United States

Department of

Agriculture

Marketing and

Regulatory 

Programs

Animal and 

Plant Health 

Inspection 

Service 

Citrus Greening Control

Program in Florida

Nurseries 

Environmental Assessment,

January 2006
Citrus Greening Control

Program in Florida Nurseries 

Environmental Assessment,

January 2006

Agency Contact:

Joel Floyd

Team Leader, Planning and Preparedness 

Pest Detection and Management Programs

Plant Protection and Quarantine

Animal and Plant Health Inspection Service

U.S. Department of Agriculture

4700 River Road, Unit 137

Riverdale, MD 20737

Telephone: 301–734–5356

The U.S. Department of Agriculture (USDA) prohibits discrimination in all 

its programs and activities on the basis of race, color, national origin, sex, 

religion, age, disability, political beliefs, sexual orientation, or marital or family

status. (Not all prohibited bases apply to all programs.) Persons with 

disabilities who require alternative means for communication of program 

information (Braille, large print, audiotape, etc.) should contact the USDA’s 

TARGET Center at 202–720–2600 (voice and TDD).

To file a complaint of discrimination, write USDA, Director of Civil Rights,

Room 326–W, Whitten Building, 14th and Independence Avenue, SW.,

Washington, DC 20250–9410 or call 202–720–5964 (voice and TDD). 

USDA is an equal opportunity provider and employer.

Mention of companies or commercial products in this report does not imply 

recommendation or endorsement by the U.S. Department of Agriculture 

over others not mentioned. USDA neither guarantees nor warrants the 

standard of any product mentioned. Product names are mentioned solely 

to report factually on available data and to provide specific information.

This publication reports research involving pesticides. All uses of pesticides 

must be registered by appropriate State and/or Federal agencies before they 

can be recommended.

CAUTION: Pesticides can be injurious to humans, domestic animals, 

desirable plants, and fish or other wildlife—if they are not handled or applied 

properly. Use all pesticides selectively and carefully. Follow recommended 

practices for the disposal of surplus pesticides and pesticide containers.
Table of Contents

I. Need for Proposal ......................................... 1

A. Introduction ............................................ 1

B. Purpose and Need for Action .............................. 3

II. Alternatives .............................................. 4

A. No Action . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4

B. Proposed Action ........................................ 4

III. Environmental Consequences ............................... 5

A. No Action . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6

B. Proposed Action ........................................ 6

IV. Agencies, Organizations, and Individuals Consulted . . . . . . . . . . . 15
1

I. Need for Proposal

A. Introduction 

Citrus greening is considered to be one of the most serious citrus diseases

in the world. It is a bacterial disease of citrus that greatly reduces

production, destroys the economic value of the fruit and can kill trees.

Citrus greening is a disease vectored by two species of citrus psyllid

(Diaphorina citri Kuwayama and Trioza erytreae (del Guercio). Asian

citrus psyllids cause economic damage to citrus in groves and nurseries

by direct feeding and, potentially, by transmitting a serious bacterial

disease. Both adults and nymphs feed on young foliage, depleting the

sap and causing galling or curling of leaves. High populations feeding on

a citrus shoot can kill the growing tip. More importantly, this psyllid is

able to transmit an endocellular, phloem-restricted bacterium,

Liberobacter asiaticum, that causes the greening disease. The bacteria

are phloem-limited and cause yellow shoots, blotchy mottling and

chlorosis, reduced foliage, and tip dieback of citrus plants.

Citrus greening, or huanglongbing, is a bacterial disease that attacks the

vascular system of plants. Once infected there is no cure for a tree with

citrus greening disease. In areas of the world where citrus greening is

endemic, citrus trees decline and die within a few years and may never

produce usable fruit. It is widespread in Asia, Africa, and the Saudi

Arabian Peninsula. It has been reported in Sao Paulo, Brazil, and

confirmed in August, 2005, in south Miami-Dade County in Florida. 

Survey work is ongoing to determine its distribution within the State. 

How it actually got to Florida still remains unknown. 

