From the U.S. Department of Agriculture AMS docket on the sunset of certain compounds in the National Organic Program, a letter from the Northwest Horticultural Council:
NORTHWEST HORTICULTURAL COUNCIL
105 So. 18th Street, Suite 105
YAKIMA, WASHINGTON 98901 USA
May 20, 2010
Ms. Valerie Frances
National Organic Program
Room 2646 So., Ag Stop 0268
1400 Independence Ave, SW
Washington, DC 20250-0268
Dear Ms. Frances:
RE: Document Number: AMS-NOP-09-0074
Sunset Review- Additional Comments on Antibiotics
The Northwest Horticultural Council (NHC) represents the growers and shippers of conventional and organic deciduous tree fruit, specifically apples, pears and cherries, in the Pacific Northwest states of Idaho, Oregon and Washington. We are writing on behalf of the organic tree fruit producers in these states concerning the sunset review of antibiotics used in their operations.
The NHC has previously provided a letter with background on fire blight including pictures of the devastation caused by this disease, NOP Proposed Amendments to the National List of Allowed and Prohibited Substances, Document Number AMS-NOP-09-0081, March 15, 2010 and a letter dated April 6, 2010, which was entered into testimony at the Sunset Review Meeting in Woodland, California, April 26-29, 2010, in support of the retention of antibiotics until a suitable alternative is identified.
We offer the following comments to address the use of the alternative material, peracetic acid (peroxyacetic acid or PAA), for fire blight treatment.
The tree fruit industry has been aggressively seeking a range of alternatives for fire blight control and closely following the research being done in the U.S. and around the world. The following are reports from various sources:
University of California, Riverside reported that PAA was evaluated in 2003 and 2004 in a mixture with hydrogen peroxide. The peroxide being the oxidizing agent and the PAA, the stabilizer, which maintained persistence after application. Fire blight control research using this product was discontinued as a result of its inconsistency, marginal to low efficacy and its phytotoxicity to fruit and leaves. ‘…During years 1 and 2, PAA did not work at all in commercial orchards where the disease was moderate. The treatment, however, caused consistent phytotoxicity on the fruit.’ (Dr. James Adaskaveg, Department of Plant Pathology and Microbiology)