NEIC PESTICIDE SPRAY EVALUATION MICHIGAN DEPARTMENT OF AGRICULTURE AND U.S. DEPARTMENT OF AGRICULTURE GYPSY MOTH SPRAY PROGRAM September 1980 EJBD ARCHIVE EPA 331- R- 80- 002 oEPA national enforcement investigations center denver federal center bldg 53, box 25227 denver. ro 80225 ------- E3BO fi- fe- UNITED STATES ENVIRONMENTAL PROTECTION AGENCY OFFICE OF ENFORCEMENT PESTICIDE SPRAY EVALUATION MICHIGAN DEPARTMENT OF AGRICULTURE AND U.S. DEPARTMENT OF AGRICULTURE GYPSY MOTH SPRAY PROGRAM September 1980 Robert Campbell Repository Material 'ermanent Collection NATIONAL ENFORCEMENT INVESTIGATIONS CENTER Denver, Colorado and Region V Chicago, Illinois US EPA Headquarters and Chemical Libraries EPA West Bldg Room 3340 Mallcode3404T 1301 Constitution Ave NW Washington DC 20004 202-566-0556 ------- CONTENTS I INTRODUCTION. II OBSERVATIONS/EVALUATION OF SEVIN-4-OIL PROGRAM 3 OBSERVATIONS 3 EVALUATION •• • 5 III OBSERVATIONS/EVALUATION OF DIMILIN® 6 OBSERVATIONS 6 EVALUATION 8 RECOMMENDATIONS 9 APPENDICES A OBJECTIONS TO SPRAYING (NEWSPAPER ARTICLES) B PHONED RECOMMENDATIONS TO EPA REGION V ------- I. INTRODUCTION The Michigan Department of Agriculture (MDA) and the United States Department of Agriculture, Animal and Plant Health Inspection Service, Plant Protection and Quarantine Program (USDA, APHIS, PPQ) Cooperated in a gypsy moth [ Porthetria dispar (Linn.)] eradication program during the spring of 1980. The objective of the program was to provide maximum pro- tection to the forestry, recreation, and aesthetic resources in the State of Michigan. Approximately 24,744 acres within a boundary of 48,160 acres were scheduled to receive two applications of gypsy moth control pesticides within 10 days. The 1980 integrated gypsy moth management program necessitated the use of two proven chemical pesticides, Sevin-4-Oil and Dimilin . In addition, experiments were to be conducted using two formulations of Disparlure (a synthesized sex lure trap bait to attract male gypsy moths), mass trapping, and sterile male release as possbile effective interventions. The areas selected for Sevin-4-Oil treatment were in southern Michigan and consisted of Calhoun, Oakland, and Van Buren counties. These three counties contained a gross area of 3,200 acres with a proposed treatment area of 2,220 acres. Immediately prior to spraying activities, adverse public response to spraying in Oakland country reduced the total pesticide application area to a total of 1,600 acres [Appendix A]. Dimilin® applications were principally confined to central northern Michigan in the counties of Clare, Isabella, Mecosta, Montcalm, and Osce- ola. The total area scheduled to receive treatment consisted of 22,544 acres. For a period, this program was in jeopardy as a result of objec- tions to the spraying expressed by a group of organic farmers located in the proposed treatment area [Appendix A]. ------- As in previous years, the USDA/MDA conducted an intensive public re- lations program to advise individuals within the application areas to exer- cise caution during the spraying period. This information was provided through public meetings, the news media, the Cooperative Extension Service, township supervisors, and local government units. Because of environmental and possible legal considerations associated with the USDA and MDA program, the EPA, Region V Pesticides Enforcement Division requested the NEIC to provide technical review and evaluation of the USDA/MDA gypsy moth eradication program procedures, and their compli- ance with the Federal Insecticide, Fungicide, and Rotenticide Act (FIFRA). Observations from May 14 to May 24, 1980 included: (1) evaluation of pesticide storage, (2) mixing and loading operations, (3) application meth- ods and techniques, (4) cleanup and disposal, (5) personnel safety. No attempt was made to evaluate the USDA/MDA pesticide monitoring program. ------- II. OBSERVATIONS/EVALUATION OF SEVIN-4-OIL PROGRAM Spraying activities for Calhoun County were conducted from the Kellog Regional Airport in the town of Battle Creek. The area treated in the county consisted of approximately 1,200 acres in Section 25, the south Jj and the NE h of Section 24, and the north h of Section 36. The area was essentially