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EPA
Quarantine Exemptions for Light Brown Apple Moth Pheromones
Current as of August 29, 2007
EPA is responsible for the evaluation of pesticides to ensure that they
will not have unreasonable adverse effects on humans, the environment and
non-target species. A pesticide cannot be legally used if it has not
been registered by EPA's Office of Pesticide Programs in accordance with
the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA).
Pesticide registration is the process through which EPA examines the
ingredients of a pesticide; the site or crop on which it is to be used;
the amount, frequency and timing of its use; and storage and disposal
practices. EPA also approves emergency exemptions (under Section 18
of FIFRA) for unregistered uses of pesticides for a limited time if EPA
determines that emergency conditions exist and the request meets EPA
safety requirements.
EPA has evaluated and approved four products for emergency use in a
quarantine program for a new invasive pest to the continental United
States, the Light Brown Apple Moth (LBAM). The EPA-approved quarantine
products all contain moth pheromones designed to disrupt mating and
thereby reduce populations of the pest.
Detection in the California Bay Area was confirmed in February 2007.
More than 5,000 detections of the moth have been confirmed over an
affected area encompassing 500,000 acres or more. LBAM has the potential
to cause significant economic losses due to increased production costs and
the possible loss of international and domestic markets. USDA estimates
the impact on plant production costs may exceed $100 million in the state
of California. For questions about the Light Brown Apple Moth Eradication
Project in California, call the California Department of Food and
Agriculture Hotline at 1-800-491-1899.
The moth pheromone products, though artificially derived, are exact
chemical replicas of the natural pheromones produced by the female LBAM to
attract mates. The products impair males from finding female mates. Wide
dispersal is key to product efficacy.
After a careful safety review, EPA has approved a hanging dispenser
product and three additional products for ground and aerial application
over wide areas where LBAM has been detected, including residential areas
that harbor plant hosts for the new, invasive moth. The products are:
|
Product Name |
Formulation Type |
|
Checkmate OLR-F |
Microencapsulated |
|
Checkmate LBAM-F |
Microencapsulated |
|
Disrupt Micro-flake LBAM Mating Disruption |
Flake |
|
Isomate LBAM Plus Pheromone |
Hanging Dispenser |
EPA believes use of these pheromone products, including aerial
application over residential areas, presents negligible risks to human
health and the environment for the following reasons:
- The pheromone products approved by EPA for the quarantine program do
not kill moths or other pests. Instead, the pheromones disrupt mating of
the LBAM. Therefore, these products do not exhibit toxic characteristics
more common to conventional pesticides. For more information see the Lepidopteran
Pheromones Fact Sheet.
- The pheromones in the quarantine products fall into the chemical
class of Straight Chain Lepidopteran Pheromones (SCLPs). SCLPs
encompass the majority of known pheromones produced by insects in the
Order Lepidoptera, which includes moths and butterflies.
Low mammalian/human toxicity for this class of chemicals is well
documented. Data on this class regarding inhalation toxicity, toxicity
from dermal (skin) exposure, and irritation from skin and eye exposure
all resulted in “non-toxic” or “practically non-toxic” classifications.
The SCLPs also showed no evidence of mutagenicity (toxicity at the
genetic level). Data submitted for structurally similar SCLP
pheromones also identified no subchronic, chronic or developmental risks
of concern. EPA considers the low toxicity of these pheromones to
humans as well-established in literature and through a long history of
use. (See Refs 1, 2, 3, 4, 5).
- EPA has also reviewed all the inert ingredients in the approved LBAM
products. Based on their low toxicity, all inerts in the product
formulations are cleared for use in products that come in contact with
food. (40 CFR 180.910, 180.920, 180.930, and/or 180.960). The
inert ingredients are present in the products to provide slow release of
the micro-encapsulated or flaked pheromone to prolong its effectiveness
in disrupting LBAM mating (See Refs 6, 7, 8, 9 for more
information).
