Registration Considerations for Chemical Bird Repellents in Fruit Crops

harvest is most often insufficient for desired residue decline before reaching the consumer. Since 1992, new chemical repellents have been actively sought to protect agricultural crops, but only one (a.i., methyl anthranilate) has been fully registered with the US EPA. Methyl anthranilate is a GRAS-listed (Generally Recognized As Safe) food additive which is commonly used as grape flavoring. It has been demonstrated to be repellent to birds when consumed (Clark et al. 1991) and currently has 8 active product registrations with the US EPA. In 2002, the US EPA exempted methyl anthranilate from the requirement of a residue tolerance (Federal Register: August 7, 2002 (Volume 67, Number 152)). It is registered for bird control on structures, airports, ornamental plantings, turf, fruit crops (berries, grapes, pomes, stonefruit), and grain crops (corn, barley, rice, sorghum, millet, wheat, oats, sunflower), and can be applied in baits, broadcast application or as a fog. Although methyl anthranilate is currently registered as an avian repellent for use in a variety of food crops, independent research has shown that bird damage did not differ between methyl anthranilate-treated versus untreated blueberries (Cummings et al. 1995, Avery et al. 1996). Additionally, it was not effective for repelling blackbirds from ripening rice and sunflower fields (Werner et al. 2005). This paper presents the data requirements and cost considerations for US EPA product registration of a chemical repellent for protecting fruit crops (e.g., cherries, blueberries) from bird damage. Four approaches to product registration for a food use are presented: 1) development of a new active ingredient; 2) registering an existing avian repellent for use in fruit; 3) registering an existing pesticide formulation as an avian repellent for use in fruit crops; and 4) registering a new formulation of an existing pesticide product as a avian repellant on fruit crops.