay and Nelson regions do not use mating disruption
pheromones to control LBAM. They monitor in late spring with pheromone traps
specific to LBAM and codling moth. If the trap taunts warrant, an IGR is applied ~e.g.
Intrepid, Confirm: methoxyfenozide, tebufenozide}." Page S.
The authors seem to promote the use of Insect Growth Regulators ~IGR} against LBAM
in this and other statements in the report. IGRs are insect hormones or synthetic "mimic"
hormones that can be used to disrupt an insect's natural maturation process. while this
may be viable option for commercial agricultural areas and, using only limited ground-
. based applications, in some residential or natural areas, the area-wide use of IGRs is
discouraged due to its potential impact on non-target insects and some aquatic
-~ ~~-invertebrates. Pheromone use is far more innocuous than IGRs.
"Widespread LBAM eradication efforts have never been attempted in New Zealand."
Page 9.
This is due to the fact that LBAM is along-established pest throughout New Zealand,
being present for over I00 years, and such area-wide pest detection and eradication
techniques were only developed more recently.
`:..pheromones applied by any means cannot be effectively used across large diverse
areas with varying canopy heights, mixed species composition, and varying terrain
areas. " Page 10.
In fact, pheromone is used to control gypsy moth populations across areas with mixed
topography and varying tree canopy heights. Aerial applications of gypsy moth
pheromone are routinely applied over wild, cultivated, and urban-suburban environments
encompassing hundreds of thousands of hectares in the United States.
5 Sing, P., Fenemore, P.G., Dugdaie, J.S. and Russell, G.B., 1978. The insecticidal activity of foliage from
New Zealand conifers. Biochem. System. Ecol. 6:103-106.
GB Russell and GA Lane 1993. Insect Antifeedants - A New Zealand perspective. Prot. 46th NZ Plant
Prot. Conf.179-186. http:llwww.nzpps.argljournall
Pasted 411108
"~Vew Zealand researchers also note that aerial pheromone spraying interferes with
monitoring using pheromone traps, and monitoring is critical to successful control."
Page 10.
Generally, traps are baited with a synthetic pheromone that mimics the natural
pheromone used by female moths to attract males for mating. Increasing the level of
re
pheromone in the LBAM-infested areas prevents males from finding either females or the
traps and causes mating disruption. Therefore, pheromone trap shut-down, caused by
aerial or ground pheromone applications, is in fact an indication that mating disruption is
working effectively. This is true for all other effective mating disruption systems,
including those commonly used for area-wide control of codling moth and gypsy moth.
Typically, pheromone applications are effective when used in a large scale suppression
and eradication programs. Management strategies that rely on the use of insecticides such
as IGRs are commonly used at individual field levels.
"Moreover, use of broadcast pheromone spray to eradicate or control the moth is not
effective because female moths issue a more concentrated scent plume than the
dispersed pheromone scent of an aerial spray application, so male moths are able to
find the females (Shaw 2008)." Page 10.
Mating disruption is achieved through the dispersal of pheromone across a target area.
Contrary to the report's statement, the airborne concentration of the pheromone can be ~~~ f
adjusted to maximize the efficacy of mating disruption within the target area.
"HortResearch stations on both islands agree that eradicating LBAM in California
and anywhere would require extensive, widespread use of IGRs with repeated
applications to address elusive, selected populations. These experts also question the
efficacy of Bacillus thuringiensis (Bt) against LBAM. Bt can also have a detrimental
effect on beneficial insects." Page 10.
HortResearch officials dispute the report's characterization oftheir statements concerning
the efficacy of Bt and beneficial insects. 0n the contrary, HortResearch officials
indicated that mating disruption could prove effective in eradicating LBAM populations
if conducted as part of an FPM strategy using some limited use of effective insecticides in
commercial production areas. These points were also included in the T~VG
recommendations.
"...California has 85 native and localized North American species of tortricid moths;
none are problematic as a pest. All are kept in check by natural biological controls, so
there is conf Bence to believe that LBAM will also be controlled by native natural
predators or parasites. " Page 11.
There are over 300 tortricid species in California California Moth Specimen Database.
The University of California IPM Web site categorizes LBAM as an exotic and invasive
pest that threatens California's agriculture, urban, or natural areas. Eight other tortricid
species in California are listed as pests on this '~Veb site and have insecticides as one of
Pasc~~ ~e~ros
the recommended treatments: Amorbia western avocado leafroller, apple Pandemis,
codling moth, fruit tree roller, garden tortrix, oblique-banded leafroller, omnivorous
leafroller, and orange tortrix.
"Current CDFA requirements that commercial nurseries in California use the
organophosphate insecticide chlorpyrifos if LBAM larvae are found are in direct
contradiction to New Zealand findings that organophosphates destroy LBAM's natural
predators, resulting in resistance developing in LBAM populations. New Zealand
experts recommend use of IGRs in the control of LBA~1 in agricultural systems as
much safer and more effective. Page 11.
Chlorpyrifos is currently recommended only as a regulatory treatment for nursery plants
prior to transport out of LBAM infested areas of California. Chlorpyrifos is fast acting
and, because it is very close to 100 percent effective on all Iife stages of the insect,
ensures that viable moths are not spread via the movement of nursery stock. Since plants
are typically shipped within a day to a week of treatment, there is little concern regarding
the depletion of natural enemies or the development of resistance associated with the use
of chlarpyrifos.
Tests to evaluate potential alternatives to chlorpyrifos are underway, and additional
__ _regulatory_treatments,_potentially including IGR's such_ as diflubenzuron or fenoxycarb, __ _
_ T --
may beavailable for future use.
---- _
--
..
_.
e xn zng t at ~ ere as na evi-ence~~v iological or-envirotimental-threat from --
LBAM in New Zealand, which has climate and crops much like California and where
LBAM has been an established exotic for more than a century, bodes well for the
ability of California agriculture and ecosystems to accommodate to LBA~VI's presence
and suggests that ~TSDA classification of LBAM as an actionable quarantine pest
should be reviewed and revised. USDA's pest quarantine list needs to be re-evaluated
based on current, relevant, science-based information." Page 12.
The issue is not just with LBAM becoming established along California's central coast, it
also involves its potential establishment in other parts of California, and in other States,
What works in terms of LBAM control for some California cropping systems may not
work in other places, so to deregulate would be irresponsible and could potentially lead to
the entire State of California being under quarantine for domestic shipments and to the
possibility of the entire continental United States being under quarantine for international
shipments to countries such as Canada and Mexico.