urban. OBSERVATIONS Pre-Application f5\ Prior to application activities both Sevin-4-Oil* and Dimilin ** were stored in a well-marked, secure USDA shed on the outskirts of Battle Creek. Helicopeter spray system calibration was conducted by USDA personnel and adjusted to produce a 75 ft swath of spray at an equivalent rate of 1 lb/ acre to conform with contract specifications. Mixing the final formulation was accomplished at a remote area of the Kellog Regional Airport by pumping both the Sevin-4-Oil and diesel fuel into a 1,000-gal-capacity truck-mounted holding tank. Agitation produced within the tank resulted in a homogenous mixture. The ratio of ingredients was 32 oz. of Sevin-4-Oil to 8 oz. of fuel. Loading the final pesticide mix into the helicopter holding tanks was done by a hose with appropriately equipped shut-off valves; this procedure * Sevin-4=0il EPA Reg. No. 264-323. ** Dimilin EPA Reg. No. 148-1258. ------- 4 is called "open loading". Personnel conducting the mixing and loading op- eration wore proper safety clothing and made every effort to prevent spills. Application When weather permitted, spray activities commenced during the earliest morning hours. On May 19, 1980 at 9:30 a.m., Sevin-4-Oil was sprayed in Calhoun County. The spray helicopter applied the pesticide in an essen- tially east-west, west-east course at an approximate altitude of 60 to 75 ft. Correct alignment of the spray paths was controlled by ground crews manning aerial kytoons (balloons). At the completion of each pass, the kytoons were moved about 75 ft along the perimeter of the unsprayed area to create a target for the next spray path. Throughout the entire spraying operation a spotter plane observed the procedure from a higher altitude and supervised the overall operation. All personnel maintained radio communication during the entire application. Spraying operations terminated at about 11:30 a.m. because increased wind velocity created potential uncontrolled spray drift. About 4 of the assigned area had been treated when application ceased. On the following day, May 20, weather conditions were suitable to complete the spraying. Post-Application Procedures for the cleanup of used containers closely followed the EPA guidelines. All pesticide containers (55-gal drums) were triple-rinsed and stored in a security warehouse for later collection by a local barrel re- conditioning company. ------- EVALUATION The pesticide spraying program of Sevin-4-Oil in Calhoun County re- flected extensive planning by both USDA and the MDA. All operations ad- hered to the prescribed planned procedures except for several minor infrac- tions involving protective clothing. Close scrutiny and training of less experienced personnel could remedy this. Improved safety practices are necessary for the ground crews respon- sible for positioning the kytoons. Unlike the crews marking the boundaries of a proposed section, the crews controlling the spray paths are subjected to repeated contact with pesticide particles each time the aircraft fin- ishes or begins a run. It is stated in the program regulations that "all members of kytoon crews will wear raincoats and a head covering of their choice during spraying operations". Although crew members during this operation wore adequate headgear and gloves, they were provided with inade- quate raingear (ponchos) which did not sufficiently cover them. Satisfac- tory protection could be provided with throw-away, long-sleeved coveralls or raingear which covers the wrists and reaches below the knees. Full-face protection using a face shield would, for example, also contribute to em- ployee safety. If these crews are involved in more concentrated dosages of pesticide spary, respirators and goggles will also be necessary. ------- III. OBSERVATIONS/EVALUATION OF DIMILIN® PROGRAM The base of operations for the central Michigan Dimilin program was the Airport at Mt. Pleasant. The area treated comprised 22,544 acres dis- persed in the counties of Clare, Isabella, Mecosta, Montcalm, and Osceola. The target areas are essentially rural. OBSERVATIONS Pre-Application jg» The 25-Ib containers of Dimilin were transported from Battle Creek and stored at the Mt. Pleasant Airport in a security