E7VESTIGATION C? THE ETTECTS OT FCCD STANDARDS
ON PESTICIDE USE
Environmental Protection Agency Contract 68-01-2602
Prepared by
Martin Brown
Richard .Garcia
Cathlsen Magovan
Alan Miller
Michael Moran
David Pelzer
Joel Swartz
Robert van den Bosch-
Principal Investigator
Robert van den Bosch
Consultants
Richard Buxbaua
Richard Garcia
Richard Norgaard
For
Environmental Protection Agency
Office of Pesticide Programs
Charles D. Reese, Project Officer
Carl ton J. Kempter, Project Officer
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EPA Review Notice
This report has been reviewed by the Office of Pesticide
Programs of the Environmental Protection Agency and
approved for publication. Approval does not signify that
the contents necessarily reflect the views and policies of
the Environmental Protection Agency or does mention of trade
names or commercial products constitute endorsement or recom-
mendation for use.
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ABSTRACT
Three commodities, fresh market organes, processing tomatoes and cling
peaches were assessed concerning the role of pest related (largely insect)
quality standards and their relationship to pesticide usage.
In each of the commodities cosmetic quality standards appear to have
a significant effect on pesticide usage, both in regard to the amount of
chemicals used and the utilization of specific pesticides and in regard
to the general approach to pest management. In one commodity (processing
tomatoes) insect contamination of produce is also a factor. In general,
extremely strict quality standards seem to mitigate against the adoption*
of integrated pest management (IPM) or serve to prevent integrated pest
management from being fully utilized. Even where IPM programs are effec-
tive under prevailing standards, growers are reluctant to adopt such pro-
grams because they are forced by processor, marketer and consumer pressures
to strive for virtual "zero" pest levels. This is a major reason why avail-
able IPM programs which maintain crop quality and yield while reducing
pesticide usage up to 50 percent are hardly used by the growers of the
three crops assessed in this study. This is one of the most unfortunate
aspects of the prevailing produce standard situation, because IPM programs
demonstrably produce efficient pest control at reduced cost and pesticide
usage.
There appears to be a clear necessity, then, for appropriate adminis-
trative or legislative action which would permit the public agencies whose
mandate it is to protect the quality of the environment to intervene agres-
sively, if necessary, on behalf of those sectors adversely affected by
environmental degradation resulting from inadequacies in the economic and
administrative systems currently determining pest related quality standards
for produce.
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TABLE OF CONTENTS . -
... Page
Acknowledgements / 1
Summary. . ....'' . 11
''...';- Pesticide Use .;...,: ;'::'" :' \.V ;.-'..-,./;'--'-V '"..; .'';'.-. iv
. Pesticide Use Regulation . vi
Qualltr 5taTi'i^'p^!? .."'. vil
Consumer Attitudes . z
Introduction " xi
Chapter 1. Quality.Standards for Fresh and Processed
Produce in California : 1
'_ Produce Quality Standards . . 1
'''.' Quality Standards for Fresh Produce 2
* ".'"..
Marketing Orders 6
- ' *
Marketing Cooperatives . 6
Private Marketing Organizations 6
Retail Standards 7
Cosmetic Quality Standards 10
Quality Standards for Processed Foods . 11
. Processed-FoodsState"Standards 11
: , Processed 7oods«~Federal Standards . .li
. Contractual Standards 21
Consumer Attitudes 23
Quality Standards and Supply Control 25
Cosmetic Quality Standards Summary . 27
Quality StandardsFootnotes 28
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Page
Chapter 2. Pesticide Use and Regulation in California.. 33
Pesticide Use and Regulation In California 33
Fest Management Technology " ' 35
Sources-of Pest-Management Information - 39
- Regulation of Pesticide Use in California 43
." Enforcement .'_. . ' . ' 44
''".: '...'-'' . Licensing Procedures '''."."'. ; ../' ':_ ;- .. ''.'.". '' v ' '... "' ^6 -
- - .' ..' . State Action . : - .- - "... ''':/- . ' - ''- ' '. ' ' ; : :'.' 48
The Impact of Pesticide Use in. California 49
Pesticide Use and Regulation in CaliforniaFootnotes 54"
Chapter 3. . An la-Depth Case Study of Pesticide Use for
Cosmetic Quality Standards 59
. . Citrus. . ' . ' ' .
'. . -I» Supply and Demand- ' .. 59 .
Citrus Acreage and Production ". 59
The Fresh Market. . ' .59
'The Problem, of Over-Production "i 60
II. Cooperatives and Marketing Orders 65
Marketing Orders 907-908 . 67
IH^ Quality Standards . 72
. 17. Pest Management . . ' 79
7i The Citrus Thrips 86
- ';'.. ;:. . ':' History - . " .'..'.'', ; ;.. ' ' : . ' 86
Current Status 88
Alternatives and Obstacles 97
References . 101
Chapter 4. Cosmetic Quality Standards and Pesticide Usage in
Processing Tomatoes and Cling Peaches 108
Processing Tomatoes . 108
Tomato Production 108
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Page
Use Allocation of Processing Tomatoes . 110
Quality Standards for Processing Tomatoes III
Pest Management for Processing Tomatoes 113
ding Peaches ..'.... 115
Acreage and Production . 116
The Cling Peach Marketing Orders . . 116
Surplus Elimination . . ' 116
Quality Provisions . 118
Pest Management in Cling Peaches 123 *
Cosmetic Quality and Pesticide Use in Cling Peaches 125
Cosmetic Quality Standards and Pesticide Usage in
Processing Tomatoes and Cling PeachesFootnotes 128
Appendices - ' .
Table 1 : ^'L
Table 2 . . 144
Table 3 . : "* 145
Table 4 . . : 143
Table 5 . ." - . 149.
Table 6 ' 150
Table 7 . 151
. Table_8 '.. "; '-';,.''../;'...''.. ' '.' .;. ' ' ;. ; 152
Table 9 > : " r 153 .
Figure 1 . 154
Figure 2 . 155
Figure 3 . 156
Figure 4 157
. Figure 5 158
Figure 6 . ' . 159
Figure 7 160
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ACKNOWLEDGEMENTS
We wish to thank the many individuals in county, state and federal
government and in the private sector who agreed to give us their view-
points on this important subject. Specifically we wish to thank Charles E.
Kennett, Leopoldo E. Caltagirone, Christine M. Merritt and Andrew P.
Gutierrez for reviewing draft sections of the report, Mrs. Joanne Fox
for her patience and skill in typing this large document, and, especially,
.Mrs. Mary Jane Clarkin for maintaining some sort of managerial control
over things during the course of our study.
-i-
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SUMMARY
Three commodities, fresh market oranges, processing tomatoes and cling
peaches were assessed concerning the role of pest related (largely insect)
quality standards and their relationship to pesticide usage.
In each of the commodities cosmetic quality standards appear to have
a significant effect on pesticide usage, both in regard to the amount of
chemicals used and the utilization of specific pesticides and in regard
to the general approach to pest management. In one commodity (processing
tomatoes) insect contamination of produce is also a factor. In general,
extremely strict quality standards seem to mitigate against the adoption
of integrated pest management (IPM) or serve to prevent integrated pest
management from being fully utilized. Even where IPM programs are effective
under prevailing standards, growers are reluctant to adopt such programs
because they are forced by processor, marketer and consumer pressures to
strive for virtual "zero" pest levels. This is a major reason why avail-
able IPM programs which maintain crop quality and yield while reducing
pesticide usage up to 50 percent are hardly used by the growers of the
three' crops assessed in this study. This is one of the most unfortunate
aspects of the prevailing produce standard situation, because IPM programs
demonstrably produce efficient pest.control at reduced cost and pesticide
usage.
While federal and state regulations and consumer preference appear to
play some role in the determination of cosmetic standards, more direct
economic motivations on the part of growers and processors appear to be
of greater importance. Other researchers have commented on the welfare
loss due to artifically maintained prices for agricultural resources due
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to the functioning of marketing orders and other forms of quality and quanity
control. In this report, it is pointed out that further negative social
Impacts due to pesticide use are also attributable to these mechanisms.
Our investigation reveals that while modifications in consumer attitudes
and clarification of ambiguous federal and state regulations are desirable,
it is unlikely that changes in these areas alone will have a significant
effect on produce quality standards and current pesticide use practices.
In order for this to happen there must be direct incentives aimed at
modifying pesticide use patterns,. and a concurrent careful examination of the
entire system of production and distribution of specialty crops as it
relates to pesticide overuse. This latter undertaking will be particularly
difficult because the current system of allocation of resources for
specialty crops was not designed to provide a means of economic expression
on behalf of the stability of the agro-ecosystem, the health and welfare
of farmworkers, the public health, or even the long-term economic well-.
being of individual growers. The various types of legislation that were
passed into law in the depths of the Great Depression were designed to .
provide the failing small farmer with a modicum of short-term security. It'
is not surprising, then,, that the current system results in negative impacts
in areas the importance of which have been recognized only in the very
recent past. There appears to be a clear necessity, then, for appropriate
administrative or legislative action which would permit the public agencies
whose mandate it is to protect the quality of the environment to intervene
aggressively, if necessary, on behalf of those sectors adversely affected
by environmental degradation resulting from inadequacies in the economic
and administrative systems currently determing pest related quality standards
for produce.
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". RECOMMENDATIONS
The following recommendations ::..-. ..... are
suggested as areas in which the EPA may wish to sponsor further work on
produce quality standards and pesticide use. While some of the recommenda-
tions may appear to be unrelated to produce quality standards or pesticide .
use, they are designed to have an impact in these areas through the inter- '
connections described in-this report.
Pesticide Use . .
If more and better information were available to growers it is probable
that pesticide use decisions in regard to produce quality standards would
be more rational from a personal as well as a social standpoint. This does
not mitigate the fact, however, that under the most ideal circumstances in
regard to information availability, produce quality standards still would
remain as an obstacle to the full implementation of integrated pest manage-
ment. Nevertheless, a need exists for the establishment, of more realistic
and reliable economic threshold levels for pest damage and pest contamination
levels in regard to produce quality, and an efficient mechanism for the
communication of this information to the grower. Little research has been
done in the area of the relationship between pest damage and cullage due to
cosmetic defects,and more is needed. In addition experimentally derived and
verified pest damage assessment systems should be made universally available
so that growers are able to make pest management decisions on the. basis of
actual pest population levels rather than prophylactic or pre-programmed
treatment. These and other goals would be effectively approached if the
quality of pest management advisory personnel were improved. Wayne Willey
has evaluated various economic incentives that could be implemented for
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'tins purpose. Another approach would be to increase the licensing require-
ments for pest control advisors. We would suggest the following m-fnTmma .
requirements: . .. .
Pest control advisors should not be allowed to be directly or indirectly
employed by agricultural chemical companies to function in a sales capacity;
that is, the income of pest control advisors should not be related to the
< - ."".-"" *"'- ' ' ' * *.-'"' . ". ' ' ' ' . '
amount of pesticides applied. For the same reason* pest control advisors
should not be allowed to solicit pesticide application services, or for
that matter, be directly involved in sales of biological controls or other
non-chemical controls, or to be associated-with companies vending particular
pest control technologies. To allow such associations is analogous to
allowing physicians to have a financial interest in pharmaceutical companies;
it does not guarantee that the best mode of therapy will be followed.
Alternatively,it is envisaged that contract advisement provided that it is
based on a set predetermined fee could involve producers of various types of
control agents, in a way that is analogous to the the functioning of a
human HMO. '.''.- "
In addition it would be highly desirable for pest control advisors to
receive university level education in integrated pest management, plant and
animal systems ecology, pesticide toxicology, environmental health, natural
resource and agricultural economics, and law and institutions in regard to
pesticide regulations, food quality standards, marketing orders, cooperatives,.
grower-processor contracts, worker health and safety and environmental impact.
The basis for such an interdisciplinary curriculum is available at the
University of California, and probably elsewhere, but there has been no
attempt to design a specific Pest Control Advisor programsof this nature,
though the current pest management curricula do contain some of, the features
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indicated here. It would also be desirable for pest control advisors to
undergo field internships, preferably under the supervision of experienced
integrated pest management consultants. An internship program of this
nature supported by a three year grant from the Noyes Foundation, is
currently being conducted by the University of California, Berkeley.
Reaction by both students and professional pest management participants
has been extremely positive. Postgraduate education and periodic retesting
of pest control advisors would also be desirable. Finally, the Pest Control
Advisor licensing examination should be designed to test the ability of
the candidate to deal with complex pest control situations rather than the
individual's ability to respond to simple technical items.
The idea of regional pest control districts which would provide inte-
grated pest management advice should also be explored. Such districts
might be supported out of state or federal revenues, by a compulsory tax
or assessment on growers and/or other sectors of the agricultural system,
or by voluntary assessment among grower-members of special cooperatives
established for the purpose of pest management.
Pesticide Use Regulation
More stringent pesticide use regulation could serve as an incentive
for efficient use of pest management technology and discourage the use of
pesticides for non-substantial pest damage. One measure that might help in
this area would be to require that the Pest Control Advisor indicate the
reasons for recommending the use of a specific pesticide application. The
report should ideally contain data of the past and present population levels
of the pest, the expected economic damage if treatment is delayed or
cancelled, the rationale for the specific material or technique recommended
and the alternative measures considered. Such a requirement would tend to ,
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m .
discourage unjustifiable pesticide treatments and these reports could also,
serve as an important data base for the evaluation of pest, management
practices and the development of an improved, pest management strategy. In
this connection, it would be of great benefit if intensified and expanded
research on integrated pest management were undertaken by federal agencies,
the state agricultural experiment stations and perhaps agri-business itself.
It seems reasonable that County Agricultural Commissioners should be
responsible for the administration of pesticide use regulations, however,
because of their natural tendency to identify with the interests of agri-
culture, it does not seem proper that they should administer worker health
and safety regulations. More appropriate agencies might be the State
Departments of Public Health or the Federal Occupational Safety and Health
'the agricultural area it
Administration. In addition,in/would seem advisable to give some type of
official recognition to farmworker representatives for the purpose of
detecting and reporting pesticide poisoning incidents and/or violations of
worker safety regulations. In those cases where farmworker unions are
recognized, union designated persons might assume this responsibility as
is the case with other groups which function under the provisions of OSHA.
Farmworkers are certainly in a better position to detect such incidents
and violations than the understaffed offices of the County Agricultural
Commissioners. ... . - .
Quality Standards .
A systematic study of quality standards for specialty crops is needed
to determine the specific degree of cosmetic content crop by.crop. A
uniform system of quality standards should be developed and there should be
a consumer education campaign on the meaning of quality standards in fresh
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and processed produce. Quality standards should be modified with regard to
maximizing the efficiency of pest management technology. The standards
should be specified with more regard to end use, so that highly cosmetic
quality standards are not used unnecessarily in regard to produce that is
allocated to noncosmetic uses. Improved systems of allocation of produce
to various grades could facilitate this.
The Federal Food and Drug Administration regulations pertaining to
insect contamination should be clarified in regard to the source of the
insects, and processors should not be allowed to cite the FDA regulations
to justify specific cosmetic standards, for fresh produce used as an input
to the processing plant. The whole matter of insect contamination levels
and the real hazard posed by minuscule insects or insect parts should be
brought under intense scrutiny, especially since there is reason to believe
that in many cases the hazards posed by insect control far outweigh those
posed by the insect contaminants.
The role that cosmetic quality standards may play in facilitating
undue market power by growers, processors or-retailers should be investi-
gated in regard to possible anti-trust violations. This is especially
relevant since the Capper-Volstead Act and the Marketing Order Act forbid
the use of marketing cooperative or marketing order mechanisms to obtain
undue market power. Incentives to encourage the development of a greater
number of diverse marketing cooperatives and firms which could offer a
range of quality of produce to the market should be explored. At present
most specialty crops are dominated by a single marketing organization which
may not be able to serve the diverse needs of all the growers in the industry.
In this connection, California is currently experimenting with a state operated
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direct marketing system for fresh produce. Marketing order boards should
be modified so that representatives from a wider diversity of interest are
included. Marketing order boards in California now must have some consumer
representatives and this is a step in the right direction. Such repre-
sentation would help insure that quality standards are designed to fulfill
the needs of groups other than growers and processors.
The potential for absorption of surplus produce through secondary
markets should be explored. Potentials include allocation of produce that
doesn't meet the cosmetic quality standards of the primary market but is
otherwise fully wholesome and nutritious to such segregated and guaranteed
markets as federal school lunch programs or other food programs for families
below a certain income level. Such programs should not damage the aggregate
demand for produce of high cosmetic quality since the bulk of this demand
comes from high income families. Another variant of this approach is to
sell surplus produce from the processing sector on a fieldrun basis
directly to the consumer, at minimum state quality standards. This has been
done on a limited basis in California since 1975 by the Consumer's Co-
operative of Northern California, and consumer response has been highly
favorable. This latter approach, of course, could result in a reduction
in demand for some high cosmetic quality produce.
Tax shelter and subsidy programs which have resulted in false market
signals and raisallocation of agricultural resources should be examined and
modified. Possible regional or state systems of agricultural resource
allocation which might result in more rational long-term planning in
agricultural production should be explored.
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Consumer Attitudes
The determinants of consumer behavior in regard to the consumption
patterns of fresh and processed produce should be investigated. Consumers
should be fully informed on the nature of insect contamination in fresh
and processed produce and on the use of pesticides in food production.
Consumers should be educated concerning the manifold consequences of
cosmetic food production.
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INTRODUCTION
It shall be the object and duty of the State Agricultural
Experiment Stations through the expenditure of the appro-
priations hereinafter authorized to conduct original and
other researches, investigations, and experiments bearing
directly on and contributing to the establishment and
maintenance of a permanent and effective agricultural
industry_of the United States, including researches basic
to the problem of agriculture in its broadest aspects, and
such investigations as have for their purpose the develop-
ment and improvement of the rural home and rural life and
the maximum contribution by agriculture to the welfare of
the consumer, as may be deemed advisable, having due regard
to the varying conditions and needs of the respective States.
Hatch Act, 1887
Agricultural research, as defined by the Hatch Act, is based upon a
pluralistic ideal, taking the welfare of all sectors of society into account.
However, some persons question how well agricultural research, in reality,
has maintained the ideal of the Hatch Act. Agricultural Economist Alex F.
McCalla has written,
What has happened in the twentieth century is that the Land
Grant establishment has redefined its mission to be primarily
production agricultural efficiency rather than the much
broader charge contained in the Hatch Act. Thus, rather
than perceiving the general public, particularly those that
are "disadvantaged", as our clientele we have given special
attention to production agriculture....
While doing this we have identified very closely with our
perceived clientele so that often, after a couple of generations,
we begin to think like them, share their values, and come to
perceive their sanction of our activities as necessary and
desirable....
Issues of environmental quality, consumer safety, nutrition,
quality of rural life, and many others have arisen in part,
in the public's mind, because of our single purposed dedication
to production efficiency....It is time we focused our goals to
serve our many publics, including, but not limited to,
agribusiness.^
In this report we have attempted to keep in mind the original intent
of the Hatch Act. While pesticide use has had an undeniable positive effect
on the capability of production agriculture, pesticide use has also produced
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some negative externalities, externalities which often occur in subtle
and indirect ways and which impact on groups and individuals who may not
receive any direct benefit form this aspect of agricultural technology.
The purpose of this report is to investigate the relationship between
cosmetic food quality standards and pesticide use, and to detect any elements
of the current system of laws, regulations and practices which result in
negative impacts to public health and environmetnal quality. The relation-
ship between quality standards and pesticide use is not simple and direct.
It is conditioned by political, economic, legal, technical and ecological
factors that, together, constitute the environment in which-modern agri-
cultural production operates. In this report we have attempted to describe
these relevant factors and their impact on the issues under consideration.
.In Chapter 1.the origin, history and current nature of the relevant
quality standards is examined and the meaning of a "cosmetic quality
standard" is defined.
In Chapter 2. pesticide use, regulation and impact is examined,
especially in regard to California. The alternative available approaches
to pest management are examined and the factors which influence pesticide
use decisions are described.
A brief outline of the impact of pesticides on man and the environment
is also presented.
In Chapter 3. the complex relationship between cosmetic quality
standards and pesticide use is closely examined in California oranges with
emphasis on fruit produced for the fresh market.
Chapter 4 briefly treats of our investigation of produce quality
standards as they affect pesticide usage in processing tomatoes and cling
peaches.
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Sources of information for this report include the technical literature
in the fields of agricultural economics, pesticide and quality standard
law, applied entomology, pesticide toxicology, epidemiology and other
fields. We were privileged to obtain information from a number of studies
in progress or not yet published. In addition personal communications with
academic researchers; county, state and federal officials; individuals
associated with grower organizations, processing firms, shipper and packer
organizations, retail food chains; farmworker union representatives, and
private pest management consultants were carried out. It was anticipated
that systematic interviews with a large number of growers, farmworkers,
consumers and other relevant groups would be carried out. However, efforts
in this direction were frustrated by the Federal Office of Management and
Budget which refused to approve the appropriate survey questionnaire even
after all technical and administrative objections had been properly responded
to. To our knowledge, the requested survey was never actually formally
turned down and we were never notified of the reason for the survey not
receiving approval. The lack of this important research tool was made up
for, in some instances, by the coincidence of other survey studies which
partially met the needs of this report. However, the inability to conduct
survey studies in important areas of concern did restrict the study to
primarily qualitative rather than quantitative conclusions. Nevertheless
it is hoped that the tendencies identified will prove to be a useful guide
in the consideration of pesticide policy.
This report represents the first attempt to study a subject that is
complex and broad. The report, then, is primarily descriptive. However,
because this report defines and characterizes a new area of concern it can
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serve as a guide to additional, more specialized and systematic investi-
gations. Some specific areas for additional study are identified in
our recommendations. Finally, for various reasons this study primarily
concerns insecticides. However, it should be clear from what we report
that this discussion has broad implications for pesticide usage.
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mil i-
1, Alex F. McCalla, Public Sector Research and Education and the Agribusiness
Complex: Unholy Alliance or Socially Beneficial Partnership?" American
Journal of Agricultural Economics, December, 1973, p. 1001.
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CHAPTER 1. QUALITY STANDARDS FOR FRESH AND PROCESSED PRODUCE IN CALIFORNIA
The establishment and administration of quality standards for fresh
and processed produce in California is not the exclusive domain of any
single agency. To understand the nature of food quality standards a
complex system of private and public institutions at the county, state
and federal levels must be examined. The relevant institutions for fresh
produce quality standards include the California State Legislature, the
California Department of Food and Agriculture, state and federal marketing
order boards, agricultural marketing cooperatives, shipper and packer
organizations, retail food distributors and the consuming public. In
regard to processed produce the roles of the Federal Food and Drug
Administration and food processing companies and cooperatives must also
be considered.
The cosmetic aspect of food quality standards has not been formally
defined within any of these institutional structures. Thus, a definition
of "cosmetic quality standard" will be constructed and the degree to which
various institutions contribute to the cosmetic aspect of food quality
standards will be considered.
PRODUCE QUALITY STANDARDS
The two categories of quality standards that are relevant to this
study are those which pertain to the marketing of fresh produce and those
which pertain to produce which is sold as an input to processing firms. In .
both cases foraal, statutory standards exist; however, for many crops the
operationally effective standards are those that are required by contractual
agreement between producers and buyers, or by the joint agreement of producers
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through marketing cooperatives and marketing orders. In most cases this
latter type of quality standard is much more stringent than the statutory
standard. . ' .
QUALITY STANDARDS FOR FRESH PRODUCE
The establishment and enforcement of quality standards for fresh
produce is essentially a state function. The federal government does
maintain a system of federal grades as a service to buyers and sellers.
According to the National Commission on Food Marketing, "One of the principle
functions of Federal grades for fresh fruits and vegetables is to provide a
basis for describing products and, thereby, facilitate trade between
shipping point and terminal market firms." The National Commission goes
on to document the fact that federal grades do, in fact, play a substantial
role in commerce between the sellers and buyers of fresh fruits and
2
vegetables. Nevertheless, federal grades are not the same thing as
mandatory quality standards.
The purpose of federal grades is to provide buyers and sellers with a
common basis of information. Grades are not directly linked to mechanisms
that function to allocate produce between the primary and secondary markets
or to withhold produce from the market. Thus, to the extent that grades
represent accurate and accessable information, they may serve to increase
producer and consumer welfare. Quality standards may be directly linked
with mechanisms which serve to constrain the amount of produce that may
reach the primary market in a given period. In this sense, quality standards
may place constraints on the functioning of consumer sovereignty. Quality
standards may also result in other externalities, such as are the subject
of this report.
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The Federal Food, Drug, and Cosmetics Act specifically forbids federal
quality standards, providing that "no standard of quality shall be
established for fresh or dried fruits, (or) fresh or dried vegetables."^
California State Quality Standards
The California legislation regulating the quality of fresh fruits and
'-.'- - - '"'' 4 . .
vegetables began to develop early In this century. Because of progress in
transportation, eastern markets were beginning to be accessible to fresh
California produce. Thousands of small grovers and shippers scrambled to
serve these markets. It was in the interests of each grower to reach the
market first each season to reap the premium prices available for early
produce; invariably the competition resulted in many shipments of insuf-
ficiently ripe produce. Further, the hope of growers to sell all their
crop led to the swamping of the markets in peak season with produce of
marginal quality. Deceptive packaging, marking, and grading were used to
hide defective produce. Eastern wholesalers, retailers, and consumers-&
became cautious about California produce and prices began to fluctuate. To
protect consumers by eliminating deceptive practices and thus to promote
the reputation and the business of the state's agricultural industry, both
inside and outside the state, the California legislature established miniTmim
maturity, size, packing, and labeling standards for some of the major
» - - ' -. - * . " . * . .
California fruits and vegetables. ; '
The quality standardization laws have grown progressively more com-
prehensive and complex. They now apply to the sale or shipment of all fresh
fruits and vegetables, packed or in bulk.
The state of California has'enacted quality standards with respect to
pest damage which apply, across the board, to all fruits 'and vegetables.
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These criteria are rather broad and vague, providing that any fresh fruits
or vegetables cannot be sold unless 90 percent by weight, of the produce,
is free of worms, mold, decay, or any insect injury which has penetrated
the edible portion, as determined by inspection of representative samples.
Crops to which additional, specific quality standards apply are apples,
apricots, artichokes, asparagus, avocados, berries, broccoli, brussel sprouts,
cantaloupes, carrots, cauliflower, celery, cherries, citrus fruit, corn,
dates, grapes and raisins, lettuce, melons, nectarines, onions, peaches,
pears, peas, persimmons, plums and fresh prunes, pomegranets, potatoes,
Q
quinces, sweet potatoes, tomatoes and walnuts.
State quality criteria for selected crops are shown in Table 1.
In the past California state quality standards for fruits and vegetables
were established as statutes by the California legislature. Beginning in
1975 this authority was transferred to the Director of Food and Agriculture.
Under the current law the Director, upon a petition from a commercial
grower or handler, "may", and upon a petition from 10 commercial growers
or handlers "shall" hold a hearing to establish, modify or rescind a quality
standard for a fruit, nut or vegetable product. The Director's decision must
be based upon the following criteria:
1. The regulation will provide the consumer with acceptable quality .
fruits, nuts, and vegetables which will also provide stability in the
marketing of such products.
2. The regulation will tend to prevent waste in the production and
marketing of fruits, nuts, and vegetables.
3. The Director will consider the impact of the regulation upon the
agricultural industry.
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All quality standards enacted by the state legislature before 1975 are
carried over into the new system as regulations unless the Director finds
9
them to be unsatisfactory.
While it is difficult to evaluate quality standards except on a crop-
by-crop basis, it is safe to say that the Califronia state quality standards
for fresh fruits and vegetables are, by and large, directed at maintaining
a minimum level of produce quality and are concerned primarily with maturity
and substantial damage. One reason the standards have been set low in
the past is that, as the statutes required legislative action for adoption
or amendment, they could not be readily altered in response to emergency
situations, such as anabrupt change in the weather, that might suddenly
result in a substantial reduction in the quality of a specific crop, though
the crop might still be basically wholesome.
Growers apparently have no great difficulty in meeting the current
standards as evidenced by the fact that for the fiscal year 1972-73, 99.6
percent of the produce inspected in Fresno County was passed. (Fresno
County is the largest agricultural producer of any county in the United
States, measured by the gross value of sales. The value of its crops in
1972 were in excess of $550,000,000.^
There has been some pressure to increase the level of the state quality
standards. For example, the Western Growers Association, which is a major
shipping organization for California row crops, .has consistently lobbied
for increased quality standards. According to a Western Growers Association
spokesman, the effect of increased quality standards is to improve the
quality reputation of California produce and to improve the competitive
1 7
position of fresh produce relative to processed produce.
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MARKETING ORDERS ..-".'
Under the provisions of federal and state marketing orders*producers
may agree to establish and enforce quality standards in addition to those
specified by state law. In 196S there were 49 marketing orders in effect
under-the federal provision and 34 under the state of California. Of the
» '
91 federal and state marketing orders tabulated by the National Commission
on Food Marketing,76 percent contained provisions for grade, size, maturity,
14
or other quality control. The general goal of marketing orders is to
increase the net return to the grower by improving market organization,
by increasing consumer demand, by regulating the flow of the produce to
the market place, and, in some cases, by restricting the total supply of
the product. The quality standards that are specified by marketing orders
are tied to this general goal and related to one or more of these ' .-" -:r
mechanisms. ' . '
MARKETING COOPERATIVES '. *
Under the provisions of the Capper-Volstead Act the producers of a
commodity may join together in a cooperative for the purpose of jointly
marketing their produce. Marketing cooperatives may establish and
enforce their own quality standards. For example, Sunkist Growers, Inc.,
the major marketing cooperative for fresh California oranges maintains a
set of quality standards that is far more comprehensive, specific and
18
stringent than the regular state quality standards.
PRIVATE MARKETING ORGANIZATIONS . .
. Likewise private marketing organizations may maintain their own set
of quality standards. For example Kenneth Dunham of the giant, produce
marketing firm Eeggeblade-Marguleas-Tenneco testified in 1972 that, "we
-------
have consistently atrivcd with the growers to upgrade the quality of their
produce in order to compete in the marketplace, domestic and international.
We are relentlessly hammering at the growers to put up the finest package
of fruit and vegetable possible. If you ask why we have done this over
the years and are continuing to do so, it is done for the growers'
salvationnot to become fat with profit, but to enable them to compete in
the marketplace with their products, whether it is fruit, nuts or vegetables,
19
with a reasonable return to invest."
RETAIL STANDARDS
The most comprehensive use of quality standards in fresh produce occurs
in the buying transactions of large supermarket chains and in the selling
of produce to these chains by large marketing organizations. Buyers for
retail supermarkets have reported to us that cosmetic criteria are routinely
used in selecting produce. The buyers state that the standards they use are
not written down or codified in any way, but that they are acquired from a
buyer's experience regarding what consumers .will or will not buy.
Crates or boxes of produce in which.insects are found are often
rejected summarily. Buyers maintain that the presence of one insect often
indicates that more may be present in the shipment. It makes no difference
whether the insect is one which attacks the commodity on which it is found
or whether it is an innocuous insect that does not feed on the commodity.
Evidence of insect damage is treated almost as seriously as the presence of
insects. Buyers said that produce must be practically free of insect damage
to be saleable.
Size and color are also cosmetic criteria that are important to buyers.
Retail stores often like to stock tvq sizes of the commodities for which
there is a federal grading system (e.g. apples, oranges, tomatoes, etc.)
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8
Retail score buyers prefer Co buy Che largest produce wichin a given grade.
