By Vicky Boyd
The measures include buffer zones, notification of fumigation for workers and bystanders, air monitoring, written, site-specific fumigant management plans and training and certification of any worker who is involved with the fumigant application process in any way. The label changes would significantly limit many growers’ ability to use these critical crop-protection tools—and ultimately their ability to continue to produce fresh market vegetables, strawberries, cut flowers and other ornamentals.
FFVA strongly urged its producer members who use the fumigants to respond to the EPA during the comment period. Growers were asked to document how much it would cost to implement the measures and provide information that might lead to other risk mitigation options that would allow them to continue to use the products.
The requirement for buffer zones between the fumigated fields and nearby buildings is particularly onerous for the strawberry industry. Many, if not most, fields in the prime production area of Plant City/Dover have residences nearby.
As proposed, the measures also would prohibit overlapping buffer zones within production areas for adjacent plantings. In its comments to the EPA, FFVA wrote, “The ability to reduce buffers through the partitioning of farms to reduce the acreage fumigated at any one time will not work where we have solid-set irrigation for plant establishment and use drip irrigation for crop production needs. The only way to accomplish the proposed buffers would be the elimination of cropping a portion of the field.”
Ted Campbell, executive director of the Florida Strawberry Growers Association, estimates that the buffer-zone requirement would eliminate about 60 percent of the strawberry production area. “The buffer zones are a killer to us,” he said at the Florida Ag Expo, which took place Nov. 5. He predicted the label changes would cost the industry $162 million in lost farm income and have a collateral economic impact of $300 million.
At issue is whether the risk controls the EPA plans to impose are proportionate with the true risk. The risk model the agency is using is based on nationwide data, including very different climatic and production practices in other regions of the country, including California. The model needs additional data to provide a more refined and accurate picture of what occurs in Florida fruit and vegetable production.
“We need to get people to understand the real risks compared to the real benefits,” Mike Aerts, director of FFVA’s membership and marketing division, told growers attending the Expo. “In Florida, we’re talking about fewer than 15 reported exposure incidences in 8,500 applications” over the past five years. And those cases, Aerts said, stemmed from equipment failure and inappropriate applications or application techniques.
Agriculture Commissioner Charles Bronson wrote in his department’s comments to the EPA, “Bystander exposure complaints are very rare in Florida, despite thousands of applications occurring here each year. Perhaps bystander exposures occur more frequently in other parts of the country. If so, we prefer that local or regional problems be addressed with local or regional solutions, rather than imposing costly and potentially controversial mitigation measures across the nation.” Bronson is asking the agency to suspend implementation of the new measures until Florida-specific data can be used to develop measures that make more sense for producers in our state.
In concluding its comments, FFVA said the measures represent “a significant overstatement of potential risk and as a result create a situation where the ability of the grower to continue to use these very valuable tools for crop production is jeopardized.”
The comment period ended Oct. 30. After it reviews and responds to comments, the EPA plans to issue its final decisions next year, although they won’t go into effect until the agency approves the new labels in 2010.
To see a copy of FFVA’s comments or other resource documents related to the proposed label changes, visit www.ffva.com.