MSMA - an appeal to the US EPA Cancel The title field is required!

1. Stuart Cohen

   

   0 posts
   
   12/15/2011 12:12 PM

   Hi, All:
   
   We are soliciting information for a report on the benefits of MSMA. The report is due to the US EPA, in final form, by Dec. 31. Currently, only use of existing stocks is allowed in Florida, I believe, and use on other US golf courses will be cancelled after 2013.
   
   MSMA is an organoarsenical. Unlike inorganic arsenic, it is not carcinogenic, and it does not have high acute toxicity. EPA is concerned that very small amounts of it may convert to inorganic arsenic in the environment and migrate to water supplies.
   
   However, the inorganic arsenic carcinogenicity issue is scheduled to be reexamined by the EPA's Scientific Advisory Panel in June. Following this examination, and depending on the benefits analysis, the registrations of MSMA's turf uses may be extended indefinitely.
   
   1. Can any of you provide specific information about the lack of alternatives? For example, 'I only achieved 20% control of [dallisgrass, field paspalum, etc.] with a mix of herbicides X and Y, but I achieved 90% control with MSMA, which was cheaper by a factor of 2 on a per-acre basis.'
   
   2. Can any of you provide specific information on the increase of herbicide resistance in areas where MSMA use has been restricted?
   
   3. In addition to sending this info to us and/or posting this on the forum, please consider sending a letter directly to the EPA, as follows: Tom Myers, MSMA Product Manager, myers.tom@epa.gov. Please cc us if you do so, at ets@ets-md.com.
   
   Thank you for your time.
   
   stuart cohen
   Stuart Z. Cohen, Ph.D., CGWP
   President
   Environmental & Turf Services, Inc.
   11141 Georgia Ave. Suite 208
   Wheaton, MD 20902
   301-933-4700
   fax 301-933-4701
   ets@ets-md.com
   www.environmentalandturf.com

   
   
   
   
2. Brian Lentz

   

   0 posts
   
   12/18/2011 8:12 PM

   I know a lot of guys stocked up on MSMA and the effects of its loss haven't been felt by many at this point. We stopped using it soon after it was announced MSMA was on the chopping block, I think our last application was mid 2009. The alternative products have provided some good control of the basic weeds, goose and crab but at a cost of 5 to 10x compared to MSMA. We've had to increase our pre-emergent applications to compensate for the lack of economical post emergent control. The most detrimental effect we've seen is the lack of control on Tropical Signal Grass, we just haven't seen any product control or keep the weed in check like MSMA did. Even if we could get MSMA back under a spot treatment label that would be great. I don't think I'm going to get my hopes up but I'm glad to see there may still be a chance to revive its use.
   
   Brian Lentz
   Lakewood Ranch G & CC

   
   
   
   
3. McCallum David K

   
   12/19/2011 9:12 AM

   If and when it is finally banned it will certainly hurt everyone that grows turf in the south. MSMA is the cornerstone of herbicides for most superintendents. Like many I stocked up on the product when the first threat of it being removed was announced. More valuable than gold.

   
   
   
   
4. Andy Jorgensen

   

   1 posts
   
   12/19/2011 2:12 PM

   Tropical Signalgrass is the main weed I hear that most people are having issues with.

   
   
   
   
5. Stuart Cohen

   

   0 posts
   
   12/19/2011 3:12 PM

   Thanks for your support, people. Please send your notes to the EPA, at the email address in my original post. We also may cite your statements in our formal report.
   
   stuart cohen
   ets@ets-md.com

   
   
   
   
6. Wahlin Scott B

   
   1/12/2012 12:01 PM

   This interpretation of the applicability of 62-780 from the Southeast District may not be consistent with how the Rule is being interpreted in other FDEP districts. (I am being hammered by SE District EPA for historical MSMA use.) Note that an environmental law firm in Orlando published the following comment on their website:
   
   Friday, December 02, 2011
   
   Pesticide contamination on golf course: Florida DEP position
   
   Florida does not have statewide soil standards; however, when cleanup is required as a result of a spill or dumping of a chemical onto the ground, Soil Cleanup Target Levels(SCTLs) are used by the State of Florida Department of Environmental Protection to determine when cleanup is complete. The Central District of DEP just posted the following relating to a golf course property where adjacent residential property owners are expressing concern about the offsite migration from the golf course of the pesticide Dieldrin. (In the past, it was common construction practice to use Dieldrin as a subsurface slab treatment.)
   
   "The DEP does not generally enforce Direct Exposure-based SCTLs when a pesticide is present as a result of proper use of a product. The Leachability-based SCTLs may be enforceable if dumping, spilling, or misapplying a pesticide can be linked to groundwater contamination."

   
   
   
   
7. Andy Jorgensen

   

   1 posts
   
   1/12/2012 3:01 PM

   Scott Wahlin, CGCS said: This interpretation of the applicability of 62-780 from the Southeast District may not be consistent with how the Rule is being interpreted in other FDEP districts. (I am being hammered by SE District EPA for historical MSMA use.) Note that an environmental law firm in Orlando published the following comment on their website:
   
   Friday, December 02, 2011
   
   Pesticide contamination on golf course: Florida DEP position
   
   Florida does not have statewide soil standards; however, when cleanup is required as a result of a spill or dumping of a chemical onto the ground, Soil Cleanup Target Levels(SCTLs) are used by the State of Florida Department of Environmental Protection to determine when cleanup is complete. The Central District of DEP just posted the following relating to a golf course property where adjacent residential property owners are expressing concern about the offsite migration from the golf course of the pesticide Dieldrin. (In the past, it was common construction practice to use Dieldrin as a subsurface slab treatment.)
   
   "The DEP does not generally enforce Direct Exposure-based SCTLs when a pesticide is present as a result of proper use of a product. The Leachability-based SCTLs may be enforceable if dumping, spilling, or misapplying a pesticide can be linked to groundwater contamination."

   
   
   
   Scott,
   
   If Erin Brockovich walked from that lawsuit, there much not be much proof of the source of contamination and the golf course is just becoming the scapegoat since the general public has a stigma against us. I would think the best case those homeowners would have would be to petition the county to install potable water in their neighborhood, rather than fighting with a class-action lawsuit that would, in the end, net them no better drinking water than they already have.