Comment submitted by Michigan Apple Committee

Removing Guthion (Azinphos-methyl) from the list of registered tools for apple growers will have serious negative impacts on the sustainability of apple production in Michigan. Research indicates that Guthion alternatives (neonicotinoids, insect growth regulators) actually leave higher levels of residues in fruit than Guthion. If protecting human health is the highest priority, deregistering Guthion may be a step in the wrong direction. An unintended consequence of using the alternative substances is that they decrease the "good bug" populations and increase mite populations. This results in more miticide sprays and more fuel use in tractors to spray them. This, too, is a move in the wrong direction. Newer chemistries cost growers 2.5 to 4 times as much as a conventional spray schedule, which includes Guthion. Guthion alternatives require tremendous precision. Many small- to mid-size growers who do not currently use insect scouts may need to hire them to properly and effectively apply the alternatives. Additional costs of control measures, additional sprays and scouting costs all contribute to destabilizing the future of family-based apple production in Michigan. Because of the history of this state and the way it was settled, Michigan growers are smaller, family-run farms and not large plantations located in arid regions, and require consideration of the unique Great Lakes growing environment. To look at the entire picture, from human health benefits to environmental benefits, to impacts on other insects and the societal impacts of further destabilizing apple production, we recommend the EPA retain Guthion as one tool in a grower's toolbox to control insects and produce the high quality fruit demanded by the US consumer.