• What types of research and technology would improve the production and delivery of the mycoherbicides?
Research is needed to determine whether the proposed mycoherbicide strains could be produced on a large scale. Research is also needed to guide product formulation, storability, and delivery. The technology to support production and delivery could be identified or developed as needed by an industrial producer.
• What type of testing would be needed before mycoherbicides could be safely and effectively used to eradicate illicit-drug crops (for example, mode-of-action studies)?
A full complement of research documenting the efficacy, specificity, and mode of action of the proposed mycoherbicide products is needed.
For safety assessments, at a minimum, EPA’s toxicology, nontargetorganism, and environmental-fate data requirements for microbial pesticides should be met.
Testing in countries where the mycoherbicides would be used should be done, particularly to address local biodiversity and non-target-risk considerations.
• What would be required under U.S. federal and state laws to test and approve a mycoherbicide of this type, and what guidelines of the International Organisation for Biological and Integrated Control of Noxious Animals and Plants1 would apply?
The committee did not feel comfortable in developing a checklist of testing requirements that must be met, especially with regard to state and international rules, which differ by state and country. The experience from testing registered mycoherbicides suggests that the requirements become part of an evolving process as dictated by the experimental findings with regard to individual organism, host, and conditions. The committee therefore took a more general approach of reviewing and identifying the types of data required for registration in the United States and the special considerations for domestic and international uses of the proposed mycoherbicides.
1The International Organisation for Biological and Integrated Control of Noxious Animals and Plants is a professional society that promotes the use of biological control. While the organization and some of its members have been involved in the development of certain international standards for testing of pesticides and guidelines for transport and release of biological control agents, the IOBC does not have its own set of requirements. The committee interpreted this question to be a more general one about what international guidelines are relevant to mycoherbicides, and reviewed pertinent international treaties and guidance from the United Nations.