The News and Observer, Raleigh, N. C., Mon., June 6, 1983 High residue level` reduces leaf quality NCSU Agricultural Extension Service Residues of pesticides are considered a factor in determining the quality of tobacco, says Dr. T.J. Sheets, director of the Pesticide Residue Research Laboratory at N.C. State University. "This is true," he said, “because several tobacco importing countries now discriminate against leaf that contains excessive residues of MH, a sucker control chemical.” There have been problems with other pesticides, but the only major concern at present is MH or maleic hydrazide, which is used throughout the U.S. flue-cured and burley belts, Sheets said. He advised growers to follow steps recommended by the N.C. Agricultural Extension Service to hold down residue levels and at the same time ootain effective sucker control. ples appear to have declined somewhat in the past two years." he said. "The drop can be attributed to increased rainfall and to changes in production practices made by growers in an effort to deal with the MH residue problem." Sheets said average residues of MH in U.S. flue-cured leaf still are well above the tolerance of 80 ppm in tobacco products proposed by Germany. "The average for U.S. wholeleaf tobacco in 1982 was 98 ppm. After stemming and redrying, the 1982 leaf stored in hogshead will average 130 ppm or more," Sheets said. Wide variations in MH residue levels have been found in tobacco from different belts. Residues are consistently lower in the Old Belt of Piedmont North Carolina and Virginia, for example, than in belts farther south. The Middle, Eastern and Border belts fluctuate but generally fall between the high and low belts. These steps include applying the right amount of nitrogen to the crop; using contact-type solutions early in the season; harvesting once before applying MH at recommended rate; and waiting at The first leaves harvested after least seven days after MH is ap- MH application generally show the plied before the next harvest, as highest MH residues. These usualrequired by the label on the prod-ly are primings and lugs from the uct. MH, a systemic-type growth regulator that gets into the plant and moves about, was introduced for tobacco sucker control in the 1950s. It was known from the beginning that MH persists in the cured leaf, but residues in the early years were relatively low, averaging 30 to 60 parts per million. Sheets said average concentrations of MH on U.S. flue-cured tobacco began to rise in the late 1960s and increased to a peak of about 130 to 140 ppm in whole leaf (before stemming) in the mid to late '70s. "Average levels in grower sam . lower part of the stalk. Residues tend to decline in midstalk and upstalk leaves except that the tips, at the very top of the stalk, often have higher residues than the leaves just below. Sheets said rainfall is a major factor affecting MH residue levels. Residues decrease as rainfall in creases. "If it rains 12 hours or more after MH has been applied, we don't think you need to reapply at all. During that time, enough MH gets inside the plants to control suckers effectively. "In one test we had an inch of rain only four hours after application. The next day we reapplied MH at only one-half the regular rate and obtained very good sucker control. Sheets said research is incomplete on whether MH is contributing to the widespread problem of leaf immaturity and unripeness that has developed in U.S. fluecured tobacco the past few years. naca NATIONAL AGRICULTURAL CHEMICALS ASSOCIATION THE MADISON BUILDING 1155 Fifteenth Street, N.W., Washington, D. C. 20005 202 296-1585 Cable NAGRCHEM Dr. Jack D. Early February 18, 1983 The Honorable George E. Brown, Jr. Chairman Subcommittee on Department Operations, Research, and Foreign Agriculture Committee on Agriculture U. S. House of Representatives Dear George: We appreciate the opportunity to comment on the draft report entitled "Understanding Regulatory Procedures and Public Health Issues in the EPA's Office of Pesticide Programs" which is currently under review by your Subcommittee. The National Agricultural Chemicals Association (NACA) comments on the recommendations of this draft report are enclosed. They represent a detailed and careful review not only by the staff of NACA but also a goodly number of scientists from our member companies. We believe that you and your Subcommittee will find our comments constructive and helpful as you review this voluminous document. JDE/1k Enclosure Sincerely, ad Jack D. Early 2/18/83 NACA COMMENTS ON RECOMMENDATIONS OF BENBROOK REPORT GENERAL The assignment of the staff was stated as follows: (1) to gather an up-to-date factual basis to administration of the pesticide regulatory program is in accordance with the Federal Insecticide, amended." Neither of the two assignments given to the staff have been satisfactorily completed. No up-to-date factual basis is de scribed and no conclusion is reached as to whether or not EPA's administration of the program is in accordance with FIFRA. The report does not do justice to the importance of the subject. Many of the Report's recommendations involve superficial, academic approach to the problems of the Agency, and a lack of understanding of the practical issues which decide the success or failure of the regulatory process. Furthermore, the report ignores the recent conclusions of other Congressional and Administration working groups relevant to certain of the major NACA Comment The report recognizes an existing problem for minor uses, but its recommendations are vague. They do not realistically address the key issue that generating data for a minor crop or use is as expensive and timeconsuming as for a major crop. No concrete suggestions are made for dealing with this issue. The Agency and Congress should consider additional modifications in the Section 3 registration process, such as a provisional category of registration, so that a greater percentage of pesticide registrations satisfies Federal registration standards. NACA Comment Provisional registration and further analysis of environmental impact of Sections 18 and 24 (c) clearances will not help the specialty crop registration issue. However, there is a gap between a Section 5 experimental use permit and a full Section 3 registration. The USA would benefit from a phased registration system as recommended by WHO/FAO and practiced most notably in France, the UK and Australia. This may alleviate some of the pressure on the number of Section 18 petitions from states, especially for new active ingredients. Report Recommendation The Agency and Congress should develop better ways to assist states in analyzing and minimizing potential adverse environmental impacts of pesticides used under Section 18 and Section 24 (c) of FIFRA. ISSUE 2 NACA Comment In spite of increased use of Sections 18 The Tolerance Setting System Report Recommendation The Agency should proceed expeditiously with its efforts to revise the tolerance setting system in accordance with the recommendations of the Scientific Advisory Board (SAB). NACA Comment NACA feels the tolerance setting system is international ramifications, and has been and is being administering pesticide crop tolerances. Except for two areas where further improvements could be |