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From: Patricia Dines, 73652,1202
To: Bob Elliott, INTERNET:belliott@cdpr.ca.gov
Cc: Larry Wilhoit INTERNET:lwilhoit@cdpr.ca.gov
Date: Tue, Dec 10, 1996, 5:41 PM
Subject: Re: Your email re: Reduced-risk pesticides
Hi -
I was a little puzzled by the following email from Larry Wilhoit to the SAN
list:
"One of the goals of the California Department of Pesticide Regulation is
to facilitate the adoption of reduced-risk pest management practices. To
help us reach this goal, we must first gather information on pesticides not
currently registered in California and evaluate their potential to reduce
risk and to fit within an integrated pest management (IPM) program. We
would like to hear from you if you are aware of any products that meet
these criteria. Let us
know why the product is a *good fit.* What critical need does it fill?"
My understanding of the original definition of IPM is that it first work to
understand and work with natural systems and only use any pesticide at all
as a last resort, if it's shown to be vital in some way. I'm aware that
the definition of IPM has been changed by some to mean other things - such
as a program that uses _any_ alternative approaches, no matter what their
approach to pesticide use or the quantity they use. It's even gotten to
the extreme where pesticide companies are putting out programs they call
IPM, where the first solution given is a pesticide - in complete opposition
to the original IPM theory/approach.
So my first response is this - Are you considering pesticides as the first
response of an IPM system, just less-toxic ones? If so, I'd suggest you
reconsider that approach by studying the original definitions of IPM, which
focus first on working with nature by understanding its dynamics, not by
introducing any kind of chemical input.
I am hopeful that your query is part of an overall plan, which starts first
by exploring existing knowledge and gathering more understanding about how
natural systems maintain equilibrium so that no particular species becomes
a problem in the first place. Hopefully you are aware that often human
pesticides/inputs makes problems worse, not better, by disrupting the
natural processes - reflected in the fact that a large percentage of the
top ag pests in this country were not pests until we started using
pesticides and killed off naturally-balanced systems (predators, etc.).
I would be so delighted if you all, in your work on this issue, were
heeding the lesson, for instance, of Indonesia in the 1980s, where they had
a wide scale program to introduce pesticides and increase rice production -
and instead had catastrophic losses costing billions of dollars - because
the pesticide(s) used killed a natural predator of another pest, whose
population skyrocketed. They got their production back up by removing
nearly all pesticide registrations and investing instead in a program to
empower farmers to wisely use alternative nontoxic techniques and
methodologies. To me, the essence of any such training would be to support
farmers and other users in seeing and understanding natural processes and
knowing nontoxic ways to work with and support the functioning of these
processes (vs. overriding them in our mistaken belief that we are competent
to take them over).
So first I respond to encourage/support California DPR in acting to reduce
our toxic load by first not thinking of pesticides at all, but to think in
terms of how we can work with natural processes, learn better how to, and
educate users how to. I'm concerned that pesticide companies' sales
objectives too often establish amd define our ways of approaching our goals
and issues with nature, and hope that you can see past that in your
efforts.
Second, given that as a context, I'd like to encourage you to first look at
allowing legal use of materials that are "generally recognized as safe" and
developing a procedure for their legal use "as pesticides" - and not
require that they be in a product to be used. Could a common material such
as baking soda be used for certain pest problems on roses? So our local
Parks and Rec has said - but they can't legally use it, they say, because
it's not registered as a pesticide!
Wouldn't it be wonderful if there could be a procedure that allowed it to
legally be used if basic safety criteria are met. And if we could use it
not just because it's included in a labelled pesticide product, but just
off the shelf as a consumer-purchased basic material. Being able to buy it
as a material and not just as a product has a number of benefits. It's
quite likely much cheaper that way (to the consternation of the chemical
company but the benefit of budgets, both institutional (government,
schools, etc.) and personal). It's simpler and easy to get - we may
already have some around and we can just try a little and see. But, most
importantly perhaps, it's pure, without the so-called "inerts" that are in
so many pesticides products, hidden from our view and often quite toxic.
I know there are many such simple pretty much nontoxic or very low toxic
materials, for a variety of problems. For more information on the
specifics, I'd like to recommend that you contact an expert like Rodale
Press (who publishes Organic Gardening magazine and many organic farming,
etc. books) at 33 E. Minor Street, Emmaus PA 18098-0099, (215) 967-5171.
If your objective is to reduce our toxic exposure, I would consider it
vital and necessary to make such an inquiry to this organization, and
others that could likely assist with this (as well as them being able to
give you extensive info on pre-pesticide methods to use and educate others
on, as discussed above). I'd also recommend contacting: ATTRA, P.O. Box
3657, Fayetteville, ARK 72702 (501) 442-9824 (which has substantial
alternative info on commercial sustainable ag) and perhaps even AgAccess,
POB 2008, Davis CA 95616 (916) 756-7177.
Note - I'm aware that the federal EPA is working on a similar program for
allowing "generally recognized as safe" substances, but that this program
is more limited than the vision I describe (ex. still focussed on products
only, not just allowing people to use the substances; and missing some key
substances - like the above baking soda). And last I heard it wasn't clear
whether California EPA was going to set up a parallel program.
If your commitment is reducing our toxic exposure, including using less
toxic pesticides, I'd like to encourage you to implement such a program in
California, and allow it to be for not only products with these ingredients
but also just using these materials themselves. After the approach in my
first point above, I think this would be by far the quickest way to the
goal line, and the most fruitful use of your efforts - and thus the best
priority use of our government's time, energy, resources, and attention in
this matter.
Please let me know if you want to know more about these points above - I
would be delighted to assist, or give you referrals to others who could
assist, in making them a reality.
Patricia Dines
Resident of California