7
Pasted ~111D8
CDFA > Public Affairs > Press Release
News Release
~~.~#~(3~wlr~ aEPr~~,7~Eh#~ ~F ~f}D~ r1~~ID ~G~RI~~IJL'fld~~E
S:
Media Contacts:
Steve Lyle, CDFA Public Affairs, ~916y 654-0462
Jay Van Rein, (916) 654-0462
Page 1 of 2
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Arnold 5chwarzenegger, Governor
A. G. Kawamura, Secretary
Stricter Regulations in Canada,
Mexico for Growers in Counties ~(cdfa
Infested with Light Brown Apple 'r^
Release k08~019
Moth
Exporf mQrkets to be impacted
SACRAM~NT4', Tuesday, March 11, 2008 -Revised and expanded regulations put into place in both Canada and
Mexico will make it substantially more difficult for growers in counties infested by the light brown apple
moth-an invasive species-ta certify their crops as "free from" the moth, which is a requirement far ex orts
P
to be accepted in those countries. These heightened restrictions on California growers are indicative of the
serious measures taken by trading partners to keep the most significant invasive pests out.
Farmers throughout California are evaluating the new regulations to assess their impacts. In general, the more
stringent requirements call for growers to conduct vastly, labor-intensive trapping efforts on any agricultural
field inside a~r~ infested county -even if that field is miles away from the infested area. Previously,
certification at the packinghouse was deemed acceptable. The new requirements may also lead to additional
pesticide applications to ensure that growers can continue to ship their goods to trading partners.
"Since we first detected the light brown apple moth, one of our primary concerns has been the affect it would
have on California's food supply," said CDFA Secretary A.G. Kawamura, "These new regulations demonstrate
the complex threat posed by the moth not only to our environment and habitat, but also to our ability to
produce a reliable and sustainable food supply. As growers incur more casts to meet export requirements it
has a negative impact throughout the entire food distribution system. The best way to reverse that is by
eradicating this pest."
The light brown apple moth is native to Australia and is found in New zealand, the United Kingdom and
Hawaii. The range of host plants is broad with more than two-thousand plant species known to be susceptible
to attack by this pest, and more than 250 craps. It threatens California's environment-including cypress,
redwood and oak trees-by destroying, stunting or deforming young seedlings and damaging new growth in the
forest canopy, The moth also feeds on host plants favored by a number of endangered species; spoils the
appearance ~f ornamental plants; and injures citrus, grapes, and deciduous fruit tree crops.
A USDA study indicates that, if California becomes generally infested, the moth could cause billions of dollars
in crop damage annually, Additionally, it would hinder export opportunities and interstate commerce due to
http;Ilwww.cdfa.ca.~ovle~ovlPress ReleaseslPress Relea~P acn?PRn,~m=nQ_n14~rr;ri+=~~A~ ~ ~~ ~~nnQ
,, ~DFA > Public Affairs > Press Release
Page 2 of 2
quarantine restrictions, as demonstrated by the action of Canada and Mexico. California agricultural exports
to the two countries totaled more than $2.4 billion in 200b.
A cooperative eradication program run jointly by CDFA and the U.S. Department of Agriculture ~USDAy is
already underway to suppress and eradicate infestations in nine counties along California's Central Coast and
Bay Area. Since its detection in February 2007, the Light Brown Apple Moth has been found and quarantines
have been enacted in the counties of Monterey, Santa Cruz, Santa Clara, San Mateo, Contra Costa, Mann, San
Francisco, Alameda and Solano.
Small, isolated infestations detected last year in Los Angeles and Napa counties have already been eradicated.
Twist ties that emit math pheromone were utilized in both counties. In Santa Barbara and Sonoma counties,
where single moths have been detected, intensive trapping is underway to learn if there are more.
For more information on the light brown apple moth, please visit f . o
The California Department of Food and Agriculture protects and promotes California's $31,8 billion
agriru[tura[ industry. California's farmers and ranchers produce a safe, secure supply of food, fiber and
shelter; marketed fairly fora!! Californians; and produced with responsible environmental stewardship.
4
California Department of Food and Agriculture Office of Public Affairs
Nancy Lungren, Deputy Secretary
1220 N St., Ste, 214, Sacramento, CA 95814
91b-454-D462, www.cdfa~ca.gov
httn:llwww.cdfa.ca.~ovlegovlPress ReleaseslPress Release.a~n?PRn~~m=(]R-~l9Rrnrint~PC 411I~~~R
CDFA > Public Affairs > Press Release
News Release
e~.~i~~~~i~ o~~~~r~~~r~~ ~~ ~~a® ~raa ~a~aic~u~~uR~
Media Contacts:
Steve Lyle, CDFA Public Affairs, ~916~ 654-0462
Jay Van Rein, CDFA Public Affairs, ~916~ 6540462
Larry Hawkins, USDA Public Affairs, ~916y 930.5509
Page 1 of 3
.4
+~ li
P ~~ ~
Arnold Schwarzenegger, Governor
A. G. Kawamura, Secretary
Light Brown Apple Moth 2008 Action .~dfa
Plan Announced ~~-'-"~
Release k08~010
SACRAMENTO, w~dnesday, February 13, 2008 -The California Department of Food and Agriculture ~CDFA~~ and
the United States Department of Agriculture ~USDA~ have completed an action plan outlining 2008 strategies in
the ongoing project to eradicate the light brown apple moth ~LBAMI from California's Central Coast and Bay
Area communities.
The light brown apple moth is native to Australia and is found in New Zealand, the United Kingdom and
Hawaii. The range of host plants is broad with more than two-thousand plant species known to be susceptible
to attack by this pest. It threatens California's environment--including cypress, redwood and oak trees-by
destroying, stunting or deforming young seedlings and damaging new growth in the forest canopy. The moth
also feeds on host plants favored by a number of endangered species; spoils the appearance of ornamental
plants; and injures citrus, grapes, 'and deciduous fruit tree crops.
A USDA study indicates that, if California becomes generally infested, the moth would cause between $160
million and $640 million in crop damage annually. Additionally, it would hinder export opportunities and
interstate commerce due to quarantine restrictions. Already, Mexico and Canada have imposed export
regulations on California because of the l_BAM infestation.
The overall goal of the project is to eradicate the light brown apple moth from California. This task will likely
take several years to accomplish using several treatment tools, some of which are available and in use now
while others are under review ar development.
The primary tool for eradication will be aerial treatment with LRAM moth pheromone, which will disrupt the
pest's mating cycle. Moth pheromone does not harm people, pet's or plants. While conventional insecticides
are designed to kill insects, pheromones are designed to distract or confuse them so that they cannot breed.
In nature, the pheromone is released by the female moth .to attract a mate. The "scent" is undetectable to
humans and is highly specific to the light brown apple math and several other closely related species, so it
does not affect other kinds of insects or animals.
Aerial treatments are expected to begin June 1 in the infested areas of Monterey and Santa Cruz counties,
with subsequent aerial treatments expected to begin August 1 in San Francisco, Daly City, Colma, oakland,
Piedmont, Emeryville, Albany, El Cerrito, EI Sobrante, Tiburon and Belvedere. The treatments in these areas
http;llwww.cdfa.ca.govlegovlPress__ReleaseslPress Release.asp?PRnum=08-010&print=yes 2/19/2008
CDFA > Public Affairs > Press Release Page 2 of 3
are. designed to be reapplied at 30- to 90-day intervals while the moths are active.