- Other countries, such as Australia, where the LBAM is endemic, rely
on the use of SCLPs. EPA is not aware of any adverse effects being
reported as a result of these control programs. SCLPs are also
registered in the U.S. for crop use to control other pests, with a
similar track record for safe use. USEPA has received no reports
of adverse effects to human health or environment associated with
pheromone active ingredients registered for use in mating
disruption.
- In terms of exposure to the pheromones, pesticide applicators would
be expected to receive the most exposure because they handle the
concentrated product. However, even for the applicators, the
expected level of exposure is not of concern. In addition, the
product labels have standard precautionary information for handlers to
follow. (see attached labels).
- Residential and by-stander exposure is expected to be low due to the
low application rate and the specific methods of application. EPA
believes use of these pheromone products, including aerial application
over residential areas, presents negligible risks to human health and
the environment. Furthermore, there are no restrictions for
re-entering treated residential or recreational areas.
- LBAM and other SCLP pheromones naturally occur in the quarantine
areas due to the presence of LBAM females and other Lepidopteran pests.
Releasing the LBAM pheromone disrupts the mating cycle of
the pest. These pheromone mating disrupters are very specific to
targeted moth species, and are not expected to cause adverse effects or
responses in humans or any other species, including the Monarch
butterfly. SCLPs are biodegradable by enzyme systems in most
living organisms and should present no problem to normal
physiology.
- EPA carefully evaluated the safety of the requested quarantine uses
of these pheromone products and supports their use, and as noted
previously, believes the risks to human health and the environment are
negligible. In addition, the alternative approaches and controls
to use of pheromones might include more traditional pesticides that
would kill the pests rather than disrupt their mating cycle.
Populations of threatened and endangered plant species could also be
further impacted if this moth adapts to feeding on them as it has on
many other plant hosts.
Background
EPA reviewed and approved use of these products as authorized by
Section 18 of the Federal Insecticide, Fungicide, and Rodenticide Act
(FIFRA), and under its own regulations at 40 CFR Part 166 (Ref 10).
Under these provisions, a state or other federal agency may apply for
emergency use of a new pesticide or use pattern in order to help respond
to an urgent new pest problem, such as the discovery of an invasive and
damaging insect pest like LBAM. This program for release of
pheromones in mating disruption is considered a “quarantine”
emergency.
LBAM is native to Australia and is found in New Zealand, Ireland, the
United Kingdom, and Hawaii. The pest destroys, stunts, or deforms
young seedlings, spoils the appearance of ornamental plants, and injures
deciduous fruit-tree crops, citrus, and grapes.
References
- Guidance
for Registration Requirements for Pheromones and Semiochemicals Used for
Arthropod Pest Control. OECD Series on Pesticides. No.
12. Feb. 26, 2002 (25 pp, 77Kb , About PDF )
- Touhey, J.G. ca.1990. A review of the
current bases for the United States Environmental Protection Agency’s
policies for the regulation of pheromones and other semiochemicals,
together with a review of the available relevant data which may impact
the assessment of risk for these classes of chemicals. Part No.1,
Straight Chain Alcohols, Acetate Esters and Aldehydes. (Unpublished
report, 474 pp.)
- Amended
SCLP Tolerance Exemption Final Rule published in the Federal
Register 8/9/06
- SCLP
Tolerance Exemption Final Rule published in the Federal Register
8/9/95
- The 1/26/94 Federal Register Document titled Arthropod
pheromones in Solid Matrix Dispensers: Experimental Use
Permit.
- 40 CFR 180.910. Inert
Ingredients Used Pre- and Post-harvest; Exemptions from the Requirements
of a Tolerance
- 40 CFR 180.920. Inert
Ingredients Used Pre-harvest; Exemptions from the Requirements of a
Tolerance
- 40 CFR 180.930. Inert
Ingredients Applied to Animals; Exemptions from the Requirements of a
Tolerance.
- 40 CFR 180.960. Polymers;
Exemptions from the Requirements of a Tolerance.
- 40 CFR 166. Exemption
of Federal and State Agencies for Use of Pesticides Under Emergency
Conditions.
- California
Department of Food and Agriculture Web site
- National Pesticide Information Center Hotline: 1-800-858-7378
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