The U.S. Department of Agriculture (USDA), Animal and Plant Health

Inspection Service (APHIS), in cooperation with the Florida Department

of Agriculture and Consumer Services (FDACS) is proposing to

implement a designed localized program to quarantine, survey, detect, 

and apply pesticide treatments for the control of the citrus greening

disease and its vectors, found in Florida commercial nurseries. The

proposed program combines a number of control methods with regulatory

quarantines to control this disease and its vectors. This final

environmental assessment (EA) analyzes the environmental impacts of

the proposed program and its alternatives.

Under APHIS' National Environmental Policy Act (NEPA) Implementing

Procedures, 7 Code of Federal Regulations (CFR) Part 372, the proposed

action is a class of action for which an EA is normally prepared. This

final EA considers the potential effects of the proposed action and its

alternatives, including no action. 
2

In September 2005, APHIS prepared an EA to analyze and evaluate any

potential environmental effects resulting from this proposed control

program. The availability of the September 2005 EA was announced in

both The Miami Herald and The Fort Lauderdale Sun Sentinel on

September 30, 2005. The public was requested to send in comments on

the September 2005 EA by October 28, 2005. The September 30 public

newspaper notices likewise informed the public that an immediate control

program response to the serious citrus greening disease might be urgently

needed and, thus, the control program might have to begin immediately. 

Thereafter, on October 5, 2005, APHIS issued a notice of availability of a

Finding of No Significant Impact (FONSI) for the EA concerning the

Citrus Greening Control Program in Florida nurseries and extension on

the comment period. The notice of availability of the FONSI was placed

in newspapers in Miami, Fort Lauderdale, West Palm Beach, Orlando,

and Tampa, both in English and Spanish.

In that October 5, 2005, notice of availability of the FONSI, APHIS

informed the public that it had prepared the September 2005 EA for a

proposed control program to survey, detect, quarantine, remove trees, and

apply pesticide treatments for the control of citrus greening disease in

Florida nurseries in the following counties: Brevard, Broward, Charlotte,

Citrus, Collier, DeSoto, Glades, Hardee, Hendry, Hernando, Highlands,

Hillsborough, Indian River, Lake, Lee, Manatee, Marion, Martin, MiamiDade, Monroe, Okeechobee, Orange, Osceola, Palm Beach, Pasco,

Pineallas, Polk, Putnam, Sarasota, Seminole, St. Lucie, and Volusia.

APHIS also informed the public in the notice of availability of the

FONSI, that, at the time, the citrus greening disease has only been

detected in Miami-Dade and Broward Counties but has the real potential

to rapidly spread to other Florida counties if not immediately contained. 

APHIS informed the public that it had determined that the treatment

control response to the serious citrus greening disease infestation was

urgent and that it was necessary to begin the treatment control program

operations immediately in Dade and Broward Counties in order to

hopefully immediately contain the infestation before it spread further. 

Accordingly, APHIS explained it needed to immediately proceed with

the control program and, thereby, issued the FONSI for the September

2005 EA.

In that October 5, 2005, notice of availability of the FONSI, APHIS

likewise informed the public that it was extending the public comment

period for the September EA from October 28 until November 10, 2005. 

There were only two requests for copies of the September 2005 EA. As

of January 6, 2006, APHIS has not received any public comments at all

on the September 2005 EA.
3

B. Purpose and Need

This final EA has been prepared in compliance with the National

Environmental Policy Act of 1969 (42 U.S.C. 4321–4327 (NEPA)) and

its implementing regulations. In this final EA, APHIS analyses the

proposed action, namely, in response to this infestation of citrus greening

disease in Florida, a localized control program in which there are

established quarantine boundaries wherein there is limited movement of

host material, tree removal, and chemical treatments.