In some of the areas designated for aerial treatment, the plan also calls for the release of tiny, stingerless
wasps ~trichogramma) that target the LBAM eggs. The native California wasps are 1125th of an inch long,
harmless to people and pets and they are widely used by home gardeners and organic or IPM growers. The
wasps would be released in Spring 2008 and would be used in conjunction with aerial treatments -most likely
in San Francisco, Santa Crux County, and on the Monterey Peninsula. These wasps will not bother over-
wintering monarch butterflies and they would not be released near threatened or endangered plants or
butterflies and moths,
Smaller, more isolated infested areas would be treated using either pheromone-infused twist ties or a
pheromone-based male moth attractant treatment applied to utility poles and street trees on public and
private property; In each area, the infestation's size and density, the availability of host plants, and other
variables will be considered in determining the appropriate method. Twist ties have been used successfully in
several areas over the past year, and additional applications are scheduled to begin over the next few weeks
in Morin and San Mateo counties, with other areas to be announced in the coming weeks as the weather warms
up and the moths become mare active. Male attractant treatment may begin in Spring 2008.
In the event of detection of a heavy larval population, the action plan calls for handheld spraying of plants
and trees with Bt Bacillus thuringiensis~ or Spinosad, both of which derive from naturally- occurring bacteria
and are approved for use on organic crops.
The action plan also provides for consultation with the Department of Pesticide Regulation ~DPR~ concerning
pesticide use, and contains provisions far sharing information with the California Office of Environmental
Health Hazard Assessment ~OEHHA~ and other agencies for their use in educating physicians in the treatment
areas, protecting threatened and endangered species and sensitive sites, and obtaining all required permits.
4EHHA will team with other public health organizations to develop and oversee a program for the reporting,
tracking and scientific evaluation of reported illness incidents. To date, collaboration between OEHHA and
DPR has resulted in a consensus statement concluding that illnesses reported last year in Santa Cruz and
Monterey counties were not likely to have been caused by pheromone treatments there.
The action plan has been developed in consultation with representatives of the LBAM Technical Working Group
as a guide to the major elements and strategies of the eradication program, Specific actions will be guided by
this plan, which could be modified due to new moth detections and trapping results, as well as operational
constraints such as funding and the availability of treatment materials.
Since its detection in February 2002', the Light Brown Apple Moth has been found throughout the central coast
region in the counties of Monterey, Santa Crux, Santa Clara, San Mateo, Contra Costa, Morin, San Francisco,
Alameda and Solano. CDFA and the USDA continue work on treatment plans for communities within these
counties. Small, isolated infestations detected last year in Los Angeles and Napa counties have already been
eradicated. Twist ties were utilized in both counties.
Additional information on the action plan is available at: , df . vll am
http:llwww.cdfa.ca.govlegovlPress_ReleaseslPress_Release.asp?PRnum=08-D 10&print~yes 2/19/2008
CDFA ~ Public Affairs > Press Release
Page 3 of 3
The California Department a f Food and,4g~ricu[ture protects and promotes California's $31.8 billion
a~ricu(tural industry, California's farmers and ranchers produce a safe, secure supply of food, fiber and
shelter; marketed fairly fora([ Californians; and produced with responsible environmental stewardship.
California Department of Food and Agriculture office of Public Affairs
Nancy Lun~ren, Deputy Secretary
1220 N St., Ste. 214, Sacramento, CA 95$14
916.654.0462, www.cdfa:ca.gov
http:Ilwww.cdfa.ca.~ovle~ovlPress ReleaseslPress Release.asp?PRnum=o8-01 o&print=ves 2/19/2008
We, the citizens of Alameda,
are opposed to the aerial spraying of
Checkmate in our town
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Submitted by T'Hud Weber at the
04-01-08 Council Meeting
Re: Agenda Item #3-C
We, the citizens of Alameda,
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Checkmate in our town
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Science Lab e
Chemicals & Laboratory Equipment
Material Safety Data Sheet
Butylated hydrouytoluene MSDS
,
. ..:
S
.. ~ ectian;~ . Chemical Rrvduct: and:Com an ~ ' n
ldentific
atio
p Y
Product Name: Butylated hydroxytoluene Contact Information:
Catalog Codes: SLB3511, SLB1180, SLB2674, SLH2101 Sciencelab.com, Inc.
14025 Smith Rd.
CAS#;125-37-0 Houston, Texas 77396
RTECS: GQ7875000 US Sales: l-B0D-9011241
International Sales:1-2B1-441-4400
TSCA: TSCA 8~b} inventory: Butylated hydroxytoluene Qrder Online: 5cienceLab.com
C1#: Not available.
Synonym; BHT; Ionol; Ionol antioxidant};
2,6-Di-tert-butyl-p-cresol;
2,6-Bis~ 1,1-dimethylethyl}-4-methylphenol;
2,fi-Di-tert-butyl-l-hydroxy-4-methylbenzene;
2,fi-Di-tert-butyl-p-methylphenol;
3,5-Di-tent-butyl-4-hydroxytoluene;
4-Methyl-2,6-di-tert-butylphenol; Butylated hydroxytoluene;
Butylhydroxytoluene
Chemical Name: p-Cresol, 2,6-di-tert-butyl-
Chemical Formula: C15-H24-Q
CHEMTREC ~24HR Emergency Telephone}, call:
1-800-424-9300
International CHEMTREC, call: l -703-527-3887
For non-emergency assistance, call:l-281-441-4400
Section 2. Composition and Information on In redients
9
Composition:
Name
Butylated hydroxytoluene
CAS #
128-37-0
°/a by Weight
100
Toxicological Data on Ingredients: Butylated hydroxytoluene: QRAL ~LD50}:Acute: 890 mglkg [Rat]. 650 mglkg [Mouse].
10700 mglkg [Guinea pig].
Section 3: Hazardsldentification
Potential Acute Health Effects;
Hazardous in case of skin contact irritant}, of eye contact irritant}, of inhalation flung irritant. Slightly hazardous
in case of ingestion, .
Potential Chronic Health Effects:
CARCINQGENIC EFFECTS: A4 Not classifiable for human or animal.} by ACGIH, 3 Not classifiable for
human. by IARC.
Submitted b Simi Sikka atthe ~'J
Y
04.01.08 Council Meeting
Re; Agenda Item #3•C p~ 1
MUTAGENIC EFFECTS: Mutagenic for mammalian somatic cells, Mutagenic for bacteria andlor yeast.
TERAT~GENIC EFFECTS: Not available.
DEVELOPMENTAL TOXICITY: Not available.
The substance may be toxic to blood, liver, central nervous system ~CNS~,
Repeated or prolonged exposure to the substance can produce target organs damage.
Sectio:: 4. First Aitl easu s
Eye Contact:
Check for and remove any contact lenses. In case of contact, immediately flush eyes with plenty of water for at
least 15 minutes. Get medical attention.
