# EPA Issues Guidance On Marijuana Pesticides Amid Industry Uncertainty



## burnin1 (Jun 9, 2015)

From ibtimes.cim

Marijuana Legalization 2015: EPA Issues Guidance On Marijuana Pesticides Amid Industry Uncertainty

[email protected] on June 09 2015 3:18 PM EDT 







When he was managing a 3,500-plant medical marijuana grow facility in Denver, Adam Koh would have his staff thoroughly inspect his crops several times a week for signs of infestation. Tiny bite marks on the cannabis leaves could mean two-spotted spider mites were piercing the plants skin and sucking up nutrients. Small piles of what looked like powdered sugar could be the beginning of a powdery mildew incursion.
Koh opted for natural crop management options, so if his staff spotted a problem, hed isolate the infected plants or use organic pest control options. But a few times, when the infestation was out of hand, hed destroy an entire grow rooms plants and start again. That option wasnt cheap: His biggest flower room held 164 plants, and if he ever lost a whole crop in there, he could have been out 75 pounds of cannabis, which in the going rate for retail marijuana, could equal a quarter of a million dollars down the drain.
Koh wasnt surprised that some of his colleagues would do anything the could to save an infested crop, even use pesticides that werent approved for marijuana use. You hear about things where really intense chemical products were being used right before harvest to save a crop, he says. I unfortunately dont think its uncommon. Its one of the reasons he got out of the grow-management business and now works for Comprehensive Cannabis Consulting, helping clients nationwide set up sustainable, all-natural marijuana grows. I didnt want to be associated with what I was hearing, says Koh.
The legal marijuana industry is plagued by upheaval over pesticide use. In a business dependent on the health and vigor of a single plant, the lack of guidance over what kinds of cannabis pest-control measures are appropriate has left growers struggling to safeguard crops as they try to appease regulators and the public.
In recent months, tens of thousands of marijuana plants have been quarantined in Colorado over concerns they were doused in dangerous chemicals. Protesters in the state are picketing marijuana shops, claiming consumer health is at risk. And business owners are claiming that if the status quo continues, crops worth hundreds of thousands of dollars could sicken and die. The problem is the regulatory agency that determines pesticide registrations and what sites are appropriate is the EPA, a federal agency, and they have refused to accept cannabis as a [pesticide] site at all, says Colorado State University entomology professor Whitney Cranshaw. Under that situation, technically any kind of pesticide cant be used on cannabis. So we have had a wild west when it comes to pesticides.
But now, for the first time, some relief for growers is on the horizon. The Environmental Protection Agency is offering a process through which pesticides could be approved for cannabis in states where medical or recreational marijuana is legal. By applying to register certain cannabis-related products as a Special Local Need as defined under section 24(c) of the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), the marijuana industry could have a comparatively swift and cheap way to obtain appropriate pest control options without running afoul of federal law. I think it is very positive sign, says Mitch Yergert, director of the Colorado Department of Agriculture (CDA)s Division of Plant Industry, who received the letter from the EPA detailing the process on May 19. It allows us to move forward in a very normal manner on pesticides for marijuana, just like any other crop. I think it is a huge step forward for the EPA, the industry and us.
But until marijuana pesticides are thoroughly vetted and fully registered by the EPA as safe for use wherever cannabis is grown, the 24(c) process is a stopgap measure at best. It remains to be seen whether pesticide makers will be willing to wade into the marijuana industry and attempt to register any of their products for marijuana use under 24(c)  and, if they do, whether the EPA will ultimately sign off on those attempts.
*Lack of direction*
Since pesticides are considered a potential public health risk, manufacturers work with the EPA to gain approval for each crop use for all but the most innocuous pesticides. But so far, the EPA hasnt created a crop category for cannabis, and since marijuana remains illegal under federal law, its unclear whether the agency is able to do so. EPA spokesperson Catherine Milbourn declined to comment for this story, noting, The [24(c)] letter is all we can say right now.
Even if the EPA allowed pesticides to be registered for use on marijuana plants, its unlikely major pesticide companies would stomach the cost of collecting all the scientific data necessary to register their products for cannabis, considering the industry is still in legal limbo. A registration for a pesticide for a company can cost millions and millions of dollars, says Yergert. I dont think any of those companies is willing to go down that road until there is a clear federal framework as to what they should be doing.
For years, regulators in states that had legalized medical marijuana largely avoided the pesticide issue as cannabis growers used any means necessary to care for their plants. But as recreational marijuana has rolled out in several states, state agriculture officials, who usually work closely with the EPA on pesticide issues, have begun to tackle the issue themselves. Washington State, Colorado and California have provided guidance on what sorts of pesticides can be used on cannabis. But according to Erik Johansen, Washington State Department of Agriculture (WDA)s policy assistant for registration services, in most cases, these lists dont cover the synthetic pesticides that most conventional growers use on wheat or apples or corn or just about any crop you can think of. If you get in an area where you have an outbreak that you have to control, these products [on the current state lists] are not necessarily the most effective products you want.




