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6 Answers to Charge Questions
Pages 121-131

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From page 121...
...  Have the mechanisms of action of the proposed mycoherbicides' toxicity to illicit-drug crops been established? o The types of diseases produced by the proposed mycoherbicide strains are wilt diseases in cannabis and coca and a blight of the ae rial parts of opium poppy.
From page 122...
...  Are the proposed mycoherbicides host-plant-specific? o The proposed mycoherbicide strains can cause disease in their target plants, including those grown legally and those which occur natu rally near the illicit crops.
From page 123...
... However, the latter appears im practical because of the amount of water required for spraying and the possible inability to apply from low altitudes.  What is the overall technical feasibility of the large-scale industrial manufacture of the proposed mycoherbicides?
From page 124...
... o More epidemiological data on the proposed mycoherbicides from experiments with consistent protocols are needed before extensive field tests can be conducted. In general, the field-test conditions should mimic the climatic and environmental conditions under which the illicit-drug crops are grown, and the mycoherbicides should be applied in a manner that simulates the intended delivery method.
From page 125...
... papaveris occur naturally in the native geographic ranges of their target crops. Particular strains probably have geo graphic and climatic boundaries that would limit their survival and infectivity, but the strains that were tested were evaluated under par ticular environmental conditions, so it is not possible to define those boundaries.
From page 126...
... o Prolonging persistence: The available data support the hypothesis that increased inoculum levels could be maintained for a few months after application but do not support the hypothesis that the mycoher bicide strains could persist indefinitely at higher population densities than those of the indigenous strains of the same fungi. TOXICITY TO NONTARGET ORGANISMS  Would the proposed mycoherbicides harm licit crops or kill other soil fungi?
From page 127...
... The persistence of indigenous strains of the fungi across the native range of their hosts is consistent with the conclu sion that introduced mycoherbicide strains are unlikely to be con tained or eradicated once they are released. POTENTIAL FOR MUTATION AND RESULTING TOXICITY TO TARGET AND NONTARGET ORGANISMS  What would be the potential of the pathogens to mutate?
From page 128...
... Selection for crop varieties that are resistant to existing fungal genotypes follows, and the cycle repeats. Selection for resistant drug crop varieties would reduce the effectiveness of the mycoherbicides and would require continued development of new mycoherbicide strains that could attack the newly developed target crop genotypes.
From page 129...
...  What types of expertise would be most relevant for improving the effectiveness and safety of the proposed mycoherbicides? o At a minimum, a team with expertise in the growing practices and conditions under which the drug crops are grown; in plant ecology; in plant disease epidemiology; in plant pathology; in fungal genet ics; in fermentation, formulation, and application technology; and in nontarget risk assessment is needed to develop the proposed strains as mycoherbicides, to assess their effectiveness and safety, and to gather data for Environmental Protection Agency (EPA)
From page 130...
... The committee therefore took a more general approach of reviewing and identifying the types of data required for registra tion in the United States and the special considerations for domestic and international uses of the proposed mycoherbicides. 1 The International Organisation for Biological and Integrated Control of Noxious Animals and Plants is a professional society that promotes the use of biological control.
From page 131...
... An environmental assessment or an environmental impact statement would probably be required for each mycoherbicide and perhaps for each strain. o At the international level, applicable guidelines and potential limita tions for testing, approval, and application of mycoherbicides against illicit crops fall under the International Plant Protection Convention, the International Standards for Phytosanitary Measures, the Biological Weapons Convention of 1972, and legal requirements in the country where the mycoherbicides would be used.


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