building distinctly posted with warning signs. Five fixed-wing aircraft were checked and calibrated by USDA person- nel, and their flat fan spraying systems were adjusted to provide a flow rate of h gal/acre at 40 psi over a swath with 75 ft. The pesticide spray solution was prepared at a secluded area of the airport. Before mixing, the dilution water obtained from the Mt. Pleasant municipal supply was acidified to a pH of 6.5 to 7.0 with phosphoric acid. To assure a pesticide application rate of 0.015 Ib/acre, the mixture ratio ® of ingredients to dilution water was 25 Ib of Dimilin to 200 gal of water. These mixtures were prepared on a batch basis usually 600 to 800 gal at a time. The aircraft were loaded using a closed metered pumping system which reduced the liklihood of spillage. ------- Application The Dimilin® treatment program began during the early morning hours May 22, 1980. Weather conditions were favorable. Kytoon crews were in position and five fixed-wing aircraft were treating three sections under the supervision of three MDA observer planes. Aerial spraying was accomplished by two planes flying in tandem at an altitude of about 50 to 60 ft. Spray paths were marked by red aerial ky- toons (balloons) manned by ground personnel. At the completion of each pass, the kytoons were moved 150 ft along the road bordering the treatment area. Organic farmers and others objecting to pesticide applications did not want their land sprayed. Therefore, to prevent any mishaps, the perimeters of these sensitive areas were clearly marked with white kytoons. The spray plane pilots were directed not to fly over these areas. Spraying activities in the vicinity of a sensitive area (organic farm) were observed by EPA personnel and every precaution to avoid overspary of this area was fol- lowed. Upon completion of spraying operations on May 24, 1980 about h of the I3l 8,800 ha (22,000 acres) had received their first treatment of Dimilin . Post-Application Procedures for the cleanup of used containers closely followed the EPA guidelines: all containers were triple-rinsed, punctured, and stored in a security warehouse area. Disposal of used containers does not pose an immediate problem in the State of Michigan. Although the state does not have a dump site especially designed for the disposal of highly toxic or environmentally damaging com- pounds or containers, referred to as a Class I dump site, the Michigan De- partment of Natural Resources issues special permits to allow controlled ------- dumping at selected sites. This is the procedure being followed during the 1980 gypsy moth eradication program. EVALUATION Observations during the first few days of the Dimilin program indi- cated that it was well planned with every effort made to make it success- ful. However, a few unsafe practices were noted in the mixing-loading zone. The contractor personnel conducting the mixing did not have proper protective clothing, wearing short-sleeve shirts during mixing. Moreover, in performing the mixing, the 25-lb pesticide containers were emptied through the top portal of the mixing tank. A cover was not immediately placed over the opening to prevent the escape of Dimilin dust into the surrounding atmosphere. To prevent contact with this dust by the crews supervising loading operations, employees should be provided with suitable safety equipment such as respirators and goggles. Personnel not so equip- ped need to remain a safe distance from the mixing area. ------- RECOMMENDATIONS 1. Kytoon crews marking the spray paths during Sevin-4-Oil application should be equipped with long-sleeved throw-away coveralls or knee- length raincoats, face shields, or respirators and goggles. 2. Proper safety clothing should be worn constantly during pesticide mixing operations. ® 3. A method should be devised to prevent the escape of Dimilin dust from the mixing tank during the mixing operation. 