They have commented Chat consumers are ofcen uninformed as Co whac size
indicates; smaller produce within a grade may have becter Caste qualities
according to Che buyers but consumers seem to always equate maturity and
quality with size. Color is important for the same reasons; consumers
equate good color with maturity and quality. According to the buyers, this
is not always true. The cosmetic criteria applied are flexible and vary
with the season and with the availability of produce. Buyers are conscantly
in touch by phone and by personal visits with wholesale brokers and with
large growers who sell directly to retailers. They actively compare the
produce which is available and buying decisions are made by balancing price
with cosmetic quality, assuming that the produce is acceptable on other
A 20
grounds.
Don Dressier of Che Wescern Growers AssociaCion concurred wich this
viewpoint. He asserted that the use of agricultural chemicals was vical
in obGaining produce with Che "righc color" and for "blemish concrol". He
thought that the cosmetic appearance of fresh produce was a major'factor in
competition against canned and frozen produce which have the advantage of
picturesque labels and elaborate packaging. According to Dressier, "fresh
produce is ics own label". Dressier also contended that even a small
proportion of non-cosmetic produce appearing in the marketplace could spoil
the consumer market for the entire industry. He was especially upset about
21
the marketing of "organic crap".
Not all produce people feel this way. According Co Bill Ramsey,
supervisor for Mann Packing Company, which ships 25 percent of the nation's
broccoli, it is the retail buyers, not the consuming public, who demand the
-------
maintenance of high cosmetic quality standards. According to Ramsey, a
reduction in the cosmetic quality standards would result in a saving to
both the grower, who would use less pesticides, and the consumer. "Consumers
buy the relative best so if quality goes down, they would buy the relative
22
best," said Ramsey.
According to the Sunkist Newsletter of August, 1976, regreened oranges,
Valencia oranges that have turned green when left on the tree beyond the
point of early ripening, are "sweet and juicy", as good or better than
orange colored fruits. However, the Sunkist Newsletter of September, 1976,
reports that, "Regreening continues to be a serious problem this season
and is proving to be a major factor contributing to heavier amounts of
non-premium fruit".
Barney McClure of the Botsford-Ketchum advertising agency has designed
campaigns to educate consumers to the non-cosmetic aspects of fresh produce.
"One winter (artichoke growers) had a heavy frost which turned the outside
leaves of the chokes brown. They put on a campaign which explained that
frost-kissed artichokes really have improved flavor. They turned frost
damage into a money-maker." According to McClure, "Some of the new peach
varieties have been developed with an eye toward blush, that beautiful
color that is associated with peaches. But there is a problem with them.
They don't taste so good. I think people are ready for a change. This
growing emphasis on consumerism is beginning to counter 40 years of effort
23
and promotion of the perfect produce."
This "consumerist" attitude was expressed by Christina Rose, of the
California Department of Consumer Affairs, who testified in 1973, that,
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10
In spice of the original purpose of commodity standards, there are
those who question whether their real benefit accrues to the consumer
in every instance.
They ask, for example, if consumers might not gladly purchase fruit
and vegetables for cooking purposes which did not meet the stringent
standards to which they have become accustomed, but which could be
purchased at a reduced price consistent with greater supply.
The price of a food product is, in some measure, influenced by the
quality and maturity standards applied to basic agricultural commodities.
To increase the price, one may raise the standard acceptable on a
given commodity and thus reduce the legal supply available on the
market.
A substantial lowering of the standard will increase the supply and
may reduce the price, but will possibly provide to the consumer what
would previously have been considered an inferior product.
COSMETIC QUALITY STANDARDS
Nowhere in the vast system of quality standards for fresh produce is
there a definition of a "cosmetic" quality standard. However, commentators
within and outside of the fresh produce system have acknowledged the
existence of such a thing for many years. At this point, based upon our
review of quality standards for fresh produce, it seems clear that a cosmetic
quality standard can be defined in the following manner: A cosmetic quality
standard is one that refers to superficial damage to or alteration of
/
the exterior appearance of the commodity; damage or alteration which does
not significantly affect the taste, nutrition or storage capacity of the
produce. Of course, this report is concerned, more specifically, with
cosmetic damage that is actually caused by, or is attributed to, insect or
other pests.
From our review of quality standards for fresh produce we can make
the following comments regarding the relative degree to which quality
standards incorporate a cosmetic component. The regular state quality
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11
standards refer, by and large, to minimal maturity and non-cosmetic quality
criteria. The quality standards that are established and enforced by
marketing cooperatives and marketing orders often contain substantial
cosmetic components. Finally, at the retail level, cosmetic factors seem
to play the decisive role in decisions of the large marketing concerns to
buy or not to buy fresh produce. According to retail store buyers this
reflects a "cosmetic consciousness" on behalf of the consumer.
QUALITY STANDARDS FOR PROCESSED FOODS
PROCESSED FOODSSTATE STANDARDS
The states play little part in setting quality standards.for processed
foods. The first attempts to regulate processed foods were made by the
states, but the emergence of a national economy and the dominant proportion
of processed food shipped through interstate commerce made national regulation
necessary. State power to regulate products in interstate commerce was
limited. Conflicting regulations made it difficult for producers to serve
multi-state markets. The Federal Food, Drug and Cosmetic Act now is the
dominant force in regulating processed foods.
California's health codes illustrate the merger of state and federal
regulations. Claifornia does have one state stuatute which controls the
quality of food which can be processed, but the standards are totally
non-cosmetic.25 But beyond this statute California has adopted the federal
standards.
PROCESSED FOODSFEDERAL STANDARDS
The primary federal statute which regulates, inter alia, the quality
of processed food is the Federal Food, Drug, and Cosmetic Act (FDCA).
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12
The main purpose of the Act is to protect consumers from the dangers of
unwholesome food. In general, FDCA provides for the promulgation of three
types of food standards which an interstate processor must meet. The
three types of standards are identity, quality, and fill of container.
The Act prohibits from interstate commerce, foods which are "adulterated"
28
or "misbranded," and the receipt or delivery of such defective foods.
Almost all the civil and criminal violations with respect to food under
FDCA involved adulterated or misbranded food, both of which are given
broad definitions. The Food and Drug Administration, (FDA), under the
Department of Health, Education, and Welfare, is responsible for ad-
ministering the major part of FDCA.
29
Section 402 of FDCA gives the Secretary of HEW the authority,
delegable to FDA, to "promulgate regulations fixing and establishing for
any food, ... a reasonable definition and standard of identity, a
reasonable standard of quality, and/or reasonable standard of fill of
container" excepting most fresh fruits and vegetables. FDA has issued a
large number of regulations under the authority of section 402 covering
nearly all processed food. Most of these regulations are concerned with
mandatory standards of identity and fill of container to insure that
consumers receive what they reasonably expect they are buying.
FDA has also issued standards of quality for the major processed foods,
but very little of the standards' contents are concerned with quality that
could be termed cosmetic. The general exception is the requirement that
most processed fruits cannot contain more than a stated percentage of
fruit (usually between 15 and 20 percent) blemished with "scab, hail
injury, scar tissue or other abnormality or discoloration." But none of
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13
the quality standards are mandatory; the processor may market his product
without penalty if only it is labeled as being below the FDA standards.
The objective is disclosure to the consumer as to what he is buying, giving
him the opportunity to make decisions on quality without setting govern-
mental quality standards which are mandatory. Hence, the FDA has chosen
not to use the authority delegated by section 402 to set minimum quality
standards.
Rather, the FDA regulates the quality of processed foods by promul-
gating regulations and tolerances which, in part, define adulteration as
the failure to meet certain quality standards. Because FDCA prohibits the
introduction or delivery for introduction into interstate commerce, or
the receipt in interstate commerce, of adulterated food, it then becomes
a crime to use interstate commerce to sell processed foods which do not
meet these quality standards.
Section 402(a)(3) states that a food is adulterated if "it consists
in whole or in part of any filthy, putrid, or decomposed substance, or if
it is otherwise unfit for food." The FDA and the courts have applied this
section in such a manner as to define and enforce standards to include
32
insect debris which in fact, poses no threat to human health whatsoever.
If section 402(a)(3) were strictly construed and enforced, it would
ban all processed food from interstate commerce. Even with the best of
technology all defects in food cannot be eliminated. Technologists using
only a microscope can find at least minute quantities of decomposed or
moldy substances in almost all processed food. These minute amounts make
the food "in part" filthy and hence adulterated, even though they pose no
33
possible danger to human health.
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14
Further, the courts have uniformly held that 402(a)(3) is to be
34
interpreted in the disjunctive-, that the phrase "otherwise unfit for
food" does not limit the phrase which bans food in whole or in part which
is filthy, putrid, or decomposed. Thus food containing minute amounts of
"filth" could be found to be in violation of 402 (a) (3) even though it is
fit- ' for food, and indeed, even if it is of excellent quality. This
interpretation reads the word "otherwise" out of the statute. But .the
courts have accepted this interpretation, rationalizing that Congress nay
have wanted to set a standard well above what was required for the health
of consumers. A high standard would force the industry to Inspect strictly,
thus reducing the probability that dangerous food might reach the public
even very infrequently. ' x
Thus the dilemma arises that, despite the clearly undesirable result,
the Act if strictly enforced would conceivably ban from interstate commerce
essentially all processed foods. Section 306 of the Act allows FDA the
discretion not to prosecute minor violations, but this only begs the
question as to when to prosecute because there is no guidance in the Act
as to what constitutes "minor" adulteration since all food is to some
degree adulterated. .
To reasonably limit the application of the Act, FDA has established
* ' ' ' * "
what are called "defect action levels for natural or unavoidable defects
in food for humans that present no helath hazard". These are amounts of
defects or filth which are allowed in some categories of food because such
amounts are. often unavoidable. They are established at levels that present
no health hazard to humans. They do not represent an average level of
defects in processed foods, but are higher than actual empirical averages
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15
of such defects. Many of the defect levels are tolerances as to the amount
of insect debris allowed in food, and as insect debris poses no threat to
human health, these defect levels are minimum quality standards which are accom-
modated in our definition of cosmetic quality standards. If a product,
assuming the processor employs good manufacturing practices, is within
the tolerances set by the defect levels, the .FDA will not .take legal action
38
against it.
In order to explore the FDA's contention that defect action levels
apply to damage or debris that does not constitute a human hazard a review of the
literature on the human health hazards of ingested insects has been
conducted.
From man's antiquity insects and other small invertebrates have been
consumed either intentionally as a food source, or unintentionally, hidden
from view, in the fruits, seeds and other foods gathered as nutrients.
The range of insects consumed as food is extensive and includes species
from all major orders including such loathsome forms, by Western standards,
as the head louse. The major criteria in the use of insects and related
invertebrates as a food source appear primarily related to their abundance
and the ease of capture and/or the large size of such individual insects
as aquatic beetles and bugs. Thus even rather small insects that occur
in great numbers in time and place such as the ephedrid flies of brine
lakes were harvested in great numbers by North American Indian tribes, as
39 40
were locusts. ' Bodenheimer has extensively reviewed the use of insects
as food by peoples of the world and points out that in some human popu-
lations insects constitute a substantial source of nourishment. The
natives of tropical Africa have used termites extensively as food and
-------
these dried or fried insects can be found in the markets for sale. The
desert locust is another insect prized as a, food in Africa and can be
found for sale in markets (e.g., Morocco).
i
. Bodenheimer points out that, insects were particularly important to
human populations where large-animal protein was scarce and that these
insects formed a valuable addition of protein and fat as well as certain
minerals, vitamins and salts.' . . ; '.'- . .
Certain insects do serve as intermediate hosts of various parasites
which, when consumed with the insects may continue to develop in humans.
For example, the spiny headed worms, Acanthocephala, utilize as intermediate
hosts various beetles and other insect species.- On rare occasions these.
rms have been reported as parasites in humans. Certain tapeworms of
bgs and rodents which utilize fleas and other insects as intermediate
hosts have' been reported in man, particularly in children. E. nana which .
is capable of undergoing autoinfection in humans and is a normal parasite
of rodents may be transmitted on occasion to humans by grain beetles
Tribolium spp. which serve as excellent intermediate hosts in the laboratory.
Contact between rodents infected with tapeworms and grain or grain products
41
infested with the beetles would be the potential route of infection.
Treatment for these tapeworm infections is relatively safe and constitutes
no serious threat to health. Additionally, cooking of the insects, which
often takes place in processing, would eliminate the threat of transmission.
Ron Taylor, a forensic toxicologist, has studied the use of insects as
food for several years. Taylor found that some people, chronically exposed
to cockroaches develop allergies. However, Taylor found no evidence of any
allergies to insect parts in processed food, nor has he found any toxins
in insects that would present a health hazard to humans.
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17
Thus, while some insects and associated debris could be a health
hazard to humans under certain conditions, there is no evidence to suggest
that herbivorous insects found in food that has been processed present a
health hazard to humans.
While extraneous inclusions in food which are within the defect action
43
levels are not hazardous to humans, health hazard is not a criterion
used in establishing these defect levels. Instead, the levels are based
upon the processing industry's technological ability to remove, through
whatever means, the inclusion (defects). The levels are subject to change
44
as technology or new. information develops. The FDA states that the
defect levels have been and will continue to be reduced and that the food
industry has a continuing responsibility to minimize even innocuous defects
, 1 . 45
in food.
The courts have accepted the defect levels as having the force of
law. FDCA does not provide authority for FDA to set administrative
tolerances for filth, and one court, although basing its decision on an FDA
46
defect level, questioned the scope of the validity of the defect levels.
But a substantial majority of the courts accept the defect levels as
47
dispositive. The courts recognize that they do not have the expertise
to know what standard of food quality is necessary for the public health
nor what performance can be expected from the processing industry. As
a minimum, recent decisions show that courts accept the defect levels but
49
imply that they are not bound by them.
The FDA has not adopted defect levels for many processed foods. When
a processed food which is under prosecution as adulterated does not have
an action defect level, the courts interpret the words "filth, purtid, or
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18
decomposed substance" in their ordinary rather than any scientific meaning.
The courts have emphasized that the sensibilities and esthetic feelings
of consumers are protected by the Act. Without defect levels to guide
*
them, courts often look to expert witnesses to inform them as to what
52
levels of defects are "usual" or "unavoidable." If the contamination
is "unavoidable," courts are likely to label,the defect as de minimis,
below the concern of the law, and find no adulteration. This approach
implicitly adopts the same criteria the FDA used to establish its defect
levels.
But being beyond the narrow objection of de minimis, insect fragments
54
in other than infinitesimal amount are "filth" even without a danger to
health. This would be particularly true for any visible insect fragments.
Nearly all the FDA defect levels are-set at amounts of filth indiscernible
to the human eye, and to our knowledge, there exist no cases that hold
that processed food with visible insect debris is not adulterated regardless
of whether it is in a category to which a defect level has been assigned.
Hence by recognizing consumer sensibilities and by adopting a meaning of
filth which does not include any element of potential human harm, courts
have interpreted FDCA as including cosmetic quality standards with respect
to insect debris.
There are circumstances under which food which is within the defect
action levels would still be in violation of FDCA. Section 402(a)(4)
states that a product is adulterated "if it has been prepared, packed, or
held under insanitary conditions whereby it may have become contaminated
with filth, or whereby it may have been rendered injurious to health."
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19
To constitute a violation under 402(a) (4), the court in Berger v. United
States held that it is sufficient that the manufacturing conditions "would
with reasonable possibility result in contamination." A "mere possi-
bility" of contamination is not enough, but it is certainly not necessary
that the food actually be contaminated. The focus of section 402(a)(4)
is on the conditions of manufacturers; the objective is to prevent
adulterated food by condemning the conditions under which it could be
produced.
In 1969 the FDA promulgated regulations applicable to the entire
58
food industry, called good manufacturing practice (GMP) regulations.
FDA's'objective was to provide detailed standards as to what is and what is
not a violation of section 402(a)(4). The regulations specify proper
practices relating to plant construction and design, the surrounding
grounds, the equipment and utensils, sanitary facilities and their control,
maintenance, animal and vermin control, raw material handling, packaging,
and personnel work procedures. The FDA intended that the GMP regulations
have the force of law and that a violation of one of them would be a viola-
tion of section 402(a)(4). Immediately after they were issued, industry
lawyers scrambled to argue that the FDA had no authority to endow the
regulations with legislative status. They maintained that the regulations
could at most be guidelines for the industry which were not binding on
59
the courts.
The FDA has made it clear that violations of the GMP regulations will
bring prosecution and the FDA has a high percentage of convictions under
section 402(a)(4). But the courts response to the GMP regulations has
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20
not been clear. Courts have acknowledged the existence of the GMP regu-
lations, but have grumbled that they are generally inadequate because
they are too vague. Generally courts have not mentioned the regulations
in their opinions, but have continued to apply the Berger "reasonable
possibility" test.62
While the FDA recognizes that defect action levels do not refer to
contaminants that are hazardous to human health and are not reliable
indices of processing plant sanitation, it is FDA policy to "periodically
lower (defect action levels) as technology improves". On the other hand
this statement is balanced with the FDA declaration that,
The alternative to establishing natural defect levels in some foods
would be to insist on increased utilization of chemical substances...
(and)...the very real danger of exposing consumers to potential
hazards from residues of these chemicals, as opposed to the
aesthetically unpleasant, but harmless natural and unavoidable defects
Pimentel, et al., have shown that for broccoli and spinach, defect
action levels for insect debris has become more stringent over the years.
Between 1938 and 1973 the defect action level.for aphids, thrips and/or
mites in broccoli was 80 per 100 grams. Currently the defect action level
is 60 per 100 per 100 grams. In the 1930's the defect action level for
aphids in spinach was 110 aphids per 100 grams. Currently the defect
action level is 50 per 100 grams. The defect action level for leaf miners
in spinach was 40 per 100 grams in the 1930's. Currently it is 8 per 100
grams. Pimentel et al. report that one of the effects of tightening up the
defect action level for leaf miners in spinach has been the increased use
of insecticides. They conclude that,
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21
Evidence has been presented that suggests that FDA's ad hoc policy of
reducing tolerances in food for small insects that offer no known
threat to public health contributes to increasing health hazards
from pesticides, deducing environmental quality, using more energy
for pest control, and increasing the economic cost of food. Therefore,
reducing tolerances for small herbivorous insects in foods to improve
the "cosmetic appearance" of the food appears not to be in the best
interest of society and this nation.^
Contractual Standards
The FDA regulations may be used to justify quality standards that
are written into contracts. For example, according to Stanley D. Ray,
Agricultural Commissioner for the California County of Stanislaus, where
food processing is a major industry,
"The contracting system between growers and processors does have some
effect on pest contamination and the related use of pesticides. The
requirements, however, are dictacted by strict Pure Food and Drug and USDA
regulations, and growers and processors cannot afford to have their
commodities condemned because of insect contamination." Additionally
James Bell, Executive Vice-President of the Canners' League of California,
an organization which represents many marketing cooperatives and small
independent canneries., told us that contamination by field insects and
insect damage was a major problem for canners because of "consumer standards
and behavior and FDA standards."
There is no way in which the FDA regulations can be easily translated
into insect-related quality standards for the grower, especially since all
insects must be considered potential contaminants whether defect action
levels for them have been promulgated or not. Nor are just the fresh produce
standards followed in the case of produce that is used as an input for
processing. The most important quality standards are those that are
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22
specified in contractual agreements between processors and growers. The
quality standards for insect and insect danage specified in such contracts
are usually much more stringent than state quality standards for fresh
produce.
A 1971 contract form from the Canners League of California for
tomatoes specifies that the buyer may reject the entire shipment if more
than 1/2 percent of the tomatoes contain any worm or worm damage that
penetrates the flesh of the tomato. A Hunt-Wesson Foods, Inc. tomato
contract specifies that the buyer may reject the entire shipment if any
worms or worm damage or insect infestation is present in the flesh, core
or stem cavity of any tomato. A Canners League contract^for peaches says
that the buyer may require peaches to be free of worms, worm damage,
parasite or insect damage, and San Jose scale and may reject the entire
shipment if there are more than one percent wormy or worm damaged peaches.
Stokely-Van Camp, Inc. which contracts for frozen vegetables specif-
ically requires that produce, be delivered, "in the condition buyer may
require, in order to meet the tolerances permitted by and requirements of
the United States Food and Drug Administration and in all respects conforming
to any applicable Pure Food & Drug requirements of the state or political
subdivision thereof in which this contract is to be performed and the crop .
is to be processed". From this passage one might get the impression that-
FDA places specific quality requirements on produce at the point of
delivery to the processor, which is not the case. It can only r.efer to
the exceedingly vague requirement that input produce from the grower does
not contain a level of insect contamination which would result in the
processed output exceeding the FDA defect.action level for insect debris.
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23
A 1974 Stokely-Van Camp contract for frozen spinach contains the additional,
appended provision that, "Any lot of spinach infested with insects including
worms or aphids or seriously damaged by any of the above defects (which
includes insect damage effecting an area of one square inch on leaf or
stem) beyond the level normally accepted in the frozen spinach industry,
may be rejected by Buyer."
*
These stringent contractual standards for insect debris and insect
damage may be justifiable, after the fact, on the basis of FDA regulations,
but there is no reason to believe that these standards are primarily
motivated, in the first place, by the FDA regulations. The FDA regulations
are based upon "good industry practice" not vice versa.
CONSUMER ATTITUDES
The other major reason given by industry spokesmen for the tough insect
quality standards, is consumer attitudes. It is asserted that consumers
demand cosmetically perfect produce and would not stand for processed
produce which showed signs of insect damage or contained insects or insect
t
parts. There is undoubtedly a large measure of truth to this assertion,
although systematic studies of consumer attitudes toward insect contamination
are non-existent. Additionally, it should be noted that many of the insects
which are so strictly controlled by the contractual standards would not
be detectable in many forms of processed food even if they were present
at levels far in excess of current contractual levels, except, of course,
by careful microscopic examination.
It should also be asked to what extent current attitudes of consumers
are endogenous to human nature and to what extent they are the result of
promotional activities by the food industry itself. The United States
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24
Department of Agriculture estimates that in fiscal year 1962 1,200 agri-
cultural groups in the United States spent a total of $86 million to
68
promote agricultural products. Among all California marketing orders
advertising and promotion costs averaged about 69 percent of total
69
expenditures in the decade 1960-70. John A. Jamison notes that, "Growers
have generally been very optimistic about advertising and promotion through-
out the post-World War II history of marketing orders. Demand expansion
programs have seldom been met by the vocal opposition that has accompanied
quantity control programs. The very fact that the results of these
promotional efforts can seldom be measured seems to encourage rather than
discourage their use. ' ...the great faith of producers in such programs
seems to be based principally on two premises: (1) that these efforts
must be beneficial because advertising is so widely practiced and supported
in the case of product advertising vs. brand-name advertising. Furthermore,
the effect of this promotional atmosphere may be to raise the overall
quality expectations of the consumer for all produce.
Consumer attitudes toward insects in food may also be related to
more basic cultural values. In a review of "entomophobia", the irrational
fear of insects, Helga and William Olkowski comment,
A review of the literature on entomophobia and personal discussions
with a phychiatrist have confirmed our impression that the basic
syndrome is one of fear of contamination, penetration, and/or
filth. We find people who take a 'disinfectant' or sanitizing
approach to gardening. In some cases it seems to.be the germ theory
gone astray....This general attitude may be extended to life
generally, the natural world is feared, it is repulsive, dirty....
These attitudes are not at all helped by government regulations that
refer to insect parts as filth, lumping them together with rodent
droppings, the inference being that any insect part is evil whether
from beneficial or pest species.
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25
Of course, less acute aversion to insects may be thought of as part
of the accepted cultural norm. However, to the extent that consumer
aversion to insects is based upon irrational fear or ignorance, it can be
countered by informational and educational programs. An intrinsic aspect
of such programs should be not just how insect-related quality standards
affect consumers directly, but how they affect other segments of the
society and social welfare in general.
QUALITY STANDARDS AND SUPPLY CONTROL
There are other possible reasons for the maintenance of extremely
stringent contractual quality standards, as well as fresh produce standards,
besides consumer attitudes. The contracts are written in such a way that
the quality standards can be used as a mechanism for regulating the flow
of the supply of raw produce to the processing plant. In periods of short
supply quality standards may be relaxed, or below quality produce may be
accepted with a penalty loss to the grower. In periods of peak supply,
below quality shipments may simply be rejected.
s
In tesitmony before Senator Gaylord Nelson's U.S. Senate Subcommittee
on Small Business hearings on "Corporate Giantism and Food-Prices" in
1973, Ruben Reyes, of the Cannery Workers Organizing Committee, stated,
I know that when I worked as a weightmaster for the Libby, McNeill
and Libby people for ten years, I know that the grading procedures
that they used are not overseen by the state or any regulatory
agency. In other words, the plant, itself, pruchases the product
and they do whatever they want in regards to grading it and paying
the farmer.
I know that for the ten years that I was a weightmaster, the company
I worked for was ripping off the farmers for at least $50,000
$60,000 a year in their deliveries on spinach, altering the grades,
and by altering the grade of spinach they were purchasing. I have
written evidence by some of the company employees that were doing
the purchasing...they were ripping off the fanner.
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26
The quality control that the companies all have are under their control.
In other words, there is no outside agency to oversee the quality
control work done by the companies themselves. They grade the product,
they buy the product, they grade it to whatever category they want
to and they sell it. It can be the worst product in the world but
they can sell it as prime stock because there is nobody there to
stop them.72
It is not strictly true that there are no outside agencies to oversee
quality control, state inspection on the input side and FDA regulations on
the output side set lower bounds for quality. But, Reyes1 remarks suggest
that between these lower bounds and the upper bounds set by contract
provisions, processors may exercise discretion in adjusting the enforcement
level of quality standards to meet their economic requirements.
In Table 1 we have summarized the quality standards for several
commodities that prevail under the various systems we have described. It
can be seen that the quality standards specified by private marketing
organizations tend to be more stringent, more specific and more comprehensive
than those promulgated by public agencies.
As indicated, quality standards of all kinds are written by and
primarily in the interest of producers, processors, and retailers. The
preferences of the consumer may be given recognition but, in fact, consumers
have had little to say about the development of the current system of
quality standards. However, even less consideration has been given to the
possible consequences of quality standards on the welfare of agricultural
workers, the stability of the agro-ecosystem and the general environment,
or the long-term economic and physical health of the public. While the
current system of quality standards may benefit some groups, they may
actually be a detriment to other groups that have had no influence in
devising the system.
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As Cha late Senator Philip-Hart observed, "You can make 'certain book
that consumers will elect to have unblemished fruit unless and until they
become aware that the price of unblemished fruit is dead'farm workers."
COSMETIC QUALITY STANDARDS SUMMARY
As we stated earlier (pg. 11), it would seem reasonable to define a -
"cosmetic1* quality standard, as "one that refers to superficial damage (
-- = - . - : - .'!
to or alteration of the exterior appearance of the commodity; damage or
alteration which does not significantly affect the taste, nutrition or . !
storage capacity of the produce". The state quality standards for fresh .'
~ . »
produce do not seem to be, primarily cosmetic standards. Rather they set .
m-i-n-i-m'm levels for maturity of produce and prevent misrepresentation in ;
packaging- and labeling. However, the actual effective quality standards,
which are established and enforced by marketing organizations, with input
from retail sellers, often contain considerable and significant cosmetic
quality aspects.
In the case of processed produce, the quality standards that ar%
established by processing firms and enforced through contractual agreements
with growers often contain cosmetic quality aspects, especially in. regard
to insect parts, which are sometimes justified by referring to Federal
Pood and Drug regulations. ...
The additional proviso should be made, that damage due to insects or
other arthropod pests or their effect on produce appearance can only be
considered cosmetic if the specific pest does not in some other way
significantly disrupt the production system for the crop.
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15. Alison Masson, "The Economic Effects of Marketing Orders", in Report
on_ Agricultural Cooperatives, Bureau of Competition, Federal Trade
Commission, Washington, D. C., 1975.
16. J. P. Doll, V. J. Rhodes and J. G. West, Economics of Agricultural
Production, Markets, and Policy, Richard D. Irwin, Inc., Homewood -,
Illinois, 1968, pp. 491-513.
17. U. S. Congress, House Committee on the Judiciary, Subcommittee on
Monopolies and Commercial Law, Hearings, Food Price Investigation,
93rd Congress, 1st Session, June, July, 1973, Serial No. 15, p. 711-715.
18. "Rules and Regulations Governing Fruit Packed for Marketing by Sunkist
Growers, Inc. Under'its Trademark Sunkist, Excel, SK, and Red Ball
and Under Association Non-advertised Brands," Sunkist Growers, Inc.
November 1, 1967.
19. Fond, op. cit., December 4, 1973, p. 80.
20. Tsueio Koto, Assistant Produce Buyer, Co-op, Pers. Comn., Richmond,
California, March 14, 1975.
21. Dressier, op. cit.
22. Bill Ramsey, August, 1974, Salinas, California.
23. Evan Maxwell, "Perfect Produce: Cosmetic Defects Hold Key to Profits,"
Los Angeles Times, August 20, 1971.
24. California Legislature, Assembly Select Committee on Agirculture, Food
and Nutrition, March Fong, Chairman, Interim Hearing, The Shipping
Point Inspection System, December 3, 1973, Riverside, California, p. 70.
25. Cal. Food and Agric. Code p. 41361 (West 1968)
26. 21 USC pp. 301-392.
27. 21 USC p. 341.
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30
28. 21 USC p. 331.
29. 21 USC p. 341.
30. Sec. 21 CFR pp. 10-125.
31. 21 USC pp. 341, 342. .
32. 21 USC p. 342 (a) (3).
33. Ibid.
34. U.S. v. 1.500 Cases More or Less, etc.. 236 F2d 208 (7th Cir. 1956).
35. See Circuit Judge French's dissention U.S. v. 449 Cases, Etc.. 212
F2d 567, at 575 (2nd Cir. 1954).
36. 21 USC p. 336.
37. Anonymous, Current Levels for Natural or Unavoidable Defects in Food
for Human Use that Present no. Health Hazard, HFF 342, HEW-9NS-FDA,
Wash., B.C. 1976.
38. 21 C.F.R. p. 128.10.
39. C. T. Brues, Insect Dietary, 1942 Cambridge, England, pp. 419-422.
40. E. 0. Essig, "The Value of Insects to the California Indians, "
Science Monthly 38(2); 181-186. 1934.
41. C. J. Weinmann, personal communication, Department of Entomological
Sciences, University of California, Berkeley.
42. Ron Raylor, pers. comm., September 23, 1974, Los Angeles, California.
43. Alex McCormick, pers. comm., Compliance Offices, FDA, in San Francisco,
pers. comm., July 31, 1974.
44. 21 C.F.R. p. 128.10 (c) .
45. 38 Fed. Reg. 854 (1973).
46. U.S. v. 449 Cases, etc., 212 F2d 567 (2nd Cir. 1954).
47. U.S. v. 1500 cases, Mora or Less, etc.. 236 F2d 208 (7th Cir. 1956).
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31
48. Ibid., at 211.
49. U.S. v. 484 Bags, More or Less. 423 (F2d 839 (5th Cir. 1970;
U.S. v. 1,200 Cans, Pastuerlzed Whole Eggs, etc., 338 F. Supp. 131
(N.D. Ga. 1972).
50. U.S. v. Roma Macaroni Factory, 75 F. Supp. 1663 (N.D. Cal. 1947.
51. U.S. v. 1.500 Cases More or Less, etc.. 236 (F2d 208 (7th Cir. 1956);
U.S. v. 935 Cases of Tomato Puree, 65 F. Supp. 503 (N.D. Ohio, 1956.
52. U.S. v. 1,500 Cases More or Less, etc., 236 F2d 208, 212 (7th Cir. 1956)
53. U.S. v. Capital City Foods, Inc... 345 F. Supp. 27 (N.D..1972).
54. U.S. v. Cassaro. Inc..443'F2d 153 (1st Cir. 1971).
55. 21. U.S.C. p. 342 (a) (4).
56. 200 F2d 818, (8th Cir. 1952).
57. Ibid, at 821.
58. 21 C.F.R. p. 128.