Skin Contact:
Incase of contact, immediately flush skin with plenty of water, Cover the irritated skin with an emollient, Remove
contaminated clothing and shoes, Wash clothing before reuse. Thoroughly clean shoes before reuse. Get
medical attention.
Serious Skin Contact:
Wash with a disinfectant soap and cover the contaminated skin with ananti-bacterial cream, Seek immediate
medical attention.
Inhalation;
If inhaled, remove to fresh air. !f not breathing, give artificial respiration. If breathing is difficult, give oxygen. Get
medical attention,
Serious Inhalation: Not available.
Ingestion:
Do NOT induce vomiting unless directed to do so by medical personnel, Never give anything by mouth to an
unconscious person. If large quantities of this material are swallowed, call a physician immediately. Loosen tight
clothing such as a collar, tie, belt or waistband.
Serious Ingestion: Not available.
. ~ ..
. ,. ...
.. .Section :5. Fir . .
e an, Ex~p o~~on Data
Flammability of the Product: Maybe combustible at high temperature.
Auto-Ignition Temperature: 470°C X878°F~
Flash Points: CLQSED CUP:118.3°C X244.9°F~, QPEN CUP: 126.67°C X260°F~.
Flammable Limits: Not available.
Products of Combustion: These products are carbon oxides ~C4, C42~.
Fire Hazards in Presence of Various Substances: Slightly flammable to flammable in presence of heat.
Explosion Hazards in Presence of Various Substances:
Risks of explosion of the product in presence of mechanical impact: Not available.
Risks of explosion of the product in presence of static discharge: Not available.
Fire Fighting Media and Instructions:
SMALL FIRE: Use DRY chemical powder.
LARGE FIRE: Use water spray, fog or foam. Do not use water jet.
Special Remarks on Fire Hazards:
When heated to decomposition it emits toxic fumes, As with most organic solids, fire is possible at elevated
temperatures
p. 2
Special Remarks on Explosion Hazards: Not available.
:. :S ..
i eM .
.: ~ . ect~on 6. Acc
'den#al Releas
. eas u res
Small Spill:
Use appropriate tools to put the spilled solid in a convenient waste disposal container, Finish cleaning by
spreading water on the contaminated surface and dispose of according to local and regional authority
requirements.
Large Spill:
se a shovel to put the materia! into a convenient waste disposal container. Finish cleaning by spreading water
on the contaminated surface and allow to evacuate through the sanitary system. Be careful that the product is not
present at a concentration level above TLV. Check TLV on the MSDS and with local authorities,
..
..Sec~ion.l: Ha ,,
ndl~n and~St
g orage .
Precautions:
Keep away from heat. Keep away from sources of ignition. Ground all equipment containing material. Do not
ingest, Do not breathe dust. Wear suitable protective clothing, If ingested, seek medical advice immediately and
show the container or the label, Avoid contact with skin and eyes. Keep away from incompatibles such as
oxidizing agents.
Storage: Keep container tightly closed. Keep container in a cool, well-ventilated area.
e .. , Ex osure ... . .
Controls
S ~ ction 8. p (Personal Protection
Engineering Controls:
Use process enclosures, local exhaust ventilation, or other engineering controls to keep airborne levels below
recommended exposure limits, If user operations generate dust, fume yr mist, use ventilation to keep exposure to
airborne contaminants below the exposure limit.
Personal Protection:
Splash goggles. Lab coat. Dust respirator. Be sure to use an approvedlcertified respirator or equivalent.
Gloves.
Personal Protection in Case of a Large Spill:
Splash goggles. Full suit. Dust respirator. Boots. Gloves. A self contained breathing apparatus should be used
to avoid inhalation of the product. Suggested protective clothing might not be sufficient; consult a specialist
BEFORE handling this product. E
Exposure Limits:
TWA;10 ~mglm3} from OSHA ~PEL} [United States] Inhalation
TWA:10 ~mglm3} from ACGIH TLV} [United States] Inhalation
TWA:10 ~mglm3}from NIOSH [United States] Inhalation
TWA:10 ~mglm3} [United Kingdom AUK}] InhalationConsultlocol authorities for acceptable exposure limits,
ca ., emi
n 9. Ph si cal Pr .: .
Sectfo
y land Ch
open ies
Physical state and appearance: Solid, Crystalline solid,}
Odor: phenolic Slight,}
Taste: Tasteless.
Molecular Weight: 220.3fi glmole
Color: White to yellowish,
p. 3
pH ~1 % solnlwater~:Not applicable.
Boiling Point: 2fi5°C X509°F}
Melting Point: 70°C X158°F}
Critical Temperature: Not available.
Specific Gravity: 1.048 water =1 }
Vapor Pressure: Not applicable,
Vapor Density: 7.6 Air =1 }
Volatility: Not available.
Odor Threshold: Not available,
Waterl0ii Dist. Coeff.: Not available.
Tonicity din watery: Not available.
Dispersion Properties: See solubility in water, methanol, acetone.
Solubility:
Soluble in methanol, acetone.
Insoluble in cold water,
Freely soluble in Toluene.
Soluble in Isopropanol, Methyl Ethyl Ketone, Cellosolove, Benzene, most hydrocarbon solvents, Ethanol, Petoleum
Ether, Liquid Petrolatum, Linseed ail.
Insoluble in alkali
..
.. , , ~ tivit D
.: y
.~ ~ :: Section 1A. StabE~~t and y ::
...
as
Stability: The product is stable.
Instability Temperature: Not available.
Conditions of Instability: Excess heat, incompatible materials
Incompatibility with various substances: Reactive with oxidizing agents.
Corrosivity: Non-corrosive in presence of glass.
Special Remarks on Reactivity: Not available.
Special Remarks on Corrosivity: Not available.
Polymerization: will not occur.
. ~ : ~ .: a pn ,.; .:. ~9 Io . ......, .. .. .
~: ..Sc
t 1 ~:.. Toxi o ~ca~~lnfvrmat~on
....
9.
Routes of Entry: Absorbed through skin. Dermal contact, Inhalation, Ingestion.
Toxicity to Animals: Acute oral toxicity ~LD5o}:650 mglkg [Mouse],
Chronic Effects on Humans:
CARCINaGENIC EFFECTS: A4 Not classifiable for human or animal.} by ACGIH, 3 Not classifiable for
human.} by IARC.
p. 4
MUTAGENIC EFFECTS: Mutagenic for mammalian somatic cells. Mutagenic for bacteria andlvr yeast,
May cause damage to the following organs: blood, liver, central nervous system ~CNS}.
ether Toxic Effects on Humans:
Hazardous in case of skin contact irritant}, of inhalation flung irritant}.
Slightly hazardous incase of ingestion, .
Special Remarks on Toxicity to Animals: Not available.
Special Remarks on Chronic Effects on Humans:
May affect genetic material ~mutagenic}. .
