Policy Challenges Impacting Pest Management of Medical

Policy Challenges Impacting
Pest Management of Medical
Marijuana in Colorado
BSPM Department Seminar
March 12, 2014
Whitney Cranshaw
Private Citizen
Some Background – Key Date
• November 2000 – Passage of
Amendment 20
– Allows usage of Cannabis for patients with
written medical permission (“medical
marijuana”)
– Patients may grow up to 6 plants
– Patients may acquire Cannabis from a
caregiver or from non-state affiliated
clubs/organizations (dispensaries)
Some Background – Key Date
• November 2012 – Passage of
Amendment 64
– Allows personal use of Cannabis
– Establishes regulations on production and
sale of Cannabis
– Sets excise tax on wholesale sales
• Additional taxes are on November 2013 ballot
– Industrial hemp also included in ballot
initiative
Cultivated Cannabis involves the use
of two species (subspecies?) that
freely interbreed
Cannabis indica
Cannabis sativa
Excellent introduction
to the history and
recent developments
related to production
of psychoactive
Cannabis
Note: Cultivars grown to
produce fiber (hemp) are
selections of Cannabis
sativa with low levels of
psychoactive
compounds.
Under federal law all
Cannabis is classified as
“marijuana” and regulated
as an illegal drug
CSU Policy Statement on Hemp
o With regard to industrial hemp, for many years CSU has followed issues surrounding
industrial uses of hemp and the potential for hemp as a cash crop, and we recognize
that there are numerous research opportunities for production and use of
hemp. That said, we have to keep in mind that hemp remains a controlled substance
under the federal Controlled Substances Act, which criminalizes the possession,
growing and use of hemp, notwithstanding the provisions of Amendment
64. Recently, the Agricultural Act of 2014 (the “farm bill”) was signed into law,
which contains language allowing the cultivation of “industrial hemp” for research
purposes by universities and state departments of agriculture. Section 7606 of the
farm bill does not change the definition of marijuana, but creates a limited research
exception for industrial hemp. CSU is watching closely to see how the farm bill
results in necessary changes to permissibly cultivate, grow, and conduct other
activities related to researching industrial hemp in the US. CSU is poised to help
explore the possibility that hemp could become an important crop in Colorado.”
Memo from the College of Agriculture, February 28, 2014
Federal Laws on Cannabis
• Marijuana classified as Schedule I
Controlled Substance
– Substances in this schedule have no currently
accepted medical use in the United States, a
lack of accepted safety for use under medical
supervision, and a high potential for abuse
• Other examples of Schedule I drugs
include:
– Heroin, LSD, peyote, methaqualone, Ecstasy
– Schedule II drugs include cocaine, most
opiates, amphetamines
Medical/”Recreational” Cannabis
Production Practices
State laws
specify that all
production is
grown indoors
Propagation is by seed
or by cloned cuttings
Production Size Varies
It can be expected that there
will be a proliferation of
small “home grows” and
very large production grows
in near future.
Cultivation is extremely
intensive, expensive, - and
produces a crop of very
high value per unit area
Intense lighting
and extensive use
of fans is part of
standard practice.
Most growers
use a pot or bag
to culture, with
drip irrigation.
Some growers utilize
hydroponics for
production.
Primary crop outcome
– Sinsemilla
Unfertilized,
grossly enlarged,
female flowers (aka
“bud”)
Primary Pest Problems of Indoor
Grown Cannabis
• Abiotic disorders
• Pathogens
– Powdery mildew
– Pythium root rots
• Arthropods
– Twospotted spider mite
– Hemp russet mite
– Rice root aphid
– Fungus gnats
Twospotted spider
mite
Tetranychus urticae
Photograph by Karl Hillig
Hemp russet mite
Aculops cannabicola
Rice root aphid
Rhopalosiphum abdominalis
Darkwinged fungus
gnats
Bradysia spp.
Powdery mildew
of Cannabis
Sphaerotheca macularis
Pythium root rots
Pythium spp.