59. Cody, Authoritative Effect of F.D.A. Regulations 24 (f.A.C.L.J. 195
1969).
60. Alex McCormick, pers. comm., see footnote #16.
61. U.S. v. 1,200 Cases, Pasteurized Whole Eggs, etc., 339 F. Supp. 131,
141 (N.D. Ga. 1972).
62. See U.S. v. H. B. Gregory Co., 502 F2d (7th Cir. 1974); U.S. v.
Cassaro, Inc.. 443 (F2d 153 (1st Cir. 1971).
63. Anonymous, Current Levels for Natural or Unavoidable Defects in Food
fojr Human use that Present np_ Health Hazard, HFF 342, HEW-PHS-FDA,
Washington, D. C., 1976.
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64. D. Pimentel, et^ aL_., "Pesticides, Insects in Foods, and Cosmetic
Standards," Bioscience, in press.
65. Stanley, D. Ray, pers. comm., August 6, 1974.
66. James Bell, pers. consn., August 16, 1974. Sacramento, California.
67. See Appendix A for copies of contracts.
68. Godwin, op. cit., p. 359.
69. Jamison, op. cit., p. 307.
70. Ibid.
71. Helga and William Olkowski, "Entomophobia in the Urban Ecosystem,
Some Observations and Suggestions," paper presented to American
Institute of Biological Sciences, Tempe, Arizona, June, 1974.
72. R. Reyes, statement before U. S. Senate Subcommittee on Small Business,
Hearings on "Corporate Giantism and Food Prices," 1973, reported in
The AgBiz Tiller. September, 1976.
73. Statement of Agribusiness Accountability Project on Occupational
Safety and Health Act of 1970 before U. S. Department of Labor Hearings,
August 23, 1973.
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CHAPTER 2. PESTICIDE USE AND REGULATION IN CALIFORNIA
In considering the relationship between produce quality standards and
pesticide use it will be helpful to divide pesticide use into two broad, but
distinctive categories, rather than a large number of arbitrary ones.
Then rather than attempting an evaluation of the Impact of cosmetic quality
standards on the use of hundreds of materials it will be necessary only to
evaluate the effect of these standards on the general approach to pest
control. This approach is not only convenient, it is also appropriate
because, in fact, two competing concepts of pest control exist and the ability
of the grower to adopt one or the other concept in his overall approach may
be significantly influenced by the existence of cosmetic quality standards.
These two general concepts of pesticide use will be described, and current
status of the two in California will be evaluated. Additionally, the effect
of federal and state pesticide use regulations on grower pesticide use
decisions will be examined.
PESTICIDE USE AND REGULATION IN CALIFORNIA
It is important and useful to examine pesticide use and regulation in
California for several reasons. More pesticides are used for agricultural
purposes in California than in any other state in the nation. In 1973,. 183,657,000
pounds of pesticides were sprayed on 26,618,000 acres of California farm land.
Partly because of this high use, California was one of the first states to
develop a system of pesticide use regulation and it currently has the most
highly developed regulatory system in the country. In fact, the California
system has been looked upon as a model for the development of a Federal
2
system of pesticide use regulation. For this reason, it is important to
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critically examine the California system. Additionally, California is the
leading state in the production of "specialty" crops in which cosmetic
quality standards may play an important role and in which a substantial
amount of pesticide use may be attributable to "cosmetic" pests. California
is the leading producer of almonds, apricots, artichokes, broccoli, grapes,
lemons (second in oranges), lettuce, nectarines, peaches, pears, strawberries
and tomatoes, all crops in which cosmetic quality plays an important role.
Nationwide, fruits and vegetable crops account for 21 percent of agricultural
insecticide use. Many of these crops account for a greater usage of pesti-
cides than would be expected on the basis of their acreage. For example,
apples, which account for 0.07 percent of total crop acreage, account for
6 percent of all agricultural insecticide use. Citrus, which accounts for
0.08 percent of total crop acreage, accounts for 2 percent of all agricultural
4
insecticide use.
In California, where most of the nation's specialty crops are grown,
these crops account for a very significant proportion of pesticide use, as
Table 2 demonstrates.
Thus, while the use of pesticides attributable to the need to
meet cosmetic quality standards cannot be said to be the bulk of agricultural
use, it may be significant enough to have important consequences for public
health and the stability of the ecosystem, especially as an accumulative
process. Furthermore, the average figures tend to obscure the fact that
pesticide use attributable to cosmetic quality standards nay be
relatively highly concentrated, in localized growing regions. Thus, the
agricultural counties of Fresno, Imperial, Kern, Merced, Monterey, San Joaquin,
Tulare and Ventura which comprise only about 20 percent of the area of
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California, accounted for over 60 percent of all pesticide use
in that state in 1974.
PEST MANAGEMENT! TECHNOLOGY
Pesticide use decisions related to cosmetic quality standards are
partially dependent on the pest management technology which is available
and, just as important, is acceptable to the user. Current pest management
technology can be characterized by two basic, and sometimes conflicting,
concepts. These characterizations are general, and are not meant to describe
the specific pest management practice of individual advisors, which consists
of the whole spectrum of possible practical approaches encompassed by these
idealized concepts. The first concept, "conventional chemical control," has
grown with the production and use of agricultural chemicals and has become a
major approach to pest management, especially in the last two decades.
This approach is centered around what is felt to be the pragmatic use
of agricultural chemicals for the suppression of specific insect pest popula-
tions. This often includes the use of chemicals in a preventive or prophylactic
manner and the use of pesticides which have a broad-spectrum of activity,
including toxicity to beneficial insects, and other non-target species and
humans. The efficacy of conventional chemical control has as a total
strategy been seriously questioned in recent years by some entomologists.
For example, C. B. Huffaker and Ray F. Smith of the Department of Entomological
Sciences of the University of California, Berkeley, have written that:
There was (in conventional chemical control) a general
disregard of the fact that even the simplest agricultural
system presents a maze of- delicately balanced ecological
intricacies. Elaborate calender treatment schedules
were developed on a prophylactic basis. Both approaches
not only ignore the complexity of agroecosystems, but
both of them ignored the two giants of nature's own
system of pest control, i.e., over-the-eons-evo I ved
p I an-t resistance and control by natural enemies.
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Since the single objective of the unilateral broad-spectrum
chemical approach was total and lasting destruction of the
pests, serious disturbances soon arose. Target species
counterattacked, developing resistance to one material
after another. Adverse effects on natural enemies and
stimulating effects on some pests have released the
target species to rapid resurgence and caused minor or
innocuous ones .to become serious pests. Increasing dosages,
and more kinds of, and more frequent, chemical applications
have led to pesticide addiction from which .it is difficult
to withdraw. Problems of residues and adverse environmental
effects at places even far removed from treated areas have
led to public clamor against all pesticides.
We do not believe that our insect problems would simply
disappear if we would stop using insecticides but we do not
believe the consequences would be quite as intense,
ubiquitous or prolonged as some would have us believe.
Yet, this public clamor, indeed, threatens to deny the
research needed to assure availability of frpoper chemicals
to save our crops when needed and, as well, to perpetuate
an enlightened, lasting control program.
The unilateral chemical approach has not even had the
prolonged success in the control of the initial insect
targets that was first suggested. Insect problems have
not lessened; they are even greater than before. We
are using more chemicals and against more species of
insects than ever before. Some agricaltural enterprises
are threatened with disaster from mounting pest control
costs, yet poor pest control.^
Table 3 tabulates the most important insect and insect-like pest species
in California and the degree to which they have developed resistance to
insecticides and are involved in resurgence or secondary outbreak problems.
The table gives stunning insight into the breakdown of the chemical control
strategy in California, an area of advanced agro-technology.
The alternative concept that Huffaker and Smith, and others, have pro-
posed is integrated pest management or integrated control. Integrated pest
management strategies attempt to take into account all the relevant factors
that impinge upon the agroecosystem. For example, Pimentel lists: pesticides,
non-target species, pathogens, insects, weeds, pollinators, human health,
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37
biocontrol agents, rotations, soil preparations, fertilizer, diversity,
water, plant density, sanitation and plant genetics as relevant factors.
According to Pimentel, "the total costs, benefits, and risks of the factors
in the system can be evaluated and used as a basis for making sound decisions
about pest control measures." Pimentel concludes that, in general, pesticide
use in the United States could be significantly reduced if,
1. Bioenvironmental pest'controls which were placed with pesticides
. were again put into full practice wherever possible.
2. Some or all of the 60 million acres currently diverted at a
cost of $3 to $4 billion annually were planted to help balance
the increased crop loss resulting from a reduction in pesticide
use. (In recent years this has been done^)
3. A "treat-when-necessary" program based on monitoring pest
populations was . initiated and aircraft spray drift was
reduced.
4. The public were educated to be concerned for the safety of
their fruits, vegetables, and other produce and attach less
importance to "cosmetic appearance."'
While a specific pest may be suppressed by a number of alternative
means, such as chemical control, biological control or cultural control,
integrated pest- management is an overall strategy for maintaining the health
and productivity of the agro-ecosystem. Integrated pest management includes
the option not to control for a pest when it is determined that the costs
outweigh the benefits. As Luck, van den Bosch and Garcia have recently
commented:
This (integrated pest management) represents a change in the
philosophy of pest control: it utilizes and builds upon the
natural mortality that affects any pest population, it tolerates
uneconomic densities of pests and it aguments natural control with
a variety of techniqeus that are tailored to be minimally dis-
ruptive. . . . Thus, there are various techniques and materials
that can be utilized in pest management systems in which knowledge
of the species and their ecosystems permit the integration of
natural and artificial mortality factors in mutually augmentative
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38
programs. These can lead to maximum pest control efficiency with
miminum ecological impact .... Under this concept chemical
control reverts from its present role of a single strategy to that
of a mere tactic.' Confusion of the latter with the former is a
basic reason for much of our current pest control dilemma.^0
The philosophy of integrated pest management, when carried to its
logical conclusion, implies that, in addition to the immediate welfare of
the grower, the welfare of other groups in society should be considered in
pest management decisions. However, it is unlikely that this will be the
case when the pest control advisor is employed directly by, and in the
interests of the grower. As was stated at the 1973 IB? Integrated Pest
Management Conference on Economic Injury Evaluations:
There is often a conflict betaeen farmers and the rest of
society. Farmers on one hand make decisions which directly
affect production costs or yields and thus influence profits
whereas society may consider a pesticide free environment
to be more important than pest control in an individual
field, farm or area. Therefore, we must consider who
benefits from Pest Management Programs; both farmers
and society should benefit from these programs if they
are to be truly successful.
The costsof using pesticides may be greater than the
benefits which we usually associate with increased
yield or better quality because of externalities.
For example, in many of our cost/benefit calculations
we exclude damage to the environment, the hazards in
using pesticides etc., and base our calculations of
benefits only on increased yield or quality.11
Feder and Regev have considered the case in which agricultural pests are
conceptualized as a common property resource and biological interactions and
environmental effects are taken into account. When this .kind of a situation
is mathematically modeled and the pest control decision expected from a
single grower is compared to the decision that would be made as the resulc
of a social optimization rule, the following results are obtained:
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The stock externalities inherent in the decentralized solution
lead to myopic decision rules that are not optimal from society's
viewpoint. An additional external effect for some pesticides is
pollution of the environment by pesticide residue. A centralized
control solution incorporates the population dynamics and environ-
mental effects. The optical decision rule then equates marginal
benefits with monetary marginal cost of control plus the user
cost. The three elements comprising the user cost involve the
effect of the marginal-unit of control on the stocks of pest,
predator and residue.
This is not to say that pest control must be conducted by a central
authority, only that it would be preferable to employ incentives or regula-
tion so. that the sum of individual grower pest control decisions would
approach the socially optimal decision.
While the integrated pest management approach, even when applied for
the direct benefit of a client grower, takes more of the total social welfare
into account than the conventional chemical control approach, there is still
plenty of room for conflicting goals. An economic threshold level of popula-
tion which is determined on the basis of meeting a cosmetic quality standard
for the benefit of the grower may be socially inappropriate if, in addition, .
the welfare of the farai worker or the long-term stability of the agro-ecosystem
not
is/taken into account. Just how such factors are to be accommodated is a
political and economic problem.
SOURCES OF PEST MANAGEMENT INFORMATION
The particular approach to pest management that growers adopt depends on
the availability and the effectiveness of various pest management informa-
tion sources. Von Rumker has studied this problem in relation to com and
soybean growers in Iowa and Illinois. It is clear from the von Rumker study
that the conventional chemical control approach dominates in Iowa and
Illinois corn and soybean farming. According to von Rumker:
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A substantial portion of the corn soil insecticide uses appear
unnecessary or wasteful, while most growers consider their
individual decisions to use a preventive treatment a necessary
protection against possible yield losses.^
On sources of pest management information von Rumker comments:
There are currently no effective, unbiased channels through
which growers could receive such information regularly and in a
timely fashion from the public agency originators of the
information.^-
The available information indicates that the situation iri California
with regard to pest management information is similar to Illinois and Iowa.
However, there are some notable differences. In California integrated pest
management information is available not just from some public sources but
it is also available from some private independent pest management consultants.
Most of these private consultants, who have no ties to chemical companies
and sell their professional advice rather than chemicals, are members of
the Association of Applied Insect Ecologists (AAIE), a professional society
which explicitly endorses integrated pest management. The AAIE defines
Integrated Pest Management as "The modern concept of careful monitoring of
crops for insect populations, recognition of economic damage thresholds and
avoidance of pesticide applications on simply a preventative schedule. IPM
includes environmental and cultural management, biological control as well
as the careful use of pesticides." AAIE's professional and general member-
ship numbers about 100. This can be compared to the force of state
licensed pest control advisors employed directly by private agricultural
chemical companies in California. To determine this Dr. Christine Merritt,
a Staff Research Associate in the Department of Entomological Sciences,
University of California, Berkeley, has polled the 133 California agricultural
chemical firms listed in the directory of the Western Agricultural Chemical
Association. Ninety-five of the firms responded to the poll: 89 percent of
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41
the firms employed agricultural pest control advisors; the total number of
the advisors employed by the firms was 1648. This was a slight underesti-
mation because one of the largest agricultural chemical companies did not
specify the number of advisors it employs. If the average 17.35 advisors
per firm is projected to all 133 firms the number of advisors would be
about 2300. Thus, in the private sector the number of pest control advisors
that would tend to favor the conventional chemical control concept far
out-numbers those who endorse integrated pest management. In fact the top
five agricultural chemical firms alone employ in excess of 550 advisors,
more than five times the membership of AAIE. The bulk of California's pest
control advisors are in the direct employ of private agricultural chemical
companies and they far out-number the combined advisors, private and public,
that are available in California to provide independent pest management
j * 16
advice.
Gutierrez and Loew have polled 1200 California cotton growers on their
preferred source of pest management information. Of the 415 growers who
responded, 66 percent listed chemical company representatives as the pre-
ferred source, 13 percent listed independent pest management consultants, and
17 percent listed themselves. Fifty-seven percent of the growers reported
using a prophylactic miticide, a strong indication of a conventional
chemical control approach. Gutierrez and Loew could detect no correlation
between the grower's decision to use integrated pest management and grower
experience or size. The 13 percent figure for the use of independent pest
management consultants may be atypical because integrated pest management
has made more head-way into cotton than any other crop in California.
Based on an intensive survey of pest control practices in cotton,
alfalfa hay, processing tomatoes, and grapes in Calfiomia, Wayne Willey
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determined that, in 1972,8.7 percent of these crops, by acreage, were under
independent pest management. It was also determined that with sugar beets,
nuts, deciduous fruits, vegetables, melons, and alfalfa seed, 6.7 percent
of the crops were under independent pest management. The total revenue of
the independent pest management consulting industry in 1972 was $3 million.
18
This compares to a total pest control industry revenue of $600 million.
Data from a survey of the California citrus industry indicates that
about 6 percent of California orange growers utilized independent pest
19
managers in 1972.
In evaluating the factors which determine growers' decision to adopt, or
not to adopt, integrated pest management, Willey observes that:
Several consultants indicated that they would not seek to
expand the acreage served until they become certain that
existing clients are satisfied. The implication is that
the growers must develop enough confidence in the consultant
so that an occasional less than "satisfactory performance
will be overlooked. Such poor performance will inevitably
happen- to even the best consultant due to the complexity
of the agroecosystem that he attempts to control. The
crux of the problem vis-a-vis the grower's confidence is
that when poor performance occurs, the tendency is to
place the blame on the consultant's low pesticide use
at certain times when pest populations are present.
However, "the fact often is that a heavier use of pesticides
would not have provided economically viable control.
Subject to massive pesticide advertisement via the
media and salesmanship centered around an exploitation
of the grower's ever present fear of losses, the tendency
among growers to single out the consultant's low pesticide
use p.ersists. Instances in which pesticide salesmen
have approached growers immediately after a consultant has
indicated that a pesticide treatment should not be
undertaken have occurred. The salesmanf's strategy in
these cases was to "fear talk" the grower into a lack
of confidence in the consultant's judgement. Such fear
is easy to exploit when a pest is present and can be
visually identified for the grower by the salesman. Thus,
the uncertainty to the consultant which accompanies his
attempt to gain the confidence of a sufficient number of
clients i£iQ2 key factor in the availability of information
serv i ces . A
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It should be added chat the existence of stringent cosmetic or pest
contaminant quality standards can only magnify the "fear factor" whether
it originates in the promotional activities of the pesticide salesman or
the mind of the grower. In this regard, we know of at least two reported
cases where growers deliberately sprayed beneficial insects because they
were afraid of having marketing organizations find insect "contamination"
in their fields. In one case a Syrphid fly-larva (an aphid predator) was
Interpreted as a looper infestation by a lettuce packer, resulting in re-
jection of the crop; in another case a tomato grower sprayed his crop because
21
of an "infestation" of lady beetles.
REGULATION OF PESTICIDE USE IN CALIFORNIA
California has a well developed system of pesticide use regulation.
Pesticide dealers, pest control operators, and pest control advisors are
licensed by the State Department of Food and Agriculture. Pesticide use
permits must be obtained by operators and users in the case of restricted
substances from County Agricultural Commissioners and pesticide use reports
must be filed with the County Commissioners. The County Commissioners are
also responsible for enforcing pesticide use regulations, including the
State farm worker safety regulations which preempt those promulgated by the
22
Environmental Protection Agency.
California provisions for the protection'of farm-worker health are more
comprehensive than the federal EPA provisions which apply to most states in
which state provisions do not exist.
According to
23
Greenstone, the California provisions, which are promulgated by the
California Department of Health, are similar to the kind of provisions non-
agricultural workers enjoy under the federal Occupational Safety and Health
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44
(OSHA). Greenstone considers the exemption of agricultural workers from
unjustifiable discrimination against farm workers.' According to
Greenstone:
The Environmental Protection Agency has not, by its promulgation
of pesticide reentry regulations similar in form to those originally
. a-nd tentatively formulated by OSHA, actually exercised authority
over agricultural working conditions, because its standards en-
vision workers as only one element in an ecological balancing
process. . . . EPA can give worker protection no greater weight;
protection of the^ work force is defined as incidental to a con-
sideration of the" environment as a whole. . . .No language man-
dating a balance of economic, social, and ecological benefits can
replace the assurance of a workers' bill of rights. Worker health
and safety *r>A the legislation which guarantees it may not be
compromised, as OSHA early recognized.^
ENFORCEMENT .
While the California farm worker safety provisions come closer to the
SEA ideal than federal EPA provisions, several observers have expressed
reservations about the efficacy of enforcement by California County Agricultural
Commissioners.
Cunning, as well as others, is concerned about the political origin .
of County Agricultural Commissioners, noting that they are "hired and fired
by the county board of supervisors, which in rural counties generally is
dominated by local growers." The Commissioners see themselves as politically
neutral. In response to a recently proposed bill which would have required
the election of County Agricultural Commissioners "to assure agricultural
workers are given as much attention as the growers," the California
Agricultural Commissioners Association stated that the commissioners "are
the least politically-oriented group of any, and if we had to start playing
25
politics our office simply would not function as well."
Cunning also noted that when pest control operators violate regulations,
sanctions are weak. A criminal sanction exists, but it is rarely used. Even .
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45
when it is sought by commissioners, district attorneys throughout California
26
have been reluctant to comply. Dunning noted the use in Imperial County
of mass appeals' by the Agricultural Commissioner:
For example, pest control operators have been asked to avoid
spraying fields with workers in them; to take precautions against
the drift of sulphur, an irritant to the eyes, onto residential
properties; and to avoid applications which do not conform to the
product's registration, unless special authorization is obtained.
All the acts cautioned against are unlawful, and the warnings
suggest that the Agricultural Commissioner's office has had reason
to believe they were taking place with some frequency. A general
warning may be helpful in curbing such violations, but the use of
this technique also seems to reflect the present lack of any 'middle
level1 sanction for violations by pest control operators. 7
28
Howitt reports the following information on the level of enforcement
activities of all County Commissioners in California:
Fiscal Year District Attorney Court Citations License Suspensions
Hearings Issued
1969-70 2 3 56
1970-71 6 3 70
-1971-72 - 2 70
1972-73 - 23 117
This level of enforcement activity is in reference to several thousand
pest control advisors and applicators. Chronic and acute pesticide poisoning
remains a substantial problem for California's farmworkers and others
associated with pesticide usage at this current level of enforcement._
Dunning also found the job permit system, upon which compliance with
pesticide use regulations is based, to be cumbersome and inadequate.
According to Dunning:
With the manpower available, this is inevitable, for the quantity
of applications forbids meaningful individual review within the
time available. Furthermore, there is insufficient information
upon which to base a decision. Permit applications presently
show only the pesticide(s), location of the area to be treated,
grower's name and address, total acres to be treated, commodity,
pest(s), type of material (dust, spray, or other) and method of
application. This enables one to determine some basics on label
compliance, but little else. If pesticide use were limited to
"need," for example, and if the permit system were to be locked
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46
to for enforcement of that concept, then the regulatory officials
engaged in review of permit applications would have to have, far
more information in order to make intelligent decisions. In fact,
given the complexity of pest control, it would probably be necessary
for an official to visit the field to be treated under the permit
for which application is made. Ultimately the most serious
contemporary need in pesticide use is sound judgement exercised
by decision makers with ecological awareness, and this need will
not be met simply by insistence upon filling out and review of
forms.29
Indeed, Agricultural Commissioners report that they needed more man-
power for field inspection, and that they do not have adequate resources
to enforce worker safety regulations.
LICENSING PROCEDURES
Imperial County pioneered all licensing of pest control advisers. Pest
control advisers are required to register, pass a qualifying examination
and pay a license fee. It might be thought that the examination require-
ment would improve the quality of pest control advice available to growers
but, according to Dunning, "the examination specified refers to knowledge
of pesticides, not pest control . . . ." No one in Imperial County who had
been engaged in the pesticide business has been excluded as a result of the
examination.
Since the Dunning study, the examination requirement for pest control
advisers has become a state-wide requirement. Barry Wilk, who has a Masters
Degree in entomology and has worked as a graduate Research Assistant and
Staff Research Associate in entomology for five years, took and passed the
state examination in 1975. Wilk felt that anybody who carefully read the
study guides provided by the state could pass the examination and that
passage of the examination would not qualify the individual to be a
competent pest control advisor. Wilk spoke to another person taking the
exam who stated that he had taken a course at Modesto Junior College in
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47
which he had been drilled in many questions which were identical or similar
to those which appeared on the examination. Additionally, a grower friend who
had previously worked for a major agricultural chemical company in Los
Angeles, offered Wilk a large stack of past exam questions when Wilk
informed him that he intended to take the examination. Wilk said that his
impression was that these questions were available to the employees of
- 32
agricultural chemical companies who were preparing to take the examination.
Ironically, during the course of our investigation, we were refused copies
of past examinations by CDF&A officers on the grounds that the validity of
the examination depended on this security measure.
Wilk proposed that a more valid certification procedure would require
a series of courses in pest management, similar to certain pest management
courses taught at the University of California, supervised field experience,
and" an examination which required the individual to explain how he would
deal with specific pest management situations and scientific justification
for the proposed course of action.
Everett Dietrick, a commercial insectary owner and licensed pest
control advisor, told us that his secretary (clerk, typist, receptionist)
with no prior pest management training, acting on a dare, studied for the pest contrc
advisor's examination, passed it and is now a licensed advisor. It would
seem, from what has just been described, that the examining and licensing
standards for California pest control advisors hardly rank with those
34
required in high quality professions. Dunning proposes that the up-grading
of pest control advisor quality could be approached by the simple measure
of making it illegal for any licensed pest control advis°r to be an enployee
of, or have financial interest in any agricultural chemical company, or any
company which has a financial interest in any pest control technology.
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STATE ACTION
Dunning found basic failures at the state level in taking the initiative
on pesticide policy. In 1971 the State's Director of Agriculture determined
that integrated control would be officially supported as the best method for
dealing with agricultural pest problems, but Dunning notes that little has
36
been done to implement this decision.
According to Dunning the Department of Food and Agriculture has also
failed to follow through on state legislation, enacted in 1969, which re-
quired the development of "an orderly program for the continuous evaluation
of all economic poisons (pesticides) actually registered" in order to
"endeavor to eliminate from use in the state any economic poison which
endangers the agricultural or nonagricultural environment, if not beneficial
for the purposes for which it is sold, or is misrepresented." The Department
of Agriculture has stated that it simply did not have the resources to carry
out such an ambitious program. However, the Department has been
criticized by the State's Legislative Analyst for wasting its resources:
One reason the registration workload is not handled on a timely
basis is because the registration staff spends a large portion
of its time correcting errors in the applications for registra-
tion or requesting copies of the proposed label. This time-
consuming and expensive practice of correcting errors should be
curtailed. It is the responsibility of the registrant prior to
submitting the application to assure that it is correct. The
Department now permits itself to be used as a service arm of
the industry which it is to regulate. Much of the time which
should be spent implementing new statutory policies is diverted
to performing a service for the most inefficient registrants of
economic poisons.38
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49
THE IMPACT OF PESTICIDE USE IN CALIFORNIA
The ultimate purpose of this study and the reason for preparing this
report has been to ascertain, if possible, whether statuatory or privately
imposed produce quality standards increase the hazard posed by pesticides
(insecticides in particular) to human health and the environment. To do
this we chose California as our laboratory because it was convenient to
us, it has a great diversity of crops which enter the specialty fresh
produce or processing markets, it has pioneered through legislation and
private action the imposition of cosmetic and pest contamination standards,
and it is the nation's most intensive pesticide user.
Pesticides are hazardous; for example the modern synthetic insecti-
cides are overwhelmingly either''nerve poisons or cholinesterase inhibitors
which affect exposed insects and humans in exactly the same ways. In
addition, some of these insecticides are actual or suspected carcinogens,
teratogens and mutagens. The other classes of pesticides such as the
.herbicides, fungicides and rodenticides also include materials which are
hazardous to human health and to the environment.
There is a considerable literature on the impact of pesticides on
wildlife and other lower life forms ranging from fish, birds and mammals
39 40 41
to honey bees. * ' Suffice it to say, this impact is often severe.
On the other hand there is a paucity of organized information on the
effect of these materials on the food chains and food webs in our agro-
ecosystems in which arthropods play a fundamental role. This in unfortunate
because much of the ecological backlash, and hence the resultant treadmill
effect of pesticide usage in crops (and other resourcas too), results from
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50
the disruption of insect communities by insecticides and other pesticides
(e.g., fungicides).
As for human health impacts, there is no existing systematic review of
evidence concerning the effects of pesticide use on the health status of
farmers, farmworkers, pesticide applicators or the general public, either
for California or the nation as a whole. However, the official report
42
of more than 1300 human pesticide poisonings in California in 1975 indicates
that adverse effects of pesticides on human health is a serious and continuing
environmental problem deriving from crop protsction. Indeed, if we
accept the public pronouncements of Dr. Ephraim- Kahn, Chief, Epidemiological
Studies Laboratory, California Department of Health, that the reported
poisonings only represent about 1% of the actual cases of pesticide caused
43
intoxication, the list of "official" poisonings is but the tiny tip of
a disturbingly large toxic iceberg. Dr. Kahn not only supports his con-
tention, with data developed fay himself, but he is further backed by a
44
1969 study by the California Department of Health which revealed that
fewer than 1% of farmworkers with pesticide-caused illnesses serious enough
to require treatment reported their illnesses via the worker's compensation
channel. And, this is the channel through which statistics are largely
obtained to compile the "official" annual reports of illnesses.
A later study by Richard Howitt of the Department of Agricultural
Economics, University of California, Davis reported a lower discrepancy
between actual pesticide-caused illnesses and those reported through
workmen's compensation. In this early assessment of his data Howitt
indicated that roughly half as many illnesses were reported as actually
45
occurred. However in recent testimony before a hearing of the California
Senate Committee on Health and Welfare, Howitt indicated that only about
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51
5 percent of the illnesses are reported. The findings of Kahn and Howitt
are highly disturbing for they clearly indicate that there is a very high
risk of illness from occupational exposure to organophosphate and other
pesticides. In fact, comparing the number of working hours lost to pesticide
illness per 1,000 man hours (5.25 hrs/1000 man hrs.) with that in the other
most hazardous occupation in California,"the construction industry.(4.9 "
''.'' 47 - -
hrs lost to illness and injury/1000 man hours), the farmworker appears to
have one of the most, if not the most, dangerous occupations in California.
There is also evidence of widespread occurrence of chronic, low grade
(virtually symptomless) intoxication among farmworkers (and by inference.
others in the general populace, too) which certainly magnifies the pesticide
poisoning problem.
A statement by Dr. Thomas Milby points up the nature of the chronic
toxicity problem. Milby states: "our research leads us to suspect,
furthermore, that there is probably an even more common form of adverse
effect, one which is even slower to develop and even subtler in its
manifestations. The individual may not feel nauseated, dizzy, etc., he
may not lose any time from work at all,, but he may have a little more
difficulty getting to sleep at night. His appetite may be a little less
hearty than it was. And there may be a gradual impairment of his hand-eye.
coordination and other neuromuscular functions, so that he is able to
pick 10Z fewer oranges or peaches, say, than formerly. The affected
individual may not notice the difference at all, or if he. notices, .will
most likely shrug and ascribe it to 'getting older.' Impairment of neuro-
i
muscular functions is not measurable through the cholinesterase test
referred to a moment ago, but we in California are working on new methods
48
for directly measuring these kinds of pesticide 'poisoning'."
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52
Several studies in the. U.S.A. and abroad involving human and animal
subjects indicate that chronic exposure to organophosphate and other
pesticides can have neuromuscular effects, that it can affect such factors
as serum creatine phosphate, glutonic oxalic transaminase, cholesterol, and
urine protein levels, and can cause damage to such organs as the liver and
49,50,51,52,53,54,55,56,57,58,59,60 _ ...,.
kidneys. »>»»»»»»»»» xhe possibility of carcinogenic,
teratogenic, and mutagenic effect is another factor that must be taken
into account in pesticide usage.
To sum up, then, there is-evidence for several adverse health effects
resulting from chronic pesticide exposure. These include damage to the
nervous system with such accompanying effects as muscular weakness,
difficulty in sleeping, damage to the liver and kidneys, and possible
development of cancer. These effects can occur even when no acute symptoms
(such as those accompanying cholinesterase inhibition) are present, and may
occur even when cholinesterase depression is not detectable. Virtually, no
work has been done which would indicate a dose-response relation for any of
these effects. At this time we can only conclude that at present levels
of exposure, long-term contact with pesticides is likely to produce one or
more of these effects among a large number of persons occupationally
exposed. Any sizeable reduction in pesticide use, therefore, would probably
make a goodly contribution to the health of persons occupationally associated
with pesticides, or otherwise exposed to pesticide residues.