May cause cancer based on animal test data. No human data found.
May cause adverse reproductive effects and birth defects ~teratogenic}
Special Remarks on otherToxic Effec#s on Humans:
Acute Potential Health Effects:
Skin: Causes mild to moderate skin irritation.
Eyes: Causes moderate eye irritation.
Inhalation: May cause respiratory tract nose, throat} irritation.
Ingestion: Maybe harmful if swallowed. The clinical manifestatioins of acute are not well known. May cause
gastritis, vomiting, hypermotility, diarrhea. May affect behaviorlcentral nervous system~dizziness, weakness,
somnolence, slurred speech, ataxia, visual and auditory hallucinations, headache, confusion, temporary Ions of
conciousness}, respiration respiratory depression}, blood reduced ability to clot}
Chronic Potential Health Effects:
Ingestion: Prolonged or repeated ingestion may affect the liver, kidneys, thyroid, adrenal gland, behaviorlcentral
nervous system and learning ability, blovd~reduced ability to clot}, and may cause weight loss.
Ingestion or skin contact may also cause allergic reaction dermatitis, asthma},
..
o.
2 Ecolo ical I ~.
.. .. g nfo~mat
.. ec ion :.
in
~.
Ecotoxicity: Not available.
BOD5 and COD: Not available.
Products of Biodegradation:
Possibly hazardous short term degradation products are not likely. However, long term degradation products may
arise.
Toxicity of the Products of Biodegradation: The products of degradation are Tess toxic than the product itself
Special Remarks on the Products of Biodegradation: Not available.
..
. :.. osa~ Co. ,
.. ct~a
.. ~.e'
., n ~3.,Dis ions
S
~. p
ns~de~at
Waste Disposal:
Vllaste must be disposed of in accordance with federal, state and local environmental
control regulations.
' r
~~
:.
Section,14: Trans
oft Information .
D4T Classification: Not a D4T controlled material United States}.
Identification: Not applicable.
Special Provisions for Transport: Not applicable.
. , ... S
. :~ ~ ~ , ~.
:.:
. ectivn .
~ 5.4therRegulator Information
.~ Y :.
p. 5
Federal and State Regulations:
Illinois toxic substances disclosure to employee act: Butylated hydroxytoluene
Rhode Island RTK hazardous substances: Butylated hydroxytoluene
Pennsylvania RTK: Butylated hydroxytoluene
Minnesota: Butylated hydroxytoluene
Massachusetts RTK: Butylated hydroxytoluene
New Jersey: Butylated hydroxytoluene
California Director's List of Hazardous Substances: Butylated hydroxytoluene
TSCA 8~b} inventory: Butylated hydroxytoluene
Other Regulations:
OSHA; Hazardous by definition of Hazard Communication Standard X29 CFR ~ 9t O.t 200},
EINECS: This product is on the European Inventory of Existing Commercial Chemical Substances.
Other Classifications:
INHMIS Canada}: It has not yet been classified by the Service du repertoire toxicologique.
DSCL ~EEC~:
822-Harmful if swallowed.
836137138- Irritating to eyes,
respiratory system and skin.
S26- Incase of contact with eyes, rinse
immediately with plenty of water and seek
medical advice,
S37139-wear suitable gloves and eyelface
protection,
HI~IIS U.S.A.}:
Health Hazard: 2
Fire Hazard:l
Reactivity: 0
Personal Protection: E
National Fire Protection Association U.S.A.}:
Health: 0
Flammability: t
Reactivity: 0
Specific hazard:
Protective Equipment:
Gloves,
Lab coat.
Dust respirator. Be sure to use an
approvedlcertified respirator or
equivalent.
Splash goggles,
..
..
.: . ~ Sections 1G Other Information ~. .. .
References: Not available.
Other Special Considerations: Not available.
p. 6
Created: 10109/2005 04:22 PM
Last Updated:1010912005 04:22 PM
The information above is believed fo be accurate and represents the best information currently available fo us. However, we
make nv warranty of merchantability or any other warranty, express or implied, with respect to such information, and we
assume no liability resulting fram ifs use. Users should make their own investigations to determine fhe suitability of fhe
information for their particular purposes. In no event shall ScienceLab. com be liable for any claims, losses, or damages of any
third party or for lost profits or any special, indirect, incidental, consequential or exemplary damages, howsoever arising, even
if ScienceLab. com has been advised of fhe possibility of such damages.
p. 7
a ~
Tricapryimethylammanium Chloride
MSDS Number: T4770 * * * * * Ef, fectiue Date: 0218103 '~ * * * * Supercedes: 051081p0
24 Hoor i~margahey'Teieph~ne; ~f6~8~9•~161
]~,(~ ~~t~@~$~ ~~fi~~l ,~a~a ~~@i~"t ~ CHEM~'R~~: 't~00~12d«93~0
~lf~,,~~
.... ... . ......:...:...::. - ado
;:..... ...~ .:.:..:::.:..:.........;..:,..~.,, ,.:.:...:.° tatcnataesPonaeln~an
. CANUT~C; ~1~•986~66~
4utSidaU,S, Artd Can~Ia
Ci~emtrec: lp3-a''27-3887
From: hliallinckrodtBakor, Inc. ~~~~~ 7
~2 fed 9c~ad Lane I~OT~: CI~EIYI#'Rt~C ~LtNU~~C antl H~tl~~
Phillipsburg, NJ 88685 ~eapa~'iw~hteremN`g~ricy.num~~#a~ki~
u~~d dn}y ~~:#ite~rvnto>`:c11Ga1..
eme~r~ai~es inval~ln~ as~ilE,.teatc,:~f~,
ri~a~ufa;ar ac~ld~ri~,lnv~lving:ds~rr~c~fs~.
AN iron-cency qu~rokar~B show I~ d~r~ct~ ~a Cu~tom~r S~rvir~ ~i~~}-58.2537} ~r asv~s~ce.
Tricaprylmethylammonium Chloride
I. Product identification
Synonyms: None
CAS No.; 5137-55-3
Molecular Weight: 404.17
Chemical Formula: (CSH17)3N(CH3)Cl
Product Codes; W450
2. CompositionlInformation on Ingredients
Ingredient CAS No Percent Hazardous
TricaprylmethylammoniumChloride 5137-55-3 80 - 100 Yes
3. Hazards Identification
Emergency Overview
DANGER! CAUSES SEVERE SKIN AND EYE BURNS. HARMFUL IF SWALLOWED
OR INHALED. TARGET ORGAN(S);Eyes, skin, mucous membranes.
Potential Health Effects
Inhalation;
Is harmful
Ingestion:
Burns to mouth, throat, and stomach.
Skin Contact:
Severe bums.
Eye Contact:
Severe burns.
Chronic Exposure:
No information found.
Aggravation ofPre-existing Conditions;
Damaged skin,
4. First Aid Measures
Inhalation:
If inhaled, remove to fresh air, If not breathing, give artificial respiration, If breathing is
difficult, give oxygen, Prompt action is essential.
