Filename: US reply to MBTOC on CA strawberry fruit Page 1

NOMINATING PARTY : The United States of America DATE: AUGUST 2 9 , 2013

BRIEF DESCRIPTIVE TI TLE : Response to questions from M BTOC bilateral of June 26

, 2013 on strawberry fruit

SITE NAME (OPEN FIEL D): Strawberry Fruit

NOMINATING PARTY CONTACT DETAILS:
Contact Person: Federico San Martini, Ph.D.
Title: Policy Advisor
Address: Office of Environmental Policy U.S. Department of State 2201 C Street, N.W. Room 2657 Washington, D.C. 20520 U.S.A. Telephone: (202) 647

- 3819

Fax: (202) 647

- 1052

E

- mail: SanMartiniFM@state.gov

CONTACT OR EXPERT(S) FOR FURTHER TECHNICAL DETAILS: Contact/Expert Person: Yu

- Ting Guilaran
Title: Acting Director
Address: Biological and Economic Analysis Division
Office of Pesticide Programs U.S. Environmental Protection Agency 1200 Pennsylvania Avenue, N.W. Mailcode 7503P Washington, D.C. 20460 U.S.A. Telephone: (703) 308

- 0052

Fax: (703) 308

- 7042

E

- mail: Guilaran.Yu

- T ing@epa.gov



### Strawberry Fruit

The United States is requesting that MBTOC recommend the full amount requested of 373,660 kg for strawberry fruit for the U.S. Critical Use Nomination for 2015. We have been working closely with this industry sector for a number of years on their transition and, as you know, they face a range of barriers to phasing out methyl bromide, in particular given the overlapping State and Federal regulations that apply to alternatives. Nevertheless, we believe that this sector will be able to fully phase out of methyl bromide by 2017 to allow time to ensure the successful adoption of alternatives. The U.S. government is willing to commit to ensuring that the phase

out of controlled uses of methyl bromide for California strawberries will be completed by the end of 2016 ( in other words, that 2016 will be the last use year for which we intend to request a methyl bromide CUE for this sector ). It is vital that MBTOC recommend CUEs for these finalFilename: US reply to MBTOC on CA strawberry fruit Page 2

two years to ensure we can make the transition we need to without putting growers out of business simply because they were not allowed enough time to fully complete the transition.

A transition time to 2017 is needed because, despite the recently approved higher use rates of chloropicrin, the regulatory landscape California strawberry growers face is uncertain. In particular , there are pending label changes that have been proposed by the California Departme nt of Pesticide Regulations (Cal DPR) this year to the two key methyl bromide alternatives in California, chloropicrin and 1,3

- dichloropropene. We anticipate that those regulations will be finalized next year or in 2015. The lack of a clear understanding by growers of when and how they can use the se alternatives will hamper the ability of growers to transition

more quickly to the alternatives than envisioned in our transition plan

.

Furthermore, we believe this transition plan will ensure that sufficient time is available for practices and procedures to be developed, refined, and tested so that growers can use chloropicrin at these higher rates safely and effectively. The final transition will provide time to develop standard procedures for high rates of chloropicrin targeting Macrophominia or Fusarium ; control of these pests is still causing significant difficulties and loss of crops in
California at this time

. This will also allow additional development of practices using straight chloropicrin to ensur e consistent performance on different soil types, soil temperatures, pest pressure, and other conditions. The additional time will also be used to develop educational materials to help growers choose the appropriate fumigant alternative(s) within the Cali fornia regulatory constraints, select the appropriate cultivar when single or multiple pathogens are present, as well as develop better sampling and identification processes when pathogens are first
discovered in fields. Work continue s to be conducted to test for strawberry cultivars that are resistant to the different plant pathogens present in strawberry fields , and we believe this work will continue to reduce the need for methyl bromide

. The California Strawberry Commission has supported research for many years on non

- fumigant production systems such as the raised bed trough system and anaerobic soil disinfest at ion with the ultimate goal of producing a high quality fruit without the need for fumigants. Such work will continue but, as MBTOC knows,
the results to date with some of these approaches have revealed significant challenges

.

We agree with MBTOC that chloropicrin has been in use commercially in California for a long
time. However, as noted above, practices and procedures need to be developed so that the high use rates needed to control the key pests are effective. Furthermore, time is needed to demonstrate that high rates of chloropicrin are effective against Macrophominia or Fusar ium

. Researchers in California plan to collect data this fall on the effectiveness of chloropicrin at the higher use rates on fields infested with Macrophominia or Fusarium

. The higher rates that are needed to ensure control in fields with high pest pres sures

— the fields with critical needs addressed by our nomination

—have only recently been approved. A recommendation from MBTOC for the full amount of methyl bromide for use in 2015 will put California strawberryFilename: US reply to MBTOC on CA strawberry fruit Page 3

growers on a path to successfully transitio n to alternatives and complete the methyl bromide phase

- out sector by the end of 2016.

The U.S. government would like to thank MBTOC for our bilateral meeting in the margins of the
33 rd Open

- Ended Working Group. During that bilateral meeting, MBTOC a sked the U.S. delegation a number of questions. We have reproduced and answered those questions below.

1 . Question from MBTOC

- In the bilateral meeting between MBTOC and the California Strawberry commission Edgar Kelly (strawberry grower in Ventura Coun ty, CA) stated that he had failures when using straight chloropicrin on his farm. Could you describe any problems providing pathogen control using straight chloropicrin in California?

U.S. Reply : The following table list s strawberry fruit fields in Ven tura County, CA

, where straight chloropicrin was tested and did not provide season

- long control of crown and root pathogens.

Table 1

. Performance of straight chloropicrin in Ventura County, CA.

