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
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
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.
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
· 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.
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
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.
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.
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
read the label and obtain all pertinent information about endangered
species before using pesticides that have endangered species
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
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
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.
are commonly grown in some of the most beautiful environments in the
world—let’s work hard to keep it that way!