Ingestion:
If swallowed, DO NOT INDUCE VOMITING. Give large quantities of water. Never give
anything by mouth to an unconscious person. Get medical attention immediately.
Skin Contact:
In case of contact, immediately flush skin with plenty of water far at least 15 minutes while
1211$07 ~D:34 PM
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1 1
Tricaprylmethylammonium Chloride
removing contaminated clothing and shoes. Wash clothing before re-use,
Eye Contact:
In case of eye contact, immediately flush with plenty of water for at least 15 minutes,
5. Fire Fighting Measures
Fire:
Flash point: 102C (21bF} CC
Explosion;
Fire or excessive heat may produce hazardous decomposition products,
Fire Extinguishing Media:
Water spray; Dry chemical; Carbon dioxide.
Special Information:
Wear self-contained breathing apparatus and protective clothing to prevent contact with skin
and eyes.
6. Accidental Release Measures
Absorb material in sand or other suitable absorbent and place in container,
7, Handling and Storage
Keep from contact with oxidizing materials. Containers of this material may be hazardous when
empty since they retain product residues (vapors, liquid}; observe all warnings and precautions
listed for the product.
S. Exposure ControlslPersonal Protection
Airborne Exposure Limits:
None established.
Ventilation System:
A system of local andlor general exhaust is recommended to keep employee exposures as low
as possible. Local exhaust ventilation is generally preferred because it can control the emissions
of the contaminant at its source, preventing dispersion of it into the general work area, Please
refer to the ACGIH document, Industrial Ventilation, A Manual of Recommended Practices,
most recent edition, far details.
Personal Respirators (NIOSH Approved}:
For conditions of use where exposure to the substance is apparent and engineering controls are
not feasble, consult an industrial hygienist. For emergencies, or instances where the exposure
levels are not known, use afull-facepiece positive-pressure, air-supplied respirator.
WARNING: Air purifying respirators do not protect workers in oxygen-deficient atmospheres.
Skin Protection:
Wear impervious protective clothing, including boots, gloves, lab coat, apron or coveralls, as
appropriate, to prevent skin contact.
Eye Protection:
Use chemical safety goggles andlor a full face shield where splashing is possible. Maintain eye
wash fountain and quick-drench facilities in work area.
Uther Control Measures:
There is insufficient data in the published literature to assign complete numerical SAF-T-
DATA* ratings and laboratory protective equipment for this product. Special precautions must
be used in storage, use and handling, Protective equipment far laboratory bench use should be
chosen using professional judgment based on the size and type of reaction or test to be
conducted and the available ventilation, with overriding consideration to minimize contact with
the chemical.
9. Physical and Chemical Properties
Appearance:
Clear reddish brown liquid.
Udor:
No information found.
Solubility:
Appreciable (~ 10%)
Specific Gravity:
No information found.
1~~1,8~07 10:34 PM
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Tricaprylmethyiammonium Chloride
pH'
No information found.
% Volatiles by volume @ 21C (70F):
0
Boiling Point:
225C (437F)
Melting Poin#:
No information found.
Vapor Density (Air=],);
No information found.
Vapor Pressure (mmHg}:
o @ lac (~sF}
Evaporation Rate (BuAc=1}:
0
lo. Stability and Reactivity
Stability:
Stable under ordinary conditions of use and storage.
Hazardous Decomposition Products:
Carbon dioxide, carbon monoxide, oxides of nitrogen, Hydrogen chloride gas
Hazardous Polymerization;
Will not occur.
Incompatibilities:
Strong oxidizing agents.
Conditions to Avoid:
No information found.
11. Toxicological Information
--------(Cancer Listsl------------------------------------------------------
---NTP Carcinogen---
Ingredient Known Anticipated IARC Category
TricaprylmethylammoniumChlaride No No None
(5137-55-3)
12. Ecological Information
Environmental Fate:
No information found.
Environmental Toxicity:
No information found,
13. Disposal Considerations
Whatever cannot be saved far recovery or recycling should be managed in an appropriate and
approved waste facility, Although not a Iisted RCRA hazardous waste, this material may exhibit
one or more characteristics of a hazardous waste and require appropriate analysis to determine
specific disposal requirements, Processing, use or contamination of this product may change the
waste management options. State and local disposal regulations may differ from federal
disposal regulations. Dispose of container and unused contents in accordance with federal, state
and local requirements,
14. Transport Information
Domestic (Land, D.O.T.)
Proper Shipping Name: CORROSIVE LIQUID, N.O.S
(TRICAPRYLMETHYLAMMONIUM CHLORIDE}
Hazard Class: 8
LTNINA: UN 17b0
Packing Group: II
Information reported far productlsize; SOOG
International (Water, I,M.O.)
Proper Shipping Name: CORROSIVE LIQUID, N,O.S.
(TRICAPRYLMETHYLAMMONIUM CHLORIDE}
12 J 18J07 10:34 PM
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Tricaprylmethylammonium Chloride
Hazard Class: 8
UNINA: UN17bQ
Packing Group: II
Information reported for productlsize: SOOG
15. Regulatory Information
--------(Chemical Inventory Status -Part 11______________________.,________.,_
Ingredient TSCA EC Japan Australia
'IricaprylmethylammoniumChloride (5137-55-3) Yes Yes Yes Yes
--------(Chemical Inventory Statue -Part 21---___..___________________..______
--Canada--
Ingredient Korea DSL NDSL Phil.
TricaprylmethylammoniumChloride (5137-55-3y Yes No No Yes
_____--_IFederal, State & International Regulations -Part 11----------------
-5ARA 302- ------SARA 313------
Ingredient RQ TPQ List Chemical Catg.
I'ricaprylmethylammoniumChlaride (5137-55-3)No Nv Na No -__.._
-_-_____IFederal, State & International Regulations -Part 21----------------
-RCRA- -TSCA-
Ingredient CERCLA 2fi1.33 8~d)
TricaprylmethylammoniumChloride No No No
(5137-55-3)
Chemical Weapons Convention: No TSCA 12(by: No CDTA: No
SARA 3111312: Acute: Yes Chronic: Yes Fire: Nv Pressure; No
Reactivity: No (Pure /Liquid)
Australian Hazchem Code: None allocated.
Poison Schedule: None allocated.
wHMIS:
This MSDS has been prepared according to the hazard criteria of the Controlled Products
Regulations (CPR) and the MSDS contains all of the information required by the CPR.
16. Qther Information
Label Hazard Warning:
DANGER! CAUSES SEVERE SKIN AND EYE BURNS. HARMFUL IF SWALLOWED OR
INHALED. TARGET ORGANS}:Eyes, skin, mucous membranes.
Label Precautions:
No SAF-T-DATA Ratings have been developed for this product. Read and follow all warnings,
precautions, instructions and other safety and handling information on the label and MSDS.
Avoid contact with eyes, skin, clothing.