The proposed control action includes all ornamental citrus psyllid host

plant material, in addition to all citrus which is quarantined and

prohibited from movement out of those infested counties, in Florida. The

infested counties in Florida will be regulated to prevent the spread of

citrus greening with several mitigating requirements. One such

requirement is a compliance agreement which has been developed in

conjunction with FDACS and APHIS that will include recommended

controls and treatments for the citrus psyllid. These treatments will allow

for commercial citrus psyllid host plant material (other than citrus) from

regulated counties to be shipped within the State of Florida and to noncitrus producing States. For all other counties (those not infested), the

interstate shipping (shipments outside the State of Florida) of all citrus

psyllid host plants (including citrus) is permitted except to citrus

producing States or U.S. Territories (American Samoa, Arizona,

California, Guam, Hawaii, Northern Marianas Islands, Louisiana, Texas, 

Puerto Rico, and the Virgin Islands). If citrus greening is detected in

additional counties, the regulations that are established for the presently

infected counties will be applied. 

APHIS is the Federal agency with the authority and responsibility for

taking actions to exclude, prevent, eradicate, and/or control plant pests,

including the citrus greening disease, under the Plant Protection Act (7

U.S.C. 7701 et seq.). APHIS has been delegated the authority to

administer this statute and has promulgated Quarantines and Regulations

(7 CFR 319) which regulate the importation of commodities and means

of conveyance to help protect against the introduction and spread of

harmful plant pests. APHIS and the FDACS have imposed regulations

governing the movement of certain material from infested counties in

Florida. These regulations and control measures, as part of the proposed

localized control action, apply only to commercial nurseries at this time

because it is the area that presents the most risk for spreading the disease

and its vectors to other parts of the country. If control efforts are needed

in groves and residential neighborhoods, further environmental analysis

will be done on a proposed control action that would include those

locations.
4

Not much is known at this time regarding the most definitively effective

efforts to control the citrus greening disease although we do know the

basic control methods that need to be immediately employed. To help

effectively control the disease and the threat it poses to North America’s

citrus industry, aggressive and comprehensive research projects are

underway to learn more about this pest’s biology and develop appropriate

management, control, and eradication options. 

II. Alternatives

APHIS carefully considered the two appropriate alternatives in response

to the need for better methods to immediately address and quickly

respond in order to locally control and contain citrus greening disease in

commercial nurseries in Florida: (1) no action, and (2) proposed action. 

Each alternative is described briefly in this section and the potential

impacts of each are considered in the following section.

A. No Action 

Under the no action alternative, APHIS would not implement any

quarantine or control measures to eradicate or even attempt to locally

contain the spread of citrus greening disease. Some control measures,

albeit limited ones without APHIS’ involvement, could be taken by other

Federal or non-Federal entities; those actions would not be under APHIS’

authorities, expertise, control, or funding. Absent APHIS’ assistance and

expertise along with the absence of more effective measures to contain

and control the spread of citrus greening disease, new areas of

infestations would be expected to continue and become more widespread. 

Local business owners and area residents could attempt to control

damages from citrus greening disease by removing the infested trees from

their properties. The lack of effective control measures to prevent the

spread of citrus greening disease from sites of infestation to other areas

and counties could lead to higher production costs and an increase in

shortages of availability of citrus fruits and plants to the general

economy. This would result in potentially significant additional costs for

survey, detection, and treatment for the control of citrus greening disease

as it spreads to other areas and counties. 

B. Proposed Action

Under this proposed action (preferred alternative), APHIS would work

cooperatively with the FDACS to locally quarantine the infected/infested

area and to implement program control measures to contain citrus

greening disease and prevent its dissemination from nurseries in Florida. 

Under the proposed alternative, surveys will be conducted throughout 
5

Florida to determine if the disease exists in a particular area and to

delimit the infestation. Inspectors who perform these surveys and take

regulatory action will adhere to strict guidelines to ensure that disease

spread to other areas does not occur. 

The proposed program control measures include that commercial

nurseries must treat all regulated articles for the control of psyllids with

an EPA-approved product labeled for use in commercial and ornamental

nurseries before moving outside the quarantine. In addition, all plants

which have been treated in accordance with the required control program

compliance agreement (which the commercial plant nursery must follow)

with requirements, include the following: (1) must be inspected and

found free of the Asian citrus psyllid within 72 hours of shipping, 

(2) each shipment will be certified by an authorized representative of the

FDACS, (3) shipments will not be authorized for distribution to the

following citrus-producing States or U.S. territories: American Samoa,

Arizona, California, Guam, Hawaii, Northern Marianas Islands,

Louisiana, Texas, Puerto Rico, and the Virgin Islands, (4) all regulated

articles must be treated with a soil drench or foliar spray from an

approved list of pesticides, and (5) any article moved out of the State

must be accompanied by a PPQ Form 530 “Limited Permit.” 