Year Field Rate of chloropicrin Impact on crop (cultivar)
2010 Ramelli BLK 1 28 gal/ac. Inline (strip trt) w/
VIF 60% of crop was dead by mid

- May (San Andreas cultivar)
2010 Ramelli BLK 2 28 gal/ac. Inline (strip trt) w/
VIF 90% of crop was dead by mid

- May (San Andreas)
2011 Ramelli BLK 1 200 lbs/ac. Pic broadcast w/TIF 30% dead by mid

- May (San Andreas)
2011 Ramelli BLK 2 300 lbs/ac. Pic broadcast w/TIF 25% dead by mid

- May (Ventana)
2012 Ramelli BLK 1 350 lbs/ac. Pic broadcast w/TIF 25% dead by mid

- May (San Andreas)
2012 Ramelli BLK 2 350 lbs/ac. Pic broadcast w/TIF 30% dead by mid

- May (San Andreas)
2013 Ramelli BLK 1 350 lbs/ac. Pic broadcast w/TIF Yet to be planted (planted Oct 2013)
2013 Ramelli BLK 2 350 lbs/ac. Pic broadcast w/TIF Yet to be planted (planted Oct 2013)

The United States government is working to understand why these failures occurred. We believe that as practices and procedures are developed, refined and tested, growers will be able to use chloropicrin at the high rates listed in Table 1 to effectively control pests.

How ever, some time is needed for growers to complete the process and, as noted above, significant challenges remain

.

2 . Question from MBTOC

- Anaerobic soil disinfestation (ASD) works very well in Morocco. What types of experiences have the California stra wberry growers had with ASD?

U.S. Reply : We have had generally good results with ASD but have not seen it to be effective in controlling Fusarium wilt in two separate experiments. Below is a picture of the
field trials at M onterey B ay A cademy with ASD treatments. While initially the ASD treatment appeared to be effective, that effectiveness declined after two years. All treatmentsFilename: US reply to MBTOC on CA strawberry fruit Page 4

have plants collapsing with Fusarium wilt with year

- after

- year ASD treatments (personal
communication

, D. Legard)

.

Figu re 1. Damage from Fusarium in Anaerobic S oil D isinfestation trials at Monterey Bay Academy, California.

Photo courtesy D. Legard 2013 Figure 2. Additional da mage from Fusarium in Anaerobic S oil D isinfestation trials at Monterey Bay Academy, California (ASDRB9 = 9 tons rice bran/acre)

.

Photo courtesy D. Legard 2013Filename: US reply to MBTOC on CA strawberry fruit Page 5

The United States is encouraged by further research work the California Strawberry Commission is conducting on ASD as well as other non

- fumigant pest control methods. In

pa rticular, we would like to highlight the work of the “Nonfumigant Strawberry Production Working Group.” This group will continue its work to develop non

- fumigant alternatives

, and we are relying on this type of work to help us complete our transition by t he end of 201 6

.

3 . Question from MBTOC

- Is there any additional data on the efficacy of metam

- sodium for pathogen control in California?

U.S. Reply : Husein Ajwa (personal communication) reports that in experiments over 630
lbs/ac of Na

- methyldithiocarbamate were needed to control Macrophomina phaseolina

. This is equivalent to 150 gal/ac of metam sodium (1 gal of metam

- Na contains 4.22 lbs a.i). These results are from laboratory dose

- response experiments using infested plant materials pl aced in 250 g soil in closed jars over 24 hours at 22 o C. The actual LC90 was over 4300 umol a.i/kg soil. These rates are substantially higher than those permitted in California.

The paper published by Aida Zveibil (Israel) showed results from studies c onducted at 50

o C under solarization

, which is much hotter than the 22 o C that is representative of

C alifornia strawberry growing conditions. The work from Israel relies heavily on soil bioassays . There is no method that can determine Macrophomina in soil due to
interferences

. Husein’s lab spent 1 year trying to replicate the Israeli results but could not get the isolation method to work under local conditions

.

4 . Question from MBTOC

- Is Pic

- Clor 80 registered in the United States or California ?

U.S. Reply : Pic

- Clor 80 i s not registered in the United States or California and was not considered in calculating the Telone (1,3

- dichloropropene) township caps.

5 . Question from MBTOC

- Does the United States have additional data on Telone (1,3

- dich loropropene) in terms of efficacy with shank applications, or changes in the regulations?

U.S. Reply : There is n o additional information on Telone performance or regulations at
this time

.

6 . Question from MBTOC

- I f the Cal ifornia D epartment of P esticide R egulation reregistration proposal for chloropicrin has elements that are less restrictive than the US EPA Federal label what would happen?Filename: US reply to MBTOC on CA strawberry fruit Page 6

U.S. Reply : In the United States, state and local pesticide regulators can place additional
restrictions on the use of a pesticide without additional approval from the EPA. However, to be less restrictive (e.g. smaller buffer distances than the EPA level) the EPA would have to be consulted and approve those changes.

7 . Question from MBTOC

- How would the a llocation rule be used to reduce the amount of methyl bromide produced during the year of the critical use nomination if the Cal DPR regulations become less restrictive in how chloropicrin can be used?

U.S. Reply : In each year’s allocation rulemaking, EPA considers new developments on the registration status and availability of alternatives that occur after the approval by Parties of a U.S. critical use exemption . For example, EPA made specific reductions in the am oun t of methyl bromide allocated in 2006, 2007, and 2008 to account for the registration of sulfuryl
fluoride. Were California to register d imethyl disulfide or finalize provisions that facilitate the use of chloropicrin, EPA would evaluate the potential uptake of that alternative on critical use crops and potentially make reductions to the allocation as a result.