In this latter connection^ the general public is exposed to pesticides
largely in the form of residues in produce that has been sprayed in the
field. These residues are generally of magnitudes of 1 ppm, or less. Such
residues are too small to cause any acute effects, the amount ingested as
residues on produce being far less than those impacting on persons occupationally
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53
exposed. Although there are no acute effects from such exposures, the
possibility exists that certain chronic effects can be caused by continued
.ingestion of pesticide residues.
Not the least consideration here, is the possible synergistic or
potentiation effect that may occur where mixtures of molecules (which may
not necessarily be exclusively pesticidal) occur. Synergism and potentiation
are known to occur where mixtures of pesticides or pesticides and other
chemicals exist. Thus, whether exposure occurs in the field or through
ingestion of minute residue of the chemicals in.produce, the phenomena
of synergism and potentiation must be of concern to us and measures taken
to minimize the chances of their occurrence.
Thus, until it can be shown that the types of low level exposure to
pesticides just described are not a real threat to human health, every
effort should be made to keep pesticide usage at a minimun. Specifically,
in -food production the use of pesticides should be related to maintaining
or increasing yields and to assuring the real needs of produce quality.
But, in this usage of pesticides the goals of high yield and quality should
not be attained at undue risk to human health and environmental quality.
In this latter connection it is particularly important that frivolous or
superfluous pesticide usage based on invalid cosmetic or pest contamination
standards be avoided.
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Pesticide Use and RegulationsFootnotes
1. Pesticide Use Report, 1973, Agircultural Chemicals and Feed, California
Department of Food and Agriculture, Sacramento, California, p. 289.
2. Harrison C. Dunning, "Pests, Poisons, and the Living Law: the Control
of Pesticides in California's Imperial Valley," Ecology Law Quarterly,
Fall, 1972. p. 636n.
3. California Agriculture 1970, A Report on California's Principle Crop
and Livestock Commodities, California Department of Agriculture, 1971.
4. David Pimentel, "Extent of Pesticide Use, Food Supply and Pollution,"
New York Entomological Society, March, 1973. p. 15.
5. C. B. Christensen,' Pesticide Use Report, 1974, California Department
of Food and Agriculture, Sacramento, California, 1975.
6. Ibid, p. 179.
7. Anonymous, Statistical Abstracts of California, Sacramento, California,
8. C. B. Huffaker and Ray F. Smith, "The IBP Program on the Strategies and
Tactics of Pest Management," Proceedings, Annual Tall Timbers Conference
on Ecological Animal Control by Habitat Management, Feb. 24-25, 1972.
p. 220.
9. Pimentel, op. cit., pp. 27, 29.
10. Robert F. Luck, R. van den Bosch and R. Garcia, "Chemical Insect Control,
A Troubled Pest Management Strategy," Bio-Science, (in press).
11. "The Principles, Strategies and Tactics of Pest Population Regulation
and Control in Major Crop Ecosystems," Proceedings, IBP Integrated
Pest Management Conference on Economic Injury Evaluation, April 5, 6,
1973, Dallas, Texas, p. 18.
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55
12. G. Feder and U. Reigev, "Biological Interactions and Environmental
Effects in the Economics of Pest Control", Journal of Environmental
Economics and Management, 2, 75-91 (1975).
13. Rosemarie Von Rumker, Farmer's Pesticide Use Decisions and Attitudes on
Alternate Crop Protection Methods,'U. S. Environmental Protection Agency,
Washington, D. C., 1974. p. 3.
14. Ibid., pp. 5, 6.
15. IPMSA brochure, IPMSA, 100 North Winshester Blvd., Suite 260, Santa
Clara, California 95050.
16. C. M. Merritt, Department of Entomological Sciences, University of
California, Berkeley, personal communication, January, 1975.
17. A. Gutierrez and W. Loew, "Pest Control Decision Making in California
Cotton", in progesss.
18. W. R. Willey, "The Diffussion of Pest Management Information Technology",
doctoral thesis, University of California, Berkeley, 1974. pp. 10, 11.
19. D. C. Hall, ja£ al^., "The Performance of Independent Pest Management
Consultants in San Joaquin Cotton and Citrus", California Agriculture,
October, 1975, p. 12.
20. Willey, op. cit., p. 105.
21. Personal communications with growers who wish to remain anonymous.
22. Delvan W. Dean, pers. comm., Chemicals and Feed Division, California
Department of Food and Agriculture, July 15, 1974.
23. E. S. Greenstone, "Farmworkers in Jeopardy: OSHA, EPA and the Pesticide
Hazard", Ecology Law Quarterly, Vol. 5, No. 1, p. 69, 1975.
24. Ibid.. p. 121.
25. Dunning, op. cit., pp. 639, 640.
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56
26. Dunning, op. cit., p. 651.
27. Dunning, op. cit., p. 652.
28. R. Howitt, doctoral thesis, University of California, Davis, 1975.
29. Dunning, op. £it_., p. 648.
30. Robert Howie, pers. comm., August 6, 1974; Claude FinneJL, pers. conm.
August 8, 1974.
31. Dunning, op. cit., p. 655.
3.2. Barry Wilk, pers. conm., March, 1975.
33. Pers. comm. with State Department of Food and Agriculture, Licensing
Division, January, 1975.
34. Everett J. Dietrick, Riverside, California, personal communication.
35. Dunning, op. cit., p. 675.
36. Dunning, op. cit., p. 675.
37. Dunning-, op. cit., p. 678.
38. Dunning, op. cit., p. 678n.
39. D. Pimentel, Ecological effects of pesticides on non-target species.
Executive Office of the President, Office of Science and Technology.
June, 1971. U. S. Printing Office Stock No. 6106-0029. 229 pp.
40. R. L. Rudd, Pesticides and the living landscape. Univ. of Wise. Press.
320 pp. 1964.
41. R. K. Tucker and D. G. Crabtree, Handbook of toxicity of pesticides
to wildlife. Resource Publication No. 84. U. S. Dept. Inter. Fish
and Wildlife Serv. 131 pp. 1970.
42. State of California, Department of Health and Department of Food and
Agriculture. Illness of employed persons reported by physicians to
the state as due to exposure to pesticides or their residues according
to type of illness. 1975. 1 page.
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43. Dr. Kahn made this comment in a seminar held in the Biological Sciences
Department, Stanford University, on May 3, 1976. During this dis-
cussion he presented data supportive of his conclusion.
44. California Community Studies on Pesticides, Contract Report #19.
Jan. 1-Dec. 15, 1969.
45. R. Howitt, Ph.D. Thesis, University of California, Davis. 1975.
46. Hearing held in Sacramento on November 16, 1976.
47. Howitt, op. cit.
43. T. Milby, Testimony on Federal Environmental Control Act of 1971.
Hearings before Senate Subcommittee on Environment Serial #92-80, p. 397.
49. K. Jager, et al., Br. J. Irid. Med. 27: 273. 1970.
50. Dreuth, et al., Arch Envir. Health. 25: 395. Dec., 1972.
51. L. Schmertzler, "Achilles tendon reflex force as a sensitive test
for organophoshate exposure." To be published.
52. Rayner, et al., pers. comm., Chem. Path, and Pharm. 4(3). Nov. 1972.
53. F. Medred, Residue Reviews 6: 42.
54. L. Reiter, G. Talens, D. Woolie, Proc. West Pharm. Soc. 15: 123, 1972.
55. Tocci, et al., Ind. Med. Sur. 38(6): 188, 1969.
56. J. Davies, In Proc. of Nat'l. Conf. on Protective Clothing and Safety
for Pesticide Workers. Atlanta, Ga., May, 1972.
57. M. Wasserman and D. Wasserman, In "Fate of Insecticides in the Environment."
S. A. Tahori (Ed.), Butterworth, London. 1972. p. 521.
58. F. Kaloyonova-Siaieomova, Report at meeting of subcommittee on Pesticides
of International Association of Occupational Health. Amsterdam, 1971.
Summary of Conference in Arch. Envir. Health 25, Dec., 1972.
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58
59. M. Boguzs, Clin Chim ACTA 19: 367. 1968.
60. T. Nakazawa and T. Nakazawa, J. Japan Assn. Rural. MeH. -22(6): 756.
1974.
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CHAPTER 3. AN IN-DEPTH CASE STUDY OF PESTICIDE USE FOR COSMETIC QUALITY
STANDARDS.
In this chapter a specific crop is assessed regarding cosmetic quality
standards and their possible effects on pesticide use decisions. -The crop,
California navel and Valencia oranges, is primarily a fresh market one.
Cosmetic quality standards may also play an important role in crops pro-
duced entirely for the processing market, as we have indicated in Chapter 1.
CITRUS
I. SUPPLY AND DEMAND
CITRUS ACREAGE AND PRODUCTION
The citrus industry is an important part of California agriculture.
California oranges ranked as the state's number one crop between 1930 and
1950 in terms of cash value. Since 1950 citrus has fallen in relative
importance, but was still the number ten crop in the state in 1969. Navel
and Valencia oranges account for seventy percent of the California-Arizona
2
citrus crop, while lemons make up another 20 percent. We shall restrict
most of our discussion to the orange crop.
THE FRESH MARKZT
California Navel and Valencia varieties tend to have a lower juice yield
than Florida oranges, a more cosmetically attractive exterior color, and they
tend to have a higher level of citric and ascorbic acid which are associated
with taste and nutrition. Since the California citrus industry was more
or less fully developed before the advent of frozen orange juice concentrate
it is geared, in other ways, toward the fresh market. The quality standards
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which prevail in California are designed to meet the demands of the fresh
market. The major marketing cooperative of California-Arizona oranges,
Sunkist Growers, Inc. has spent many years and millions of dollars to
4
cultivate and maintain a market image for fresh citrus. Consequently, the
financial well-being of California-Arizona orange growers has been tied to
the state of the fresh fruit market. Table 4 gives data on the return to
California citrus growers for Navel and Valencia oranges utilized j.n the
fresh and by-products markets. The data indicate that California-Arizona
orange growers have made little or nothing on oranges sold to the processing
market. They must sell a large percentage of their crop to the fresh market.
This is in contrast to the Florida citrus industry where the prices received
for citrus for processing are comparable to those received for citrus for
the fresh market.
THE PROBLEM OF OVER-PRODUCTION
The California-Arizona citrus industry has suffered from the problem of
"over-production." There are several possible factors that contribute to
this problem. The per-capita consumption of fresh oranges has declined
sharply in recent years. Between 1945 and 1960 per-capita consumption de-
clined from 37.9 pounds per year to 16.2 pounds per year. Since 1960 the
per-capita consumption has remained essentially constant at about 16 pounds
per year. In terms of total consumption, the utilization of fresh citrus
declined from 72 million boxes in 1945 to 38 million boxes in 1962.
In addition to slackening per-capita demand for fresh citrus, the -grower
has been receiving a decreasing proportion of the total return on citrus.
Marketing margins, the difference between the prica paid by the consumer
and the amount received by the producer, have been increasing since 1950 for
oranges. In particular retailer margins have increased dramatically since
1950. It should also be noted that when supplies of oranges are low and the
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retail price is high the proportionate return to growers is relatively high,
whereas when supplies of oranges are high and retail prices relatively low,
the retailer margin is relatively high. This is a special case of the
general observation by Jamison that, "The grower demand curve is generally
price inelastic in the relevant output range while the demand facing the
marketing firm is generally elastic. Total revenue maximization therefore
calls for opposite control policies at these two levelse.g., growers, as a
group, gain from decreased quantities sold and marketing firms, as a group,
g
gain from increased supplies.
Given this situation, of decreasing per-capita demand for fresh citrus
and a decreasing proportionate return to the grower, we might expect to see
a pattern of decreasing acreage and production of California-Arizona citrus
in the post 1950 era. However, this is not the case. California orange
acreage did, in fact, decline from 235,000 acres in 1945 to 132,000 acres in
9
1961. However, this was due primarily to the urbanization of the Los
Angeles basin. Starting in 1960, California acreage started to increase
rapidly to about 230,000 acres in 1970. Since 1970 California acreage in
oranges has remained fairly stable. Orange acreage continued to decrease
in the Southern California growing region in the sixties, while there was a
steep increase in orange acreage in the Central California growing region, and
an increase of lesser magnitude in the Arizona-California Desert region. The
increased acreage was disproportionately allocated to the production of
navel rather than Valencia oranges.
This pattern of acreage increase in the 1960fs is explicable for the
following reasons. Growers who were forced out of production in the Los
Angeles area due to urbanization undoubtedly received very substantial capital
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62
gains upon the sale of their land. It would seem logical, from the viewpoint
of an individual grower, to reinvest this capital in new orange acreage in
Central California where the weather was conducive to citrus production,
water was available and land was relatively cheap. For navel oranges grown
in Tulare county in 1971 the cost per acre for water was $36 and the cost per
acre for taxes $64. For San Bernardino County the respective figures were
$64 and $125. . For Valencia oranges grown in Tulare County in 1971 the cost
per acre for water was $36 and taxes were $55 per acre. The respective
figures for Valencias grown in Orange County was $80 and $150. It would
be logical to invest in navel rather than Valencia oranges since a higher
percentage of navels make it to the fresh market, and therefore the potential
return is higher on navels. In addition, under the federal tax laws operative
in the 1960's citrus growers were allowed to count cash expenditures on
orchard development as capital expenses. Thus, the investor could deduct
depreciation, cultural costs, interest, taxes and management fees associated
with establishing the citrus orchard, from other income. After the orchard was
established the cost of planting the trees was depreciable over their useful
life. This incentive toward "tax shelter farming" undoubtedly contributed to
the expansion in citrus acreage in Central California. The Tax Reform Act of
1969 wiped-out the tax shelter provisions for citrus and almond orchards and
this may account, in part, for the leveling off of citrus acreage since
1970.12'13'14
The 1950's and 1960's were also periods of increasing population and
increasing real income. Both these factors could be expected to contribute
to an increase in the total consumption of fresh citrus. The larger the
population, especially in California where fresh citrus consumption is
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63
_relatively high, the larger the total consumption of the fresh product. Since
the demand for citrus has been shown to be income elastic, that is families
with higher incomes purchase more citrus per-capita, an increase in real
incomes for all' families would be expected to result in an increase in
total consumption of citrus. If these were the expectations of the 1960s
they have not been fulfilled by the 1970s. The population growth-rate
is declining as is the level of real family income. It is not clear that
either of these trends are likely to be reversed before 1980.
The combined effect of these factors, some of which induced an expansion
of citrus acreage for reasons unrelated to consumer demand, is evident in
the data for the percentage of California-Arizona citrus that is actually
sold to the fresh market. For Valencia oranges, the percentage-of the crop
sold to the fresh market averaged about 67 percent in the period 1950-1960.
Between I960 and 1973 the percentage of the Valencia crop sold to the fresh
market und,er-went a steady decline, averaging 60 percent for the period
1S60-1973. Navels follow a similar pattern. In the period 1950-1960,
88 percent of the navel crop,.on the average, was sold to the fresh market.
16
For the period 1960-1973 this figure dropped to 78 percent. The season
average on-tree returns for California oranges, which had been increasing
between 1950 and I960 also declined between I960 and 1973- These various
trends .are illustrated in figures 1, 2, and 3 and Table 5-
The situation in citrus production seems to fit the general model of
economic behavior described by the National Commission on Food Marketing:
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64
For a variety of reasons bearing acreage of some perennial crops
exhibits broad, cyclical movements. The basic cause of such cyclical
movements'appears to be the tendency of producers to formulate
expectations of future price of a commodity upon the current
price or those prices of the recent past. If expectations of
earnings are high .car a single commodity relative to those for
alternative uses of resources in some given period of time,
planting of the former commodity tends to increase. As plantings
come into bearing in a subsequent period, production rises and
prices falls, other- things being equal. At that time the
cyclical movement tends to reverse. Because of the perennial
nature of the crop and the relatively high proportion of fixed
to variable costs involved in bearing acreage, resource adjust-
ments occur in a laggad and sluggish manner. Price may remain
comparatively low for several years during the cyclically high
level of bearing acreage. In time, the price and market mechanism
would bring about adjustments in resource use. In the meantime,
owners of resources are concerned with the short run and the. hard-
ship which the impersonal forces of the market might invoke.
Given this situation in California citrus, food quality standards
take on a critical role. Quality standards are the mechanism by which
the citrus crop is allocated between the fresh market and the juice and
by-products market. From the viewpoint of the entire industry this
allocation is necessary in order to stabilize the industry and maintain
adequate returns to growers as a whole. From the viewpoint of the
individual grower, quality standards are important because his returns
become dependent upon maximizing the proportion of his crop that is
allocated to the fresh market.
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65
II. COOPERATIVES AND MARKETING ORDERS .
The situation that prevails in citrus production, the low rate of return
and fluctuating price structure, the inordinate degree of market power
of the input and retail sectors; these factors have long been recognized
by citrus growers and agricultural economists concerned with California
agriculture. Two basic institutional arrangements have been constructed in an
attempt to stabilize intra-seasonal and inter-seasonal prices.and increase
the general level of grower return. These institutions, each of which
make the grower exempt from certain provisions of anti-trust law, are the
marketing cooperative and the marketing order.
The dominant marketing cooperative for California-Arizona citrus is
Sunkist Growers, Inc. which markets about 80 percent" of California-Arizona
9 n
citrus and represents 8,500 citrus growers. Under the provisions of the
Capper-Volstead Act of 1922 Sunkist growers are allowed to join together
into one organization for the collective processing and marketing of their
fruit without being held in combination or conspiracy. However, ?n
Case-Swayne Company, inc.y. Sunkist Growers, Inc. the U.S. Sumpreme Court
ruled, .in 1967, that Sunkist no longer qualified for exemption under the
.'
Capper-Volstead Act because 5 percent of its membership consisted of
corporate growers having their own packing houses and 15 percent were
private corporations and partnerships owning and operating packing houses
for profit, whose relationship to growers was defined not by a cooperative
2.3.
agreement but a cost-plus-fixed-fee marketing contract. Since 19&7 Sunkist
22
has reorganized to comply with the Supreme Court ruling. However, as recently
as 197^ Sunkist still listed Goodyear Tire & Rubber Company and Kaiser
Aluminum and Chemical Company among its grower-members. The practice of
allowing giant corporations like these to take advantage of the Capper-Volstead
exemption, which was meant to give economic paver to the small farmer, has
been criticized by some. ^3
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66
Each member of Sunkist is also a member of a local association or
district exchange. The members, whether they market through a cooperative
packing house or a private packing house licensed by Sunkist, elect
representatives at the level of the district exchange. The most .important
lechanism of communication between 'Sunkist management and the grower-members
Ls the annual meeting of Sunkist. In addition, according to Sunkist repre-
jentative, Curtis Anderson, "Many opportunities are provided each year for
growers to attend local and central organization board, meetings, to hear
24
how their business is being conducted." ' .
Sunkist has. engaged in substantial promotional activities, spending $33
nillion between-1934 and 1960 for radio, television, newspaper and magazine
advertisements designed to build a quality image for fresh California citrus.
In order to maintain the quality reputation of the Sunkist trade-mark, Sunkist
issues a set of quality standards in excess of statutory state quality
standards, which must be adhered to by all packing-houses that market 'through
it. (See Table 1 for comparison of Sunkist and state quality standards.) It
has been estimated that the Sunkist quality reputation confers a price pre-
mium of five to ten percent on Sunkist products over the prices of competitive
26 '
products.
Sunkist also plays a significant role in the administration of the mar-
keting order under which the California-Arizona orange industry operates.
The marketing order itself specifies that five out of the eleven members on
the Administrative Committees of the orange marketing orders shall be members
of Sunkist.27 .
The other major citrus marketing cooperative in California-Arizona is
Pure Gold, Inc. which markets about ten percent of the crop. The giant
vertically integrated agribusiness corporation, Tenneco, currently markets
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67
about five percent of the California citrus crop. Tenneco is attempting to
increase its share of the fresh produce market through aggressive marketing
which places special emphasis on the cosmetic appearance of the produce and .
28
on increased packaging designed to appeal to consumer reflexes.
Taken together, the top four firms (e.g., cooperatives) in citrus mar-
keting account for about 90 percent of the market.. A concentration ratio of
this magnitude would ordinarily be taken to represent a high degree of monopoly
29 ' ' '
power. Under the Capper-Volstead Act, marketing cooperatives are allowed
to possess monopoly power as long as it is not exercised to produce anti-
competitive effects. In any case, it is doubtful that citrus marketing
cooperatives really possess the kind of monopoly power that the concentration
ratio would appear to suggest. The marketing .cooperatives face a retail
sector that is'also highly concentrated and well coordinated. In addition,
the over-production problem we have already described puts the marketing
cooperatives at a great disadvantage when bargaining with retailers. The
what * '
Capper-Volstead Act, which allows/the organization of marketing cooperatives
does not, however, allows the organization of cooperatives which function to
control the total production of citrus products..
MARKETING ORDERS 907-908.
The California-Arizona orange industry also functions under federal
marketing orders, the intent of which is to stabilize the price level for
oranges and to increase the net returns to growers. These marketing orders
are made possible by the Agricultural Marketing Agreement Act of 1937, the
federal law which exempts the activities of marketing orders from certain
anti-crust provisions.
Charles Teague, the visionary president of Sunkist, in the 1930*s and
one of the pioneers of citrus marketing orders,, explained the purpose and
-------
function of the citrus marketing order in a 1938 radio broadcast, in which
he stated:
Supply and demand set the price. When supplies are in surplus they
must be regulated. Otherwise prices will fall until they do not
cover packing costs and freight.
A small surplus is all it takes. If unregulated, it can be just
as disastrous as a large one.
Regulation of supplies must take place at the source of production.
For we are dealing with perishables. And once a surplus of perish-
ables is shipped to market it will be sold even if the price does
not cover the freight charges.
There are only two ways of regulating at the source:
1. By cooperative control of the product.
2. By prorate agreements, either State or Federal, or both.
. . .-There is probably a lack of understanding among growers and
the public alike, of the difference between regulation of ship-
ments and elimination of surplus. We regulate shipments to improve
returns to growers and insure a steady supply and reasonable price
to consumers, even when all the production is marketed over the
season. But in some years the crop is larger than can be marketed
at any return to the growers. Then it becomes necessary not only
to regulate the quantity shipped each week, but also to divert
the surplus to by-products, or otherwise eliminate it from fresh
fruit trade channels.
The present marketing orders governing oranges, marketing order 907
for navel oranges and marketing order 908 for Valencia oranges, came into
33
being in the 1950's. Each of these marketing orders is managed by
an Administrative Committee composed of six growers, four handlers, who may
also be growers, and one non-industry'member who has always been nominated
by the other members to serve as the chairman of the Administrative
Committee.
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69
Under the provisions of the marketing orders three of the grower members
and two of the handler members of the Administrative Board must belong
to Sunkist Growers, Inc. The other marketing cooperatives, Pure Gold, Inc.
and Gold Banner Association get one grower and one handler member each,
and two grower members and one handler member are chosen to represent
independent growers and handlers. The Administrative committees require
34
six concurring votes to take any action. Obviously, with five votes,
s
Sunkist has a good chance of dominating the policy of the navel and
Valencia Aiministrative Boards. Some non-Sunkist growers and handlers
have complained about Sunkist domination of the Administrative Boards.35
There is certainly a possibility of a conflict between Sunkist and non-
Sunkist interests in regard to marketing order policy since Sunkist
enjoys a special "reputation for quality not shared by non-Sunkist
growers and handlers. Thus, Sunkist may wish to set a marketing policy
based on higher prices and lower market volumes than non-Sunkist people
would 1 ike to see.
The orange Administrative Co,mmittees are empowered to establish a
"best" policy for the marketing of California-Arizona oranges. A "best"
policy, presumably, is one which minimizes price fluctuations and
maximizes returns to the grower. In order to achieve the goals of this
policy the Administrative Committees collect and analyse information ori
the available crop of oranges, including estimated quality and composition
of sizes, the estimated utilization of the crop, available supplies of
competitive oranges, the level and trend of consumer income, estimated
supplies of competitive citrus commodities, and any other pertinent infor-
mation. Based upon this information the Adminsitrative committees
produce a schedule of estimated weekly shipments designed to meet the
goals of their marketing policy.
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70
The recommended weekly volume of orange shipments, which may be revised
as the season progresses, is implemented by a system known as Pro-rate.
Under the pro-rate system the weekly quantity of oranges that may be
shipped to the fresh market is fixed for each of the three growing regions
in the California-Arizona market. Each packing house is allocated a
specific percentage of this quantity based upon its percentage of the
total production of the pro-rate region. The packing-house is thus con-
strained to allocate only a certain proportion of each grower's crop to the
fresh market. The mechanism by which this allocation takes place is the
enforcement by packing-houses of the quality standards established by
marketing cooperatives. Tha administrative committees may also regulate
directly the size of oranges that are allowed to be sold on the fresh
market. Specific exemptions from regular allotments are allowed in the
case of early maturing fruit, fruit with a short-tree-storage life,
and for weeks of the season in which freeze damage takes place.
The orange marketing orders do not apply to fruit that is sold for
processing into juice and by-products or to fruit that is exported to
r
countries other than Canada. The marketing orders have no effect on the
development of new orange acreage or the entry of new growers. As a
result, while intraseasonal price fluctuations have followed a fairly stable
37
pattern, interseasonal prices do not. In addition, it is doubtful that
the operations of the orange marketing orders can have any significant effect
on the over-production problem. The marketing order could effect over-
production only if there were no commodity 'substitute available for California-
Arizona fresh oranges. While this is true to a great extent from the consumer's
point of view, it does not mean that highly concentrated retailers may not
choose to feature other commodities than oranges if they perceive that the
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71
38
weekly volume flow of oranges is being unduly restricted.. The resultant
drop in wholesale price might force the Administrative Boards to restrict
the flow to even a greater extent in an attempt to make up for the loss in
projected revenues. If this tendency exists, as the.pattern of declining
fresh market allocations and declining power returns indicate it might, then
it might also be dampened by the promotional activities of Sunkist, which
retailers may exploit in their own promotional activities.
Under the Pro-rate system, critically important in determining the
grower's returns is the size distribution of the fruit, which is beyond his
immediate control, and quality of the fruit, which is, to some extent,
affected by pest control practices. Each grower, then, seeks to increase
the total yield of the crop and seeks to maximize the proportion of his crop
that is allocated to the fresh market and -to the top grade in the fresh
39
market. The long-run consequence of these atomistic efforts may be to
decrease the industry-wide.average proportion of the crop that is allocated
to the fresh market, and this has, in fact, been the case in recent years.
The result of this pattern is to increase, even more, the incentive of the
individual grower to maximize yield and quality, resulting in increased
production costs and increased reliance on input factors. This, along with
inflation of input costs, has lead to an increase in the minimal size of the
production unit. One grower we spoke to stated that in the 1950's a ten acre
40
orange grove could provide a living income, but today 40 acres is the minimum.
Robert Howie, the agricultural commissioner of Riverside County also indicated
that the smaller orange growers are being driven out of business by increasing
41,42
input costs.
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72
In summary, the institutional arrangements Which have been developed
in response to the over-production problem, the marketing cooperative
and the marketing order, are incapable of directly attacking the root
causes of the over-production problem, the disproportionate market power
of the input and retail sectors compared to the atomistic production
sector. Instead attempts are made to deal with the over-production
problem in a symptomatic way, resulting in additional dislocations
which may not be beneficial to society. Such dislocations are not a
product of insincerity or ineptitude on behalf of orange growers and
their institutions, but result inspite of the best motivated and best
informed efforts on their part.
Within this system quality standards play an important role, and it
is to a consideration of these standards that we now turn.
III. QUALITY STANDARDS
The California-Arizona citrus industry operates under two kinds of
quality standards for fresh fruit. In the first instance, the fruit must
meet the statutory quality standards which are established and enforced by
»
the state. The California standards require that oranges have a soluble
solids (sugar) to acid ratio of eight to one if 25 percent of the surface
of 90 percent of the fruit has attained an orange color, and a soluble
solids to acid ratio of ten to one if the average surface of 95 percent of
the fruit is orange. These state standards clearly relate to maturity and
are written so as to ensure that green or sour fruit does not appear on the
43
fresh market.
The statutory standards are not, in reality, the effective quality
standards that orange growers must meet. Rather, quality standards of a much
more comprehensive and stringent nature are enforced by the orange marketing
cooperatives. For example, Sunkist maintains a set of quality standards
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73
that specify criteria which oranges must meet in order to be sold under the
various Sunkist labels, e.g., "Sunkist,"' "Excel," "Red Ball" and SK."
These standards are shown in Table 1.
The non-statutory standards contain a number of specifications which
relate to the external appearance of the fruit and may have no bearing on
the taste and nutritional quality of the fruit.
Obviously, the non-statutory standards do not serve as a "standardiza-
tion" mechanism, assuring to all parties a minimum level of quality, especially
in regard to taste and maturity. This is done by the statutory standards,
which-are, in fact, subsumed as part of the non-statutory standards. It
might be thought that the non-statutory standards have been established in
response to a consumer preference for high cosmetic quality. This theme has
been stressed by numerous commentators, including many of those who are highly
critical of the current pattern of pesticide use related to cosmetic quality
standards. For example, David Pimentel, writing in the March, 1973 journal of
the New York Entomological Society, observes, "Oranges also are in the same
category as apples, because of the currently high 'cosmetic standards' now
44
expected by the consumer. P. S. George and G. A. King,
agricultural economists with the Giannini Foundation, have indirectly
derived an "elasticity of quality" for oranges* This elasticity is slightly
negative (-.035).which could mean a number of things; but it at least leaves
open the possibility that the current level of quality of oranges is higher
than consumer preference would warrant, that is, the level of quality could
be lowered without a fall in the price of oranges.
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74
Whatever the current state of consumer preference for cosmetic quality
in oranges, it is no doubt, in part, a product of decades of promotional
activities by Sunkist rather than just an endogenous property of the human
psyche. The Florida "russet grapefruit" which is severely cosmetically
affected by mites and whiteflies, receives a premium price because of its
high interior quality. In this case, the cosmetic damage has become a
trade-mark, as it were, of the high quality of the fruit. The green color
of the re-greened Valencia .orange is now being advertised as a "guarantee"
46
that the fruit is ripe, which, in fact, it is. Thus, consumer attitude
does not seem to be an insurmountable barrier to the alteration of cosmetic
quality standards once other obstacles to change have been overcome.
Non-statutory standards may exist for another reason, quite apart
from consumer preference, and that is as a mechanism for allocating oranges
to the fresh market, in accordance to the policy goals of the orange
Administrative Boards. It is in the packing-house that the enforcement of
non-statutory quality standards takes place and it is as a result of this
enforcement that a certain number of oranges are offered for sale on the
fresh market and the remainder diverted to juice and by-products.
This is all of great importance to the grower, for he receives a
significantly lower price for oranges that are classified as "Red Ball"
rather than "Sunkist" and an even lower price for oranges that go to
juice and by-products. For the years 1950-51, 1965-66 and 1967-68, Rausser
reports the following composite relative prices that were received for the
different grades of navel and Valencia oranges.
-------
Navels Relative Price Valencias Relative Price
Sunkisc
Excel
Red Ball
1.00
.82
.74
Sunkist
Excel
Red Ball
1.00
.83
.71
In regard to the price differential between oranges that are allocated
to the fresh market and those that are allocated to the by-products
market, the data in Table 4 indicate that groves receive little or
no return on fruit allocated to the by-products market and that the
price situation has constantly deteriorated in the by-products market
since 1960.
Data from pack-out sheets that we have received for 1973 and 1974 confirm
this general situation. These pack-out'sheets, which report to the grower
the distribution of his crop into different grades and the prices received,
indicate that the grower receives between $.-50 and $1.50 less per packed
(50 Ib.) box for oranges that are graded "Red Ball" or "Choice" rather than
"Sunkist" (or "Pure Gold"). Pack-out sheets for navel oranges indicate
t
that growers received from nothing to $10.00 a ton for navel oranges that
went to juice and by-products. This latter figure is equivalent to $.25
per box. Obviously, there is a great financial incentive for growers to
meet the quality standards that adhere to the top grade for fresh oranges.