Federal Laws and Pesticides
• Marijuana is classified as Schedule I
Controlled Substance
– As a result no federal agency will recognize the
crop for any purpose – other than drug law
enforcement
• EPA will not establish a crop category for
cannabis under pesticide laws
– EPA regulates the use of pesticides under
provisions of law defined by FIFRA
– No pesticides can be used legally on a crop if
the use is not allowed for that crop category
Present Status of Pesticide for Use on the
Crop: Any pesticide that is a registered
pesticide is illegal to use on Cannabis under
federal law
A “Catch-22”
Definition: A problematic situation
for which the only solution is denied
by a circumstance inherent in the
problem or by a rule
Suggested Crop Site
Classification
• Best fit – Indoor grown “Herbs and
Spices” crop category (Category 19)
• Examples of Category 19 pesticides
– Insecticidal soaps
– Horticultural oils
– Pyrethrins
– Neem
– Phosphorous acid
– Some microbial insecticides
– Some microbial fungicides
Legal Products in Absence of
Federal Registration
• Biological control agents other than
microbes
– Entomopathogenic nematodes
– Predatory mites
– Insect predators/parasitoids
• Section 25b Minimum Risk Pesticides
– Primarily various vegetable/essential oils
of botanic origin
Biological Control
Organisms not
Regulated as Pesticides
Predatory mites
Steinernema feltiae
Soil predator mites
Photograph by Krister Hall
25(b) Minimum Risk Pesticides
Result of Federal Resistance
to Cannabis Production
• Inability to disseminate information on
diagnostics
• Inability to disseminate information on
IPM practices
– Inability to conduct research to improve
pest management practice
• Unregulated, illegal and often unsafe
use of pesticides to manage pests
August 14 Letter from a Cannabis Producer
Checklist of treatments July 18-August 12
• BioWar (unspecified “beneficial soil microbes)
• Sulfur/pyrethrins
August 14 Letter from a Cannabis Producer
Checklist of treatments July 18-August 12
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BioWar (unspecified “beneficial soil microbes)
Sulfur/pyrethrins
Abamectin (Avid)
Chlorfenapyr (Pylon)
Abamectin/binfenzate (Scirocco)
Fenpyroximate (Akari)
Abamectin
Fenazaquin (Magister)
Washington State Finesse on the Subject
of Pesticide Use on Cannabis
• Pesticides that require federal
registration under Section 3 of FIFRA
– Active ingredient is exempt from the
requirements of tolerance, and
– Label has directions for use on
unspecified food crops, including
unspecified food crops grown as bedding
plants
– EPA and WSDA registration is required
• Section 25b minimum risk pesticides
(exempt from federal registration)
Washington State Finesse on the Subject
of Pesticide Use on Cannabis
• Pesticides that require federal
registration under Section 3 of FIFRA
• Section 25b minimum risk pesticides
(exempt from federal registration)
– WSDA registration is required
– Use allowed if product is labeled for use
on unspecified food crop, home gardens,
or herbs (including bedding plant uses)
Note: Net effect of the WSDA guidelines are to allow the
types of pesticides allowed under Category 19 Site
established by EPA
Products allowed with WDA
Finesse
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Azadirachtin
Bacillus pumilus
Bacillus subtilis
Bacillus
thuringiensis
Canola oil
Chromobacterium
Gliocladium virens
Hydrogen peroxide
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Mineral oils
Neem oil
Phosphorous acid
Potassium
bicarbonate
Insecticidal soaps
Pyrethrins
Streptomyces spp.
Trichoderma spp.
Cannabis Regulatory Status In
Colorado?
• Department of Revenue
– Controls almost all regulations affecting
recreational/medical Cannabis
• Department of Agriculture
– Involved in developing regulations related
to industrial hemp
– Sometime in the future will produce
guidelines related to pesticide use on all
types of Cannabis production in the state
Present Options for Pesticide use in Colorado Cannabis Production
Option One. Use products that are typically
registered as pesticides but do not overtly sell
them with pest control claims.
