Comments on Public and Environmental Perspective on California…

     Comments on Public and Environmental Perspective on California Department of Food &
         Agriculture (CDFA) Light Brown Apple Moth (LBAM) Eradication Program
                 Nan Wishner, Chair, City of Albany Integrated Pest Management Task Force
                      prepared for the California State Assembly Committee on Agriculture

                                                       March 12, 2008

Summary
The general public and environmental perception is that the State has not proven that the Light Brown
Apple Moth (LBAM) eradication program is safe, effective, or necessary. In the absence of solid science
from the State, the burden of research and proof has been shifted to the public.
Background
Aerial spraying is the most controversial element of the LBAM eradication program. Pesticides are
sprayed from planes flying at 500-800 feet through the night, typically for three nights per month.
Spraying is planned to take place approximately 3 nights per month, 9 months per year. CDFA plans to
spray for 3-5 years or indefinitely until the moth is eradicated. The 2008 CDFA spray zone map
(http://www.cdfa.ca.gov/phpps/PDEP/lbam/lbam_main.html) covers a number of counties and urban
areas with a total population of about 7 million people. Ground treatments are also planned for 2008. The
public is concerned about the chemicals and methods to be employed in this part of the program,
particularly the entry of CDFA representatives to private property.
Safety
Concerns about the safety of the aerial spray program revolve around the lack of testing of key
ingredients in the pesticides being used, known dangers of other components of the pesticide, health
complaints reported by residents of the Monterey and Santa Cruz areas after spraying there last year, and
the potential that CDFA may use a different and untested chemical in the 2008 spray program.
Pesticide used in 2007
The active ingredient in the pesticide products that CDFA used in 2007 is a synthetic moth pheromone.
The two pesticides used in fall 2007, Checkmate OLR-F and Checkmate LBAM-F, also contain a number
of toxic, potentially carcinogenic, mutagenic so-called "inert" 1 ingredients, one of which is a
reproductive effector associated with birth defects, and several of which should not be inhaled. This
information is readily available on the Material Safety Data Sheets for the ingredients and in the National
Institute of Occupational Safety and Heath database.
The pesticide mixture is packaged in minute plastic capsules that are inhaled by anyone exposed to the
spray. These capsules are as small as 10 microns in size, according to a U.C. Davis study released last
year (Werner et al. 2007). The American Lung Association, among other sources, notes that particles of
10 microns and smaller can be inhaled into the deep lung, from which they cannot be expelled. The
plastic capsules in which the pesticide is sprayed break down over approximately 30 days, releasing the
pesticides. Recent information from OEHHA indicates that the spray particles may remain suspended in
the environment for up to 12 months.
The only ingredients in the pesticide that have been thoroughly tested are the inerts. The active ingredient,
the synthetic pheromone, has not undergone any long-term human toxicity testing, as noted in court
testimony and analysis by independent toxicologist Dr. Richard Philp. Moreover, the State's Consensus
document on the health risk of the spray, prepared by the Department of Pesticide Regulation (DPR) and
the Office of Environmental Health and Hazard Assessment (OEHHA), contains the explicit disclaimer
that the conclusion that the spray is safe for human exposure is based studies of the active ingredient only,
and that these studies assume "aerial application over agricultural areas rather than aerial application over