Once a detection of citrus greening is confirmed, a quarantine “hold” will

be placed on the property to prevent the removal of any greening host

plants, budwood, or psyllid vector hosts. The commercial plant nursery

will be required to apply a pesticide treatment as soon as possible after

confirmation. These treatments are limited exclusively to commercial

establishments and, therefore, exposure to the general public is

precluded. Six different pesticide formulations have been proposed to

control citrus greening: acetamiprid, chlorpyrifos, fenpropathrin,

imidacloprid, kaolin, and a cyfluthrin/imidacloprid formulation. These

pesticides will be applied foliarly through the use of backpack applicators

(by employees or agents of the commercial plant nursery), other ground

equipment, or through soil drench by watering or dipping. The potential

environmental effects are summarized for each of the pesticides below.

III. Environmental Consequences

There are potential impacts from each of the alternatives being

considered. The significant pest risk from citrus greening disease is an

important consideration for evaluating both alternatives. Potential

program impacts arise from each of the chemical treatments; however,

most of the treatment impacts are not expected to be substantial, as

described below in subsequent sections. The only potential affected areas

to be treated pursuant to the proposed control program are within the

Florida commercial and ornamental nurseries at this time. 
6

The analysis of potential environmental consequences possibly resulting

from this proposed control program will be considered within the

alternatives of no action and the preferred alternative. Under the no

action alternative, APHIS will not be involved and plants will not be

quarantined and infected plants may be imported to non-infected areas of

Florida and the United States. The proposed alternative includes APHIS’

involvement and uses insecticides to treat citrus greening. As will be

analyzed and described below, each of these alternatives has the potential

for adverse environmental consequences. 

A. No Action

Citrus greening disease is a serious bacterial disease which greatly

reduces production, destroys the economic value of the fruit, and can kill

trees. It is vectored by psyllids. The Asian form of psyllid, Diaphorina

citri, has been found throughout the citrus growing areas of Florida,

although citrus greening bacterium (Candidatus Liberibacter africanus),

has only been detected in parts of Florida. Under the no action

alternative, APHIS will not be involved in any actual control or interstate

plant quarantine measures and, thus, plants that contain citrus greening

may be sent to other parts of Florida and even shipped or moved

interstate to other States within the United States allowing for the spread

of citrus greening to these areas. If established in other counties

throughout Florida and/or other States, significant pesticide use by

individuals and organizations would be required to try to control the

spread of citrus greening and such significant pesticide usage may cause

substantial environmental impacts which would significantly exceed

those limited environmental impacts of the proposed alternative.

B. Proposed Action

APHIS will be involved in the actual proposed control program measures

described above which include regulations and required compliance

agreement restrictions and conditions. The required aspects of the

proposed control program, which includes routine surveys, quarantines,

and inspections of commercial nurseries, are program activities that pose

very negligible environmental effects that need not be described in detail. 

Such “routine” control measures are specifically designated as

“categorically excluded” activities and actions pursuant to APHIS’

NEPA implementing regulations (7 CFR § 372.5(c)(1)). The primary

program control action in this proposed control program that could be

associated with any potentially noteworthy environmental impacts is the

use of chemical control measures which are discussed further in this

section. 
7

1. Chemical 

Control

a. Acetamiprid

Human Health

Acetamiprid is a systemic, chloro-nicotinyl insecticide chemically related

to the tobacco toxin nicotine. The mode of toxic action is unique and

works by interfering with the transmission of stimuli in the insect’s

nervous system. Specifically, it causes a blockage in a type of neuronal

pathway (nicotinergic) that is more abundant in insects than in warmblooded animals. Because of their molecular shape, size, and charge,

nicotine and nicotinoids fit into receptor molecules in the nervous system

that normally receive the molecule acetylcholine. This molecule carries

nerve impulses from one nerve cell to another or from a nerve cell to the

tissue that a nerve controls. Acetamiprid overstimulates the nerve,

ultimately resulting in the insect’s paralysis and eventual death. Since

this nicotinergic site of action is more prevalent in insects than in higher

organisms, the pesticide is selectively more toxic to insects. Signs and

symptoms in humans include fatigue, twitching, cramps, and muscle

weakness, including the muscles for breathing. Acetamiprid is classified

as an “unlikely” human carcinogen by EPA. 