Neem oil products registered as
pesticides – illegal to use on Cannabis
Neem oil sold as a “leaf polish”
without label claims for pest control –
legal to use on Cannabis
Microbial biological controls sold as
registered pesticides – illegal to use
on Cannabis
Same microbial agents formulated into a
soil amendment without pesticidal claims
– legal to use on Cannabis
Present Options for Pesticide use in Colorado Cannabis Production
Option Two. Use products as pesticides that are
not registered as pesticides
Sulfur
fogs
CO2 fumigation
Sodium bicarbonate
Yes
Potassium bicarbonate
No
Present Options for Pesticide use in Colorado Cannabis Production
Option Three. Ignore the law and use pesticides
that are not registered for the crop
Present Options for Pesticide use in Colorado Cannabis Production
Option Three. Ignore the law and use pesticides that are not
registered for the crop
Illegal due to regulatory indecision
Azadirachtin
Microbial controls
Horticultural
oils
Pyrethrins
Present Options for Pesticide use in Colorado Cannabis Production
Option Three. Ignore the law and use pesticides that are not
registered for the crop
Illegal and
unsafe
Fenpyroximate
Bifenazate
Abamectin
Twospotted spider
mite
Tetranychus urticae
Spider Mite Management on the Internet
“….Consider this situation, you spray your
chemicals, the mites may not die right away
depending on the mode of action, what
happens next is the mites panic and start
laying eggs like crazy. Before you know it,
the mites have become twice as bad as
before you hit them……”
Information from Legal Hydro web site
Spider Mite Management on the Internet
“….The best method to control this pest is
to switch your mode of attack each and
every day. Never spray them with the same
stuff twice in a row, if you choose the
chemical approach, you want to use a
Neem Oil along with as many other forms of
Miticides as you can get your hands on…”*
*Italics are mine
Information from Legal Hydro web site
How can we improve the management of
pest problems on Cannabis in Colorado?
How can we improve the management of pest problems
on Cannabis in Colorado?
We probably have to first
remove the CSU lawyers to
an undisclosed location.
Then begin a discussion
among adults on how to best
handle this peculiar situation.
When reasonable
agreements for progress on
key issues have been
developed we can then
release them so they can
overly complicate some other
situation.
How can we improve the management of pest problems
on Cannabis in Colorado?
Most important step!!!!
Remove the gag on the ability
of CSU employees to discuss
pest management with
Cannabis producers.
Mites are the
#1 pest
problem on
the crop
Twospotted spider mite
Hemp russet mite
Photograph by Karl Hillig
Provide
information on
how to identify
problems
Photograph by Karl Hillig
Symptoms associated with twospotted spider
mite (flecking) and hemp russet mite (leaf roll)
Exclude Mites from
Growing Area
Cuttings, if used, must
be disinfested of all
living stages of mites
before introduction
into a growing area
Avoid conditions that allow “steamrolliing” of
mite populations
Management of air flow will be important in how
mites get distributed within a planting
Powdery mildew
Conditions that Promote
Powdery Mildew
• High humidity
• Moderate temperature
• Still air
Pythium
root rots
Some IPM Tools for
Pythium Root Rots
• Exclusion of causal organism
• Avoid hydroponic production
• Avoid producing soil conditions
favorable for growth
• Incorporation of effective biological
control agents into root growing media
Fungus Gnats
Some IPM Tools for Fugnus
Gnats
• Use growing media that do not favor
development of fungus gnats
– Soil moisture management
• Trapping
• Azadirachtin drenches
• Biological control agents
– Soil-dwelling predatory mites
– Entomopathogenic nematodes
– Bacillus thuringiensis var. israelensis
Larvae primarily feed
on various decay fungi,
more incidentally
damaging healthy roots
Fungus Gnat Trapping
Steinernema feltiae – the nematode for use against certain Diptera larvae
Soil Predator Mite
Hypoaspis miles
How can we improve the management of pest problems
on Cannabis in Colorado?