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  Inert ingredients are so named because they do not actively work to kill the target pest. In most cases, the U.S. Environmental
Protection Agency tests only the active ingredient of a pesticide, not the complete formula including inerts, and the inerts are
usually considered proprietary business information and are not disclosed. For Checkmate LBAM-F only, the inert ingredients
disclosed after the first round of LBAM spraying in 2007.
populated areas (such as in the present situation)."
CDFA obtained an exemption from U.S. EPA to use the products in this manner and warns people and
pets to stay inside during the spraying. Checkmate had not been sprayed over urban areas until CDFA
used it over Monterey and Santa Cruz last fall; it had previously been sprayed aerially only over
agricultural areas.
Health Complaints
Following the spraying in Monterey and Santa Cruz in 2007, there were more than 600 reports of health
problems, including asthma-like attacks and difficulty breathing, chest pains, headaches, blurred vision,
swollen glands, skins rashes, and feelings of chronic fatigue. These symptoms are consistent with the
health impacts of the ingredients of the pesticide formula whose effects are known. The State's
Consensus document on Health Risks says that " it is not possible to confirm the symptoms are or are not
due to the application of Checkmate," and "because not all 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." These health complaints were
reported despite the absence of an infrastructure to collect them and the failure to notify and train
physicians regarding the spray and the symptoms of pesticide exposure. These complaints have not been
formally and thoroughly investigated by the State, and CDFA's Robert Dowell has publicly dismissed the
complaints, stating that they are likely imaginary.
There is public concern that CDFA is exploring using a new pesticide that is currently being investigated
but not tested for human health and environmental safety. Given the risks of the pesticide used last fall
and the health problems reported, the potential that another unknown and untested product will be used
over large populated areas is disturbing at best.
Are Pheromone Controls Environmentally Preferable?
CDFA stresses that pheromone-based products are one of the safest eradication tools available and that
environmentalists "want" pheromone pest controls. While many environmental and organic agriculture
groups have advocated the use of pheromones, the formulation and encapsulation in plastic of the
products being used in this case, the lack of testing of human exposure, and their aerial application
differentiate them from environmentally preferable pheromone products such as stationary bait traps.
The recent position statement released by California Certified Organic Farmers (CCOF) expresses
concisely the view of many environmental and health groups: "CCOF supports the use of pheromones in
ground applications and other ecologically sound organic integrated pest management (IPM) approaches
as far preferable to the use of dangerous organophosphates. However, CCOF does not endorse further
aerial applications of pheromones in LBAM eradication efforts due to potential human health and
environmental concerns."
Effectiveness
Aerial pheromone spraying has never been used to and cannot successfully eradicate a pest because the
spray only confuses mating behavior and does not kill pests.
In addition, the conditions necessary for successful use of a pheromone cannot be met by the varied
terrain, plantings, and moth concentration in the large area CDFA proposes to spray. According to a
report recently released by botanist and Executive Director of the UC Santa Cruz arboretum Dr. Daniel
Harder on integrated pest management (IPM) for LBAM in New Zealand, pheromone coverage is only
effective under the following conditions:
            ·   Extensive, even, and complete coverage of the pheromone
            ·   Uniform blocks of a single crop (single canopy height)
            ·   Uniform topography (no slopes, hills or valleys)
            ·   Low population density of target pest (not too concentrated)