An important aspect of the quality standards that are specified by
Sunkist is their non-quantitative nature. For example, it is difficult to
know exactly what "more than slightly scarred" means. Additionally, the
cause of many of the defects is not specified. Scarring may result from a
number of factors, including wind, mechanical abrasion by branches, and
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48
various insect pests. The wide range of exterior defects specified in the
quality standards are not detected by any quantitative technique. Rather,
the oranges are screened visually by packing-house workers as they are
carried down a conveyor belt. It would seem that the non-quantitative
nature of the exterior quality standards and the inspection procedure would
allow 'for the adjustment of the enforcement level of the quality standards
without any change in the specification of the quality standards themselves.
It has been suggested, for example, that this could be accomplished by
simply increasing the speed of the conveyor belt that carries the oranges
past the quality inspectors, or by increasing or decreasing the number of
inspectors on duty. Spokesmen for Sunkist categorically denied that any
"adjustment of the quality standards" takes placet In the strict technical
sense of this phrase they are correct.
However, there, is evidence to suggest that adjustment
of the level of enforcement of quality standards does, in fact,
take,place. First of all, the decreasing proportion of oranges that
are sold to the fresh market indicates that either the actual
quality of oranges has been deteriorating or that theTevel of quality
standards enforcement has become more stringent. The first possibility
is explicable only if we assume that insect related damage is the pre-
dominating factor in determining the level of quality and, furthermore,
that orange growers had increasing difficulty in dealing with insect
pests in the last decade. Though there may be some element of truth in
the latter of these assumptions, they cannot explain the regular decline
in the proportion of fruit sold to the fresh market. If this hypothetical
quality decline is not due to insect damage it might be due to various
cultural and mechanical factors, but here again, there is no reason to
expect a regular increase in damage due to these factors. It is much more
credible to assume that as orange acreage and production has expanded,
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77
the enf or cement level for quality standards has had to be annually
adjusted to fulfill the marketing policy established by the orange
Administrative Boards. This phenomenon should not be all that surprising.
In the June, 1972 issue of Citrograph, "The Magazine of the Citrus Industry,"
agricultural economists Leon Garoian and Kirby Moulton.wrote, "Certainly
at the grower level weTve -seen the results of low or nonexisting barriers
[to entry]. New growers can raise the required quality of citrus and can
50 ' '' ' '-' ' ' '
join marketing associations." (emphasis added) Still this issue seems
to be a sore point with the marketing cooperatives. As to whether the
level.of enforcement of quality standards is adjusted during the season,
as changes in the weekly volume flow of oranges to the fresh market might
suggest, the orange growers we interviewed unanimously and emphatically
agreed that this does occur. (See =Table 6 for summary of citrus
grower interviews.)
-..-....-. - ' . ;...
When the percentage of fruit that is allocated to the fresh market is
regressed against the total seasonal crop, using data for the years 1949-
1973- from Table 2. A positive correlation is shown to exist between these
two variables (especially when freeze years are eliminated from the data).
This would indicate that quality standards are adjusted, at least on an
inter-seasonal level.. When the same procedure was applied to weekly
data for the year 1973-74 no such relationship was found to exist. Thus,
at least, according to this test, quality standards do not appear to be
adjusted within the season. Thus, pro-rating appears to function fairly
well in allocating the volume flow of the average crop within the season,
but it fails in controlling the total quantity of oranges from season to
season.
-------
. . '..-..'. . - '78
The negative result of the "second test, above, does not necessarily
mean that the Individual growers > . ' were entirely wrong in their
perceptions of intra-seasonal quality standard enforcements. While there
was no overall correlation between the percentage of the weekly crop
allocated to by-products and the total weekly crop, the weekly data for
1973-74 do appear to indicate a tine pattern in the allocation. At least
for Navel oranges, the percentage of the crop allocated to by-products
increasing throughout most of the season. . .
These results are summarized in Figures 4, 5, 6 and Tables3 and 4. .
Spokesmen for the citrus Industry emphatically deny that
there is a cosmetic component involved in the quality standards as far as.
insect related damage is concerned. Two grounds are cited in support of
this position. Richard Breuner, the President of the Industry-Committee
on Citrus Additives and Pesticides, a citrus industry advisory and lobbying
organization, stated that insect related external damage is symptomatic of
52 ' ' ' '
lower interior quality. .
Don Avis, manager of pest control for Sunkist, also contended that.any
cosmetic effects obtained from pest control are strictly the side benefits
of sound pest management practices.-necessary for the maintenance of fruit
yield and tree vigor and, that fruit exposed to proper pest control
automatically meets the Sunkist quality standards with regard to insect-
related damage. On these grounds Avis denied' that the Sunkist quality
... . . < eo
standards contain any operationally effective cosmetic components.JJ
The viewpoint is not universally shared by the citrus industry. For
example, the Florida Department of Citrus initiated a campaign in 1975 in
which it "tells consumers that the external appearance of Florida oranges has
nothing to do with internal qualitythe same climatic conditions that make
Florida oranges exceptionally juicy and delicious also mean that they usually
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79
carry a few blemishes, wind scars, scale, and sometimes have a pale color or
a peel that has regreened."
IV. .PEST MANAGEMENT
Citrus is among the top ten food crops in the U. S. in terms of pesticide
application. Ninety seven percent of all citrus acreage is treated on a
regular basis and citrus accounts for 2 percent of all agricultural insecti-
cide use. In 1973 over twelve million pounds of various pesticides were
sprayed on California oranges, according to the California State Department
of Agriculture Pesticide Use Report. The chemicals used included such toxic
substances as Delnav-dioxathion, Malathion and Parathion. The dispropor-
tionately large amount of pesticide use in citrus is reflected in the
extremely high pest control costs for this crop. For.example, the average pest
control cost (excluding control costs for weeds and nematodes) was estimated
at $160.00 an acre for the 1973-74 growing season for navel oranges in Central
California. The significance of this cost can be appreciated by comparing
it to the net return for navel oranges which ranges between $500.00 and
58
$1,000.00 per acre.
There are important variations in the number, type and severity of citrus
insect pests according to the growing region. Southern California is relatively
inhospitable to a number of important citrus pests, most notably the citrus
thrips. In addition, the parasites of certain citrus pests thrive in .
southern California but not in other growing regions. This is especially
true of Aphytis melinus DeBach, an effective parasite on the California red
scale.
In the Central California growing region the citrus thrips, the citrus
red mite, and the California red scale are major pests. Other .citrus pests
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80
are also more severe in these regions than in Southern California. From a
pest management perspective, the enormous expansion of citrus acreage into
Central California was unfortunate. It took place, anyway, for reasons
already discussed. In recent years growers in this region have felt the
consequences in the form of increasingly difficult pest problems and swiftly
rising pest control costs. ' '
The specific approach toward pest control also depends upon the basic
philosophy of the grower and his pest control advisor. There are essentially
two approaches to citrus pest control: conventional chemical control and
integrated pest management. In conventional chemical control the approach is
to suppress specific pests without regard for the long-term effects of
chemical treatment or the actual level of the pest population necessary to
cause damage of economic significance. This strategy has often led to
episodes of unexpected pest resurgence or outbreaks in citrus. For example,
an important citrus pest, the cottony cushion scale, was brought under
effective biological control in 1892 with the deliberate introduction of its
adapted predator, the vedalia beetle. With the advent and widespread use of
DDT in the 1940's, the vedalia beetle was decimated in many orange groves.
As a consequence there was a serious resurgence of the cottony cushion scale
to the orchards
which subsided only when the vedalia beetle was re-introduced/and the use
62
of DDT was discontinued on or near citrus groves. Currently, attempts to
control the citrus thrips through conventional chemical control has led to
the elevation of the citrus red mite as a serious pest .in California, as well
as to the exacerbation of a number of other citrus pest problems. (See
discussion of the citrus thrips, below, p. 86).
The integrated pest management approach attempts to take the entire
agro-ecosystem into account. The population levels of insect pests are
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81 .
carefully monitored to determine whether economically significant infesta-
tions exist, and if so, when and how they can be most effectively controlled.
Use is made of cultural techniques, the introduction of predatory or parasitic
insects, and the selection and use of chemical materials on the basis of
their long-term, as well as short-term, effects on the target pest and the
entire agro-ecosystem. . ' . . . . .
In tables 7 and 8 idealized programs of citrus pest.control for Central
California based upon the conventional chemical approach and the integrated
peat management approach are compared. According to University of California
citrus entomologist, C. E. Kennett, citrus red mite falls to low status in
the pest hierarchy because integrated pest management consultants attach less
importance to it than chemical control specialists. "Citrus thrips retain a
high position not so much because of their actual damage potential but more
so because the arbitrary classification, by the citrus industry of thrips
feeding scars on the fruit as serious damage, does not. allow the supervised
v
control specialist to relegate it to a position of lesser importance,"
Kennett comments. . . . . . .
Richard D. Strong, Commodity Specialist, California Farm Bureau Federation,
analyzed comparative cost of conventional and integrated control on Valencia
oranges in Tulare County over a five year period. Be reported that integrated
control programs cost $45 per acre as compared to $101 per acre for conven-
tional control. (See Table 9.)
Hall, Norgaard and True have compared citrus growers who use integrated
pest management and those who use conventional chemical control. Thirty-nine
orange growers in the San Joaquin Valley were interviewed. Seventeen were
clients of independent pest management consultants, while twenty-two were not.
An additional eighteen growers in the coastal region of Southern California
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82
were interviewed. All of chese growers were clients of independent pest
management consultants. Differences in the general characteristics of
Central California management adopters and nonadopters seem apparent from
the survey. On the average adopters have a smaller percentage of acreage in
crops other than oranges; they have a lower quality of land as measured by
the Storie Soil Index; they watered more often with less water per applica-
tion; they have fewer trees per acre and younger groves. On the average
adopters tend to be better educated, have less contact with their farm advisor,
and to read more technical journals. They tend to have less total assets and
less total debts and a higher asset to debt ratio than nonadopters. These
characteristics vary from grower to grower and this average composite picture
cannot be applied to any individual grower. Additionally, the differences
between the average adopter and nonadopter are not striking in all of these
categories and it cannot be concluded that a cause and effect relationship
necessarily exists between these characteristics and the decision to adopt
or not adopt integrated pest management advice. Nevertheless, these data are
suggestive of what some of the actual factors might be.
When the nonadopters were asked to rank, in order of their preference,
their sources of pest control information, 15 out of 22 listed chemical
company salesmen as their most preferred source of information. Significantly,
none of the nonadopters listed independent pest management consultants, even
as a second, third or fourth preference.
The orange growers were also asked to rank reasons for utilizing the type
of advice they used. The adop-ters attributed about equal weight to: "respect
for and friendliness with the advisor,""a lower cost of pest control," and
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83
"a lower risk of pest damage." The nonadopters weighted "personal respect
and friendliness" much higher than other factors and also listed "free
advice of the chemical company salesman" as the second most important
factor. These responses would seem to indicate that the nonadopter is
being "sold" more on the personality of the salesman than on the effective-
ness of the pest control procedure. This conclusion is supported by the
fact that most nonadopters, as well as adopters, agreed that integrated
pest management is cheaper and more effective than conventional chemical
control.
It is difficult to know to what extent the attitudes of adopters and
nonadopters is the cause of their decision to adopt or not adopt independent
pest management consultants or the effect of having done so. In any case,
grower attitude, though probably very important, may not be the only barrier
to the greater use of independent pest management consultants. Another
barrier is the economic difficulty of an advisor starting an independent
small business enterprise, especially when competitors in the market are
the salaried and commissioned salesmen (fieldmen) of large chemical
corporations.
The Hall, Norgaard and Tree Study yields the following information on
.the actual economic effects of independent pest management. The average
net return per acre for San Joaquin Valley adopters was $480.00 while for
the nonadopters it was $460.00. Other things being equal, the adopters of
independent pest management have not been adversely-affected financially.
The adopters also experienced a significantly lower average per acre pest
control cost than the nonadopters, even when the pest management consultant's
fee is added in. The average per acre expenditure on insecticides reported
in the survey was $20.53 for the adopters and $42.35 for the nonadopters
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84
over the years 1970 and 1971. When Norgaard, Willey and Hall applied re-
gression analysis to the information from the survey results, the following
estimates were obtained for the profit accruing to the grower as a result
of adopting independent pest'management. For 1970 the 90 percent confidence
interval for the average profit realized by adopters, attributable to
independent pest management, was -$14.44 to $153.03 per acre. For 1971 the
interval was -$8.56 to $159.07 per acre. The location of these confidence
intervals indicates that adopters could expect to have benefited from inde-
pendent pest management. The analysis also suggests that there is a likeli-
hood that one-third of the nonadopters in the sample would also have benefited
from using independent pest management if they were to become adopters.
The relatively favorable environment for natural pest control of coastal
Southern California was also confirmed by this survey. When growers were
asked to estimate the percent pest damage loss if no pesticides were used,
the San Joaquin adopters gave an average estimate of 40 percent while the
Southern California adopters gave an average estimate of only 7 percent. The
actual level of pest damage loss reported by the two groups was 22 percent and
2.5 percent respectively.
A notable example in which citrus growers have taken advantage of the
favorable environment of coastal Southern California and integrated pest
management is the Fillmore Citrus Protection District, in Ventura County.
It is a citrus grower's cooperative pest control association which is respon-
sible for the maintenance of insectaries, for the release of predators and
parasites of citrus pests into the groves of its member growers, and for the
general citrus pest management on the 8,000 acres of orchards over which it
has jurisdiction. The organisation has been heavily involved with integrated.
pest management and biological control since 1922. Red scale and.black scale
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85
are tinder relatively effective biological control in the Fillmore District
and the amount of chemical treatment used for the control of other insect
pests is relatively low. In 1973, a fairly typical year of the 8,000 acres
in the Fillmore District, 660 acres vere treated for black scale, 75 acres
were treated for red scale, 200 acres were treated for aphids, 800 acres
were treated for citrus thrips, and 2100 acres were treated with a medium oil
spray designed to prevent the fall and winter build-up of red spider mites.
Currently, any pest control strategy, -.conventional chemical or inte-
grated management, must take cosmetic factors into account. When we asked
nine citrus growers to list insect pests which they considered partially or
wholly cosmetic eight listed citrus thrips, four listed citrus red mite, five
listed red scale and one listed worms. When asked to estimate the proportion
of their pest control cost that is attributable to cosmetic pests, the
average estimate was 71 percent, with a range from 50 percent to 100 percent.
When asked if they were able to take full advantage of integrated pest
' *
management under the existing quality standards, eight of the nine said they
68
were not. For these growers, then, there is a definite relationship
between quality standards which they consider cosmetic and their mode of
insect pest management, including the degree to which they must use chemical
.pesticides. This response also indicates that at least eight of the nine
growers defined "cosmetic quality standards" in a way consistent with the
definition used in this report. That is, these growers understood "cosmetic
damage" to refer to revenue loss.due to down-grading of fruit and not related
to yield loss, or deterioration of fruit flavor, nutrition or storability.
(See Table 6..)
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V. TEE CITRUS THRIPS
If any major agricultural insect pest has gained a reputation for
causing essentially cosmetic damage, it is the citrus thrips, Scirtothrips
citri (Moulton). Yet, even in this case controversy rages as to the nature
of citrus thrips damage. In an evaluation of whether, or to.what extent,
the citrus thrips should be considered a cosmetic pest, a'complexity of
factors must be taken into account, including the nature of the damage caused
by the insect pest, the age and location of the citrus grove, current and
past environmental conditions, current and past cultural and pest management
procedures, prevailing and projected economic conditions and quality standards.
Many of these factors have been discussed above and it is within this context
that the nature of citrus thrips damage will be examined.
HISTORY
The citrus thrips was first identified as an insect pest in California
in 1908 after a severe outbreak of thrips-related damage to the Tulare County
citrus crop. A 1918 report of citrus thrips by the United States Department
69
of Agriculture provides us with information on the nature and extent of
thrips damage before the era of effective control. The report notes that
severe infestations of citrus thrips can cause stunted growth on nursery stock
and. young groves. Severe infestations can also result in fruit drop and the
splitting of fruit, as well as substantial deformation of fruit. Certainly
this type of damage must be classified as non'cosmetic. However, according to
the 1918 USDA report, such damage was relatively rare even when thrips were
left totally uncontrolled. Fruit drop occurred only "in exceptionally severe
infestations," thrips were responsible for "only a small proportion of the
usual fruit splitting," and substantial malformation due to thrips occurred
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in from one to six percent of the orange crop. This is not to dismiss the
fact that certain groves at certain times suffered severe damage due to
thrips. But, as the 1819 USDA report observed:
The most important damage resulting from the feeding of thrips
upon trees that have passed the period of rapid growth is the
lowering of the market value of the fruit by unsightly scabbing
and scarring. Although the eating quality of the orange is not
affected thereby, its commercial grading is lowered considerably
and the selling price correspondingly reduced.
Specifically, it appears that the typical mature citrus grove is pri-
marily susceptible only to the characteristic "stem-end ring scarring" of
fruit which occurs without significant loss of fruit yield or tree vigor.
The extent to which such damage constitutes an economic loss to the grower
depends not only on the severity and incidence of scarring, but on the .
level and enforcement of quality standards. In the case of citrus thrips
scarring other than that which causes splitting or substantial deformation of
the fruit, applicable quality standards seem to fall into the cosmetic
category.
In the severe thrips year of 1909 more than 80 percent of the oranges in
Tulare County were so damaged by citrus thrips as to lower the grade of the
fruit. In 1910 this figure fell to 63 percent even though no treatment
procedure was available at the time. In the fairly typical season of 1911 it
was estimated that the economic loss to San Joaquin Valley citrus growers
due to citrus thrips damage was in excess of $180,000. This would certainly
be an incentive to control citrus thrips' scarring to a level of noncosaietic
damage.
A 1938 report by the University of California Agricultural Experiment
70
Station concurs with the 1918 USDA report regarding the nature of thrips
damage. As to tree damage it comments, "Citrus nursery stock and young
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groves are often stunted and malformed by thrips'attack." On fruit damage
the report states, "The fruit injury is rarely severe enough to cause
dropping or malformation, although some splitting is attributed to excessive
thrips1 attacks. Though the eating quality remains unaffected by the surface
scarring, the market grade is definitely lowered and the selling price
reduced." According to the 1938 report,thrips'damage in the Central
California growing region was reduced to 3.8 percent of the fruit by a
control procedure involving a series of three sulfur treatments. With no
treatments 46.6 percent of the fruit was affected by citrus thrips. What
proportion of this damage resulted in grade lowering and what proportion
resulted in more severe damage is not stated in the report.
CURRENT STATUS
Contemporary opinion on the nature of citrus thrips1 damage is mixed.
Certainly, citrus thrips is still considered a major insect pest in California.
According to estimates by Ronald M. Hawthorne, survey entomologist for the
California Department of Agriculture, citrus thrips accounted for $8,762,922
in crop damage in 1974. This figure is based upon estimates submitted by
county Agricultural Commissioners and is probably rather inaccurate. How-
ever, it may serve, at least, to indicate the order of magnitude of the
problem. According to the same source an additional $2,024,898 was spent
in 1974 in attempts to control the citrus thrips, bringing the total direct
economic loss attributed to citrus thrips to about 10.8 million dollars.
In the Desert and Central California growing regions the citrus thrips
is considered a leading insect pest. In a 1973 article on "Citrus Pest
Management Studies in Tulare County," University of California entomologists,
D. L. Flaherty, J. 3. Pehrson, and C. E. Kennett write, "Thrips are rated
high as pests in Tulare County. The fruit must meet marketing standards:
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too much scarred fruit results in heavy culling and reduced grade, both
72
influencing grower profits." The "1974-75 Treatment Guide for California
Citrus Crops," published by the University of California, recommends treat-
ment for citrus thrips "to prevent fruit scarring" implying that thrips1
damage is primarily cosmetic. In a 1971 newspaper account Don Avis,
manager of pest control for Sunkist Growers, Inc. "acknowledges that the
74
thrips damage to citrus is mostly cosmetic in nature." According to the
1974 Sunkist Citrus Defects Market Handbook, "The interior quality of the
fruit is not affected (by citrus thrips1 scarring)."
As we mentioned above, some citrus growers consider citrus thrips a
cosmetic pest. In the previously discussed survey, it was listed as a
major pest more times than any other insect and it was designated either
wholly or partially cosmetic by all of those who listed it. It was mentioned
specifically by several growers as constituting a large part of cosmetic
pest control costs and as a barrier to more effective utilization of inte-
grated pest management.
On the other hand, Avis, in a recent communication modified his position
on the cosmetic nature of citrus thrips1 damage, contending that it was not
treated as a cosmetic pest as such, but that cosmetic results were achieved
as a side benefit of generally sound pest management practices. This
position was reiterated by William K. Quarles, Vice President for Government
Affairs for Sunkist, who stated, "The current level of pest control activity
is necessary to maintain tree vigor, as well as crop productivity at a level
of economic necessity for the grower. Most pest control activity has a
side benefit of improving the cosmetic appearance of the fruit, but there is
little use of chemicals for purely cosmetic purposes."
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In a recently published report on citrus thrips' treatment, Elmer,
78
Ewart and Brawner noted that:
The ring-scar on the stem end of the fruit is of primary concern
along with scars caused by feeding of the rind along the sides of
the orange. There is no evidence that these scars affect the
internal quality of the fruit, but for marketing purposes scarred
fruit are given a lower grade in the packinghouse with a subse-
quent monetary loss to the grower .... There is some question
about the necessity for using an insecticide to prevent ovi-
position marks and rind silvering . . . and, besides adding to
the grower's costs, these sprays may cause an increase of other
citrus pests.
This study also presents evidence which indicates that treatment for
citrus thrips had no effect on the growth rate of young orange trees.
In addition, this study provides some evidence that fruit yield was
higher in plots where heavy chemical treatment, involving eight applications
of organophosphate insecticides per season, was used, than in plots where
no treatment was used. ' However, this study was conducted on young, not
mature trees; thus the results'cannot be extrapolated to mature,"commercially
producing groves.
Even for the young trees the results of the study in regard to fruit
yield cannot be interpreted unambiguously. The report gives data for fruit
yield, over a three year period, for four treatment procedures: no treatment,
botanical (insecticide) treatment, light chemical treatment - one application
of organophosphate insecticide per year, and heavy chemical treatment - eight
applications of organophosphate insecticides per year. The report provides
no statistical evaluation so it is difficult to tell whether any of the
differences in fruit yield are actually statistically significant. In one
year out of three, the yield from the lightly chemically treated plots was
actually lower than from the untreated plots. This particular negative
result would indicate that, in order to be statistically significant the
difference in fruit'yield would have to be in the range of 15-20%. (Since
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the negative result, which was one out of nine total samples, was of the
magnitude 6.8%). Thus the only fruit yield differences that might be
statistically significant are for the years 1972 and 1974 for the heavy
chemical treatment. In a personal communication Dr. Ewart indicated to us
that he did not consider his data on fruit yield differences to be statis-
79
tically significant.
Even if we are to accept the dubious statistical nature of this evidence,
there is still another problem. The trees in this study were randomized in
this grove. However this procedure does not actually eliminate systematic
differences between the sample plots, because eight applications of organo-
phosphate insecticides per year may have effects other than those resulting
from thrips'control. It has been shown in other crops, such as cotton, that
repeated applications of organophosphate insecticides has a fertilization
80
effect, and a similar possible effect was not assessed in the citrus thrips'
study. In addition the report does not indicate how the possible effect of
repeated organophosphate treatment on other insect pests was accounted for.
Even if we were to dismiss all of these problems, there is yet another
consideration; the economic implication of this treatment procedure. The
report does not take this into consideration but some elementary calculations
will show how important it is. Assuming that the heavy chemical treatment
increases yield by 25%, then for an average mature grove producing 300 boxes
per acre (The Tulare County average), this would result in an increase of
about 75 boxes per acre. At $2 per box, this would increase grower revenue
by $150 per acre. But the cost of eight organophosphate treatments per year,
81
at $20 per treatment per acre, is $160 per acre. Thus there would be a
net loss to the grower of $10 per acre, even under very generous assumptions.
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Finally, the heavy chemical treatment may have other negative conse-
quences for farmworker and environmental health, and for the long-run
stability of the orchard's insect community, as we have indicated.
It is of interest to note that, in apparent reference to the Ewart
study, the Sunkist Pest Control Circular for Arizona and California desert
regions, which formerly read:
Citrus thrips attack all varieties of citrus. Control to prevent
foliage damage is important on young plantings and in citrus
nurseries but is seldom practical on healthy, mature trees.
Young fruit of all varieties is attacked from the time it is
pea-size to walnut size or larger, which results in scarring and
lowering of graded
has been changed to read:
University research also indicates that ineffective control of
thrips can reduce yields.$3
This new sentence also appears in Sunkist Pest Control Circulars that recommend
treatment for thrips in other citrus growing regions. The pest control cir-
culars neglect to mention Ewart*s other, more statistically defensible result;
that thrips' treatment did not significantly effect the growth of young
citrus trees.
Citrus entomologists Flaherty, Pehrson and Kennett note that, "In many
cases treatments for thrips are overdone, with unwise choices of chemicals.
In their zeal to protect their fruit, growers frequently resort to multiple
treatments, some of which include combinations of insecticides. Often
treatments are applied beyond the stage of fruit development susceptible to
thrips' damage. Such treatment programs trigger biological upsets and
promote resistance. Costly citrus red mite, brown soft scale, cottony
cushion scale, or yellow scale treatments are the likely aftermath of thrips'
84
control programs by multiple applications or combinations of insecticides."
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More research is needed to determine exactly the role citrus thrips'
damage plays in the grading of fruit. If a realistic economic threshold
level for thrips can be developed it must still be effectively communicated
to growers by credible sources of pest control information. The difficulty
with this approach is that the packing-house can instantly change the
effective economic threshold for thrips' damage simply by changing the
level at which it enforces this aspect of the quality standards. Further-
more, such a change is not readily detectable without constant, after the
fact,monitoring of quality standards enforcement procedures. As long as
growers are competing with each other to meet cosmetic quality standards
they are running a risk in assuming an economic threshold level for citrus
thrips greater than a few percent.
Sunkist states in regard to its quality standards that, "These rules
and regulations are necessary, not only to preserve the legal rights of
Sunkist Growers, Inc. in the Sunkist, Excel, SK and Red Ball trademarks,
but to assure a continuing reputation of high quality which now attaches to
them. This is the only way in which these famous trademarks can be used
to derive the maximum benefits and returns for those marketing their fruit
through Sunkist Growers, Inc. In adhering to these rules the strength and
value of the trademarks will not only be maintained but will continue to
85
increase." Unfortunately, the current system of quality standard enforce-
ment, which attempts to maximize the joint profits of growers, has negative
social consequences. Some of the social costs can be enumerated in the
case of citrus thrips.
As already indicated, the control of citrus thrips results in a cost of
several million dollars annually to California citrus growers. The former
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widespread use of DDT for citrus thrips and later broad-spectrum organo-
phosphate insecticides, has resulted in the elevation, to serious pest
status, of a number of heretofore minor insects and mites. The most
notable example of this phenomenon is the citrus red mite, Panonychus
citri, which has become one of the leading citrus pests in California, in
86,87
large part as a side-effect of citrus thrips treatment.
This increase has paralleled the world-
wide increase in the importance of spider mite problems as the use of
synthetic organic insecticides has increased. This problem is highlighted
by a recent issue (March, 1975) of Citrograph. This leading citrus industry
journal contains a full page advertisement by American Cyanamid for its
*
insecticide Cygon. The advertisement is headlined, "FOR THRIPS CONTROL
USE CYGON" and.goes on to say, "When it comes to thrips on citrus, CYGON 267
Systemic Insecticide is outstanding. It's been doing a superior job on
both bearing and non-bearing trees for many years and is now widely used
for thrips and aphids." The generic name for Cygon is dimethoate. Dimethoate
is an organophosphate insecticide which, according to von Ruiaker, is highly
88
toxic to beneficial insects, including bees.
In the same issue of Citrograph there is a full page advertisement for
Dupont's Lannate. As a giant size cartoon thrips falls dead to the bottom
of the page, the advertisement tells the reader, "This year, protect your
treesand harvest more scar-free fruit. See your pest control advisor and
spray LANNATE this season." The generic name for Lannate is me thorny1.
.Methomyl is a highly toxic carbamate which also adversely affects beneficial
89
insects such as honey bees. No mention is made in either of the
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95
advertisements of the possible adverse effects of using these insecticides,
such as the induced outbreaks of citrus red mite and other serious pests.
It is not known to what extent these advertisements affect grower pesticide
use decisions, but they surely are a reflection of what American Cyanamid
and Dupont salesmen are telling their client growers. Guthion, Phosphamidon
and malathion are also highly destructive to Amblyseius hibisci, the pre-
daceous mite that, in the past, has often kept the citrus red mite under
90
effective biological control.
The citrus red mite is one of the most expensive citrus pests treated.
The estimated cost for citrus red mite control in 1974 was $4,427,322. The
estimated loss of crop value, much of it attributable to cosmetic damage,
91
was $6,049,014. Citrus red mites are widely sprayed with chemical acara-
cides but the populations are rapidly becoming resistant to many of these
92
chemicals. One of the leading acaracides now in use is Kelthane, manu-
factured by Rohm and Haas. Kennett and Flaherty have pointed out that the
citrus red mite has developed a moderate degree of resistance to Kelthane
and as a consequence Kelthane is usually ineffective against the mite in the
spring when populations are increasing at a rapid rate. On the other hand,
the predator of the citrus red mite, ^. hibisci has not developed resistance
93
against Kelthane. Rohm and Haas ran a two page, full color advertisement
for Kelthane in the March, 1975 issue of Citrograph which features photo-
graphs of cosmetically perfect citrus fruit, but doesn't inform the reader of
Kelthane's limitations as an effective acaracide.
As pesticide costs increase, the financial burden made necessary by
quality standards for citrus thrips and the consequent resurgence of other
pests, looms as a growing social cost to citrus growers as a whole, though
as individuals they continue to strive to maximize their returns through
the control of cosmetic insect pests.
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The current level of control for thrips damage may constitute a threat
to the welfare of farm workers. It is difficult to determine the exact
amount of pesticides that are applied for the cosmetic control of citrus
thrips, since the California Pesticide Use Report does not report pesticide
use by pest category. The University of California and Sunkist recommenda-
tions list parathion, Delnav-dioxathion, guthion, phosphamidon, and dimethoate
94
for the treatment of citrus thrips. These are all organo-phosphates with
high mammalian toxicities. The $3 million spent 'annually for citrus thrips
control indicates that there is a substantial use of insecticides against
this pest. According to the California Pesticide Use Report 23, 319 Ibs. of
Delnav-dioxathion, 35,580 Ibs. of guthion, 16,581 Ibs. of phosphamidon,
109,629 Ibs. of dimethoate, 194,061 Ibs. of parathion and 236,188 Ibs. of
95
malathipn were sprayed on oranges, in California in 1973. Undoubtedly, a
large amount of this material was used for the treatment of citrus thrips.
Unfortunately, the California Pesticide Use Report does not classify pesticide
use by target pest. An attempt to explore this question was made in the
survey conducted by Norgaard. Unfortunately, the data on this question were
sparse. The data that do exist and published pest control recommendations
point to the use of organophosphates for thrips control. Growers and pest
management consultants also indicate that organophosphates are often used in
this manner, especially as the more selective botanical insecticide, such as
Ryania and Sabadilla have become increasingly difficult to obtain.