Do not breathe vapor. Use only with adequate ventilation. Keep container closed. Wash
thoroughly after handling.
Label First Aid:
If swallowed, DO NOT INDUCE VOMITING. Give large quantities of water. Never give
anything by mouth to an unconscious person. If inhaled, remove to fresh air, If not breathing,
give artificial respiration. If breathing is difficult, give oxygen. Prompt action is essential. In
case of contact, immediately flush eyes ar skin with plenty of water for at least 15 minutes
while removing contaminated clothing and shoes, Wash clothing before reuse.
Product Use:
Laboratory Reagent.
Revision Information:
MSDS Sections} changed since last revision of document include: 8.
Disclaimer:
Mallinekrodt Baker, Inc, provides the information contained herein in good faith but
makes no representation as to its comprehensiveness or accuracy. This document is
intended only as a guide to the appropriate precautionary handling of the material by a
properly trained person using this product. Individuals receiving the information must
exercise their independent judgment in determining its appropriateness for a particular
purpose, MALLINCKRODT BAKER, INC. MAKES NO REPRESENTATIONS OR
WARRANTIES, EITHER EXPRESS OR IMPLIED, INCLUDING WITHOUT
LIMITATION ANY WARRANTIES OF MERCHANTABILITY, FITNESS FOR A
PARTICULAR PURPOSE WITH RESPECT TO THE INFORMATION SET FORTH
12J1SJOl 10:34 PM
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Tricaprylmethylammonium Chloride
HEREIN OR THE PRODUCT TO WHICH THE INFORMATION REFERS.
ACCORDINGLY, MALLINCKRODT BAKER, INC. WILL NOT BE RESPONSIBLE
FOR DAMAGES RESULTING FROM USE OF OR RELIANCE UPON THIS
INFORMATION.
Prepared by: Environmental Health & Safety
Phone hCumber: (314y 654-1600 (U.S.A.)
12~1$~07 10:34 PM
http:~ jwww.jtbaker.com~msds~englishhtml~t4770.htm Page 5 of 5
.~- ~
POLYVINYL AhCOHOL
MSDS Number: P5282 * * * * * Effective Date: 02J1610b * * * * '~ Supercedes: 05J1~4103
LY Hour En1~a+rg9r~GyT$t~phon9i p1I9~~A~L~i7~
~ Materiel ~af+~ D~~~ She~~e~
~ cM~~R~c: ~.~ao~azA~ao
:,
.H, .,., ,..,.....,..
.,. , , .... .....~. ... ..... , Na~a~al F~esp+~ns~1n Canada
CANl11'~C: ~93~96~868
4utsid~ U,S, And Canada
Ch~mtrec: 703•aZ1-3887
dram: Ma11i~c~trodtBnkerr Inc.
~~ Ned Schod Lang ~~~~" NL7T~: CHEMTRI»~; CANIf~~C ~~nd Na~i:~i^i~l
Phtllfpabur~, N,t X8885 I~aspar~s~ Cei~tet eme~'~6niy rtumb~s #o b$
usad only iri;th~ ant ~f rho~nlrat::....., . .
~j em~~~n~ias.~~nu~lvln~:a~pi9l;I~a~i;~~ira~.
~xpa~uro ~r ~~~~~nt invotving t~~mical~,
~l! ~o~cency que~iiano rohauld ~ direr ~ C~sbm~r S~rwi~ ~l-~3-5~ 2x37} iar a~~atance,
POLYVINYL ALCOHOL
1. Product Identification
Synonyms: Polyvinyl alcohol; PVA; Polyvinol; ethenol homapolymer
CAS No.: 9002-$9-5
Molecular Weight: Not applicable to mixtures.
Chemical Formula: [ -CH2CHQH- ]n
Product Codes; 0227, U22$, U229, U232
2. CompositionlInformation on Ingredients
Ingredient CAS No Percent Hazardous
Methyl Alcohol 67-5fi-1 ~ 1$ No
Polyvinyl Alcohol 9DD2-B9-5 > 95$ Yes
3. Hazards Identification
Emergency Overview
CAUTION! MAY FORM COMBUSTIBLE DUST CONCENTRATIONS IN AIR,
NUISANCE DUST.
J.T. Baker SAF-T-DATAItmI Ratings (Provided here for your convenience)
Health Rating: 0 -None
Flammability Rating: 2 -Moderate
Reactivity Rating: 0 -None
Contact Rating: 0 -None
Lab Protective Equip: GOGGLES; LAB COAT; CLASS B EXTINGUISHER
Storage Color Code: Red (Flammable}
Potential Health Effects
Inhalation:
Dust may be formed under certain conditions of use. Treat as a nuisance dust. When heated
above 200C, fumes irritating the eyes nose, throat will be evolved. Symptoms may include tears
in the eyes with itching, redness, burning pain in throat and nose.
Ingestion;
Not expected to be a health hazard via ingestion.
Skin Contact:
Not expected to be a health hazard from skin exposure.
Eye Contact;
Mechanical irritation only.
Chronic Exposure;
12J11JOT 11:48 PM
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i
POLYVINYL ALCOHOL
No human data. Animal studies showed a drop in hemoglobin and erythrocyte(red blood cell)
number with eventual complete coagulation inhibition. There is the possibility of
carcinogenicity as seen in some animal studies.
Aggravation of Pre-existing Conditions:
Na information found.
4, First Aid Measures
Inhalation:
Remove to fresh air. Get medical attention for any breathing difficulty.
Ingestion;
Nat expected to require first aid measures.
Skin Contact;
Wash exposed area with soap and water. Get medical advice if irritation develops,
Eye Con#act:
Wash thoroughly with running water. Get medical advice if irritation develops.
5, Fire Fighting Measures
Fire:
Flash point: 79C (I74F) OC
As with most organic solids, fire is possible at elevated temperatures or by contact with an
ignition source. Minimum dust cloud ignition temperature: 450C (842F),
Explosion:
Fine dust dispersed in air in sufficient concentrations, and in the presence of an ignition source
is a potential dust explosion hazard. Maximum explosion pressure: 78 lb.lsq. in.
Fire Extinguishing Media:
Water spray, dry chemical, alcohol foam, or carbon dioxide.
Special Information;
In the event of a fire, wear full protective clothing and NIOSH-approved self-contained
breathing apparatus with full facepiece operated in the pressure demand or other positive
pressure mode.
6. Accidental Release Measures
Remove all sources of ignition. Ventilate area of leak or spill, Wear appropriate personal
protective equipment as specified in Section S. Spills: Clean up spills in a manner that does not
disperse dusk into the air. Use non-sparking tools and equipment. Reduce airborne dust and
prevent scattering by moistening with water, Pick up spill for recovery or disposal and place in
a closed container.
7, Handling and Storage
Keep in a tightly closed container, stared in a cool, dry, ventilated area, Protect against physical
damage. Separate from incompatibilities, Avoid dust formation and control ignition sources.