There is also the larger question of what is meant by "eradication." According to a list provided by
CDFA, the agency undertaken 274 separate emergency eradication projects against 9 pests since 1982,
with projects repeating annually for the same pests. In every case, CDFA has failed to eradicate the
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target pest, and emergency eradication programs for 6 of these pests have been in process since 1982.
This cycle of continual pesticide use is the basis for positions like the Sierra Club's opposing the LBAM
eradication. The Sierra Club resolution, passed in January 2008, specifically calls on the state to take the
"precautionary approach of an alternatives assessment to determine control strategies that do not
compromise human and environmental health and that is sufficiently effective to manage the pest to the
acceptable thresholds is completed. The assessment must be based on a realistic assessment of the
feasibility of eradication." It is increasingly clear to environmental and health organizations that, in this
era of global trade and global warming, the arrival exotic pests is inevitable and likely to increase. We
cannot blanket spray for each new pest that is introduced or re-introduced.
Necessity
CDFA has stated that there has been no damage to crops in California attributable to LBAM. Independent
scientists, including Dr. James Carey, UC Davis entomologist and invasive species specialist, say that,
based on the range over which it has been found, LBAM has likely been in the state for up to 30-50 years,
which is certainly long enough for us to have seen crop damage. A report recently released by Dr. Daniel
Harder, botanist and Executive Director of the UC Santa Cruz arboretum, finds that, in New Zealand,
LBAM is effectively controlled by native predators of the same types that are present in California.
Native Predators
A Dr. Harder's report finds that, in New Zealand, which has climate and crops like those of California's
coastal areas and where LBAM has been an established exotic pest for more than 100 years, there is no
evidence of biological or environmental threat from LBAM. LBAM does not do significant economic or
biological damage to crops or native flora there. The report also notes that 80-90% of LBAM larvae are
parasitized by native predators in New Zealand. The same "generalist" native predators, including birds,
spiders, specific types of wasps, and others, are found in California, which is currently home to more than
85 native and localized species of Tortricid moths similar to LBAM (none of which is the subject of an
eradication program).
Potential Crop Damage
With regard to potential crop damage, CDFA's list of 2,000 potential host species for LBAM is
speculative and exaggerated. The list includes species that LBAM, which is a leaf-roller moth (i.e., it
requires leaves to wrap around the larvae to protect them), would not likely inhabit, such as redwoods and
pines. And the list includes any plant on which LBAM has ever been seen, whether or not it fed on that
plant. CDFA says that the criterion for LBAM's inclusion on the list is that it is "capable of being eaten
by LBAM," according to Steve Lyle.
In hearing reports of LBAM crop damage from Australia and New Zealand, it is important to note when
the damage occurred. LBAM has been a problem past in the past when broad-spectrum organophosphate
pesticides were in wide use and had destroyed the populations of beneficial predator insects that attack
LBAM. A frequently cited report of LBAM-damaged grapes was a single incident in the early 1990s
when organophosphates were heavily used. Since 2001, when organophosphate use was abandoned in
New Zealand and beneficial insect populations have rebounded, LBAM is no longer a problem pest there,
according to Dr. Harder's report.
Risk to Central Valley
Some have expressed the concern that LBAM will be very destructive if it reaches California's Central
Valley. However, LBAM does not reproduce well below 7.1 degrees C (45 degrees F) and or above 30.7
degrees C (87 degrees F) (Venette et al. 2003), so it is unlikely to establish in the Central valley or in "80
percent of the U.S." as CDFA staff predicts.
Risk of Increased Pesticide Use if Aerial Spray is Not Employed
The argument presented by CDFA that, in the absence of spraying, California residents will irresponsibly
begin a "never ending" cycle of pesticide use is highly unlikely.
First, LBAM does not do serious damage. While some photos have been shown by CDFA and the press
of LBAM damage that may look frightening, there is no information about the source of the damaged
fruit; how old are the photos and where do they come from? how widespread was the damage? were the

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growers using best management practices? were the plants inoculated with LBAM as part of study, or is
the damage a result of LBAM's natural presence and behavior ? were organophosphate pesticides being
used and what was the state of the population of natural LBAM predators? New Zealand scientists report
that LBAM is a superficial feeder that does primarily cosmetic damage to the surface of fruit and only
nibbles at leaves. It would not be in LBAM's interest to defoliate a tree or completely consume the leaves
that protect it.
Second, as part of the preparation of Albany's Integrated Pest Management ordinance, our Task Force last
year surveyed residents' pesticide use and found that 60% use only organic pest control methods
(California Certified Organic Farmers earlier this week came out in opposition to the aerial spray
program). It seems unlikely that residents of environmentally conscious California would suddenly begin
freely using pesticides to combat a moth that does little or no damage.
Trade and Quarantines
Finally, with regard to economics and trade, the numerical values of potential crop damage from LBAM
that CDFA cites appear inflated based on information regarding costs to meet the U.S. Department of
Agriculture's zero-tolerance LBAM quarantine, not on values of crops damaged in Australia or New
Zealand. The concern that Mexico and Canada will reject produce if LBAM is not eradicated seems
overblown given that Canada adopted its LBAM restrictions following the U.S.'s lead, and Mexico's
LBAM quarantine advisory of May 2007 notes "the present phytosanitary conditions may be modified or
harmonized whenever we have more technical and scientific information regarding E. postvittana, as well
as we receive more information about the evolution status of this pest in the United States."
What Should We Do?
If LBAM has indeed been in California for decades and there is no evidence of damage, the likely
conclusion is that it is being kept in check by natural predation. Sound integrated pest management (IPM)
practices dictate that the first step in responding to any potential pest is to monitor to determine the degree
of damage and assess whether any action is needed and what a reasonable threshold for action should be.
There certainly appear to be no grounds for emergency action against LBAM.
As Dr. Harder's report suggests, no intervention for LBAM may be necessary. We should suspend the
LBAM eradication program and monitor to determine the extent of natural parasitization of LBAM. If
monitoring data show that some LBAM control is necessary, we should follow the IPM best practices
New Zealand has found to be effective, using insect growth regulators (IGRs), which are least-toxic
chemical controls, at specific problem sites.
Consistent with IPM best practices, we should stop use of organophosphate pesticides for LBAM in
nurseries to protect the beneficial predators of LBAM and other pests as well as workers, consumers, and
the environment.
We should ensure that this and other invasive species eradication programs are subject to a broad range
independent scientific review, and that no population, urban or rural, is subjected to pesticide spray
without consent.
In view of the background research Dr. Harder has performed, we should request that the U.S.
Department of Agriculture re-evaluate the classification of LBAM based on up-to-date science.
Sources
Abraham, Kera. November 15, 2007. "Pheromone spraying aimed at wiping out the light brown apple
moth maybe fruitless." Monterey County Weekly.
Alexander, Kurtis. Nov. 10, 2007. "State Wraps Pesticide Use, Some Still Bugged." Contra Costa
Times.
California Department of Pesticide Regulation, California Office of Environmental Health and Hazard
Assessment. 2007. Consensus Statement on Human Health Aspects of the Aerial Application of
Microencapsulated Pheromones to Combat the Light Brown Apple Moth. October 31.
http://www.cdfa.ca.gov/phpps/PDEP/lbam/lbam_main.html