4. Ground crews supervising loading operations should be equipped with suitable safety equipment or retreat a safe distance during the pesti- cide mixing operation. These recommendations were conveyed to Mr. Carl Erickson, Pesticide In- spector, Region V in a telephone conversation on May 28, 1980 [Appendix B]. ------- APPENDIX A OBJECTIONS TO SPRAYING (Newspaper Articles) ------- A-l Aerial spraying to kill insects sparks flaps Sunday, May 18,1980 By JAMES L KERWIN NMI SUII WHIM Fears that aerial sprays or Insecticides may pose a risk to pregnant women — while elimi- nating populations of birds and ecologically valuable insects — have triggered furors In several targeted Michigan communi- ties In Bloomfleld Township, a planned aerial spraying of 600 acres of wooded residential area by the State Department of Agri- • culture — to eradicate o concentration of dreaded gypsy moth caterpillars — was can- celed by the township board of supervisors last week following o public protest. Object of the current protests is the chemical Sevin. manufactured by Union Carbide The department soys tlie chemical has been used for 27 years throughout the world — without any reported ill effects — to treat vegetables, fruits, poultry and livestock for pests It is sold in retail stores to home gardeners SINCE THE 1960's the state has been trying to check the spread of the gypsy moih with the use of traps, various hormones and sprays The moth caterpillar began stripping for- ests in New England and Pennsylva- nia in the 19SO's and hitched rides Shaded area on map indicates the 600 acres to be sprayed. west on cars and recreational vehicles But wherever the state has sought to halt the spread It has run into difficulty. The Dloomfeld critics voice the concerns of most protesters To some, the issue bolls down to trees ,vs the health risk to humans and wildlife Critics of aerial spraying argue that It causes birth defects and may be carcinogenic (a cancer-causing agent) "Nature is too complex to try fix- ing Spraying is only buying a little time There are safer alternatives," insists James P Wells, a botanist at Continued on Pag* 10B Continued from Page 1B j ; Cranbrook Institute who helped lead • the protect in Bloomfleld Township ! WELLS SAYS, "too often, in getting rid of one pest, the habitat is chang^ ed so much that another moves in " He says the public doesn't trust government researchers "after PBB and Three Mile Island " But Homer Case, a Bloomfleld Township supervisor caught in the center of the controversy, replies bluntly "Hogwash " " "Scvm hasn't been proven danger- ous The stuff is on the vegetables you buy in the market and nobody thinks anything about that." said Case, whose family has been using chemicals for three generatnons in raising fruits "1 handled by hand arsenated lead and DDT and I'm still healthy, insists the M-year-old supervisor, who bos held his township post for 24 years. - "The whole hullaloo comes from the outcry over the use of Agent Orange in Vietnam." said Case Agent Orange is a defoliant that has been suspected of causing cancer and genetic diseseas THE FUROR OVER chemical spray- ing isn't confined to Bloomfleld Township State officials have been engaged in court battles outstate over the use of Dimlm, a more potent chemical, in wooded areas infested with the g)psy moth But under coui t guidelines to pro- tect organic farming, the state is pro- ceeding with aerial applications of Dimlm this week in the Kalamazoo- Battle Creek area as well as in five counties in central Michigan >•,' Critics of aerial spraying say tbe federal government's ban last March against use of a powerful presticide I — 2.4.5-T — on forests of Oregon and Washington should be extended to other chemicals Some women in Washington and Oregon blamed 2,4.5-T for miscarriages Even the experts within the Envi. ronmental Protection Agency (EPA) are divided as to the advisability of aerial spraying ' Mama Marshall, director of EPA's pesticide research program believes Sevin "does not pose an imminent hazaid " But she concedes "unneces- sary exposure" should be avoided and no one can conclude "Ilie risk is zero" IN HIS RESEARCH, WcllS Sa>S othei r.PA researchers have found Carbaiyl (from which Sevin is made) causes birth detects in rats and shouldn't be used near water — where it can become a part of the food chain Officials of tbe agriculture depart- ment, which conducts the aenal spray programs for gypsy moth in Michigan, claim precautionary steps were being taken in Bloomfleld Township Lakes and ponds were