A May 30 Denver protest over pesticide use on cannabis plants. Jose Silva 
Marijuana growers, then, have turned into gamblers: Do they use approved products that might not fully protect their crops from pests, or do they opt for stronger stuff and risk running afoul of the law? This spring in Colorado, some of those gambles proved unwise. In March and April, the City of Denver ordered 11 local cultivation operations to quarantine tens of thousands of marijuana plants that they suspected of being treated with unapproved pesticides, meaning they could continue growing but couldnt be sold. The Cannabis Consumers Coalition, a citizens group, has begun waving signs like "No Pesticides on My Flower in front of the companies that were part of the sting, and most of the quarantined plants remain on hold. Some of the plants, which can fetch several thousand dollars each when mature, have already been destroyed voluntarily.
Circumstances are particularly vexing for growers because two of the pesticides used that led to the quarantine  Eagle 20 and Avid  arent listed in Colorados rules on marijuana pesticides, which means there wasnt clear indication they were prohibited. Its been devastating, says Sean McAllister, a Denver marijuana business attorney who represents four of the growers affected. People have had to borrow hundreds of thousands of dollars to cover their lost inventory. People are having to scramble to adjust because they were doing something they had no idea was unlawful.
*Health risks?*
Are pesticide residues on marijuana a health concern? That question led Jeffrey Raber, a chemist who runs the Werc Shop marijuana testing lab in Los Angeles County, to analyze the smoke generated from marijuana treated with pesticides. The results, published in the _Journal of Toxicology _in 2013, were striking: 70 percent of the pesticides applied to the plants could be exposed to the lungs when smoked in a device like a glass bowl. That is pretty much like injecting it into your bloodstream, says Raber. The smoking didnt destroy the pesticide molecules, so you could have some pretty significant amounts of exposure.

Findings like this, plus the fact that neither Colorado nor Washington, the two states that allow recreational marijuana, have yet to launch full-scale product monitoring programs for pesticide and other contaminants, lead some folks to think its only a matter of time until marijuana companies start facing lawsuits over pesticide contamination.
Its why some people think the lack of approved pesticides for the marijuana industry might be a good thing. Without these chemical crutches, maybe cannabis growers could lead the way in developing an all-natural agricultural industry. The reality is you can absolutely grow quality cannabis with organic methods, says Chris Van Hook, a lawyer and USDA accredited founder of the Clean Green organic cannabis certification program in California. Many of the pests people are talking about dont necessarily damage the flower.
But others think an all-organic marijuana industry is an impossible ideal when you have pests like spider mites, powdery mildew and root rot than can quickly decimate a finicky, closely spaced crop like marijuana -- and these risks might be exacerbated as the industry moves towards large-scale outdoor grows and porous greenhouses where it might prove even harder to manage pests. Its very difficult for someone growing outdoors to be able to manage their crops without pesticides and get the yields they want, says Kurt Badertscher, co-owner of Otoké Horticulture, a Colorado marijuana consulting company. Frankly, if you talk to anybody who is in high-production agriculture and say, I am going to take away most of your pesticides, they will say, I am selling my farm.
*EPA weighs in*
The need for more guidance on pest control caused the Colorado and Washington State department of agricultures to ask the EPA in February whether FIFRA section 24(c) could be used to approve marijuana pesticides as a Special Local Need, leading to the federal agencys response in May. Special Local Need registrations are a state-based process designed for localized pest problems or minor crops, where an addendum to a pesticides registered use label is more practical than the full-scale EPA registration process. According to the EPA letter, to get a marijuana pesticide approved as a Special Local Need, a manufacturer would likely have to identify a product that is federally registered for uses similar to cannabis, such as those used on food or tobacco crops that are grown under comparable circumstances. Pesticides that have potential, according to CDAs Yergert, include the insecticides Imidacloprid and Spinosad and the fungicide Azoxystrobin.




