Gathering that information is exactly what the Western Integrated Pest Management Center does, although next to no one knows it.
“People know the Western IPM Center funds new IPM research and promotes the adoption of IPM practices in agricultural and urban settings,” said Center Director Jim Farrar. “Few people know we employee three comment coordinators throughout the West to respond to these kinds of requests for information from federal and state agencies.”
Each comment coordinator maintains an active network of growers, commodity organizations, Extension advisors, pesticide applicators and state IPM coordinators who can provide on-the-ground information about how a pesticide is used, applied and rotated.
“We archive all of the replies to information requests our comment coordinators have written on our website,” Farrar said. “There are more than 300 dating back to a 2002 comment on methyl parathion and going up to a May 29 comment on fenbutatin oxide.”
See them all under “Info Request Replies” at www.wripmc.org.
David Epstein, an entomologist at the USDA’s Office of Pest Management Policy, said the comments from the Western IPM Center and other regional centers become the growers’ voice in Washington, D.C.
“What we do here is represent growers at the federal level where policy and regulation collide,” he said. “We need data to be able to argue for them. If we don’t have data, then the agency charged with regulating a product may assume far greater usage and use patterns than actually exists in the field.”
Knowing how and where a product is used – and that there are regional differences in how the same crop may be grown in different parts of the country – can help the regulatory agency get a more accurate picture of the actual risk a specific product poses.
“Understanding the differences between the label allowances and actual use can help identify potential ways of mitigating risk as a chemical undergoes review,” Epstein said. “If a product is labeled for aerial application in a crop but the product is only ever applied with ground rigs, for example, that can have a significant impact on the risk evaluation because of the reduced drift potential.”
With that kind of specific information, Epstein and his colleagues at of the Office of Pest Management Policy can argue against new restrictions on the product, or go to the company that registered it and suggest they update the label by removing crops or application methods that aren’t being used. Some companies do, he said, and some don’t.
“The information we get from the regional centers helps educate the process, and without information on how the chemical is actually used and applied, we don’t have much to argue with,” Epstein said.
Continuing to provide that information is a priority for the Western IPM Center.
“Like most federally funded operations, we’ve had to cut our budget,” Farrar said. “In making those cuts, we protected the comment coordination roles because it is so important to agriculture in the West.”
To provide even better information to Washington, Farrar would like to recruit more growers and commodity organizations in the comment network, where they would occasionally be contacted by the Center’s comment coordinators.
“By becoming a resource for the Center, you help all growers,” Farrar said. “It’s likely you’ll only be contacted once or twice a year, and your small investment of time can have a big impact on pest management regulations.”
If you are interested in joining the comment coordination network, email Jim Farrar at firstname.lastname@example.org with your name, location and a brief description of your crop or pest experience.
The Western Integrated Pest Management Center promotes IPM practices to solve pest problems in agriculture, urban areas and natural lands throughout the West. We encourage a science-based approach to pest management using pest biology, environmental information and all available technology to reduce pest damage to acceptable levels by the most economical means, while reducing the risk to people, property and the environment. The Western Integrated Pest Management Center is one of four regional centers funded by the USDA's National Institute of Food and Agriculture to promote IPM practices, and serves 13 Western states and Pacific island territories.