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Carey, James, PhD. 2007. Testimony Submitted in Edna Williams, 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.
Cox, Caroline, and Michael Surgan. 2006. Unidentified Inert Ingredients in Pesticides: Implications for
Human and Environmental Health. Environmental Health Perspectives. August.
Harder, Daniel, PhD. 2007. Testimony 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 Practices for the Light
Brown Apple Moth in New Zealand: Implications for California.
http://democrats.assembly.ca.gov/members/a27/pdf/HarderNZReportFINAL.pdf
"Light Brown Apple Moth in California: Quarantine, Management, and Potential Impacts." 2007. U.C.
Davis IPM website. September 12. http://www.ipm.ucdavis.edu/PDF/PUBS/lbam091207.pdf
Lynberg, Mike and David Dilworth. 2008. Complaints of Adverse Reactions to Aerial Spraying in
Monterey and Santa Cruz Counties. January 3.
Material Safety Data Sheet. Butylated hydroxytoluene.
Material Safety Data Sheet. Polyvinyl alcohol.
Material Safety Data Sheet. Tricaprylmethylammonium Chloride.
McCord, Shanna. 2008. "Hundreds of health complaints followed apple moth spraying." San Jose
Mercury News. January 6.
National Institute of Occupational Safety and Health Registry of Toxic Effects of Chemical Substances.
2008. 1,2-Benzisothiazol-3(2H)-one; p-Cresol, 2,6-di-tert-butyl- (butylated hydroxytoluene); Ammonium,
methyltrioctyl-, chloride (Tricaprylylmethylammonium chloride)
Philp, Richard B. 2007. Analysis of Toxicology Studies with LBAM and Related Lepidopteran
Pheromones. October.
Philp, Richard B. 2007. Testimony in County of Santa Cruz v. CDFA, Superior Court of California, Santa
Cruz County. October 31.
Reynolds, Julia. 2008. "Marketing of Moth Spraying." Monterey Herald. Jan. 27
Venette, RC et al. 2003. Mini Risk Assessment: Light Brown Apple Moth. Department of Entomology,
University of Minnesota. Sept. 21.
Werner I, Deanovic LA, Markiewicz D. 2007. Toxicity of checkmate® LBAM-F and Epiphyas
postvittana pheromone to Ceriodaphnia dubia and fathead minnow (Pimephales promelas) larvae.
Aquatic toxicology laboratory. University of California, Davis.




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