We have dealt with the citrus thrips and- its potential as a cosmetic
pest in some detail. It should not be forgotten, however, that a number of
the growers we spoke to also listed the citrus red aite and red scale as at
least partially cosmetic pests. This is to say, there is some level of these
pests which requires treatment, not because they' have yet reached a density
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which constitutes a threat to the yield of fruit, internal fruit quality, or
to tree vigor, but because the grower must meet cosmetic standards.
While at higher population levels, red scale and citrus red mite may
be very serious non-cosmetic pests, the treatment for these pests at
cosmetic levels may result in the same types of negative impacts that we
have discussed in regard to citrus thrips. Moreover, it is possible that
the same kind of effects that we have described for citrus thrips may occur
in other crops that are marketed as fresh produce under strict cosmetic
quality standards.
ALTERNATIVES AND OBSTACLES
There are several imaginable alternatives to the current situation regarding
the citrus thrips' problem. These involve the changing of pest control
*
practices, the changing of quality standards, or the changing of marketing
practices, including consumer attitudes.
It may be possible to meet current quality standards regarding citrus
thrips1 damage with substantial reduction in the amount of pest control
materials actually applied. As we have indicated, the available information
suggests that an integrated control program, as opposed to an intensive
chemical control program, results in a generally reduced application of
insecticides as well as reduced over-all pest control costs. However, in
regard to citrus thrips, the implementation of ah effective integrated
v
control program.is problematical. Integrated control consultants would like
to lower the status of citrus thrips in the pest hierarchy, or, what amounts
to the same, to increase the economic threshold level for citrus thrips to
some value greater than zero. If this could be accomplished the entire
outlook for integrated pest management in oranges would be improved. As it
is, there are two barriers to this policy. First of all, both the grower
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and the consultant may be uncertain as to the actual relationship between
citrus thrips1 damage and economic return. Additionally, the actual effective
quality standards for citrus thrips, even if known with certainty, may be
unreasonably high from an integrated pest management viewpoint. The over-
whelming majority of growers market through marketing cooperatives, mainly
Sunkist, that adhere to strict quality standards for thrips1 damage. This
difficulty could be resolved through the establishment of an explicit
quality standard for oitrus thrips' damage, a. standard that takes the
requirements of integrated pest management more into account.
Even under the current quality standards, integrated pest management
consultants have sometimes been able to successfully tolerate a finite level
of citrus thrips1 damage. It has also been shown that citrus thrips can be
partially managed through the use of cultural techniques and relatively non-
disruptive insecticides. It is known that the presence of cover crops and
the use of overhead sprinkler systems for irrigation greatly reduces the
severity of citrus thrips1 infestations, even to levels below a reasonable
economic threshold. An experiment conducted in Tulare County between 1970
and 1972 demonstrated that citrus thrips can be effectively controlled
through the use of such botanical insecticides as Ryania and Sabadilla rather
Ofi
than much more hazardous organo-phosphates." Hopefully, a comprehensive
and effective strategy for the integrated control of citrus thrips will
97
eventually result from this research. However, we should not lose sight of
the current quality standards with regard to citrus thrips1 damage which
appear to constitute a barrier to the full development of an integrated pest
management program for oranges as well as an integrated control program for
citrus thrips itself.
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Another alternative would be to simply not treat for thrips in mature
groves except against infestations of such severity that tree vigor or yield
is threatened. In the Fillmore Protection District only about ten percent
98
of the acreage is treated for cttrus thrips on the average. If the level
of enforcement of quality standards were relaxed even moderately it might
be possible to eliminate the need for treatment against citrus thrips in
this coastal growing area. According to many commentators, the primary
obstacle to a change in quality standards is the attitude of consumers
toward the cosmetic appearance of fruit. For example, W. Leland Brown,
Agricultural Commissioner for Sacramento County comments: "Part of the
problem is educating the consumer that just because a fruit is scarred with
thrip (sic.) or whatever, doesn't mean that the interior quality is inferior.
Oranges that are clean and perfect on'the exterior just naturally sell better
than oranges scarred by thrip (sic.) even though there is no difference in
99
eating quality: But how do you convince the consumer of this?" However,
for the reasons already cited, it is net likely that consumer attitudes are
the primary obstacle to altering existing quality standards. Consumer
education campaigns, can be successfully waged if somebody is willing to
carry them out. The Consumer Cooperative in Berkeley, California, a major
retail food outlet that is consumer owned and operated, recently featured
cosmetically lower quality oranges, at 19c per pound as a "superior buy" over
29c per pound "Sunkist" oranges. This suggestion carried the prestige of
the store's home economist. Safeway Stores, on the other hand, recently
ran an extensive television advertising campaign which featured Sunkist
oranges and high-lighted the cosmetic aspect by showing grapefruit-sized
oranges in Christmas stockings. While Sunkist officials say that they
give equal weight to taste and nutrition in their advertising, ' it is
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100
far-fetched to think that Sunkist would risk its quality reputation by
campaigning for cosmetically lower quality oranges.
"Finally, it must be recognized that these suggestions deal with the
problem in only a symptomatic manner. The unnecessary use of pesticides
is but one of the social costs incurred as a result of a fundamental mis-
allocation of agricultural resources and economic power and the short-sighted
attempts to deal with these problems. It is not reasonable from an
aggregate point of view, for the entire orange crop to be treated for optimal
cosmetic appearance, when a large proportion of the crop ends up as juice
and by-products. But, under the current system, for many growers, operating
in isolation, seeking to maximize individual net return by maximizing the
proportion of the crop that qualifies for the fresh market and the highest
quality grade, means-spraying the entire crop for full cosmetic effect,
regardless of how much of the aggregate crop goes to juice and by-products.
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REFERENCES - -
1. Gordon Rausser, "A Dynamic Econometric Model of the California-
Arizona Orange Industry," Doctoral Dissertation, University of
California, Davis, 1971, p. 1.
2. Walter Reuther, ed., THE CITRUS INDUSTRY, University of California,
1967, p. 80.
3. Reuther,-op_. cit., p. 69.
4. Reuther, op. cit., p. 139.
5. Sunkist Growers, Inc., CITRUS FRUIT INDUSTRY STATISTICAL BULLETIN, 1975,
p. 12,13.
6. Reuther, op. cit., pp. 65-67.
7. James Youde, "Marketing Margins," CITROGRAPH, June, 1972, p. V.
8. John A. Jamison, "Marketing Orders and Public Policy for the Fruit and
Vegetable Industries," FOOD RESEARCH INSTITUTE STUDIES IN AGRICULTURAL
ECONOMICS, TRADE, AND DEVELOPMENT, Volume X, No. 3, 1971.
9. Reuther, op. cit., p. 66.
10. R. C. Rock and R. G. Platt, CALIFORNIA ORANGES, ACREAGE AND PRODUCTION
TRENDS, COSTS AND RETURNS, Agricultural Extension, University of
California, 1973, p. 1.
11. Rock, op. cit., Supplement.
12. Hoy Carman and James Youde, "Alternative Tax Treatment of Orchard
Development Costs: Impacts on Producers, Middlemen, and Consumers,".
AMERICAN JOURNAL OF AGRICULTURAL ECONOMICS, Vol. 5'5, No. 2, May, 1973.
13. Hoy Carman, "Tax Loss Agricultural Investments After Tax Reform,"
AMERICAN JOURNAL OF AGRICULTURAL ECONOMICS, Vol. 54, No. 4, November, 1972.
14. Jeanne Dangerfield, "Sowing the Till", CONGRESSIONAL RECORD, May 16, 1973,
Vol. 119, No. 74.
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15. Between 1967 and August 1974 average weekly take-home wages as measured
in 1967 dollars increased by less than 12 from §90.86 to $91.49
according to the Bureau of Labor Statistics.
16. CITRUS FRUITS, Statistical Reporting Service, United States Department
of Agriculture, Washington, D. C., 1949-1974.
17. Rock, op. cit.. p. 26. . .
18. FRUIT AND VEGETABLE INDUSTRY, National Commission on Food Marketing,
Tech. Study No. 4. June, 1966.
19. Leon Garoian and Kirby Moulton, "Structure of the California-Arizona Market,"
CITROGRAPH, June 1972, p. VIII. p. 355.
20. Curtis Anderson, "Structure of Sunkist," CITROGRAPH, June, 1972, p. X.
21 U.S. Congress, House Committee on the Judiciary, Subcommittee of
Monopolies and Commercial Law, Hearings, "Food Price Investigation,"
93rd Congress, 1st Session, June, July 1973, Serial No. 15, p. 711-715.
22. Anderson, op. cit.
23. Linda Kravitz, WHO'S MINDING THE CO-OP?, Agribusiness Accountability
Project, March, 1974, Washington, D. C. p. 47.
24. Anderson, op. cit.:
25. Rausser, op. cit., p. 139.
26. Garoian, op. cit.
27. Federal Marketing Orders No. 907 and No. 908.
28. Garoian, op. cit.
29. F. M. Sherer, INDUSTRIAL PRICING, Rand McNally Publishing Co., Chicago,
1970, p. 3.
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30. Kravitz, op. cit.
31. Garoian, op. cit.
32. Charles C. Teague, 10 TALKS ON CITRUS MARKETING, California Fruit Growers
Exchange, Los Angeles, 1939, pp. 5, 16.
33. Robert Rock, "Marketing Orders," CITROG5APH, June, 1972, p. VII. Also
see Rausser for a complete discussion of orange marketing orders.
34. Federal Marketing Orders No. 907 and No. 908, FEDERAL REGISTER,
December 30, 1961.
35. Stan Gillette, pers. coma., manager of Euclid Pure Gold packing-house,
pers. comm., October, 1974.
36. Federal Marketing Orders No. 907 and No. 90S.
37. Rock, op. cit., June, 1972.
38. For an analogous situation in cling peaches see Jamison, p. 298.
39. Floyd D. Shimomura, "A New Look at the California Marketing Act of 1937,"
40. Tom Karins, grower, pers. comm., Exeter, California, October, 1974.
41. Robert Howie, pers. comm., August 6, 1974.
42. Shimomura, op. cit., p. 191.
43. California Food and Agricultural Code, Sections 46951-46961.
44. David Pimentel, "Extent of Pesticide Use, Food Supply, and Pollution,"
NEW YORK ENTOMOLOGICAL SOCIETY, March, 1973, p. 21.
45. George, op. cit.. p. 74.
46. Everett J. Dietrick, Rincon-Vitova Insectaries, Inc., pers. comm.,
August 19, 1974.
47. Rausser, op. cit.
48. Irving L. Eaks, "Rind Disorders of Oranges and Lemons in California," in
H. D. Chapman,, ed., PROCEEDINGS OF THE FIRST INTERNATIONAL CITRUS
SYMPOSIUM, University of California, Riverside, March, 1969, p. 1343.
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49. Interview with Sunkist, Pure Gold, and ICCAP representatives, pers.
comm., September 24, 1974..
50. Garoian, og. cit., p. IX.
51. Of nine orange growers interviewed, all nine stated that the enforcement
of quality standards was adjusted intraseasonally.
52. Richard Breuner, pers. comm., August 6, 1974.
53. Don Avis, pers. comm., August 11, 1974.
54. N. G. Hardy, "New Citrus Committees Study Ways to Improve Quality,
Increase Sales," The Produce News, Sept. 11, 1976.
55. Pimentel, op. cit., p. 15.
56.. PESTICIDE USE REPORT BY COMMODITY, 1973, State of California Department
of Food and Agriculture, Agricultural Chemicals and Feed, Sacramento,
1974, pp. 170-175.
57. Don Avis, pers. comm., October 14, 1974.
58. According to data provided by Norgaard, see note 67, below.
59. Reuther, op. cit., p. 81.
60.. INTEGRATED PEST MANAGEMENT PROGRESS REPORT, Volume 1, September, 1974,
p. 87.
61. C. E. Kennett, citrus entomologist, University of California, Berkeley,
pers. comm.
62. C. B. Huffaker, "The Ecology of Pesticide Interference with Insect
Populations," in AGRICULTURAL CHEMICALSHARMONY OR DISCORD FOR FOOD,
PEOPLE AND THE ENVIRONMENT, John E. Swift, ed., University of California,
1971, p. 99.
63. c. E. Kannett, personal communication.
64. .Reported in Ray Smith, "What is Being Done by the Universities," in
AGRICULTURAL CHEMICALSHARMONY OR DISCORD, p. 141.
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65. As part of a study on pest management technology, for the Ford Foundation,
W. Willey and R. Norgaard have surveyed growers on their attitudes toward
integrated and conventional pest management and have collected objective
data on growers who have and have not adopted independent pest management
consultants. The data on orange growers has been made available to us
and we report some of our observations on these data.
66. R. c. Hall, R. Norgaard and P. True, "The Performance and Independent
Pest Management Consultants in San Joaquin Cotton and Citrus, California
Agriculture, October, 1975, p. 12.
67. Howard B. Lorbeer, FIFTY SECOND ANNUAL REPORT, FILLMORE CITRUS PROTECTION
DISTRICT, December 31, 1973.
68. A survey of nine California citrus growers, six located in the Central
California growing region and three in the Desert region.
69. J. R. Horton, "The Citrus Thrips," United States Department of Agriculture
Bulletin No. 616, February 14, 1918, Washington, D. C.
70. Stanley F. Bailey, "Thrips of Economic Importance in California,"
Circular 346, University of California Agricultural Experiment Station,
Berkeley, December, 1938, pp. 39-44.
71. Ronald Hawthorne, "Estimated Damage and Crop Loss Caused by Insect/Mite
Pests, 1974," California Department of Agriculture, Sacramento,
September 4, 1974.
72. D. L. Flaherty, J. E. Pehrson and C. E. Kennett, "Citrus Pest Management
Studies in Tulare County," CALIFORNIA AGRICULTURE,. November, 1973, p. 4.
73. G. E. Carman, et_ al. "1974-1975 Treatment Guide for California Citrus
Crops," University of California Agricultural Experiment Station, Riverside,
1974, p. 31.
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74. Dick Lyneis, "If You Rule Out Pesticide Use, You May Have to Eat Worms,"
THE PRESS, Riverside, June 3, 1971.
75. Anonymous, SUNKIST CITRUS DEFECTS MARKET HANDBOOK, Sunkist Growers, Inc.
1974.
76. Don Avis, pers. coma., August 11, 1974.
77. William K. Charles, pers. comm., December 19, 1974.
78. W. H. Ewart, H. S. Elmer and 0. L. Browner, "Effects of Citrus Thrips
Populations on Navel Orange Fruit Yield and Tree Growth in Central
Valley" Citrograph, November, 1975, p. 9.
79. W. N. Ewart, pers. coma., October 15, 1976.
80. T. F. Leigh, pers. comm., February 11, 1977.
81. Cost estimates and yield estimates provided by citrus entomologist, C. E.
Kennett, pers. comm., October 26, 1976.
'82. Don Avis, Sunkist Pest Control Circular, February, 1974, 1975.
83. Don Avis, Sunkist Pest Control Circular, March, 1976.
84. Flaherty, op. cit., p. 4.
85. "Rules and Regulations Governing Fruit Packed For Marketing by Sunkist
Growers, Inc. Under its Trademarks Sunkist, Excel, Sk, and Red Ball and
Under Association Non-Advertised Brands," Sunkist Growers, Inc., November
1, 1967.
86. C. E. Kennett and D. L. Flaherty, "Spider Mites," San Joaquin Valley
Agricultural Research and Extension Center, Parlier, September, 1974.
.87.. R. F. Luck, R. van den Bosch, and R. Garcia, "Chemical Insect Control,
A Troubled Pest Management Strategy," to be submitted to BioScience, 1975.
88. R. M. von Rumker, PESTICIDE MANUAL, RvR Consultants, Shawnee Mission,
Kansas, August, 1972, p. 234.
89. E. C. Loomis and W. Stengor, "Environmental Impact of Pesticides. Insects,
Mites, and other Invertebrates, Univ. of Calif., Div. Agric. Sci., 1972,
p. 113.
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90. Kennett, op. cit., September, 1974, p. 20.
91. Hawthorne, oo. cit.
92'. George P. Georghiou, "Resistance of Insects and Mites to Insecticides
and Acaracides and the Future of Pesticide Chemicals," in AGRICULTURAL
CHEMICALSHARMONY OR DISCORD, p. 118.
93. Kennett, op. cit., September 1974, pp. 20, 26.
94. "Treatment Guide for California Citrus Crops," p. 31.
95. PESTICIDE USE REPORT, 1973, p. 170-175.
96. Flaherty, op. cit., p. 5.
97. IPM PROGRESS REPORT, 1974.
98. Lorbeer, op. cit.
'99. W. Leland Brown, pers. comm.,. August, 1974.
100. Observed at the Berkeley Co-op, December 17, 1974.
101. Observed on Bay Area television and Safeway Stores, December, 1974.
102. Quarles, op. cit.
103. Sunkist representatives, pers. comm., September 24, 1974.
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CHAPTER 4. COSMETIC QUALITY STANDARDS AND PESTICIDE USAGE
IN PROCESSING TOMATOES AND CLING PEACHES
The conditions under which this investigation was conducted did not
permit as thorough an assessment of the produce cosmetic quality-pesticide
usage relationship in processing tomatoes and cling peaches as was done
for fresh market oranges. However, sufficient information was gathered
to indicate that the pressures, which force the orange grower to produce
"impeccable" produce, also bear upon the tomato and cling peach grower.
Taken together the three crop studies appear to set a pattern which
probably applies to many other types of agricultural produce.
PROCESSING TOMATOES
TOMATO PRODUCTION
California leads the nation in the production "of tomatoes. In 1974
83 percent of the nation's supply of processing tomatoes (4.8 million tons)
were produced in California. Along with Florida, California is the leading
producer of fresh tomatoes, each state supplying about 25 to 30 percent of
the national need. The production of fresh and processing tomatoes are.
each very specialized activities; they are essentially different crops.
Therefore, this discussion will be restricted to processing tomatoes.
Processing tomatoes are not grown throughout the state but are con-
centrated in certain geographical sections. Eighteen of California's 58
counties produce processing tomatoes, with the mid-Central Valley counties
of Yolo, Fresno, San Joaquin, Sutter, Solano and Sacramento being the major
producers. Yolo County leads the state with a. 1972 production of one
2
million tons, about one-sixth of the national total production. The
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harvested acreage for the processing tomatoes in California has fluctuated
significantly from year to year. For example the harvested acreage declined
from 231,000 acres in 1968 to 141,000 acres in 1970, but since 1970 acreage
has been steadily increasing at about 15,000 to 30,000 acres per year. The
overall trend in harvested acreage for the state has been increasing in the
post World War II period. On the other hand, for the United States, as a
whole there has been a declining trend from the peak harvest year of 1946
of some 570,000 acres, to the 1973 harvest of 300,000 acres. The yield per
acre in California processing tomatoes has doubled in this same period to
3
its present level of about 24 tons per acre. There has been a sharp
decline in the number of processing tomato growers in California, from
4
about 4000 growers in 1964 to just over 600 in 1973.
With the reduction in the number of processing tomato growers in
California from 4,000 in 1962 to about 600 in 1973, it might be thought
that an effective bargaining association would develop among tomato growers.
However, this does not appear to be the case, at least to date. With
several hundred processing tomato growers, without an effective grower
bargaining association, facing only a handful of processing firms, it
might be expected that the market is monopsonistic, with the bargaining
power centered in the processing firms. But, Chern presents some econometric
evidence which suggests that the market is competitive with respect to the
price paid for processing tomatoes. This, does not eliminate the possibility
that the processing firms may utilize the quality standard provisions of
processor-grower contracts to their advantage. Statements from the California
Tomato Growers Association do not indicate that to date, the Association
has been able to muster any significant bargaining power. In March of 1976,
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the Association accepted a contract with Hunt & Wesson, the price leader, for
$47 per ton of tomatoes, down 12% from 1975. California Tomato Growers
Association President, Jack Hayes, urged tomato growers to reduce acreage
8
by 20% from the 299,200 acres planted in 1976. However, if the lower
price fails to result in this substantial reduction in tomato acreage, the
Association has no formal method of enforcing or coordinating such a
reduction among its members.
Lower product price may not, in itself, result in the optimal decrease
in planted acreage for the following reason, according to agricultural
q
economists Doll, Rhodes and West:
As Jthe total output of a particular farm product increases, prices
received by producers decline. What started out as individual
decisions to increase output on individual units has consequences
for the group. An important aspect of the situation is that the
decision with respect to the level of production is made prior to
the time the product is ready to sell. In many cases this may be
several months or even in a few cases many years prior to the time
the product is sold. Research related to individual decision making
with respect to level of output has shown that decisions are based
on current price or the price which has existed in some recent past
period. The level of individual farm output may or may not be the
optimum one if price changes during the production period. However,
assume for the moment that the individual farmer is well aware of
the fact that if he and other individual farmers increase output
prices will decline. Will he as an individual find it desirable to
restrain his increase in output? Only if he can be assured that
others will act in a similar way an assurance he does not have!
USE ALLOCATION OF PROCESSING TOMATOES
In 1960, the latest year in which complete comparative data are avail-
able, the California processing tomato crop was allocated to the following
10
uses:
Canned Tomatoes 212,000 tons
Tomato Juice 211,000 tons
Chili Sauce 25,000 tons
Tomato Purae 142,000 tons
Tomato Products 50,000 tons
Tomato. Catsup 367,000 tons
Tomato Paste 801,000 tons
Tomato Sauce 414,000 tons
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According to Mel Zobel, Farm Advisor in Yolo County California, processing
tomatoes are not distinguished by use until after they have been acquired
by the processor* thus all processing tomatoes must meet the same quality
standards, even though, according to Zobel, it is impossible for the
consumer to detect insect _parts or insect damage in the ground-up tomato
products, such as tomato paste, sauce, puree, and catsup. As indicated
above, the presence of insects of field origin in these products has not
been known to cause a health hazard. -
QUALITY STANDARDS FOR PROCESSING TOMATOES '
Tomato is one of the few crops in which there is a state quality
standard which refers explicitly to the product meant for processing. Until
1968 the state quality standards for processing tomatoes allowed up to 10
percent worm damage. However, the provision was amended ' in 1968 to restrict
worm damage to 2 percent. .
Processor contracts generally do not allow more than one percent worm
damage, and in fact many contracts allow the buyer to reject shipments which
contain in excess of 1/2 percent worm damage, and, in some cases, the buyer
may require zero worm damage. The effect, in all these cases, is for the
grower to feel that^his tomatoes must have a zero level for worm damage, if
he is to avoid the risk of rejection of his crop at the cannery. As one
grower explained, . . - .
Standards for insect parts and damage can be graded. It is the idea
of establishing standards that are designed to eliminate ALL insects
that cause fear to develop in the mind of the farmer.
We were under scheduled treatments and most of them are bought out
of fear of very low tolerances established by processors through
contracts.
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Further reductions in pesticide usage could be obtained if there
weren't the fear of the zero tolerance for insect parts.
I know we never would have to spray tomatoes if the rumor weren't
to have zero tolerances on worms. Russet mite is sprayed for only
in unusual situations, usually after treating for worms.
In addition to contractual obligations tomato processor pressure growers who
deviate from an intensive spray program. One processor representative sent
the following letter to a tomato grower who was attempting integrated
control:
The 1971 tomato crop is in the process of being planted and, although
we have had cool weather, the crop is approximately three-fourths
emerged. The early acreage is progressing at a rather slow rate
but appears to have a satisfactory stand.
I am again making it my responsibility to remind you that a continued
emphasis on quality of raw product with special attention to insect
contamination, is mandatory if California tomato products are to
maintain their high quality reputation and market acceptance.
The company intend to protect their operations during the coming
harvest season by giving very close scrutiny to any or all your loads
where "State Inspection" has indicated a measurable amount of worm
contamination. If contamination is confirmed by our own inspection,
such loads may have to be returned to you. Presentation of two
consectuive loads containing 1% or more of worm contamination
may result in condemnation of the remainder of the field involved.
Later in the season the processor representative wrote:
It would look like we will have a full schedule for the month of
August and the early part of September; therefore, I recommend
that a twice-weekly inspection of all of the tomato fields be
carried out and a vigorous insect prevention program be in effect
at all times. We do not want insect contaminated tomatoes (emphasis
in the original)
Obviously, growers who receive letters of this kind are likely to be very
apprehensive about having worms of "a measurable amount". A "vigorous insect
prevention program...in effect at all times" can only refer to prophylactic
spraying for worms whether they are present or not.
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PEST MANAGEMENT FOR PROCESSING TOMATOES .
The major insect pests in processing tomatoes are such'Lepidopterous
larvae as the tomato fruit worm, cabbage looper, armyworms, pinworm, and
tomato hornworm. Russet mite, flea beetle* darkling ground beetle and
aphids are also commonly found attacking tomatoes. Integrated pest manage
ment and conventional chemical control depend on similar chemical materials,
with the exception that certain broad-spectrum cehmicals are
avoided under integrated pest management. However, under integrated pest
management there are generally fewer applications of the chemicals, lower
dosages of the chemicals used, and an avoidance of combination applications.
In a recent study conducted by the Association of Applied Insect
Ecologists in collaboration with Dr. Charles Summers of the University of
California, Berkeley, the effectiveness of conventional chemical control and
integrated pest management, programs in processing tomatoes were compared.
Twenty-four fields were divided into two groups, twelve under conventional
control and- twelve under integrated control. Reports of every chemical
application and the reason for it were requested. Frequently an insecticide
was applied because the grower "felt like it". At the time of a fungicide
application often an insecticide was added for good measure. Summers
reported that approximately 30 percent of the insecticides were applied as
fungicide/insecticide combinations.
The research team members did their own grading which was repeated, by
state inspectors. None of the loads were rejected. Statistical analyses
revealed that there was no difference in yield or insect damage between the
integrated pest management and the conventional chemical control fields. At
one point in the study, when the integrated fields had received one treatment
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and the conventional fields three, a group of cannery representatives and
growers were asked to compare two fields in the Lodi area; they could detect
no differences between the conventionally controlled field and that under
integrated pest management. '-....'"_ .
Overall the integrated pest management fields received 58 percent
less insecticides than the conventional chemical control fields. The
integrated control fields received between zero and three applications while
the conventional fields received between two and four applications~ The
pest management cost per acre was significantly lower for the integrated
" '"' ' ' ' 13 ' '' '
control fields than the conventional fields. Historically several
privately practicing pest control advisors have provided excellent tomato
pest control for California growers under integrated control programs
. ' . . '. ' ' 14
which utilized substantially less pesticide than conventional programs.
The indications, then, are that current quality standards for processing
' " " ' * '
tomatoes can be met with, a significant reduction in pesticide use. However,
' . . T
as we have indicated above (see page 111), implied zero tolerance cosmetic
quality or insect contamination standards form an obstacle to grower
acceptance of integrated pest management'. Furthermore* relaxation of
pest "injury" levels for processing tomatoes would allow for an additional, ..
reduction in pesticide use. ' According to Zobel, two-thirds of the current
pesticide use in processing tomatoes is for the tomato fruit worm "control".
Under prevailing standards there is a strong probability that the bulk of
this treatment is essentially for cosmetic purposes and not because of
substantial threat to crop yield, quality or wholesomeness.' In 1973,
89,923 pounds of parathion was sprayed on 113,610 acres of tomatoes in
California, according to the California State Department of Agriculture
Pesticide Use Report. In addition 163,439 pounds of Methomyl (Lannate) and
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115
256,488 pounds of Carbaryl (Sevin) were used. These pesticides are often
used in the treatment of worms on tomatoes.
There seems to be no compelling reason why the cosmetic quality and
insect contaminant standards in processing tomatoes should be as stringent
as they currently are, especially in the majority of cases where the
tolerance for isnect parts or damage approaches the zero level.. For example,
more appropriate worm damage standard would perhaps be the current state
standard of 2 percent for processing tomatoes. It seems reasonable that
quality standards could be less stringent for the high percentage of
tomatoes that are allocated to such products as paste, puree and catsup if
some more rational allocation method could be designed. In order for
there to be a relaxation of quality standards for processing tomatoes the
federal FDA regulations for insect parts debris would have- to be clarified
so that these regulations could not be used, by the processors as a justi-
fication for demanding stringent cosmetic quality standards for raw produce
at the input end of processing. As indicated above, the future adjustment
of quality standards for processing tomatoes may also depend in part on
the growers who, quite ironically, may be developing a stronger position
vis-a-vis the processors as their (the growers) numbers diminish. Whether
this stronger bargaining organization evolves., and if so, whether the
growers place high priority on modifying quality standards, remains to
be seen.
CLING PEACHES
Virtually all cling peach production takes place in California. In 1974,
51,705 acres of California agricultural land was devoted to cling peach
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116
18
orchards, producing a yield of 791,856 tons. Cling peaches are used
exclusively as an input to the canned fruit industry, along with apricots,
bartlett pears and freestone peaches. Cling peach is the predominating
commodity in California canned fruit industry accounting, in 1969, for
about 60 percent of the input in terms of tonnage and 54 percent in terms
19
of cash value to growers.
ACREAGE AND PRODUCTION
Cling peach acreage, as well as production, increased throughout the
1960's only to take a precipitous decline in the last few years. The number
of cling peach growers and canners declined significantly in the 1960's.
Between 1960 and 1968 the number of cling peach growers decreased from
about 2,800 to about 2,200, while the number of cling peach .canners declined
from 38 to 17.2°
THE CLING PEACH MARKETING ORDERS
These historical trends are, in part, a result of the operation of the
cling peach marketing orders. Cling peach growers and canners have been
under the control of state marketing orders since the early 1930's. The
cling peach marketing orders have been the most comprehensive and complex
of any, and have certainly resulted in the most heroic attempts at commodity
21
quantity control.
SURPLUS ELIMINATION
Until recently, the cling peach marketing orders contained a number of
provisions for the elimination of "surplus" fruit both by the producers
and processors. If the cling peach marketing board determined that a
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117
"general surplus" exists, that the producers aggregate capacity to produce
peaches exceeded the needs of the canning industry with consideration for
excess tonnage to assure an adequate supply in the case of adverse weather
or growing conditions, then individual growers had the option of eliminating
up to 108 bearing trees per acre from their orchards. As an incentive
for such tree elimination the grower was granted credits for trees removed
against any seasonal surplus elimination that required mandatory elimination
by green drop or tree elimination. By May 15 of each year, when the fruit
reached a degree of maturity that makes an accurate estimate of the final
yield possible, the crop was again evaluated to determine whether a "seasonal
surplus" existed. If the board determined that a seasonal surplus did
exist it could recommend to the State Director of Agriculture that an order
be issued which required each and every peach grower in California to
eliminate a specified percentage of his crop by green drop or by tree
elimination. Green drop required the removal of all peaches from a
specified number of trees in the orchard. As an alternative the grower
could remove an equivalent number of bearing trees or apply credits for
bearing trees removed under the general surplus provisions.
Surplus diversion could also take place at the cannery. Immediately
prior to harvest the cling peach marketing order board reviewed its earlier
estimates of crop tonnage available in relation to market requirements. If
a surplus was found to exist at this point, it recommended to the Director
of Agriculture that each processor be required to divert a quantity of
Number 1 cling peaches from normal processing during the season. The amount
diverted could not exceed 7 percent of the quantity of Number 1 cling peaches
?2
available for processing."
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QUALITY PROVISIONS
The cling peach marketing orders also contained provisions in regard to
quality standards. These are listed in Table 1. As we have Indicated above
there are no state statutory standards that are applicable to peaches used
as an input to processing. The state quality standards for fresh (freestone)
peaches are concise and rather conservative. The definition of insect
damage is rather vague, including injury "which has penetrated or damaged
the flesh." The tolerance for insect damage is 5 percent, or 7 1/2 percent
if damage due to all causes is less than 10 percent.
The cling peach marketing order sets quality standards for Number 1
cling peaches, the grade that fruit must meet in order to be acceptable for
processing. The quality provisions in the marketing order are much more
detailed than the state quality standards for fresh peaches and, in
addition, the marketing order contains some types of quality provisions
that are absent from the state quality standards for fresh peaches, most
notably size standards.