The application of this pesticide is limited to treatments of nursery stock. 

None of the routine or extreme exposure scenarios pose unacceptable

risks to workers or applicators. Moreover, required protective gear and

safety precautions further ensure that no adverse effects to program

workers can be expected.

Non-target Organisms

The program use of acetamiprid for treatment of nursery stock is unlikely

to impact most non-target wildlife. Acetamiprid is moderately toxic to

birds and mammals. However, the area affected by the pesticide will be

limited to nurseries and should only affect a limited number of birds, if

any at all. Although it is nontoxic to fish, it is slightly to highly toxic to

certain aquatic invertebrates. Adherence to label and program

application restrictions should preclude any drift or runoff to water. 

Some terrestrial invertebrates (particularly some insects) will have a high

mortality rate, but is unlikely to exceed that of other pesticides currently

in use in nurseries. Acetamiprid is only moderately toxic to bees. 

Acetamiprid does not pose any risks of bioaccumulation in fish or

organic sediments.
8

Environmental Quality

Any effects of acetamiprid to the quality of the air, soil, and water will be

of no consequence and of limited time duration. Acetamiprid is highly

soluble in water and will dissipate quickly. It is absorbed by soil

particles, but is readily degraded by aerobic soil metabolism. The low

application rate and rapid degradation preclude any potential for soil

mobility. Acetamiprid is readily taken up by plants and translocated, but

the program treatments are not expected to result in any bioaccumulation

hazards due to rapid degradation.

b. Chlorpyrifos

Human Health

Chlorpyrifos is an organophosphate insecticide that can cause neurotoxic

effects. The toxicity of chlorpyrifos occurs primarily through the

inhibition of acetylcholinesterase enzyme activity which permits the

transmission of nerve impulses across the nerve synapse. Signs and

symptoms of low doses include localized effects (such as nosebleeds,

blurred vision, and bronchial constriction) and systemic effects (such as

nausea, sweating, dizziness, and muscular weakness). At higher doses

the signs and symptoms include irregular heartbeat, elevated blood

pressure, cramps, and convulsions. Chlorpyrifos is not considered

carcinogenic based upon studies acceptable to EPA. 

The application of this pesticide is limited to treatment of nursery stock,

therefore, the only individuals that may be affected by the use of this

insecticide are the nursery workers and the occupational workers who

apply the pesticide. Several chlorpyrifos scenarios (such as backpack

applicators, hydraulic rig applicators, and ground personnel) do exceed

the maximum acceptable exposure that poses no evident risk to human

health (Regulatory Reference Value or RRV) when proper safety

precautions are not taken and protective gear is not worn. However, this

elevated risk is not life-threatening. Protective gear and safety

precautions required by label adherence and standard program operating

procedures are designed to ensure that no adverse effects to program

workers can be expected.

Non-target Organisms

The program use of chlorpyrifos for treatment of nursery stock is unlikely

to impact most non-target wildlife. Chlorpyrifos has a moderate toxicity

to mammals when consumed. It can be moderately toxic to birds, and

severely toxic to some individual bird species. However, mammals and 
9

birds will generally not be in the affected area at the time of spraying.

Symptoms of non-fatal exposure to birds include cholinesterase

depression (ChE), weight loss, reduced egg production, and reduced

hatchling survival. It is severely toxic to terrestrial invertebrates such as

earthworms and worker honeybees; however, this effect is not uncommon

to other pesticides which are currently being used in nurseries. 

Chlorpyrifos can be severely toxic to fish and aquatic invertebrates. 

However, the label forbids direct application to water. Residues from

drift or runoff are not anticipated to pose substantial risks to these

species. 

