Oregon State University suggests that PAA has not demonstrated the level of efficacy required by the scientific community. PAA may work on equipment surfaces but quickly dissipates on organic surfaces. ‘Epiphytic Erwinia amylovora associates intimately on surfaces of pear and apple flowers (more so than non-pathogens) and thus are not sufficiently exposed to fast acting oxidizers. A peracetic acid application may hit a few cells of E.a., but it would be only a relatively small proportion of what’s there. If conditions were right, these would be quickly replaced (a few hours).’ (Dr. Ken Johnson, Department of Botany and Plant Pathology)
The lead Washington State University scientist working on fire blight states ‘I am not aware that this product has been tested and shown to be effective for the control of fire blight. In all my years of attending ISHS World Workshops on Fire Blight (since 1986), I have no recollection of any reputable scientist claiming efficacy for this substance…’ (Tim Smith, Chelan County Cooperative Extension).
Reputable scientists in the area of tree fruit research diseases have confirmed that peracetic acid is not acceptable as a commercial replacement for currently registered antibiotics.
If the NOSB proceeds in following its plan to sunset antibiotics, we request that the efficacy data that support the effectiveness of approved alternatives be made available for scientists with research backgrounds in this area to review.
Dr. Johnson of Oregon State University has recently submitted a proposal to USDA NIFA to continue research in the area of identifying non-antibiotics programs to treat fire blight in organic apple and pear. This proposal has been attached for your review. We request that the NOSB not allow the use of antibiotics to sunset in organic fruit production until alternative products are developed in a program such as his.
Thank you for the opportunity to comment. Please feel free to contact the Northwest Horticultural Council if you require additional background information.
NORTHWEST HORTICULTURAL COUNCIL
Technical Issues Manager