Allow CSU employees to assist in pest
diagnostics
This will allow better cataloging of existing problems,
the first step in allowing the development of effective
IPM practice
Thrips injury?
Whiteflies, viruses, other pathogens……….
How can we improve the management of pest problems
on Cannabis in Colorado?
The State of Colorado needs to
complete the decisions related to
pesticide regulations on the crops.
STATE OF WASHINGTON
DEPARTMENT OF AGRICULTURE
P.O. Box 42560 • Olympia, Washington 98504-2560 • http://agr.wa.gov • (360) 902-1800
Criteria for Pesticides Used for the Production of Marijuana in
Washington
August 2013
Both state and federal law require that pesticides be applied
according to label directions. As part of the directions for use,
pesticide labels will specify the particular crops and/or sites to which
they can be applied. Depending on the particular pesticide, the
crops/sites ……….
Integrate whatever products are
allowable into pest management plans
for producers
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•
•
•
•
•
•
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Azadirachtin
Bacillus pumilus
Bacillus subtilis
Bacillus
thuringiensis
Canola oil
Chromobacterium
Gliocladium virens
Hydrogen peroxide
•
•
•
•
•
•
•
•
Mineral oils
Neem oil
Phosphorous acid
Potassium
bicarbonate
Insecticidal soaps
Pyrethrins
Streptomyces spp.
Trichoderma spp.
How can we improve the management of pest
problems on Cannabis in Colorado?
What about pest
management research?
• Determine basic outlines of life history and
habits
• Identify methods of dispersal and use of nonCannabis hosts
• Identify effective biological and chemical
controls
“….They(mites) had never been a problem
till this Spring after one of the warmest
mild winters in Colorado on record. I have
never had a russet mite infestation ever
before till this one which stemmed from
them literally being rampant in the wheat
and alfalfa fields around my home. But as I
have been arresting the further develpment
of these mites in my grows so have the
farmers in their fields too. They have been
spraying and treating their fields for them
just as I have been inside my home…..”
May 28, 1012 posting by Bluzboy http://www.thcfarmer.com/
Rice root aphid
Azadirachtin
Soil dwelling
predators
Pest Management Products
that Might Have Promise for
Root Aphid Control
Metarhizium anisopliae?
Beauveria bassiana
Mites are the
#1 pest
problem on
the crop
Twospotted spider mite
Hemp russet mite
Photograph by Karl Hillig
Some IPM Tools for Mites
(Twospotted spider mite, Hemp russet mite)
• Exclusion of causal organism
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Oils
Azadirachtin?
CO2?
Predatory mites?
Spider Mite
Predators
Predatory Mites for Potential Use on
Medical Marijuana?
• Mesoseiulus longipes
• Neoseiulus californicus
• Galendromus occidentalis
Note: The above species are
the predatory mites that are
most tolerant of low humidity.
However, performance of all
is reduced under low
humidity.
Predatory Mite: Galendromus occidentalis
Optimal environmental conditions
80-100 degrees F
> 50% RH
Predatory Mite: Mesoseiulus longipes
Can only tolerate the very low humidity of 40%
when the temperature is 70°F.
Requires increasing humidity as
temperature rises.
Development of Banker Plant Systems for Mite
Management
Graphics courtesy of University of Florida
Twospotted spider mite
– Pest of Cannabis
Banks grass mite
– Pest of grasses
Introduce generalist predator of both mite species
Development of Banker Plant Systems for Mite
Management
Graphics courtesy of University of Florida
Summary
• Cultivated Cannabis has several pest
problems, some of which can destroy
the crop
• Present pest management practices are
not guided by science, but by Internet
gossip
• Present pest management practice on
the crop is often misguided, ineffective,
and, on occasion, hazardous
Summary
• Federal obstructions produce the
biggest impediments – and biggest
challenges – to improved IPM
– Ability to discuss IPM with growers would
have immense value
– Resolution of pesticide registration issues
is needed to produce effective IPM
strategies
• Rapid progress in developing optimal
IPM practices can be expected following
release of these federal obstructions

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