off limits to aerial spraying, as were school bus stops The area around George Way Elemtnary School was to be doused at 6 30 a m, long before classes start- ed The wooded area to be sprayed is bounded by Telegraph. Long Lake Lahser and Timberlake But the spraying was called off after, Case says, "outsiders stam- peded" a hearing called to discuss ihe program "They" were people mostly outside the township, along with environmentalists and Cran brook people " Mrs John Selick, who heads a homeowner group within the area to be sprayed, claims that 103 of 110 members in her organization backed the spraying "We carefully researched and dis- cussed the sprajmg before we de- cided we wanted it," she said MUCH OF THE 600 acres to be sprayed contains virgin growth ol oak on which the gypsy moth thrives It also likes the leaves of maple and crab apple trees that a- bound in the area Case. Mrs Selick and other residents are incensed over a leaflet sent home with elementary students from Way School, in the spray areas which was headed "Important Warn- ing" The unsigned leaflet warned that "one of the recent theories concern- ing Reye's Syndrome (which has kill ed four youngstes in Michigan so far this year) is that the disease mat have a direct relation to insecticide spraying " Way school officials say the leafle. was distributed by "a small group" o a Parent-Teachers Organization, ; decision which is now being review ed because of protests There is m scientific evidence that the chemica contributes to the ailment CASE WANTS THE state and federa officials "to resolve conllictm. claims" so the spraj mg program ca: be carried out next May Aeria spraying is effective only when th. larva emerges from its egg masse and begins feeding on Icates Iron mid to-late May ------- (9 X o z I 3 . MT PLEASANT-Chemical warfare against the gypsy moth caterpillar will commence tomorrow. Thursday, if central Michigan weather conditions are favorable for aerial I spraying A ruling issued last Wednesday in the Ingham County Circuit Court gave the Michigan Department of Agriculture (MDA) the go-ahead to conduct the spraying as planned An airplane loaded with the pesticide Dimilm W 25 is slated for take-off from the Ml Pleasant City Airport at daybreak to begin MDA's 19SO gypsy moth management plan The plan calls for Dimilm to be used in the treatment of wooded areas in portions of Clare. Isabella. Mccosta, Monlcalm . and Osccola counties Other chemical, trapping or biological measures are planned for Bcrnen, Calhoun. Van Burcn and Wayne counties A planned spraying with the pesticide Sevin over 600 acres of wooded residential property in Oakland County was cancelled last week by the Bloomfield Township board Concerns among Bloomfield Township' residents that Sevin may pose a human health 1 hazard match thnsc of area critics who oppose the use of the more potent Dimilm. MDA has enlisted the aid of the U. S. Department of Agriculture (USDA) in con- ducting and funding its program aimed at eradicating the gypsy moth in Michigan. Agriculture officials claim the pesticide.' they use are safe, and that Dimilm, in par ticular. is the most effective pesticide available for eradicating the foliage-consuming pest. If the gypsy moth is not controlled, they say defoliating whole forests by the insect could have a severe aesthetic and economic impact on the state ' < Last Wednesday's hearing before Judge Ray, Hotchkiss was the result of a preliminary injunction the judge issued against th, spraying in 1978. The 1978 court action was brought about by ' a Clare County based citizens group. Citizens Against Chemical Contamination (CACC), which formed that year to oppose the spraying. Ann Hunt, a Surrey Township organic farmer and co-chairwoman 'of CACC, said Wednesday's ruling imposed the same restrictions on the spray program that were applied in 1979. The 1978 injunction requires prior court approval before MDA can conduct spray programs Last year, the injunction was modified to allow limited spraying in wooded areas. Exempted from treatment with Dimilin, both last year and this year, are the properties of organic farmers who request the exemption and incorporated villages Persons who identify themselves as,organic farmers