Employ grounding, venting and explosion relief provisions in accord with accepted engineering
practices in any process capable of generating dust andlor static electricity. Empty only into
inert or non-flammable atmosphere. Emptying contents into anon-inert atmosphere where
flammable vapors may be present could cause a flash fire or explosion due to electrostatic
discharge.
S. Exposure ControlslPersonal Protection
Airborne Exposure Limits:
None established.
Ventilation System:
A system of local andlor general exhaust is recommended to keep employee exposures as law
as possible. Local exhaust ventilation is generally preferred because it can control the emissions
of the contaminant at its source, preventing dispersion of it into the general work area, Please
refer to the ACGIH document,l'ndustrial Ventida[ion, A Manua[ o~ f Recommended Practices,
most recent edition, for details.
Personal Respirators (NIQSH Approved):
For conditions of use where exposure to dust or mist is apparent and engineering controls are
not feasible, a particulate respirator (NIOSH type N95 or better filters} may be worn. If oil
particles (e.g. lubricants, cutting fluids, glycerine, etc.} are present, use a NIOSH type R or P
12J11J47 11:48 PM
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r
,
PQLYVINYL ALCOHOL
filter, For emergencies ar instances where the exposure levels are not known, use afull-face
positive-pressure, air-supplied respirator. WARNING: Air-purifying respirators da not protect
workers in oxygen-deficient atmospheres,
Skin Protection;
Wear protective gloves and clean body-covering clothing.
Eye Protection:
Use chemical safety goggles.
9. Physical and Chemical Properties
Appearance:
White free-flowing granules.
odor:
Mild odor.
Solubility:
Moderately soluble.
Specific Gravity:
1.19 -1.31
pH'
Aqueous solution is neutral or slightly acid.
% Volatiles by volume ~ 21C (70F};
0
Boiling Point:
No information found.
Melting Point:
ca. 2000 (ca, 392F}
Vapor Density (Air=1}:
No information found.
Vapor Pressure (mm Hg};
No information found.
Evaporation Rate (BuAc~l};
Na information found.
10. Stability and Reactivity
stability.
Stable under ordinary conditions of use and storage.
Hazardous Decomposition Products:
Complete combustion will emit carbon dioxide and water when heated to decomposition.
Incomplete combustion gives in addition carbon monoxide and oxidation products, including
organic acids, aldehydes and alcohol.
Hazardous Polymerization:
Will not occur.
Incompatibilities:
Strong oxidizers.
Conditions to Avoid;
Heat, flame, ignition sources, dusting and incompatibles.
11. Toxicological Information
Qral rat LD50: > 20 gmlkg. Investigated as a tumorigen.
--------1Cancer I,istsl------------------------------------------------------
---NTP Carcinogen---
Ingredient Rnown Anticipated IARC Category
Methyl Alcohol (57-5fi-1) No Na None
Polyvinyl Alcohol t9Q02-89-5) No Na 3
12. Ecological Information
Environmental Fate:
No information found,
Environmental Toxicity;
No information found.
13. Disposal Considerations
12~11~07 11:48 PM
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POLYVINYL ALCOHOL
Whatever cannot be saved for recovery or recycling should be managed in an appropriate and
approved waste disposal facility. Processing, use or contamination of this product may change
the waste management options. State and local disposal regulations may differ from federal
disposal regulations. Dispose of container and unused contents in accordance with federal, state
and local requirements.
14, Transport Ynformation
Not regulated.
15. Regulatory Information
--------(Chemical Inventory Status -Part 11--------- ----------------------.._
Ingredient TSCA EC Japan Australia
Methyl Alcohol [67-56-1) Yes Yes Yes Yes
Polyvinyl Alcohol (9002-89-5) Yes No Yes Yes
___-___-(Chemical Inventory Status -Part 21_________ ___________..____________
--Canada--
Ingredient Rorea DSL NDSL Phil.
Methyl Alcohol (67-56-1) Yes Yes No Yes
Polyvinyl Alcohol [9002-89-5) Yes Yes No Yes
--------(Federal, State & International Regulations - Part 11----------------
-SARA 302- ------SARA 313------
Ingredient RQ TPQ List Chemical Catg.
Methyl Alcohol (67-56-1) Nv No Yes No
Polyvinyl Alcohol (9002-89-5) No Nv No No
--------(Federal, State & International Regulations - Part 21--------------.._
-RCRA- -TSCA-
Ingredient CERCLA 261.33 8(d)
Methyl Alcohol [61-56-1) 5000 11154 No
Polyvinyl Alcohol (9042-89-5) No No No
Chemical Weapons Convention: No TSCA 12[b): No CDTA: No
SARA 31].1312: Acute: No Chronic: No Fire: Yes Pressure: No
Reactivity: No [Mixture /Solid)
Australian Hazchem Code: None allocated.
Poison Schedule: None allocated.
WHMIS:
This MSDS has been prepared according to the hazard criteria of the Controlled Products
Regulations (CPR} and the MSDS contains all of the information required by the CPR.
16. ether Ynformation
NFPA Ratings: Health; ~ Flammability: 2 Reactivity: 0
Label Hazard Warning:
CAUTION! MAY FORM COMBUSTIBLE DUST CONCENTRATIONS IN AIR. NUISANCE
DUST.
Label Precautions;
Stare in a tightly closed container.
Avoid breathing dust.
Avoid dust cloud in presence of an ignition source.
Maintain adequate ventilation,
Label First Aid;
Not applicable.
Product Use;
Laboratory Reagent.
Revision Information:
No Changes.
Disclaimer:
Mallinckrodt Baker, Inc. provides the information contained herein in good faith but
makes no representation as to its comprehensiveness or accuracy, This document is
intended only as a guide to the appropriate precautionary handling of the material by a
properly trained person using this product. Individuals receiving the information must
exercise their independent judgment in determining its appropriateness for a particular
12J11J01 11:48 PM
http:JJwww.Ibamspray.comJOd_HealthJ200lJPOLYVINYL~20ALCOHOL9620M5D5.htm Page 4 of 5
j
POLYVINYL ALCOHOL
purpose. MALLINCKRODT BAKER, INC. MAKES NO REPRESENTATIONS OR
WARRANTIES, EITHER EXPRESS OR IMPLIED, INCLUDING WITHOUT
LIMITATION ANY WARRANTIES OF MERCHANTABILITY, FITNESS FOR A
PARTICULAR PURPOSE WITH RESPECT TO THE INFORMATION SET FORTH
HEREIN OR THE PRODUCT TO WHICH THE INFORMATION REFERS.
ACCORDINGLY, MALLINCKRODT BAKER, INC. WILL NOT BE RESPONSIBLE
FOR DAMAGES RESULTING FROM USE OF OR RELIANCE UPON THIS
INFORMATION.
Prepared by: Environmental Health & Safety
Phone Number: (314) 654-1600 (U.S.A.)
12 J11Jol 11:48 PM
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