Magnified image of a two-spotted spider mite. eLife - the journal (https://goo.gl/BeWpeB) 
The section 24(c) registration process could provide a way forward for states struggling to manage marijuana pesticide use without running afoul of federal law, says WDAs Johansen. It gives a little more flexibility to the state, and the EPA doesnt have to approve the registrant, they just have to say, We dont have a problem with it. Its not an ideal mechanism, but it is a step forward.
Whats more, a Special Local Need registration usually requires far less time and money than a full EPA pesticide registration. Its a shorter process and cheaper. We are hoping 6 to 8 months [for a registration], if there is a company that is really interest in moving forward with this, says Yergert.
But there lies the big question. While Johansen says hes spoken with pesticide manufacturers interested in the marijuana industry, will any of them be willing to invest in even this abbreviated product registration process? It doesnt help that unlike other Special Local Need registrations, states and manufacturers cant rely on the expertise of state university agricultural departments or the U.S. Department of Agriculture, thanks to marijuanas federal illegality.
And even if pesticide manufacturers move forward with the 24(c) process, no one knows for sure whether the feds will ultimately sign off on it. The EPA note reads something like, Sure you can try and here is some guidance on how to build the case, said Badertscher of Otoké Horticulture. There is no statement that anything will get an exception.
Its possible, then, that the pesticide industry could end up like the banking industry, where even with tacit approval from federal regulators, businesses have been reluctant to wade into the developing marijuana scene without further federal guidance. In the meantime, while state agriculture officials and industry stakeholders search for potential pesticide companies with which to partner, growers like Koh will have to keep searching their plants for bite marks and powdery mildew, hoping to catch the pests before its too late.


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## vostok (Jun 9, 2015)

bugs will only attack an 'unbalanced' plant, correct the balance and be bug free, 

is easier said than done ...! but if ever in doubt, use Neem Oil, its organic, systemic and is good for killing molds and fungi too


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## Rosebud (Jun 10, 2015)

Vostok, i hate to disagree with you but Neem oil is gross. Plants can die with it as it blocks the absorption by leaving gross oil on your bud.

Organics is the only way to go.. I have been concerned about this for decades, what people spray on cannabis. It is kinda my thing.  We need to up our game.


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## vostok (Jun 11, 2015)

In a recent outbreak ..our village came under a serious lice infection, (worst since WW2)even the local kids were sent home from school for 2 weeks, no church. school, even shops were limited to groups of 4 at a time, the government said the delay was in the foreign imports due to sanctions at the time, but what the hell, we had to defend ourselves.

I asked a buddy who owes me! and appeared with 300 litres of stinky neem oil, a life saver to many of these families, all the males were sent to the park all the females, to the school where we got drenched in thick goo- ey neem oil, the stink was  unreal, we let it sit for 10 minutes, then washed it all of ...the kids saw it as fun, and within 3 hours ...not a louse lived!!!

now the local doctors are seeing this as a viable alternative to the hydrocarbon based chems of WW2 era, that they have been using since

Thankyou you for your imput Rosebud. but I'm not here to disagree or agree with you, but to assist fellow members in growing weed ....if I may?


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