in writing to MDA are allowed a 100- foot buffer zone between their properties and a designated spray area The only incorporated village affected by the ruling, according to Hunt, is Winn The Winn •area is where MDA officials believe the current gypsy moth infestation in central Michigan originated Incorporated villages, as designated in the ruling, are allowed a 250-foot buffer zone, and do not need to apply for the exemption, ac- cording to Hunt The Dimilin spraying is scheduled for two applications in the designated areas Weather permitting, the first application tomorrow will be followed by another in seven to ten days Dick Moore, district director for USDA's Animal and Plant Health Inspection Service (APHIS), said the treatment program should be completed by June 12 or 14. Hunt suggested that persons wishing to be exempted from the spraying might consider , putting in an organic garden to qualify. Jeffrey Eibling, USDA plant protection and quarantine inspector based in Mt Pleasant,' said, however, that the exemption may apply ro only to bonafidc organic farmers This may be a point of contention, he said "People who have a 10 by 20 plot .. I don't know if they'd be exempted or not." Hunt noted that there still may be time in get an exemption if the weather is unfavorable for spraying tomorrow, and before the second application. The request for exemption must be made in writing to Dean Lovitt (chief of MDA's plant industry division), Michigan Department of Agriculture, Lewis Cass Building, P 0. Box ,30017. Lansing. MI 48909 Areas in the Buyer's Guide circulation area to be treated with Dimilin are listed below. Spraying will be conducted primarily in the wooded portions of the areas listed ISABELLA COLSTY Broomfield Township Sections 2 (EVi). 5 (S'/i). 8 through 17. 20 through 27, and 34 through 36 Deer field Township Sections 16 through 21. and 28 through 33. Fremont Township Sections 4 through 9, 16 through 17.20 through 21. and 28 through 33 Gilmore Township- Sections 5(W'/i)and 6 Holland Township: Sections 1 through 3, 4 (EVi). 9(E'/, andSVil. 10.12(N'/i),21 (S'/i), 25 (S'/j).26.28(N'/j).33and36 Sherman Township-Sections 25. and 36(NVi and SWA) Spraying in Isabella County will involve a total designated spray area of 40,640 acres of which 20,044 wooded acres will actually be sprayed CLARE COUNTS Spraying in Section 31 of Surrey Township involves a designated spray area of 640 acres of which 560 wooded acres will actually be sprayed Dimilm spraying will also be conducted in about 320 acres of Mccosta County's Sheridan Township, 160 acres in Montcalm County's Day Township and 320 acres in Ferns Township, and 400 acres in Osceola County. ------- APPENDIX B PHONED RECOMMENDATIONS TO EPA REGION V ------- RECORD OF COMMUNICATION O: Carl Erickson Pesticide Inspector, R-V Q PHONE Q OTHER _____ £ CALL QDISCUSSION Q FIELD TFIIP [^CONFERENCE' (SPECIFY) (Record of item checked above) FROM: Bob Campbell ^^ 5/?K/Bn TIME 10:45am SUBJECT ~ Michigan Gypsy Moth Control Program Called to inform Mr. Erickson of my intended suggestions or recommendations concerning safety precautions relating to the Michigan pesticide application program. This information was related with the intention of implementing these suggestions before the program was completed rather than waiting for submission of a written report to Region V. The following suggestions were conveyed to Mr. Erickson: 1. Additional protective clothing for the contracted applicator conducting the mixing operation in the form of rainwear and boots. Other necessary protection was worn. 2. Kytoon crews during Sevin application by helicopter should, in addition to head gear and ponchos, wear face shield or goggles. 3. During mixing operations a method should be devised to prevent escape of pesticide dust through the loading port. 4. Personnel in loading areas retreat to a safe distance during mixing operations to prevent contact with escaping pesticide dust. >)CLUSIONS. ACTION TAKEN OR REQUIRED Mr. Erickson will relate this information to the appropriate parties super- vising the spraying program. ^TIO.N COPIES /Harp, Schneider e°* Form 1300.4 (7-72) REPLACES EPA MQ roau sjoo-s WHICH MAY BE USED UNTIL SUPPLY 15 EXHAUSTED. ------- |