Environmental Quality

Any effects of chlorpyrifos to the quality of the air, soil, and water will

be of no consequence and of limited time duration. Chlorpyrifos can

persist in soil and water for several months under certain conditions,

however, the persistence is generally only for a month or less. This is

dependent on the organic content of the soil. Nevertheless, it can remain

in silt which can runoff or drift to surface waters. Potential

bioaccumulation in aquatic organisms could be of concern if applications

have much drift to water bodies. Residues may persist on treated

vegetation, but are not anticipated to pose bioaccumulation hazards.

c. Fenpropathrin

Human Health

Fenpropathrin is a synthetic pyrethroid insecticide which affects the

nervous system. It is a moderate skin irritant and eye irritant. Signs and

symptoms can include muscle contractions, tremors, ataxia, and nerve

paralysis at moderate to high levels of exposure. Fenpropathrin is not

considered carcinogenic by EPA.

The application of this pesticide is limited to nursery stock. Potential

pesticide exposures are limited to nursery workers and the occupational

workers who apply the pesticide. Backpack spray application and

hydraulic rig applications for the extreme exposure scenario are the only

scenarios that exceed the RRV. The extreme exposure scenario presumes

that the worker will be exposed to higher quantities of the pesticide when

that individual is not following safety protocols or wearing protective

gear. Protective gear and safety precautions required by label adherence

and standard program operating procedures are designed to ensure that no

adverse effects to program workers can be expected.
10

Non-target Organisms

The program use of fenpropathrin for treatment of nursery stock is

unlikely to impact most non-target wildlife. The toxicity of fenpropathrin

is moderate to mammals and has a slight oral toxicity to birds and

terrestrial stages of reptiles and amphibians. There is a high risk for

exposed shrews and bats; however, given the limited use in this program,

shrews and bats are unlikely to be located in the affected area. It is

highly toxic to most aquatic organisms. Nevertheless, aquatic organisms

will most likely not be affected because the limited area of application

within the nursery should not pose any risk of drift or runoff to waters

which contain aquatic organisms. Terrestrial invertebrates will have a

high mortality rate, but this is unlikely to exceed that of other pesticides

currently in use in the nurseries. 

Environmental Quality

Any effects of fenpropathrin to the quality of the air, soil, and water will

be of no consequence and of limited time duration. Fenpropathrin has

low water solubility but can be persistent in water for up to 245 days. It

adheres to soil particles easily and generally is not persistent for more

than 2 weeks. Residues on treated vegetation are also of short

persistence. 

d. Imidacloprid

Human Health

Imidacloprid is a systemic, chloro-nicotinyl insecticide chemically

related to the tobacco toxin nicotine. The mode of toxic action is unique

and works by interfering with the transmission of stimuli in the insect’s

nervous system. Specifically, it causes a blockage in a type of neuronal

pathway (nicotinergic) that is more abundant in insects than in warmblooded animals. Because of their molecular shape, size, and charge,

nicotine and nicotinoids fit into receptor molecules in the nervous system

that normally receive the molecule acetylcholine. This molecule carries

nerve impulses from one nerve cell to another or from a nerve cell to the

tissue that a nerve controls. Imidacloprid overstimulates the nerve,

ultimately resulting in the insect’s paralysis and eventual death. Since

this nicotinergic site of action is more prevalent in insects than in higher

organisms, the pesticide is selectively more toxic to insects. Signs and

symptoms in humans include fatigue, twitching, cramps, and muscle

weakness, including the muscles for breathing. Imidacloprid is not

considered carcinogenic by EPA. The application of this pesticide is

limited to treatments of nursery stock. Imidacloprid is the least toxic of

the systemic program pesticides. None of the routine or extreme 
11

exposure scenarios pose unacceptable risks to workers or applicators. 

Moreover, required protective gear and safety precautions further ensure

that no adverse effects to program workers can be expected.

