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TRANSCRIPT
Challenges and Opportunities
for Pest Management of
Cannabis in Colorado
Iowa State Department Seminar
March 7, 2014
Whitney Cranshaw
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
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
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.
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
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
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
• 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 • 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.
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.
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
25(b) exempted (?) products
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 and
unsafe
Abamectin
Bifenazate
Fenpyroximate
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
Horticultural
oils
Pyrethrins
Azadirachtin
Microbial controls
Some IPM Tools for
Powdery Mildew
• Exclusion of causal organism
• Oils, desiccants to kill stages
on leaf surfaces
• Biological control agents
• Improved air circulation
Trilogy and Triact 70 are neem oil products that
specify use on greenhouse-grown herbs and spices
Herb use is not on
these labels
Bacillus subtilis QST 713 Strain
Cease
A biological control
to suppress plant
pathogenic fungi on
leaves and in soil.
Odor issue??
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
Bacillus subtilis QST 713 Strain
Cease
A biological control
to suppress plant
pathogenic fungi on
leaves and in soil.
Some IPM Tools for
Fugnus Gnats
• Use growing media that do not favor
development of fungus gnats
• Trapping
• Azadirachtin drenches
• Biological control agents
– Soil-dwelling predatory mites
– Entomopathogenic nematodes
– Bacillus thuringiensis var. israelensis
Strains of Bacillus thuringiensis
• kurstaki, aizawi strains
– Caterpillars of moths, butterflies
• tenebrionis strain
– Larvae of leaf beetles
• israelensis strain
–Larvae of mosquitoes, certain midges and gnats
Some IPM Tools for Rice
Root Aphid
• Exclusion of causal organism
• Azadirachtin drenches (?)
• Biological control agents (?)
–Soil dwelling arthropod
predators
–Entomopathogenic fungi
Pest Management Products
that Might Have Promise for
Root Aphid Control
Azadirachtin
Soil dwelling
predators
Metarhizium anisopliae?
Beauveria bassiana
• Determine basic outlines of life history and
habits
• Identify methods of dispersal and use of non-
Cannabis hosts
• Identify effective biological and chemical
controls
“….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……”
Spider Mite Management on the Internet
Information from Legal Hydro web site
“….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…”
Spider Mite Management on the Internet
Information from Legal Hydro web site
Some IPM Tools for Mites (Twospotted spider mite, Hemp russet mite)
• Exclusion of causal organism
• Oils
• Azadirachtin?
• Predatory mites?
Cuttings, if used, must
be disinfested of all
living stages of mites
before introduction
into a growing area
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: Mesoseiulus longipes
Can only tolerate the very low humidity of 40% when the temperature is 70°F.
Requires increasing humidity as temperature rises.
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