Feasibility of Using Mycoherbicides for Controlling Illicit Drug Crops

Board on Agriculture and Natural Resources Board on Environmental Studies and Toxicology Division on Earth and Life Studies National Research Council

Committee Roster
Raghavan Charudattan (Chair), University of Florida, Gainesville Joan W. Bennett, Rutgers University Jerome Cura, The Woods Hole Group William E. Fry, Cornell University Guy Knudsen, University of Idaho John F. Leslie, Kansas State University Nu-May Ruby Reed, California Environmental Protection Agency Judith C. Rhodes, University of Cincinnati John W. Taylor, University of California, Berkeley David O. TeBeest, University of Arkansas Ariena H.C. van Bruggen, University of Florida, Gainesville Maurizio Vurro, National Research Council (Italy) Alan K. Watson, McGill University Charles P. Woloshuk, Purdue University

Statement of Task
Assess the following issues associated with the potential use of naturally-occurring strains of mycoherbicides in controlling illicit drug crops: Effectiveness Feasibility of large-scale manufacture and delivery Persistence in the environment Effects on nontarget plants and organisms Potential for mutation and resulting effects on target and nontarget organisms Research and development needs Sponsor: Office of National Drug Control Policy

Approach
Met with representative from Office of National Drug Control Policy, State Department, Environmental Protection Agency, and Department of Agriculture Reviewed publicly available information, consulted with ONDCP , State Department, and the United Nations for relevant reports Reviewed research and development performed for commercial mycoherbicides

Fungal Species
Fusarium oxysporum f.sp. cannabis Fusarium oxysporum f.sp. erythroxyli - soilborne and root-infecting pathogens; cause vascular wilts Crivellia papaveracea and Brachycladium papaveris - cause blight on aerial parts of the plant All found naturally where cannabis, coca, and opium poppy are grown; cause periodic disease epidemics

Database Limitations
Small set of data
Cannabis mycoherbicide - 2 reports (conference proceedings, short journal communication) Coca mycoherbicide 3 journal publications Opium poppy mycoherbicide 3 reports (conference proceedings, journal article, and UN report)

Experiments in greenhouse, growth chambers, or small field plots; conditions were controlled to favor infection and spread Difficult to draw conclusions or make predictions about the performance in larger field settings and under natural conditions

Effectiveness
Findings Proposed mycoherbicides shown to cause disease in target crop Disease severity inconsistent for all three proposed mycoherbicides
Cannabis mycoherbicide: one study caused plant death, one study low to moderate disease severity Coca mycoherbicide: 35 - 94% mortality; background disease high Opium poppy mycoherbicide: 6 - 100% leaf necrosis

Effectiveness
Findings Efficacy depended on biotic (age of plant, strain of fungus) and abiotic (moisture, temperature, UV radiation) factors Some cultivars of the target crop appeared to be resistant Specificity of all three fungal pathogens unproven

Inoculum Production and Delivery

Findings Technology available for large-scale production of mycoherbicides; adapt from pharmaceutical, food, or biotechnology uses Cannabis and coca mycoherbicides dry formulations to facilitate application to the soil on or near plant roots
Roughly 10s to 100s of kilograms per hectare of dry formulation might be required for a single application

Opium poppy mycoherbicides liquid formulations to facilitate application to the foliage

Roughly 100s to 1,000s of liters of liquid spray per hectare might be required for a single application

Inoculum Production and Delivery

Findings Ideally, ground application of the formulations for precision; but in hostile environment unfeasible Aerial application most feasible method
Applications will likely be performed from higher altitudes Uneven dispersal of dry and liquid formulations, reducing plantpathogen interface For liquid formulations, the amount of water required for application could be prohibitive (thousands of liters per application)

Persistence
Findings Few studies of long-term survival; restricted to a few strains
Cannabis no relevant studies Coca mycoherbicide 7 months Opium poppy two growing seasons