Non-target Organisms

The program use of imidacloprid for treatment of nursery stock is

unlikely to impact most nontarget wildlife. Imidacloprid is moderately to

severely toxic to birds including, but not limited to, American robin,

northern mockingbird, European starling, red-winged blackbird, and

house sparrow. However, the area affected by the pesticide will be

limited to nurseries and should only affect a limited number of birds, if

any at all. Although it is nontoxic to fish, it is highly toxic to aquatic

insects. Adherence to label and program application restrictions should

preclude any drift or runoff to water. Terrestrial invertebrates will have a

high mortality rate, but is unlikely to exceed that of other pesticides

currently in use in nurseries. 

Environmental Quality

Any effects of imidacloprid to the quality of the air, soil, and water will

be of no consequence and of limited time duration. Imidacloprid is

moderately soluble in water and will dissipate quickly. It is absorbed by

soil particles and has low mobility. Imidacloprid is readily taken up by

plants and translocated, but the program treatments are not expected to

result in any bioaccumulation hazards.

e. Kaolin

Human Health

Kaolin is a colloidal suspension in water that is applied as a wettable

powder to coat and protect leaf surfaces from insect damage. It is a mild

to moderate skin and eye irritant. Prolonged or repeated exposure to

lungs may cause pulmonary disorders and aggravate allergies. There are

no known carcinogenic effects associated with the use of this pesticide as

determined by EPA. The application of this pesticide is limited to

commercial and ornamental nursery stock. Other than limited dermal and

respiratory irritation, there are few hazards to workers exposed to kaolin. 

Moreover, required protective gear and safety precautions are designed to

ensure that no adverse effects to program workers can be expected.

Non-target Organisms

The toxicity of kaolin is low in mammals, birds, reptiles, and amphibians. 

There is a small concern that some developmental life stages of birds, 
12

such as the egg, are at risk from exposure; however, this is unlikely since

birds nests aren't generally found in nurseries. It is highly toxic to most

life stages of terrestrial invertebrates but risks are comparable to other

pesticides routinely used in nurseries. Fish and aquatic invertebrates

were not examined because the application of this insecticide is applied

directly to the plant and there is very little likelihood of kaolin transport

to water bodies. 

Environmental Quality

Any effects of kaolin to the quality of the air, soil, and water will be of no

consequence. Kaolin is a mineral oil that is expected to persist on treated

surface until removed by weathering or leaf fall. The label restricts

application to locations other than water or where surface water is

present. Any kaolin that drifts onto soil will adhere to the soil particles

and degrade with weathering.

f. Cyfluthrin/Imidacloprid Mixture

Human Health

Cyfluthrin is a synthetic pyrethroid insecticide which affects the nervous

system in a manner similar to fenpropathrin. Imidacloprid is a systemic,

chloro-nicotinyl insecticide whose mode of toxic action and toxicity have

already been described. Cyfluthrin is not considered to be an eye irritant

or skin sensitizer. Signs and symptoms can include muscle contractions,

tremors, ataxia, and nerve paralysis at moderate to high levels of

exposure. Cyfluthrin is not considered to be carcinogenic, mutagenic or

teratogenic by EPA. The difference in mechanism of toxic action ensures

that this mixture does not pose increased toxicity through synergistic

action. Although synergistic effects on toxicity are possible with

simultaneous exposure to organophosphates (such as chlorpyrifos) and

cyfluthrin, this type of exposure is unlikely with the safety precautions

required of this program. The application of this pesticide is limited to

treatments of nursery stock. None of the routine or extreme exposure

scenarios from this mixture pose unacceptable risks to workers or

applicators. Moreover, required protective gear and safety precautions

further ensure that no adverse effects to program workers can be

expected.

Non-target Organisms

The program use of this mixture for treatment of nursery stock is unlikely

to impact most non-target wildlife. Although imidacloprid is moderately

to severely toxic to some songbirds and cyfluthrin poses some risks to 
13

small mammals, the applications to nursery stock are not expected to

pose high risks because of the limited exposure potential. Although the

mixture poses toxicity to fish and most aquatic organisms, adherence to

label and program application restrictions should preclude any drift or

runoff to water. Terrestrial invertebrates will have a high mortality rate,

but is unlikely to exceed that of other pesticides currently in use in

nurseries. 

