Environmental Risk

by Jon Clements

Environmental risk is most often associated with legal risk. Typically dictated by state and federal rules and regulations, environmental infractions can and often do result in civil or criminal liability. That alone should be enough to make fruit growers be concerned about minimizing environmental risk and impact, however, we should inherently be good environmental stewards too!


Environmental risk is the risk that operations and activities in producing a fruit crop may harm human health, wildlife (or domestic pets), fisheries, and soil, water, or air resources. For example, consider these situations that present environmental risk and potential environmental degradation:

· A pesticide mixing and loading facility located near a stream has no provisions for containing a spill, hence threatening water and fishery resources

· A farm pond is used for watering domestic livestock and overhead irrigation of Pick-Your-Own strawberries, resulting in cross-contamination (E. coli) and threatening human health


Recognized sources of environmental risk include: Pesticides; Soil Erosion; Nutrient Application; Food Safety; Endangered Species; Civil, State, Federal, and/or Criminal Liability; and Lack of Knowledge of Rules and Regulations.  Let’s look at each source a little closer and some grower responses to minimize the risk of environmental impact.


Pesticides: Pesticide handling and application is probably the most risky—to both humans and the environment—crop production operation fruit growers regularly practice. Specific areas of concern during pesticide handling and application include:

· Storage: the main risk is groundwater contamination and fire. Adequate storage that keeps pesticides high and dry and has impermeable floor/spill containment provisions goes a long way to reducing this risk. Large fruit growers should also be aware of SARA Title III (Emergency Planning and Community Right-to-Know Act) regulations.

· Mixing and handling: again groundwater contamination and spills are potential environmental risks. An anti-backflow device on the fill hose and an impermeable/containment mixing and loading surface (pad) are advised. Handler safety is also a big concern with pesticide mixing and handling. Pesticide handlers are regulated by the Worker Protection Standard (WPS), which dictates the use of Personal Protection Equipment (PPE) and decontamination supplies (among other things) designed to protect handlers from pesticide exposure.

· Application: applicator safety is again governed by the Worker Protection Standard (WPS). Cholinesterase blood testing is recommended for frequent applicators. Rates, timing, non-target impacts, other use restrictions, etc. are regulated by EPA to minimize human health and environmental impacts. The pesticide label is the legal document that spells out use/application directions and restrictions. Remember to always read the label, it is the law! Every fruit farm should have a drift management plan in addition to label restrictions to prevent drift. The goal is for no off-site drift. Finally, pesticides should be applied according to the principles of Integrated Pest Management (IPM), combining cultural, biological, chemical control practices to minimize the use of chemicals and potential environmental impact!

· Field worker protection: where the human health concerns can result from acute or chronic exposure. Again, field worker exposure to pesticides is regulated by the Worker Protection Standard (WPS) which dictates worker training, application notification, Restricted-Entry Intervals (REI), decontamination supplies, and emergency assistance. All fruit growers must adhere to the WPS to avoid risks to their workers health and well-being.

· Disposal: the best solution to minimize environmental risk is to apply all pesticides to the crop(s) per label directions and don’t buy more than you need to avoid having to dispose of unused pesticides. If you end up with unused pesticides try donating them to another licensed pesticide applicator. Used pesticide containers can usually be cleaned (triple-rinse) and recycled or landfilled. Hazardous waste disposal sites are a last-resort option for unusable pesticides.

· Recordkeeping: pesticide recordkeeping is dictated by state and federal reporting requirements. At a minimum, certified private applicators must keep records of use of Restricted-Use Pesticides for two years. States often have additional requirements, including annual reporting, and inspections. USDA/State/Extension pesticide education programs are held frequently and your best bet for staying up-to-date on pesticide recordkeeping requirements.


Soil Erosion: In general, there is minimal potential impact on soils and erosion from fruit farms compared to field crops. Still, fruit growers must choose good sites with minimal erosion risk, including planting  rows with contours, cover cropping fallow areas, using mulch when possible (mostly small fruit), and establish groundcover (sod) as soon as possible after putting in a new orchard. Use good groundcover management practices, i.e. mowing, narrow herbicide strips, no driving when wet, etc. to minimize risk to orchard soils.


Nutrient Application: The key to avoid environmental contamination is to avoid over-application, which can lead to surface and/or groundwater pollution. Nitrogen (N) and phosphorous (P) are of particular concern. Hence, nitrogen and all other nutrient application should be based on soil and leaf or petiole analyses and should follow Extension/consultant recommendations.


Food Safety: Here, the environmental risk is to human health. Un-pasteurized cider (or any fruit juice) has been the biggest issue in the past and increased awareness among fruit growers about food safety. All fruit growers who sell wholesale and/or retail should be aware of food safety issues and practices to minimize risk of microbial contamination, such as handwashing, etc. Good Agricultural Practices (GAP) must be studied and adopted for all field, sorting and packing, storage, and transportation operations. Hazard Analysis and Critical Control Points (HACCP) certification is now a requirement for most processors and wholesalers of fruit and juice. A Cornell University website, http://www.gaps.cornell.edu/ is a good resource for more information on GAPs and preventing foodborne illness from fresh produce.


Endangered Species: It’s a federal offense to use any pesticide in a manner that adversely affects endangered species. Pesticide labels may prohibit use of pesticides in some locations in some states or counties. If so, user must obtain  an "EPA PESTICIDE USE BULLETIN FOR PROTECTION OF ENDANGERED SPECIES.”

Again, read the label and obtain all pertinent information about endangered species before using pesticides that have endangered species restrictions.


Liability: Known environmental infractions can result in civil pollution penalties (as in an accidental discharge) and should be covered by liability insurance, however, you may have to purchase a special pollution policy or addendum. Criminal (state and federal) pollution penalties are the result of intentional environmental pollution and there is no protection afforded by liability insurance! Large fruit growers are advised to perform an environmental audit, and all fruit growers must keep good application records.


Rules and Regulations: to avoid environmental risk, it’s very important to stay up-to-date on rules and regulations that govern fruit farming. Read and follow label directions. Get and stay educated on rules and regulations! USDA/Extension and state departments of agriculture hold regular training and information sessions in your state. It takes away from your time to attend these, but you really cannot afford to not attend and stay informed.


In conclusion, avoiding environmental risk is largely a case of common sense and following rules and regulations. One could argue fruit growing is environmentally benign compared to some other types of agriculture, however, we must always be aware of the risk presented by pesticides to the environment and bacterial contamination of fruit that could sicken humans. On the flip side, consider the many environmental benefits of fruit growing, including: open space preservation; potential for soil/water conservation; wildlife habitat; human nutrition and health benefits; and the local economy and jobs.

Fruit are commonly grown in some of the most beautiful environments in the world—let’s work hard to keep it that way!