Strains indigenous to where the illicit drug plants are grown have been linked to periodic disease epidemics, which suggests that the fungal strains can survive for a long time in the presence of their host plants. Survival depends on environmental conditions, especially moisture

Persistence
Findings Limited range of environmental conditions tested; no conclusions could be drawn whether the mycoherbicides have geographic or climatic boundaries Mycoherbicide strains would probably persist at some level once introduced; not clear if levels required to achieve substantial control of the target crop would be maintained Potential for transport off the application site by wind, rain, insect or animal carriers, or infected seeds, soil, or plant material

Effects on Nontarget Plants and Organisms

Findings Would pose a risk to licit crops of cannabis, coca, and poppy or native plants if inadvertently exposed Insufficient data on whether proposed mycoherbicides would pose a risk to other plants or crops
Host-range studies poorly planned and documented

No data on effects of the proposed mycoherbicide strains on soil microorganisms, animals, or humans

Effects on Nontarget Plants and Organisms

Findings Some related fungi known to adversely affect nontarget organisms, but no data to suggest that the proposed mycoherbicide strains would produce similar effects. The ability of introduced mycoherbicides to survive, propagate, and disperse depends on environmental factors that can be neither predicted nor controlled. To the extent that they directly or indirectly affect nontarget plants, microbes, and fauna, they will impact the biodiversity and ecology of the target regions.

Mutation
Findings No data on the mutation of the proposed fungi are available Fusarium are known for spontaneous mutations, and there is circumstantial evidence for gene transfer under field conditions between strains that belong to different species
No data documenting such events in the proposed mycoherbicides

It is not possible to predict what types of mutations might occur, how a pathogen or target plant might be affected, or whether the mutations would be favored by natural selection

Research and Development

Findings A concerted research program is needed to prove efficacy and specificity
Several candidate strains would have to be tested to identify strains that are most efficacious under a broad array of environmental conditions Basic research would help guide formulation development, selection of a delivery method, and the required scale-up

Multiple regulatory requirements must be met before mycoherbicides could be applied

EPA testing requirements, state requirements International agreements

Overarching Findings
The available studies on the proposed mycoherbicides are preliminary, exploratory, and insufficient to determine their suitability for controlling illicit-drug crops. Conducting research is not a guarantee that a feasible mycoherbicide product will result. Mycoherbicides will face additional difficulties in that the people cultivating the crops will work to prevent the mycoherbicides from having their intended effects.

Potential Impediments
International Approval and Cooperation
Some tests must be performed in the countries where the mycoherbicides might be used Approval and cooperation of other countries have been difficult, or impossible, to obtain in the past Country-specific requirements must also be satisfied

Difficulties in Implementation
Growers will actively try to counteract ground application, so less effective methods will be required (aerial application from high altitudes)

Potential Impediments
Difficulty in Assessment of Effectiveness
Proposed mycoherbicides unlikely to kill large numbers of target plants quickly Little or nonexistent on-the-ground assessment would make it difficult to determine the effectiveness of the application

Development of Countermeasures
Use of fungicides or soil fumigants Cultivation of resistant plant varieties

Unavoidable Risks
Risks to legal crops and native plants
Cannabis, coca, and poppy are grown in several countries for licit uses Part of the native flora in some regions

Risks to nontarget organisms

Mycoherbicide strains could have direct and indirect effects on other plants, microbes, animals, or the environment Difficult to predict how they might behave when released in substantial numbers into an ecosystem

A time scale for mycoherbicide development Typical roadmap of mycoherbicide development

Optional: Academic research Field testing & validation Strain acquisition, Large-scale field trials of testing, proof of efficacy & consistency of mycoherbicide performance and feasibility potential in greenhouse under agricultural and small-scale field production conditions - ~ 2 trials, and host range years determination - ~ 3 years The proposed mycoherbicides are still at this stage Industrial R & D and EPA registration Industrial-scale production, product development, confirmation of efficacy & economic/technical feasibility, data for EPA registration, and registration - ~ up to 5 years