In addition to these marketing order quality standards, the contractual
agreement between processors and producers further reduces the tolerances
for brown rot and worms or worm damage to 2 percent and 1 percent respectively.
The general cosmetic nature of these provisions is evidenced by the
fact that, under the provisions of the marketing order, the processor could
divert off-grade peaches or an equivalent amount of Number 1 peaches from
production. That is, once the percentage of off-grade peaches was established
by inspection of a random.sample, the processor could simply divert that
percentage of peaches fron processing, regardless of the quality of the
individual peaches diverted. The remaining peaches, which could include a
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119
percentage of off-grade fruit, was then processed. The producer, of course,
was not paid for the peaches "culled out" in this manner. . It is possible
for the canners to process off-grade peaches because, in most cases, the
"injury" is eliminated along with the skin when the peaches are boiled in
1 24
lye.
According to Jamison the quality standards for Number 1 cling peaches
25
have increased in their specificity in successive marketing orders. The
green drop and tree removal provisions were used heavily and, the extremely
heavy use of tree elimination in 1969, 1970 and 1971 resulted in a 26
percent reduction in cling peach acreage and a 31 percent reduction in cling
26
peach production between 1969 and 1972. In his study on the cling peach
marketing orders Jamison explains this history in the following way.
Operations of the cling peach marketing orders resulted in short-run
increases in net returns to the grower. But this results in a period of
27
rapid expansion in the production sector. As Jamison comments,
Monopoly pricing is, by definition, impossible in industries where
entry is not highly restricted. Where this is recognized in agri-
culture attempts have been and are still made to block new entrants.
These attempts have proven fruitless because the necessary condition
of internal homgeneity within the monopoly-seeking group of fanners
has never existed. Producers who achieve rewarding net returns under
cartel-like conditions have not long been content to subsidize their
less profitable neighbors by restricting their own production. Nor
will the profitable members of the cartel be willing to erect entry
barriers which may also limit .their own expansion. Under these
conditions, monopoly pricing is an impossible long-run goal in
agriculture, and the pursxiit of the structural conditions which are
required to achieve it is windmill-tilting in the extreme.
The same factor which draws a disproportionate amount of new resources
into the production of cling peaches, the artifically maintained price of
the crop also results in a contraction of the processing sector. If canners
pass the higher price of their raw produce on to the consumer they face a
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120
fall in demand and, consequently, a profit squeeze; if canners absorb the
increased cost of the cling peaches they also face a profit squeeze. Thus,
in the same period that the cling peach production sector was undergoing
price induced expansion, the cling peach processing sector was undergoing
contraction. The gap was partially filled by an expansion of grower-owned
cooperative canneries. However, it was also found necessary to exert pro-
gressively more stringent marketing order controls culminating in the 1969-71
28
period with a massive tree elimination program.
In evaluating the social cost of the cling peach marketing order
Jamison includes the cost of eliminated trees, of green dropped fruit, of
cannery diverted fruit, of artifically high consumer prices, and of agri-
cultural resources.allocated inappropriately to the production of cling
peaches. Jamison concludes,
Not only have resources spent in cling peach production risen to
levels far in excess of those suggested by market demand, but the
producers themselves are being assessed continually higher costs as
the burden of carrying this excess capacity. In addition, while
maintaining in production uneconomic orchards and inefficient
producers the cling peach industry continues to attract new entrants
who can operate profitably under the costly control programs and
relatively stable price levels that have been maintained. This new
capital investment increases the surplus burden, and, more importantly,
it further exaggerates the misallocation of total resources within
the economy. Because of this the consuming public loses two ways--by
prices higher than justified by total resources allocated to cling
peaches production and by the necessity of depriving o'ther more
desired production activities of these resources .... One additional
repercussion of the crop restriction pursued by the cling peach .
industry relates to its effects on the total income generated by
the product as it moves to the consumer. For example on the basis
of (postulated price elasticities) the increase in total revenue to
producers resulting from a reduction in the pack from 30 million to
24 million cases is $7.5 million. This pack reduction decreases
revenue at the processor level by $15 million and at the retail level
by $27 million. In other words, maintenance of the original level of
production at the grower level would result in a total revenue
generation of $210 million compared to $183 million at the quantity
suggested by unit elasticity at the grower level. This could be
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121
* ' ..»,
interpreted as a loss of jobs In the marketing as veil as the supplying
Industries. At the same time the retail cost of the product to
consumers Is raised from $7.00 per case (29c per 2 1/2 size can) to
$7.60 per case (32c per can). The costs of restrictionism of this
type are clear. Even the cling peach growers, the only possible
beneficiaries of the scheme, have eventually lost due to the apparent
necessity of eliminating 25 percent of their production in 1970 and
an even greater share in 1971.29
To these costs must be added the Increased cost of growing cling peaches as
individual growers, striving to Increase yields in order to beat back the .
losses due to increased quality standards and cull out rates, utilise inputs,
Including pesticides, in a more Intensive manner. Additionally, under these
conditions there is an irreaistable temptation for canners to attempt to"...
increase their supply of cling peaches and reduce the price of this supply
through the utilization of quality standards. The grower has an equal
tendancy to attempt to meet the most stringent quality standards, in order
to maintain the full maintained, price of his produce. Of course, he has an
added incentive to maintain quality in regard to the standards for worms or
worm damage, since the entire shipment can be rejected on failure to meet
this standard. Growers may even resort to expensive and time-consuming '
hand-culling at the ranch in order to insure that no worm damage is present
in their crop. Effective pest management, through chemical or other means
would obviously be preferred by the grower.
Finally the increasing production of cling peaches at an artif ically
maintained price, coupled with the decreasing capacity of canning plant
facilities, has aggravated the.problem Inherent in matching the time flow
of harvested peaches with the plant capacity of canneries. This problem Is
illustrated in figure 7. Because of a constant plant capacity but a
seasonal variation in cling peaches harvested, if the canning industry is
to run anywhere near full capacity for most of the season it will face an
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over-capacity situationan over-supply of peachesfor at least part of
the season. The cling peach industry is currently giving consideration to
the development of and distribution of cling peach varieties that would
result in a smoother seasonal yield pattern, but such a program may take
a very long time to implement. In the meantime, canners find it to their
advantage to invoke quality standards, during the surplus part of the season,
in order to reject the surplus cling peaches on the market. The severe
quality standards for worms and brown rot that are often incorporated into
standard cannery-producer contract, or are included in "dirty riders" to .
the standard contracts allow for this to happen. This is the reason why
the quality standards specified in individual processor-producer contracts
are more severe than the quality standards spelled out by the industry-
wide marketing order. Growers would like individual contracts to coincide
with the marketing order but have not been totally successful on this
30
score.
. Various attempts have been made, in recent years, by cling peach
growers to alleviate the negative aspects of the cling peach marketing
order. In 1971 the California Canning Peach Association, a grower's
bargaining cooperative, backed state legislation which would have allowed
growers to vote on the desirability of acreage limitation. This bill passed
the state legislature but was vetoed by the Governor. The Association has
bargained for long-term contracts with processors.
Since 1975 the surplus elimination provisions have been excluded from
the cling peach marketing order. The California Canning Peach Association
has attempted to constitute itself the exclusive bargaining cooperative for
the industry and thereby-replace the surplus elimination provisions of the
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123
marketing order with a combination of free market regulation and grower
discipline. However, the Association has not been successful in achieving
this goal to date. In 1976 the Association settled on a price of $115
32
per ton for cling peaches, down 10.5% from the 1975 price. Before the
cannery strike of 1976 there were 100,000 tons of cling peaches in surplus,
33
and the Association was asking for reinstatement of cannery diversion.
California Canning Peach Association President, Ron Schuler stated that,
"The larger stocks of canned fruit on hand and prospects for a good harvest
and large crops in 1976 have put a stress on the association's ability to
34
bargain for a price." Thus, the forces which make quality standards a
critical determinant in the economic survival of cling peach growers do not
seem to be at an end.
PEST MANAGEMENT IN CLING PEACHES
The major pests in California cling peaches are the Oriental fruit
moth, Grapholitha molesta (Busck), the peach twig borer, Anarsia lineatella
Zeller, and several mites: the two-spotted spider mite, Tetranychus urticae
Koch, the European red mite, Panonychus ulmi (Koch) and the peach silver
mite Aculus comutus (Banks). Other pests that can cause trouble include
San Jose scale, Coryneum blight (Shot hole), thrips, lygus, the consperse
stink bug, the western peach tree borer, the fruit tree mite and the flat-
35
headed borer. Damage attributable to the Oriental fruit moth and the
peach twig borer is summarized below:
ORIENTAL FRUIT MOTH PEACH TWIG BORER
YEAR YIELD LOSS CONTROL COSTS YIELD LOSS CONTROL COSTS
1970 $1,261,804 $2,172,979 $1,840,827 $3,027,282
1974 $2,154,950 $2,100,340 . $5,449,737 $6,157,599
Source: Ronald Hawthorne, California State Survey Entomologist
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124
Under conventional control programs these two pests have been treated
heavily with organophosphata and carbamate insecticides. In 1974 California
. peach growers sprayed 54,675 acres with 71,704 pounds of Guthion and 40,664
acres with 70,059 pounds of parathion. This practice has resulted in the
evolution, to serious pest status, of the phytophagous mites. For example,
California peach growers sprayed 15,079 acres with 25,895 pounds of the
' ' -. ' ' 37 ' " ' '.'"'
acaracide Omite in 1974. In. 1974, pest control costs for cling peaches
' - ' ' 38 ''
vere $154/acre out of total production costs of $701.19.
A preliminary integrated pest management program for cling peaches
has been developed"which is designed to take advantage of the natural controls
already present in the system through a program of careful monitoring of
insect and mite population levels and the selective use of pesticides. The
Bredacious mite Metaseiulus Occident alia which is commonly present in cling
peach orchards, is an effective predator of the two-spotted spider mite and
the European red mite. However, under conventional control this beneficial
mite is often suppressed by the imprudent application of organophosphates
' - . t -.-...
and carbamates^. The peach silver mite is an important secondary food source
for M. occidentalis, thus if the peach silver mite is eliminated with
acaracides, the population of M. occidentalis will starve, very few will
overwinter, and an inadequate population will be present in the spring to
control the population of the two-spotted spider mite and the European red
mite. Based on this.knowledge, L. E. Caltagirone, of the University of
California's Division of Biological Control, Albany, has devised the following
/
39
integrated pest management program for cling, peaches: . .
(1) Control of peach twig borer, San Jose scale, and mites (partially)
with a dormant spray.
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125
(2) Elimination of. the early spring spray.
(3) Control of Oriental fruit moth, timing the treatments very
carefully; two sprays during the season nay be sufficient.
(4) Reduction or elimination of the sprays to control two-spotted
spider mite and European red mite, if there are enough predators,
treatments are not necessary.
(5) Limitation of the treatments against peach silver mite to the
absolute nrf.nlTmnn; very few cases, if any at all should require
spraying. ' . . .
Caltagirone comments, that the importance of the peach silver mite as a. pest
has been overestimated by growers. Additionally, he comments in regard to
the Oriental fruit moth and peach twig borer that,
The economic injury level in terms of population density for these
two species has not been established. Tolerable damage to fruits
may be somewhere between zero and four percent. Some growers, and
probably most if not all canners, feel that no amount of worm damage
to fruits should be tolerated.. Apparently, damage to twigs is of
little importance in bearing trees. So, this gives some idea of
how much damage we can accept. But there is another dimension to
the problem. In order to implement a modified pest control program,
it is necessary to predict the extent of damage that a given early
season population will eventually cause, so the tactics can be
modified, if necessary, without endangering either the crop or the
program.
This critical aspect of the integrated pest management program for cling
peaches is extremely sensitive to the specification of quality standards and,
as we indicate below, has been adversely affected by recent modifications in
the quality standards.
COSMETIC QUALITY STANDARDS AND PESTICIDE USE IN CLING PEACHES
41
In private communications, an independent pest management, consultant
who manages a. substantial acreage and is familiar with both conventional
chemical control and integrated pest management in cling peaches indicated
that among the pests Lygus and thrips cause cosmetic injury, only and must
be treated simply to-meet quality standards. Furthermore, the 1st brood of
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126
peach twig borer and Oriental fruit moth cause only superficial (cosmetic)
damage that is removed with the peach skin in the processing procedure.
Mildew is superficial on fruit and is removed during processing. Coryneum
blight (Shot hole) must be controlled in the dormant season but an extra
spray to protect the fruit from Shot hole will only prevent superficial
injury which presently results in the fruit being culled. San Jose scale
can be very harmful to the tree vigor by virtue of its feeding on twigs and
limbs but the fruit feeding is not evident after the skin is removed in
processing.
According to this same pest management consultant the quality standard
for worms (peach twig borer arid Oriental fruit moth) has undergone important
modifications in the last few years. In the past fruit injury could only be
classified as worm damage if associated larvae were present in the lot of
fruit. Under the new procedure the presence of larvae is not required. The
effect of this is to make it necessary to treat the fruit to prevent
superficial damage caused by the 1st and 2nd broods of Oriental fruit moth
and peach twig borer, which feed only superficially on the green fruit.
The consequential early season spraying with organophosphates and carbaraates
disrupts the entire integrated pest management strategy. The natural enemies
of mites are suppressed and it becomes necessary to treat for these pests
with expensive acaracides. The situation is further aggravated because in
most cases the mites, develop resistance to the acaracide within two or
three seasons.
Thus, in this case, the effect of strict enforcement of cosmetic quality
standards is to force the abandoment of a well-developing and promising
integrated pest management program with resultant increases in pesticide use
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127
and further disruption of the peach agro-ecosystem. Moreover, the motive
for strict enforcement of cosmetic quality standards, in this case, is
totally unrelated to consumer preference, or to crop yield or vigor; rather,
it is a side-produce of the continuing economic struggle between the interest
of peach growers and processors, a side-product whose negative social impacts
are not well taken into account by the current economic mechanism that
determines how cling peaches are to be produced.
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Cosmetic Quality Standards and Pesticide Usage in Processing Tomatoes
and Cling PeachesFootnotes
1. Wen S. Chern, "Acreage Response and Demand for Processing Tomatoes in
California," American Journal of Agricultural Economics, May, 1976,
p. 209.
2. Gordon A. King, Edward V. Jesse and Ben C. French, Economic Trends
in the Processing Tomato Industry, University of California Extension
Service, August 23, 1973.
3. King, op. cit.
4. William H. Friedland,'Amy Barton and Robert Thomas, "De-stalking the
Wily Tomato," University of California, Santa Cruz, 1976, p. 18.
5. Chern, op. cit.
6. Anonymous, .Pacific Fruit News, March 27, 1976.
7. Anonymous, Western Packing News, February 16, 1976.
8. J. P. Doll, V. J. Rhodes, and J. G. West, Economics of Agricultural
Production, Markets, and Policy, Richard D. Irwin, Inc., 1968,
p. 472.
9. King, op. cit., p. 124.
10. Mel Zobel, pers. comm., March, 1975.
11. Cal. Food and Agric. Code 40844-40845.
12. See contractual standards, Table 1.
13. Anonymous grower, pers. comm.
14. Anonymous grower, pers. comm.
15. Charles G. Summers, The Economic Impact of Integrated Pest Management
in California Processing Tonatoes. A report prepared for the Environ-
mental Protection Agency, 18 pp.
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129
16. John Nickelsen, Louis Rudd, and Everett Dietrick, pers. cotnm.
17. Mel Zobel, op. cit.
18. State of California Department of Food and Agriculture, Pesticide Use
Report by Commodity, 1973, pp. 262-266.
19. W. R. Bowen, et. al.., "Pest and Disease Control Program for Tomatoes",
Division of Agricultural Sciences, University of California, 1973.
20. Anonymous, Cling Peach A1«nac, 1975, California Canning Peach Association,
San Francisco, California, 1975.
21. John A. Jamison, "Marketing Orders and Public Policy for the Fruit and
Vegetable Industries", Food Research Institute Studies in Agricultural
Economics, Trade, and Development, Volume X, No. 3, 1971, p. 242.
22. Ibid., p. 322.
23. Ibid., p. 241.
24. Ibid.. pp. 371-377.
25. See Table 1.
26. See p. 126, below.
27. Jamison, op. cit., p. 371.
28. Ibid., p. 352.
29. Ibid., p. 329.
30. Ibid., pp. 326, 351, 352.
31. Ibid.. pp. 341-348.
32. Anonymous, Cling Peach Quarterly, Spring, 1974, pp. 7, 10.
33. Anonymous, Cling Peach Almanac, 1972, 1975.
34. Anonymous, Pacific Fruit News, June 5, 1976.
35. Anonymous, Western Packing News, June 15, 1976.
36. Anonymous, Pacific Fruit News, June 5, 1976.
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130
37. S. C. Hoyt and L. E. Caltagirone, "The Developing Programs for Integrated
Control of Pests of Apples in Washington and Peaches in California",
in C. B. Huffaker, ed., Biological Control, Plenum Publishing Corporation,
New York, 1971, pp. 412, 413.
38. Ronald Howthorne, "Estimated Damage and Crop Loss Caused by Insect/Mite
Pests", 1972, 1974, California Department of Food and Agriculture,
Sacramento, California.
39. California Department of Food and Agriculture, California Pesticide Use
Report, 1974, Sacramento, California.
40. Anonymous, Cling Peach Almanac, 1975.
41. Caltagirone, op. cit., p. 419.
42. Ibid., p. 415.
43. Anonymous pest management consultant. This pest management consultant
chose to remain anonymous because he feels that identification would
result in pressure on growers, from processors and other sources, to
discontinue his. services.
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APPENDICES
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131
Table 1.
QUALITY STANDARDS FOR ORANGES, PEACHES, AND TOMATOES
AS SPECIFIED BY VARIOUS PUBLIC AND PRIVATE AGENCIES
A. Oranges " - - '.;.:.;."'. : . - . .
1. State of California Quality Standards for Fresh Oranges.
Article 5. .Oranges Generally : V v ; . '
(Article 5 beading amended by Stats. 1968, Ch. 738)
46951. As used in this article, "damage on the segment walls"
mggnq a water-soaked appearance, evidence of previous water-
soaking, or the presence of crystals or crystalline deposit, on
the two surface membranes of each of two or more segments as shown
on the separation of two or more segments of a. section. The
section shall not be less than one inch or more than one and
one-half inches in thickness, and shall be obtained from the
central portion of the fruit by cutting off a portion of each end.
Such evidence of freezing injury shall show for the entire length
but not necessarily the entire area of the surface membranes..
46952. Oranges shall meet the requirements which are pre- -
scribed by this article. . . -
' . (Amended by Stats. 1968, Ch. 738). '»
46953. Oranges shall be mature. Oranges, except bloods,
tangerinesj and mandarins, shall not be considered mature
unless they comply with one of the following requirements:
(a) The juice contains soluble solids which are equal to or
in excess of eight parts to every part of acid which is contained
in the juice (the acidity of the juice to be calculated as citric
acid without water of crystallization), and 90 percent or more of
the oranges in any lot, by count, before picking have attained, on
at least one-fourth of the fruit surface, at least a. minlTmnrc
characteristic orange color, as indicated by Color No. 7.5 Y .6/6,
"Munsell Color." ' .
(b) The juice contains soluble solids which are equal to or
in excess of 10 parts to every part of acid which, is contained in
the juice (the acidity of the juice to be calculated as citric
acid without water of crystallization), and 90 percent or more of
the oranges in any lot by count before picking have attained, on at
least one-fourth of the fruit surface, a m-fri-Cmim characteristic
orange color, as indicated by Color No. 2.5 GY 5.6, "Munsell Color."
No oranges may be accelerated in color unless the juice contains
soluble solids equal to, or in excess of, eight parts to every part
of acid which is contained in the juice (the acidity of the juice
to be calculated as citric acid without water of crystallization).
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, 132
Table 1 (continued)
The tolerances which, are allowed by Section 46961 do not apply
to the provisions of this section when determining whether any .lot
of oranges complies with the maturity standard.
(Amended by Stats. 1968, Ch..738)
46954. Oranges shall be free from decay.
(Amended by Stats. 1968, Ch. 738).
' ^46955. Oranges shall be free from serious damage due to
freezing. Damage from freezing to any one fruit is serious if
it causes any of the following conditions-:
(a) Damage on the segment valla, as defined in Section 46951.
(b) Drying or desiccation in 20 percent or more of the ex-
posed pulp as shown on a transverse cut through the center.
(Amended by Stats. 1968, Ch. 738).
46956. Oranges shall be free from serious damage which is
due to drying at the stem or stylar end which results from causes
other than freezing. Damage by drying- at the stem or stylar
end of all' oranges which results from causes other than freezing,
is not serious unless 20 percent or more of the pulp shows
staining, drying, or desiccation.
(Amended by Stats. 1968, Ch. 738).
46957. Oranges shall be free from damage which is caused by
splits, bruises, or punctures. Damage which is caused by splits,
bruises, or punctures in oranges is not serious if the injury is .
well healed and free from mold or decay.
(Amended by Stats. 1968, Ch. 738). . .
46958. In any season in which freezing damage to oranges which
are produced In this state has occurred, the extent of damage by
freezing to such oranges shall be determined as follows:
(a) By examination for damage on the segment walls from and
after the time when the oranges were first exposed to freezing
temperatures to the date, herein designated as date A, when the
director, after survey, shall make a determination in writing that
the drying process has developed to such extent as to furnish
additional evidence of the extent of actual damage to the fruit.
(b) By examination of the exposed pulp on a transverse cut
through the center, from and after the date, herein designated .
as date B, when the director, after survey, shall make a deter-
mination in writing that the drying process has developed to such
extent as to permit reasonably accurate determination of the full
extent of freezing damage by such examination, without regard to
damage on the segment walls. .
(c) Either by examination for damage on the segment walls or
by examination of the exposed pulp on a transverse cut through
the center, or by both such examinations, during the period from
date A to date B. In no event shall the interval from date A to
date B exceed three weeks.
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133
le 1. (continued)
46959. The extent of damage by freezing of oranges which were
produced outside of this state that are offered for distribution
and sale in this state shall be determined by the same methods
*r>A procedures as required for oranges produced in this state
unless it is not practicable to obtain sufficient accurate infor-
mation upon which to establish dates A and B as required by this
article for such, oranges. In such case the extent of damage by
freezing in any lot of such oranges shall be determined as follows:
(a) By examination of the exposed pulp on a transverse cut
through the center if examination of a representative sample of
the oranges in the lot shows that the drying process has developed
to such an extent as to permit reasonably accurate determination
of the full extent of freezing damage.
(b) In any other case, by damage on the segment walls.
46960. The percentage of serious damage to oranges in con-
tainers, or in bulk, may be established by inspection of a. repre-
sentative sample which shall consist of not less than 100 fruits.
(Amended by Stats. 1968, Ch. 738).
46961. The following tolerances which are to be applied to the
standards that are prescribed by this.article are established by
this section:
(a) With the exception of serious damage which is caused by
freezing, not more than 10 percent, by count, of the oranges in
any one container or bulk lot may be below the requirements, but
with the'exception of serious damage by drying at the stem or
stylar end of oranges which results from causes other than
freezing. Not to exceed one-half of this tolerance shall be
allowed for any one cause.
(b) In the case of serious damage by freezing injury, not
more than 15 percent, by count, of the oranges in any one con-
- tainer or bulk lot may be below the requirements, but not to
exceed one-third of this tolerance shall be allowed for oranges
which show a drying or desiccation in 40 percent or more of the
exposed pulp, as shown on a transverse cut through the center.
(c) The total tolerance for a. combination of defects shall
not exceed the tolerance permitted for any one cause by more
than 5 percent, by count.
; (Amended by Stats. 1968, Ch. 738). .
2
2. Sunkist Quality Standards for Fresh Oranges.
(1) Compliance with Federal and State Laws.
No fruit will be marketed by Sunkist Growers, Inc. under any brand or
grade, or at all, unless the same shall in all respects conform to
the laws of the State of California or the State of Arizona, and, if
the sale is made in Interstate Commerce, to Federal laws and to the
laws of the place where the fruit is sold. The Field Department
shall insepct all grades of citrus fruits marketed through Sunkist
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134
Table 1 (.continued) .
Growers, Inc. and shall in every way endeavor Co make uniform the
enforcement of the regulations and laws concerning the marketing of
California or Arizona citrus fruits.
Oranges
(2) Specifications for "Sunkist."
Oranges packed for marketing, under the trademark Sunkist shall be
mature; of one variety; of good eating quality and flavor; of good
; juice content; veil grown specimens of normal form, picked from the
tree; of good color for the variety; of good texture; practically
free from scale or other insect pests, fungus diseases, splits, or
defects of any kind that cause fruit to decay. The following classes'
of fruit shall be excluded: rough; coarse; more than slightly puffed;
more than slightly scarred; more than slightly sunburned; misshapen
fruit; dirty fruit unattractive to the consumer; fruit showing
effects of frost or which cuts dry for any reason;: immature fruit;
fruit insipid in flavor; fruit deficient in juice content; and fruit
green or very pale in color. Soft fruit or fruit showing marked
evidence of aging or shriveling shall be excluded. Fruit of extra
good texture and color may properly carry more scars than fruit
possessing only the mt-n-Tmim of color and texture required under these
"Sunkist" specifications. Oranges packed for marketing under the
trademark Sunkist shall not vary more than 5 percent below foregoing
specifications except that decay within this tolerance shall not
exceed 1 percent."
C3) Specifications for "Excel." '*
Oranges packed for marketing under brands listed in the Sunkist
Growers, Inc. brand list and/or manifested as "Excel" shall meet
specifications for "Sunkist," except that as to interior defects, the
minimum requirements of the State Agricultural Code shall apply. In
the case of damage from frost, the determination shall be made by
examination of the segment walls until that time when the interior
drying process has developed sufficiently so as to furnish sufficient
evidence of the degree of damage by this means. The tolerance for
frost damage as evidenced in damage to the segment walls shall be
15 percent of the fruits, by count. When frost damage can be
determined by drying, the amount of damage will be determined
volumetrically by three equidistant cuts of the fruit. The tolerance
for frost damage as evidenced by drying shall be 15 percent, by count,
of the fruits showing a drying or dessication in 20 percent or more
of the volume of the individual fruits, except that only 5 percent of
fruits, by count, may show a.drying or dessication in 40 percent or
more of the volume of the individual fruits.
(4) Specifications for "Red Ball."
Oranges packed for marketing under the trademark Red Ball shall be
mature; of one variety; of good eating quality and flavor; of good
-------
135
Table 1 (continued)
juice content; well grown specimens of fair form, picked from the tree;
of fair color for the variety; of fair texture; practically free
from insect pests (other than scale), fungus diseases, splits, or
defects of any kind that cause fruit to decay. The following classes
of fruit shall be excluded: very rough; very coarse; badly sunburned;
badly scarred; badly puffed; very scaly or very dirty fruit; fruit
showing effects of frost or which cuts dry for any. reason; immature
fruit; fruit insipid' in flavor; fruit deficient in juice content;
and fruit very green in color. Soft fruit or fruit showing marked
evidence of aging or shriveling shall be excluded. Fruit of extra"
good texture and color may properly carry more scars than fruit :
possessing only the m-t-n *"»"» of texture and color required under
these "Red Ball" specifications. Oranges packed for marketing under . .
the trademark Red Ball shall not vary more than 5 percent below
foregoing specifications with the following exceptions: Decay within
this tolerance shall not exceed 1 percent; as to fruit showing
effects of frost or which cuts dry for any reason, the total tolerance
shall be 10 percent, but not more than half of this tolerance shall
be allowed for serious drying or freezing damage as defined in the
State Agricultural Code.
(5) Maturity of Valencia Oranges. ...
In addition to the 8 to 1 maturity test, Valencia oranges to be
eligible for marketing under the trademarks Sunkist and Red Ball
must have a Brix reading of not less than 9.0.
(6) Storage L^^ tat ions for Oranges. .
Oranges, subject to all other regulations as to inspection, etc.,
will not be marketed under the trademarks Sunkist or Excel, except
as herein provided, if they have been off the trees more than 28
days, except that, after the following dates - January 1 on Central-
Northern California and Arizona navels; March -1 on Southern California
navels and miscellaneous, and Arizona valencias and miscellaneous;
June 15 on Central-Northern California valencias; and August 1 on
Southern California valencias - the storage limitation shall be 21
days. Associations, at the conclusion of the above dates, may only
ship after those dates by certification by the Field Department at
time of shipping, such certification to consist of grade, pack, con-
dition, .in jury. .and flavor certification, i.e., inspection with "B"
grade and pack, "2" condition and injury, and satisfactory flavor
classifications as miniTmTm requirements for certification.
Each shipper must furnish the Field Department accurate and positive
information of the date fruit has been picked; and further, all con-
tainers, must be marked with a code or date indicating the date
packed. Failure to comply with these requirements will disqualify
all fruit concerned for marketing under the Sunkist or Excel trade-
marks for association account. Should association ship fruit beyond
-------
136
Table 1 (continued)
the storage limitation without Field Department certification,
association ^"1,1 be assessed $1.00 per carton as liquidated damages,
in addition to any other penalties provided for or allowed in these
rules and regulations or in the bylaws of Sunklst Growers, Inc.
The Sales Division and Field Department shall have authority to make
equitable adjustments on fruit picked during the first 30 days of any
varietal season in any area when during that period domestic prorate
allotments have not been sufficient to permit shipment of sizes not
. . wanted in export markets. . . . . -..- . .-. ''. ,- ''
B. Peaches '. .,':'.':.'.-.- ,'' '_..'..:' ', '"'.'.:"'.'.'' '''" - : ' . ''"' ' '-'/.
1. State of California Quality Standards for Fresh Peaches
48731. Fresh peaches shall be mature, but not overripe, and
.free from any of the following defects:
(a) Insect injury which has penetrated or damaged the flesh.
(b) Split pits which are open at the stem end.
Cc) Mold, brown rot, and decay.
Cd) Serious damage, due to cuts or skin breaks,, growth cracks,
bruises, scab, rust, blight, disease, hail, or other causes.
Damage to any one peach is not serious unless it causes a waste
. of 10 percent, by weight, of the individual peach.
43732. Peaches of the freestone variety shall not be con-
sidered mature unless, at the time of picking, the flesh breaks .
free from the pit. In addition, the flesh of peaches of the '
Elberta variety shall be a yellowish color.
48733. Not more than 10 percent, by count, of the peaches in
any one container or bulk lot may be below the requirements which.
are prescribed by this article, but not to exceed one-half of this
.tolerance shall be allowed for any one cause. Individual containers
In any lot may, however, contain not more than 1 1/2 times the
tolerances specified if the percentage of defects of the entire lot
averages within the tolerances. '
2. Federal Food and Drug Administration Defect Action Levels .
For Processing Peaches.3 .
Average of 5% wormy or moldy fruit by count or 42 if a whole larva
or equivalent is found in 2QZ of the cans.
4
3. Processor Marketing Order Quality Standards for Processing Peaches.
1. "Cling Peaches" means peaches, the pits or stones of which
closely adhere to the flesh when the fruit is ripe.
-------
Table 1 (continued) '
. 13 7
2. a. "N'^ber l Cling Paach" means any cling peach suitable for
canning or freezing, not less than two and three-eighths inches
(2-3/8" or 60.32 .millimeters) in diameter, ring measure, and of good
shape, color, texture, and quality, in good condition for canning or
freezing, and of a maturity and flesh color suitable to yield a
canned or frozen product of choice grade, as such grade is generally
known in the canning or freezing industries; provided. that if the
Director, pursuant to the provisions of Subsection 3, Section D,
Article IV, of this Marketing Order, establishes minimum flesh
color requirements as a measure of peach maturity, each Number 1
Cling Peach shall meet those requirements. The m-fnJTnnm diameter
requirements established herein shall in no event be construed
as limiting or restricting the delivery of Number 1 Cling Peaches
of a diameter larger than such m-Trt-fTmnn diameter requirements.