Environmental Quality

Any effects of this formulation to the quality of the air, soil, and water

will be of no consequence and of limited time duration. Although

cyfluthrin is of low water solubility and adsorbs readily to organic matter,

it is not as persistent as chlorpyrifos in soil. Imidacloprid is moderately

soluble in water and dissipates quickly. It is also absorbed by soil

particles and has low mobility. Both compounds are readily taken up by

plants and translocated, but the program treatments are not expected to

result in any bioaccumulation hazards. 

2. Other Issues

Evaluated

a. Threatened and Endangered Species

APHIS examined and determined what, if any, of the proposed control

measures that would be required to be used or employed in reference to

their compliance with the Endangered Species Act (ESA) of 1973. 

Section 7 of the ESA and its implementing regulations require Federal

agencies to insure that their actions are not likely to jeopardize the

continued existence of endangered or threatened species or result in the

destruction or adverse modification of critical habitat. APHIS has

considered the aspects, including quarantine, survey, and insecticide

treatments in commercial nurseries. 

APHIS has prepared a biological assessment to determine if the proposed

control program could have the potential to likely jeopardize the

continued existence of endangered or threatened species or result in the

destruction or adverse modification of their critical habitat in 32 Florida

counties. Based upon the findings of that analysis, APHIS has

determined that the proposed program for control of citrus greening in

Florida will have no effect on federally-listed threatened and endangered

species and will not adversely modify designated critical habitat.

b. Minority Populations and Low-income Populations

Consistent with Executive Order (E.O.) 12898, “Federal Actions to

Address Environmental Justice in Minority Populations and Low-income

Populations,” APHIS considered the potential for the proposed control

measures to have any disproportionately high and adverse human health 
14

or environmental effects on any minority populations and low-income

populations. APHIS has determined that the environmental and human

health effects from the proposed applications are minimal and are not

expected to have disproportionate adverse effects to any minority or lowincome populations because it is only being applied inside commercial

and ornamental nurseries and, therefore, there is very little to no potential

for any effects from the control measures done inside the commercial

nurseries to have any effects that could affect minority or low-income

populations. 

c. Protection of Children

Consistent with E.O. 13045, “Protection of Children From Environmental

Health Risks and Safety Risks,” APHIS considered the potential for

disproportionately high and adverse environmental health and safety risks

to children resulting from the proposed control measures. The proposed

program applications to control citrus greening are only made within

commercial and ornamental nurseries, therefore, no exposure to children

is expected to occur. It will be the responsibility and obligation of the

program pesticide applicators (either employees of the commercial plant

nursery or hired by the commercial plant nursery to do the pesticide

applications) to ensure that the general public is not in or around areas

being treated, therefore, no exposure will occur during the application

process. The only possible exposure would be to the applicator and

nursery workers when not following the prescribed label use and safety

directions. Therefore, it was determined that no disproportionate effects

to children are anticipated as a consequence of implementing the

preferred alternative. 
15

IV. Agencies, Organizations, and

Individuals Consulted

This final EA was prepared and reviewed by APHIS. The addresses of

participating APHIS units, cooperators, and consultants (as applicable)

follow.

U.S. Department of Agriculture

Animal and Plant Health Inspection Service

Plant Protection and Quarantine

Pest Detection and Management Programs

4700 River Road, Unit 134

Riverdale, MD 20737–1236

U.S. Department of Agriculture

Animal and Plant Health Inspection Service

Plant Protection and Quarantine

Environmental Monitoring Team

4700 River Road, Unit 150

Riverdale, MD 20737

U.S. Department of Agriculture

Animal and Plant Health Inspection Service

Policy and Program Development 

Environmental Services

4700 River Road, Unit 149

Riverdale, MD 20737–1238

Florida Department of Agriculture and Consumer Services

Division of Plant Industry

website at: http://www.doacs.fl.us/pi/enpp/ent/citrusgreening.html .

U.S. Environmental Protection Agency, Office of Pesticide Programs,

1995. Imidacloprid; pesticide tolerances. Federal Register (July 5) 60

(128): 34943–34945. 

U.S. EPA, OPP—See U.S. Environmental Protection Agency, Office of

Pesticide Programs.