Attention tree fruit growers that used Kasumin, Scorpion or Venom during 2014 season
If you used kasugamycin (Kasumin 2L) or dinotefuran (Scorpion, Venom) under the Section 18 emergency exemption label, please report use through a survey that will help secure future emergency exemptions and move these products toward full EPA registration.
In Michigan, the Michigan Department of Agriculture and Rural Development (MDARD) is the state agency authorized to submit Section 18 emergency exemption requests to the U.S. Environmental Protection Agency (EPA). The term Section 18 refers to the section of the Federal Insecticide Fungicide and Rodenticide Act (FIFRA) that authorizes EPA to allow an unregistered use of a pesticide, for a limited time, if EPA determines that an emergency condition exists.
In a typical year, MDARD submits around a half-dozen emergency exemption requests to EPA on behalf of Michigan citizens who need to use those products. While MDARD typically takes the lead in preparing emergency exemption requests, they rely heavily on Michigan State University Extension specialists to provide much of the information required for the application to EPA. In 2014, MDARD requested and received three emergency exemptions, two of which were for tree fruit growers for the use of kasugamycin (Kasumin 2L) to protect apple trees from streptomycin resistant fire blight, and for the use of dinotefuran (Scorpion and Venom) to help protect pome and stone fruit from brown marmorated stink bug (BMSB).
Preparing an emergency exemption request is very time consuming, in terms of both the initial application and in providing follow-up data to the EPA once a request has been granted. One piece of information that EPA requires of MDARD after an authorization has been granted is a report summarizing the use of the products labeled under the exemption. Among other things, the report must include the county in which the product was applied, the total acreage to which the product was applied, a discussion of how well the product worked, and a description of any adverse or unexpected effects related to the use of the product.
Summary reports on use of these emergency exemptions must be submitted to EPA within six months of the expiration of the exemption, or before submitting new emergency exemption requests. EPA makes it very clear that they will not issue another emergency exemption to MDARD unless they receive the summary report for the previous exemption. In other words, if MDARD does not submit a use report on time, growers will not be able to get another emergency exemption for Kasumin 2L, Scorpion or Venom if needed for the next season.
For those of you who have benefited from the Section 18 emergency exemption labels for these products this season, we need your help. Traditionally, MDARD has gathered the information necessary for the required summary report by having inspectors contact growers directly. However, with ever increasing workloads and fewer personnel to cover those workloads, MDARD is now relying more and more on MSU and industry groups to collect the information needed for their report to EPA.
Please take time to complete a short survey on Section 18 use for the product you used under an emergency exemption this season. The information you provide is critical to securing emergency exemptions in the future and for moving this product toward full registration with EPA.