(1) Any cling peach shall not be classed as a Number 1
Cling Peach if it has worms or worm damage, a gum pocket, rot,
brown rot, black flesh, green core, if it is overripe, if it is a
windfall, if it is a visible split-pit, or-if it has more than a
reasonable amount of mildew, scab, red streaks in the flesh, bruises,
cuts, tears or punctures, parasite or insect damage, hail damage,
San Jose scale, sunburn, shothole fungus, or other imperfections.
Cling peaches having invisible split-pits shall be classified as
specified hereafter in this Section.
(2) A cling peach shall be considered to have more than
a reasonable amount of the above defects if:
(a) It has mildew infection of more than two spots
with one of the spots being larger than one-fourth inch (1/4") in . .
diameter, or one spot larger in diameter than a penny, or any spot1
containing a crack or fissure more than skin deep, or any spot, that
is warted.
(b) It has scab resulting from limb rub or other
causes longer or wider than the diameter of a penny or if the scab
is cracked. '
(c) It has red streaks in the flesh to such extent
that the peach is not suitable to yield a canned or frozen product
. of choice grade, as such grade is generally known in the canning
or freezing industries.. ".'.".
(d) It has bruises that result in discoloration .of
the peach so that it will not yield a product of choice grade.
Bruises which accidentally occur at the inspection station shall
be exempt and shall not be considered as defects.
(e) It has cuts, tears or punctures, except those
that accidentally occur at the inspection station, sufficiently
severe that the peach is not suitable to yield a canned or frozen
product of choice grade, as such grade is generally known in the
canning or freezing industries.
-------
Table 1 (continued)
133
(f) It has parasite or insect damage or hail damage
that has penetrated the skin.
. (g) It has San Jose scale that has matured and"
hardened. ' .
(h) It has sunburn, sfaothole fungus, or other
imperfections that do not peel in the normal lye peeling process,
. or that result In the peach not being suitable to yield a canned
or frozen product of choice grade, as such grade Is generally known
in the cam-Ing or freezing industries. . .
' (3) A cling peach shall be considered overripe if it.
shows deterioration as a result of overmaturity as Indicated by
wilting, softness, browning, or tissue breakdown. . . *
(4) A cling peach shall be considered to be a visible
split-pit if it has an opening at the stem end. A cling peach
shall be considered as having an invisible split-pit when the peach,
including the pit, can be pulled apart by the use of hands. Fifty
percent C50%) of the cling peaches having invisible split-pits in
any lot shall not be classed as Number 1 Cling Peaches.
(5) Bruises, cuts, tears or punctures resulting from
mechanical sorting devices, even though such mechanical sorting
devices may be operated in conjunction with an inspection station,
shall not be considered accidental and do not qualify for exception.
The entire shipment of cling peaches will be rejected for
processing if the net weight of off-grade cling peaches due to *
brown rot exceeds five percent of the total net weight of the
shipment or the net weight of off-grade cling peaches due to worms
or worm damage, either or both, exceeds four percent of the total
net weight of the shipment.
4. Processor-Grower Contractual Quality Standards.^' _ '
In addition to the marketing order quality standards, a California
Canners.League Contract for peaches reads;
Seller shall deliver at point of delivery promptly after harvesting
all peaches covered hereby of good shape, quality, and suitable for
canning as herein defined, at. the state of maturity Buyer may re-
quire, free from worms., worm damage, gum pockets, rot, brown rot,
black flesh, green core, overripe peaches, windfalls, split pits,
mildew, scab, sunburn, red streaks in the flesh, bruises, parasite
or insect damage, hail damage, San Jose scale, shothole fungus, or
other imperfections. All peaches shall also be of a color and
texture suitable for canning into Choice grade as such grade is
generally understood in the canning trade.
Buyer may . . . reject any delivery or partial delivery containing
in excess of 10% culls or in excess of 2% Rot and or Brown Rot, or
-------
139
Table 1 (continued)
in excess of 12 wormy or worm damaged peaches. Culls shall consist
of'any peaches not conforming to grade, size and quality specifica-
tions set forth in paragraph 6 hereof. (Paragraph directly above.)
Spinach : . '
1. State of California Quality Standards for Fresh Spinach.
So specific quality standards for spinach. ' .
" * ";."'" '(" - ' * ' . '. -' ,
2. Federal Food and Drug Administration Defect Action Level for Spinach
For Processing.3.' /. ':. .-.- ' - .. .- ' '.-' ;.... ---:. - ':.
Average of 50 aphids, thrips and/or mites per 100 grams.
Two spinach worms (caterpillars) or fragments of 3 mm. in length
having an aggregate length of 12 mm. per 24 pounds of spinach.
Average of 8 leaf miners of any size per 100 grams; or an
average of 4 leaf miners 3 mm. in length per 100 grams.
Average of 10% leaves by count or weight show mildew or other
type of decomposition 1/2 in. in diameter.
3. Processor-Grower Contractual Quality Standards for Spinach.
A Stokely-Van Camp, Inc. contract for spinach reads:
Seller shall deliver, at point of delivery, promptly after har-
vesting, all vegetables suitable for freezing as herein defined
covered by this contract, in the condition Buyer may require,
in order to meet the tolerances permitted by and requirements
of the United States Food and Drug Administration, and In all
respects conforming to any applicable Pure Food and Drug require-
ments of the state or political subdivision thereof in which
this contract is to be performed and the crop is to be processed.
Buyer may reject any vegetables delivered or tendered for delivery
hereunder not complying with this contract and may charge the
same and all costs, freight and expenses incurred in connection
with the receipt and return thereof back to Seller, giving notice
in writing of any such rejection to Seller, or his agent, provided,
however, that the rejection of any delivery or partial delivery or
any grading down or regrading of any delivery or partial delivery
at point of delivery specified herein by Buyer, shall not relieve
the Seller from his obligation to deliver the balance of the vegeta-
bles purchased hereunder, and to this extent this contract is
severable. ..
Irrespective of any provisions of this contract relating to the
point of delivery or passage of title, Buyer shall have the right
-------
140
Table 1 (continued)
to grade the vegetables delivered hereunder at its plant and the
right to rejection, is reserved to the Buyer until after such
grading. . . .
Spinach for freezing shall consist of fresh spinach of good typical
green color, free from decay, dirt, minor damage, worms and insects,
major damage to leaves or stems, weeds, roots and root stubs, pink
stems, excessive stems and stem length, seed stalks, crown, free
moisture, and free from damage caused by frost, hail, insects,
smog, m°chaTi^ -gal or other means*
Any lot of spinach', infested with insects including worms or
aphids or seriously damaged by any of the above listed defects
beyond the level normally accepted in the frozen spinach Industry,
may be rejected by Buyer.
D. Tomatoes . '. ...
1. California State Quality Standards for Fresh Tomatoes.
50601. Tomatoes shall be mature, but not overripe, and
shall be free from any of the following defects:
(a) . Pinworm damage which has penetrated beyond the tissue
making up the base of the core of the tomato, other insect injury
which has penetrated or damaged the flesh, and mold, decay, and
wet or soft rots. . '
(b) Serious damage due to freezing, blossom end rot, mosaic,
alkali spot, sunscald, bruises, catfaces, growth cracks, or
other causes. Damage to any one tomato is not serious unless l
it causes a waste of 10 percent, by weight, of the individual
tomato.
50602. Not more than 10 percent, by weight, of the tomatoes
in any one container or bulk lot may be below the requirements
which are prescribed by this article, but not to exceed one-half
of this tolerance shall be allowed for any one cause.
2. State of California Quality Standards for Processing Tomatoes.
A tomato shall not be regarded as suitable for canning purposes
if, as established by inspection of a representative sample, it
.has any of the following defects: .
(a) Any worm or worm damage is present which has penetrated
the flesh'of the tomato. ' .
(b) In excess of 10 percent of the weight of the tomato
cannot be used for canning purposes due to the presence of mold.
(c) In excess of 20 percent of the weight of the tomato
cannot be used for canning purposes due to the presence of rot.
(d) In excess of 25 percent of the weight of the tomato
cannot be used for canning purposes due to the presence of
sunburn, sunscald, growth cracks, insect bites, pest infec-
tions, hail damage, or other specifications which are not
specified in this article. . .
-------
14.1
Table 1 (continued)
3.
(e) The tomato is sufficiently overripe to make it useless
for eaqn-LTis purposes.
(f) The tomato is shriveled, frozen, or frosted.
(g) The external surface of the tomato is green, with no
visible shade of red color.
Any load, of tomatoes which is offered for delivery to a canner
shall be rejected and turned back to the grower if in excess of
2 percent of the delivery, by weight, does not comply with sub-
division (a) of (the above paragraph) or if in excess of 8 percent
of the delivery, by weight, does not comply with subdivision (b)
of (the above paragraph). . : . . . " ,
Any load of tomatoes which is offered for delivery to a canner
shall be rejected and turned back to the grower if in excess of
15 percent of the delivery, by weight, does not comply with sub-
divisions (a) to (g) , inclusive (of the paragraph.above.)
Any load of tomatoes which is offered for delivery to a
canner shall be rejected and turned back to the grower if more
than 2 percent of the delivery by weight is green as defined
(above).
Any load of tomatoes which is offered for delivery to a canner
shall be rejected and turned back to the grower if the load does
not meet the m-fn-tmim requirements for color based on comminuted ..
raw product sampling. . ' ,
Federal Food and Dru|
Processing Tomatoes.-
Administration Defect Action Levels For
Tomato Catsup
Tomato Juice ,
Tomato Paste or Puree
Tomato Sauce (undiluted) '
Canned Tomatoes, with or
without added tomato juice
Canned Tomatoes packed in'
Tomato Puree
Pizza Sauce (based on 62
total Tomato solids after
pulping)
Tomato Soup and other
Tomato products
Tomatoes (canned)
Microscopic mold count average of 30Z
Microscopic mold count average of 202.
Microscopic mold count average of 402.
Microscopic mold count average of 402.
Microscopic mold count average of
the drained juice is 122.
Microscopic mold count average of
the drained packing media is 252.
Microscopic mold count average of 302.
Microscopic mold count average of 402.
10 Drosophila fly eggs per 500 grains;
or 5 Drosophila fly eggs and 1 larva
per 500 grams; or 2 larvae per 500 grams.
-------
14.2
* . . .
le 1 (continued)
Tomato Juice . 10 Drosophila fly eggs per 100 grams;
' or 5 Drosophila fly eggs and 1 larva
. per 100 grams; or 2 larvae per 100 grams,
A
Tomato Puree ' 20 Drosophila fly eggs per 100 grains;
or 10 Drosophila fly eggs and 1 larva
per 100 grams; or 2 larvae per 100 grams.
Tomato Paste, Pizza _ ' 30 Drosophila fly eggs per 100 grams;
and other Sauces ..'.... . or 15 Drosophila fly eggs and 1 larva
. . per 100 grams; or 2 larvae per 100 grams.
..'."'' ' . .''. '-' "''.''"' 8 :...,.''".-'
4. Processor-Grower Contractual Quality Standards
A. Cauners League of California Tomato Contract reads:
Ho tomato shall be deemed suitable for canning if:
(a) Any worm or worm damage is present which has penetrated
the flesh of the tomato. '
(b) In excess of ten percent of the weight of the tomato
cannot be used for canning purposes due to presence of mold.
Cc) .In excess of twenty percent of the weight of the
tomato cannot be used for canning purposes, due to the presence
of rot. . .
(d) In excess of twenty-five percent of the weight of the tomato
cannot be used for canning purposes due to the presence of sunburn,
sunscale, growing cracks, insect'bites, pest infections, hail damage,
green or yellow color at the stem end, or other imperfections not
specified in (this.paragraph) of the contract.
(e) The tomato is sufficiently overripe to make it useless *
for canning purposes. . .
(f) The tomato is shriveled, frozen or frosted. '
(g) It is not well colored by which is meant that the color
.fails to meet minimum standard . . . as defined in Title III,
Section 1331 of the California Administrative Code. .
(h) It is green with no visible shade of red color on the
external surface.
Any load of tomatoes offered for delivery hereunder may be rejected
at Buyerfs option and turned back to seller if: .
(a) Over one-half (1/2) of one (1) percent of the tomatoes in
the delivery by weight fails to comply with subsection (a) of (the)
paragraph above.
(b) Over one (1) percent of the load by weight fails to
comply with subsection (b) in (the) paragraph above.
(c) Over two (2) percent of the load by weight fails to comply
with subsection (h) of -(the) paragraph above.
(d) Over fifteen (15) percent of the delivery by weight fails
to comply with subsections (a) to (h) of (the) paragraph above.
(e) Over ten (10) percent of the tomatoes in the delivery by
weight are cracked or broken. \
(f) Such load contains mud-smeared tomacoes, loose dirt, or
other foreign matter.
-------
. . 143
Table 1 (continued) .
Other processor contracts for tomatoes contain similar provisions.
(See Appendix A, below).
California state standards for fresh produce are specified in
California State Food and Agriculture Code 42501-50833.
jJSulesand Regulations Governing Fruit Packed For Marketing by
Sunkist Growers, Inc. under its Trademarks Sunkist, Excel, SK, and Red Ball
and Under Association Non-Advertised Brands," Sunkist Growers, Inc.,
Nov. 1, 1967. .. :.\ ..-;.-.''"'..'.:--..;. . '.-.':'."'''*"''.
3 '
"Current Levels for Natural or Unavoidable Defects In Food For Human
Use that Presents No Health Hazard" HFF-342 HEW-PHS-FDA, Washington, D. C.,
1976. . .
4
. Processors Marketing Order for Cling Peaches as Amended 1973-1975,
California Department of Food and Agriculture, Sacramento, California.
California Canners League Contract for Peaches, See Appendix A. .
Stokely-Van Camp, Inc. Contract for Spinach, See Appendix A.
California State Food and Agriculture Code, 40844-40845. ' / '
8
California Canners League Contract for Tomato, See Appendix A.
-------
TABLE 2
144
POUNDS OF PESTICIDES USED IN CALIFORNIA IN 1974
Used On
Percent Used
ecialty Crops*
12417
665456
135145
.674032
1940318
200744
11701
316826
123018
276751
51278
633
271089
353539
3 67409
257740
162136
216631
664253
143500
312522
For all Uses
30750
1007768
601000
728643
2918144
353584
59883
471417
133431
334439
525441
12342
554729
.84388 -
781556
485085
404290
790294
1017115
\
182765
329.015
On Spec
40
66
22
92
66
-'.-- '.'57
20
67
92
83
10
5
49
63
47
53
40
27
... . "65
79
95
Pesticide
Aldrin
Carbaryl
Chlordane
DBCP
D-D .Mixture
Diazinon
Die-ldrin
Dimethoate
Ethion
Guthion-R
Kalthane
Lindane
Ma lathion
Meta-Systox
Methomyl
Methyl-Parathion
Naled
Omite-R
Parathion
Phosdrin-R
Phosphamidon
* Almonds, Apple, Apricot, Artichoke, Avocado, Beets, Broccoli, Brussel
Sprouts, Cabbage, Carrot, Cauliflower, Celery, Cherries, Citrus, Cucumber,
Eggplant, Figs, Grapes, Grapefruit, Lettuce, Melons, Nectarines, Olives,
Peach, Pear, Peppers, Plum, ,Potato, Prune, Pumpkins, Squash, Strawberries,
Tomato, Turnip and Walnut.
1 California Pesticide Use Report, 1974, California Department of Food
and Agriculture, Sacramento, 1975"! .
-------
Table 3
The arthropod pests of California agricultural crops, each of which in 1970 caused losses of a million
or more dollars, and a summary of their insecticide resistance, their status as resurgent or secondary
outbreak pests, and the secondary pest outbreaks associated with their chemical control.
(From Luckjetjil., 1977 BioScience (in press)).!
. .
Types of insecticides to which
species exhibit general or
specific resistance^
'
Pest
species
Citrus red mite
Panonychus citri
(McGregor)
European red mite
Panonychus ulmi
(Koch)
Pacific spider mite
Tetranychus pacificus
McGregor
Two-spotted spider mite
TetranychuB urticae
(A
0)
*rl
4J
W ffl <
14 0)
O PS!
I H
W 0
.
X
.
0
0
X
8 .
a 3
rO 01 O
p. W -H
W W » M H *J
oi o w H 01 t> 4-1
ObOMHdijJ&JH.
NMn? 9*H a) b nj
OOOwiJWWH
X X
XX
X
X 0
Species
resistant in
California
X
X
X
'
X
'
. Associated
resurgence or secondary
pest outbreaks.
X
X
X
X
(Koch)
Citrus thrlps
citri
0 0 0
-------
Table 3 (Cont.)
Consperse stinkbug
EuBchlstua conspersufl
Uhler
Lygus bug
Lygus hesperus
Knight
Pear psylla
Psylla pyricola
Foerster
Cabbage aphid
Brevicoryne braBsicae
(Linnaeus)
Citrus aphid
Aphis citricola
van der Goot
Green peach aphid
Myzus persicae
(Sulzer)
California red scale
Aonidiella aurantii
(Maskell)
San Jose scale
Aspidiotus perniciosus
Corns toe k
XX
T X 0 X
0
0 X X
0
Tomato fruitworm-cotton
bollworm-corn earworm
Heliothis zea
(Boddie)
Beet army worm
Sppdoptera exigua
(Hubner)
Cabbage
Trichop
(liubner)
ni
XX
X- X X
-------
Table 3 (cont.)
Artichoke plum moth
Platyptilla carduidactyla 0
(Riley)
Potato tuberworm ''.'.
Phthorimaea operculella XXX
(Zeller)
Pink bollworm
Pectinophora gp_B_ayp_lella X 0
(Sounders)
Peach twig borer
Anarsla lineatella ">-°
Zeller
Omnivorus leafroller
Platynota Btulfcana
Walslngham
Codling moth
Laspeyresla pomonella
(Llnneaus)
Oriental fruit moth
Graphplitha molesta
(BuscK)
Cotton leaf perforator
Bucculatrlx thurberlella
(Busck.)
Alfalfa weevils
llypera spp. 00
Ord
XXX
0
0
0
aes of Insecticide resistance, target pestf' resurgence and secondary pest outbreaks cited here have
reported In the literature or via personal ummunlcatlon by research specialists,
either
to Insecticide
-------
143
Table 4
Returns for Fresh and Processed ..Oranges,, in .Calif ornia
' *"" and* Florida, "1940-41 to "1973-74 V *r - -'
Tear
1940-41
1945-46
1950-51
1955-56
1960-61
1965-66
1966-67
1967-68
1968-69
9-70
1970-71
1971-72
1972-73
1973-74
Calif
Fresh
$/box1
.98
2.82
2.43
2.96
5.24
1.39
1.48
2.95
1.49
1.41
1.77
1.50
2.14
1.92
. Navel
Processed
$/hox1
.20
-12
;.Mp7;>. J
.*'''"* . .-,
.48
.04
.04
.06
-.11
-.12
-.17
-.18
-.30
-.43
Calif.
Fresh
1.55
3.52
2.14
3.05
3.71
1.61
1.31
2.56
1.10
1.55
1.55
1.28
1.83
1.76
Valencia
Processed
$/box1
.44
1.76
;.;>.4i.'.;' -.-.;
1.04
1.82
.61
.31 .
.51
.06
.21
.14
as
.18
.00
Florida
Fresh
$/box1
.88
.30
1.30
.99
- .73
.91
1.25
.93
1.14
oranges
Processed
-
.80
.48
.98
.83
.56
.71
1.01 *
.77
.76
Source: 1940-1960 Walter Seuther, ed., The Citrus Industry, University of California,
1967,. p. 70. . '
1965-1973 - USDA Crop Reporting Board - Citrus Fruits by States,
Agricultural Prices; Florida Agricultural Statistiscs
1940-1960 a box - 75 Ibs. .
For 1965-1974 a box - 50 Ibs.
-------
149
Table 5' ''-.
Production Levels and Prices of California Oranges from 1949-50 to 1973-74
California Navels -,,^ .
Tear Prod.' Fresi
~~~~ o.-i.cuu.i.rta
i Proc. Price ' Value PT-O^ . '» v ' ,
49-50 14909* 13003* 1906* 2^25
50-51 14200 13147 1053. 2.63
51-52 12121. 10338 ,1783 2.75
52053 16385 14785 1600 0..99
53-54 14080 11945
54-55 14887
55-56 14693
56-57 15000
57-58 8860
'8-59 16610
'9-^^0240
0-61 24600
1-62 7360
2-63 12270
3-64 14950
V-65 15200
'-66 18200
<-67 16900
£Q n- __ '
-os 9100
-69 18525
-70 21144
__ ^ ^ . ,.
~'l .17865
-7 7 ^^ - -
c
-73^
'* J
-74 1
BOO
«% 4*
00
12816
13070
13280
8485
14530
22530
19130
6660
90000
12636
13880
14090
14540
5530
14190
15949
14690
16600
12500
2135
2071
1623
1720
375
2080
7710
5470
700
3270
2314
1320
4110
2360
3570
4335
5195
3175
5700
6200
* «»t!UU 17AO° 4500
In thousands of tons #
rce: ci *.^.._ .-_ ..
.2.49
2.52
3.04
2.96
4.82
3.08
3.78
4.10
6.03
4.39
3.84
3.70
2.90
3.24
. 4.33
3.12
2.74
3.65-
3.n
3.52
**caa rroc. Price Valus
33545^25825" 14555* 11270* 1.89 488ol
37346 30179. 17928 12251 1.79 54020
33333 25394 16895 8499 1.83 . 46471
32606 28970 I0fi7n o-»nn "','
*/u 190/0 9300 .1.68 48670
35059717585 13028 4557 " 3.01 ' " «o«'
37515 23730
44667
44400
42705
51159
114290
100890
44381
53865
57408
56240
52780
54756
39403
57798
7935
65207
69353
65824
22880
20200
13858
22890
17040
15840
12890
16200
16300
16100
- 17500
19600
9950
24900
17700
20650
21100
23400
15000
14330
12100
10978
14460
10980
10880
8630
9380
9800
11130
10950
12380
3730 ' 2.31
8550
7100
2880
8430
6060
4960
4240
6820
6500
4970 :
6550
7220
6110 3840
12900 12000
10400 7300
11250
9400
10820 10280
11600 11800
4.03 88257 18800 12100
in thousands of dollars
6700
2.70
2.27
4.64
2.74
3.81"
3.30
3.65
3.67
4.43
2.56
3.25
2.27
4.44
2.03
2.73
2.92
2.55
2.83
3.65
*t**J^J.
54816
» »^» * w
61776
45854
64301
62719
64922
52272
. 46976
59454
72209
41216
56875
44492
44178
50547
48321
60298
53805
66222
68620
c * wuuusanas ot dollars
crus.Fruits, Statistical Reportin* Ser^,a 'trcm ,«*«..,*
-------
150 '
Table 6 -
Summary of Interviews with Sine Citrus Growers . .
Location of ranch : Central California. ..... ....6
California/Arizona' Desert... 3
2. Acreage: Range = 103500. acres, Average = 905 acres
3. Crops grown: Navel Orange,.... 5 (Most growers raise more than one
Valencia Orange. .7 citrus crop)
Grapefruit ....... 2 . .
Lemon ...*.. ....... 3
- ' .' -. ... Tangerine ..... '...2 .. ..;. ' " . / '
4. What are the major pests: Thrips. ....... ...8 . :
Bed Scale ........ 5
.'.'.- '.-'-. ' ... . Mites ............ 5 . :
. .. " 'Worms........ -....3 '
'.'. Citricola scale.. 2 . '
' Leaf Roller ...... 1 . ..
5. Which pests are considered wholly or partielly cosmetic?
Thrips ...... ....8
Mi tea ........... 4 . .''
Red scale ....... 3 (partially in all cases)
Citricola scale. 1 -
Soft brown scalel
Worms .......... .1 .'
6, What proportion of 'pest control cost is necessary to meet co'smetic
standards? . . . .
0-50% ..... 0
50-75%..... 4 Average » 71% :
75-100%.. .5 .
7. Do D.C. pest control recommendations take integrated control into
account? ....
Yes.. 2 . . . - - ' - ' ',. ' ':.'.''". ' . ,
. . .' No. ..6 ;.. . ; -. ... .,' ... ;" ... -\ :' ' ' .- ' . .
8. Does your buyer adjust quality standards according to prevailing
market conditions? ...
Yes . . 8
No ... 0
9. How is the crop marketed? .
Cooperative ..... . ...... .4
Packinghouse Contract.. 3
Independent ............ 1
-------
Table 7 '
CITRUS 'PEST HIERARCHY IN CENTRAL CALIFORNIA-'
r Conventional Control , ' ' .
^^W . -
-------
CONVENTIONAL AND INTEGRATED PEST MANAGEMENT FOR CITRUS PESTS IN CENTRAL CALIFORNIA^
Pest Species Timing of Treatment Pesticides Natural Enemies
Conventional Integrated Conventional Integrated Conventional Integrated
Citrus thrlps May-post petal Post petal guthlon*
Citrus red
ml te
Red scale
Brown soft
scale
Cl trlcola
scale
Katydid
Fruit tree
leaf roller
and cutworms
fall
Spring
Spring
Yellow scale Spring
Spring
Summer
Fall
Summer
Spring
Spring
Leafhoppers Fall
Citrus aphlds Spring
fal I
Winter
Summer
Spring
Summer
Summer
Fal I
Winter
Spring
Spring
Fall
Spring
Dlmethoate
Delnav
Phosphamldon
Ryanla*
parathlon(OC)
Ineffective
Kelthane NR.oll
Oml te
Chlorobenzllate
'effective some
years
parathlon
malathlon
parathlon 4
malathlon
NR oM
same as red
scale
carbaryl -f NR oil
NR ol I
parathlon(TC)
ndne
ma lath Ion none
(most disruptive
chemical for citrus)
parathlon
NR ol I
parathIon
guthlon
parathlon
Dfbrom
carbary I » -w-«
NR ol I
parathlon (OC)
NR 445 olI
parathlon (OC) '--
Bad I tus thurlnglensls
parathlon (OC)
carbaryl
hydrated lime hydrated lime --
rotenone rotenone '--....
rotonone 4 olI
partially effective
effective
effectlve
Ineffective
Ineffective
Ineffective
Ineffective
effective
-------
153
; ; TABLE .9- .-
.Peat Control Costs in California Citrus
Conventional vs. Integrated Pest Management
Cut per Acre (Tniar* Canal?)
ALTKHNATm: USE OF CHEMICALS
. Traditional Prst and Disease Control
Major Pert Problem
CatptrAo*
< Hint* ihri(ni
Red and yellow wale.
Ctrus ml mite
.-..." Petal fall organophosptiale . :
' . Summer organophosphate or
botanical* for thrips
'. 29 ;';
9
Glrirala sralr
Gilworm»
Orancedos
Brawn *nft yralc
!.rafliap|M!T*
Brown rnl ami Scploria npnl
Fall miliridc for miles
Kail whiJcwnsh fungicide
26
19
TOTAL
}101
Intre^ratesi Pest and DL*ra5e Control
M«K>* Pt*t Problem
Solulioo
CcxtpcrAen*
Ctriroln wnlr>"
Leafrollrr
Cutworm*
Yellow and red scales
Brown soft «rali;
Glrtr» mi miles
Lra/lio|iprr»
Turin* (latter season)
Brawn rot and .Vptoria spot
HipJirr iliresliold of economic damage
Uln/de preliloom orptnophosphate . $ 18
On thrips and mitesa number
. of prcdaeeotts insects plus diseases
ParasiteCompcrella bifascaia none
ParasiteAphjctu latenlus none
Optional, drpnndini; on monitored
population
Petal to postbloom botanicals
(two applications at J9.00) $ 9
Fall whitewash funejcide 9 18
TOTAL
4S
PrM and disease cost as percentage of total input costs VL2%
Difference between traditional aad integrated programs $S6 per acre
Savings as * reduction of net loss - . ' ' 38J7»
^ ^^*^^^ *
* TirtJ aTrmcn* Itv 5-rrur pvrierf. J9NS 107O, on 1.000 »em at Omnce Caro ia TuUro Conntjr:
niorlu ptanleii nineo 19&0 prorinccii 700 ta 1.000 fitld boxn rwr acre
Hlnriw 40 r«r» anH nwro old Jirorfnirrf 300 la SOO Held bold per Mm
fofit,^ at .'.nv with yr»r-l«ne |Mrk (hichcrr triUi unuanoi imrk)
NOTK: N«r«i anneex 500 la TOO baza viUt tax than 100% p»ekont (ye«r tone)
From R. Smith, "What is Being Done by the University,"
Agricultural Chemicals Harmony or Discord, p. 141.
-------
Figure 1
NAVEL ORANGES.
f-
*£
C
3>
U
e
u.
B,
Q
0
0
0
90 .
80 ..
70 .
60.
50 .
* -
. . -
^ *
~~
'^^
* * .
xx'Xs>^
'^'NVX/-
- .'.- . . -
. ' . . ..'..-.- '.'-.-.
Note: solid lines are regression lines
for the period:
1949-58,1959-63,1964-74.
.
50 55 60 65 70 75
YEAR.
O
o
o
U
o
la
c
o
150
100
50
50 55 -60 65 70 75
YEAR.
-------
Figure 2
I-'
UJ
-------
156
Figures PER-CA PITA CONSUMPTION OF FRESH ORANGES
cc
u
O
I
ec
Ui
a.
CO
o
o
a.
30
20
10
50 55 6O 65 7O 75 YEAR.
SEASON AVERAGE ON-TREE RETURNS PER FIELD BOX FOR CALIFORNIA
ORANGES.
$4
$3
$2
$1
$3
$2
$1
Navels.
Valencias.
Note: solid lines are
regression lines for
the period: 1950-55,
1959-63, 1964-71.
50 55 60 65 70 75
YEAR.
-------
157
Figure 4
CALIFORNIA NAVEL ORANGES.
CO
Q
O
cc
CL
O
a
ui
O
O
30
20
o
c
o
or0
10
1967
1972
1961
Fraeze Years
10 20
TOTAL CROP.
30
Slope = 1-1029
Hypothesis that slope = o
is rejected at the s%
confidence leve!.
Freeze years eliminated
from data.
-------
Figure 5
CALIFORNIA VALENCIA ORANGES
50
en
5
3
O
O
fiC
O.
40
Q
UJ
O
O
a.
O
a:
o
30
20
=Freeze years
10 20
TOTAL CROP.
30
S10pe=0-5602
Hypothesis that slope = o
is rejected at the 5%
confidence level.
Freeze years eliminated
from data.
-------
Figure 6
CALIFORNIA ORANGES 1973-74.
(0
H .
0
D ' ' ' '
a
o
DC
a.
>l 50 .
m
o
"- 40 .
a
IU
5 30 .
0
o
d 20 .
<
a
0 10
(DC
U
o
ov
' * X
rv
* -
*** ***
* x
-'*' t * " *
''******' K ' * ' *
^ w '
XX ** M
*
' « X x
X X *
K M XX X
X X X X x% X X
'':. ' x x . ' ;
. VALENCIA
x x NAVEL
*Mfr*IBf^l1l!USffltfflllWffftMkiitV^
10
WEEK
20
30
40
-------
Figure 7
^
^,
537
100,000
90,000
80,000
70,000
60,000
50,000
**
,000
30,000
20,000
10,000
OPTIMUM
PRODUCTION
WEEKS ENDING 7-7 7-14 7-21 7-28 8-4 8-1! 8-18 8-25 9-19-89-21
1973 WEEKLY VOLUME OF DELIVERIES
NEEDED VOLUME.
EXCESS VOLUME ABOVE PLANT CAPACITY.
------- |