VOC Issue Comes to the Forefront 

New air quality regulations could impact price and availability of many popular almond compounds

By Marni Katz

Special to "California Almonds"

California pesticide regulators are aggressively pushing to reduce smog-forming emissions from pesticides, called volatile organic compounds, or VOCs. This move is likely to change how and to what degree several major pesticides and fumigants are used in almond orchards and other crops.

The state Department of Pesticide Regulation in June announced it is initiating an intensive program to meet federal and court-ordered mandates to reduce VOCs from pesticides in some of the state's smoggiest areas. The announcement made clear that the decade-old VOC issue is becoming a priority in the air quality regulatory arena, with potential implications for almond growers in the very near term.

"This is the first time pesticides are being regulated as air pollutants," said Gabriele Ludwig, senior manager, of global technical and regulatory affairs for the Almond Board of California. "This could impact 10 to 15 compounds widely used in almond orchards."

VOCs react with nitrous oxide compounds (NOx) in sunlight to form ozone, which is regulated at the ground level under the Clean Air Act. The top five known sources for VOCs in the San Joaquin Valley are cars, oil industry emissions, cows, pesticides and home products, such as paint and cleaners. All five still account for only 30 percent of the total VOCs inventoried in the valley. The rest come from what could be millions of other unknown sources.

Pesticides in California produce about 6 percent to 9 percent of all known VOC emission sources in the state, according to DPR.  About half the pesticide VOCs in California come from soil fumigants, and the other half from emulsifiable concentrate formulations of hundreds of pesticides. It is not the active ingredient in most pesticides that emits VOCs, but the inert ingredients.  Typical inert ingredients are the compounds that make the pesticide soluble or stick to leaves. In many cases, though, those ingredients are critical to the pesticide's efficacy.

As the State Department of Pesticide Regulation seeks to curb emissions of Volatile Organic Compounds (VOCs) from pesticides, DPR announced it will be emphasizing alternatives including application technologies such as the SmartSprayer, which can reduce the emission of fine particulates into the air. (Photo by Marni Katz)

Thus, to reduce VOC emissions from pesticides means 1) reducing off-gassing of soil fumigants and 2) reducing the VOC emissions from emulsifiable concentrate formulations.

Existing efforts to address worker and bystander exposure concerns about soil fumigants will likely have the greatest immediate impact on reducing VOCs from soil fumigants. Fumigants are considered 100-percent VOC emitters by the state, meaning that for every pound of fumigant applied, there is one pound of VOC calculated to be available to go into the air. Thus, measures to reduce off-gassing or reduce the amount of fumigant used will reduce the VOC contribution. The Almond Board has been funding several research projects looking at ways to amend the soil to reduce off-gassing or to more precisely apply soil fumigants and reduce the amount used.

Reducing the VOC emitted from liquid formulation pesticides is a more complicated matter.  For EC formulation pesticides, DPR's default assumption is that for every pound of pesticide applied, 0.39 pounds of VOC leaves the orchard as a VOC (unless DPR has product specific emissions data for a specific formulation). To reduce emissions from EC formulation pesticides, growers will have to switch to a less volatile formulation, change to a different class of chemistry entirely, or employ application technology and other solutions that reduce the amount of EC applied.

ALMOND COMPOUNDS IN THE CROSSHAIRS

Ludwig said growers might begin to feel the pressure from new air quality regulations on many EC pesticides within the next two to three years. They may face added regulations, restrictions and higher costs for perhaps 10 to 15 major almond crop protection products, including Lorsban and Pounce, the miticides Omite and Agri-Mek, and herbicides including Roundup and Goal.

As DPR considers how to meet mandates to reduce VOC emissions from pesticides, manufacturers of EC formulation pesticides registered in California are facing pressure to reformulate potentially hundreds of pesticides, a financial burden that is likely to be ultimately passed on to growers. DPR last year asked all registrants to provide information on whether or not they could reformulate EC formulation pesticides and that information is still coming in.

Ludwig is concerned key products growers rely on in standard almond IPM programs will no longer be available or will become much more expensive and perhaps cost-prohibitive.

"Reformulation is not a minor feat because you have to make sure you retain the efficacy of the product, do not have phytotoxicity, retool your production line, and you have to bear the cost of getting new federal and state registrations," Ludwig said. "And in some cases registrants might decide to simply remove the product from the California market because the cost is too high to reformulate and California is the only state requiring the change."

WORKING PROACTIVELY

DPR has expressed an interest in working cooperatively with commodity groups, growers and pesticide registrants in finding voluntary measures to reduce VOC emissions.

Ludwig said the Almond Board of California is working proactively on the VOC issue to get strategies and alternatives to growers that address air quality concerns. She recently prepared a document with the help of growers and PCAs outlining the formulation, chemical, and cultural alternatives available to the most commonly used high-VOC contributing pesticides, as well as the comparative costs, advantages and disadvantages of those alternatives.

Consultant Jim Wells is working with almond growers and other commodity groups to find economically viable alternatives to the use of high VOC pesticides and fumigants. Wells, a former director for the Department of Pesticide Regulation and now president of Sacramento-based Environmental Solutions Group, has assembled the Pesticide Ag Support Group that includes almonds, grapes, strawberries, citrus, carrots and other crops, to address the issue head-on.

"We are looking at pest management profiles, what key pests are, what chemicals growers are using and comparing what they are using against their VOC content to figure out if we can reduce emissions that might come off the field and into the air," Wells said. "That might include switching to less volatile formulations of the compound, switching chemicals to accommodate pest control without volatiles, and developing and using spray techniques that reduce fine particulates or VOCs."

He said it is important that groups such as the Almond Board continue working toward finding solutions and strategies they can live with that achieve reduction goals, before solutions are thrust upon them.

"We have an opportunity to put forward strategies we think are attainable and also to point out what some of the problems are in achieving these reductions in terms of both cost and efficacy," Wells said. "DPR says they will accommodate our input, so if we want to try and put forward the things we can live with and point out problems with other strategies that have been suggested to us, we have to do that now."

Unfortunately, in some cases few alternative compounds exist that are not either less efficacious or cost-prohibitive. Take the case of Lorsban, the most popular inseason spray to control peach twig borer in almonds. DPR considers Lorsban EC the greatest VOC emitting compound used on almonds between May 1 and October 31, based on pesticide use data from 2000 to 2003, and its VOC emission factor.

"But when you look at alternatives, while there is a lower VOC emitting formulation of Lorsban registered in almonds, it costs at least twice as much as the traditional EC formulation," Ludwig said.

The popular miticide avermectin, or Agri-Mek, also among the top-10 VOC emitters in almonds, depends on its EC formulation to penetrate the leaf surface and no satisfactory alternative exists.

However, in the case of herbicides, such as glyphosate (Roundup), several low-VOC emitting formulations are already on the market at similar cost, and are being widely used. Thus, a grower could choose to use the lower-VOC formulation in such a situation.

"Moving forward, as growers are choosing pesticides, one of the factors in their decision may be that they have to think about what formulation they use as it contributes to VOC emissions," said Ludwig.

 "It's like the early days of Worker Safety. All of a sudden now you have to think about worker safety and how to integrate it into our thinking about everything we do," agreed Wells. "Water quality is becoming the same way and now air quality is the next thing."