EPA Administrator Carol Browner announced last month that the Agency was banning one pesticide and restricting another, raising renewed concern in the pest control industry.
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“EPA bans 1 pesticide, has tests for others.”
“Pesticide crackdown announced.”
“EPA to limit use of toxic pesticides.”
“Citing children, EPA is limiting use of a pesticide.”
You’ve seen the headlines before. But this time, the headlines are hitting closer to home than you may think.
What prompted this most recent round of pesticide restrictions was an announcement made by the Environmental Protection Agency (EPA) on Aug. 2. On that date, EPA Administrator Carol Browner announced that EPA had completed its evaluation of the first one-third of chemicals to be reevaluated as part of the Food Quality Protection Act (FQPA) (see “What is FQPA?").
In the most recent action, EPA announced it was going to cancel all uses of methyl parathion and restrict certain uses of azinphos methyl. Both are organophosphates (OPs).
The two chemicals are used widely by the agricultural community on crops such as cotton, apples, pears, cherries and peaches. Although these specific chemicals are used by farmers, the announcement was important to the pest control community because both are organophosphates. OPs are the class of pesticides at greatest risk of regulatory action as a result of FQPA and are key chemicals in the pest control industry.
On Aug. 2, Browner announced the restrictions on the first two OPs. Although Browner’s remarks didn’t directly affect the pest control industry, a Congressional hearing the next day did.
On Aug. 3, the Committee on Agriculture, Subcommittee on Department Operations, Oversight, Nutrition and Forestry, held a hearing on the likely impact of FQPA on public health, including how it would affect the structural pest control industry.
The hearing was supposed to have focused on public health issues, but most of those who testified before the committee discussed the previous day’s announcement. Although Browner’s earlier remarks directly affect the agricultural industry, they indirectly affect the pest control industry as well.
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WHAT IS FQPA? Passed unanimously by Congress in 1996, the Food Quality Protection Act (FQPA) is an immensely complicated law. The law affects farmers, structural pest control operators, turf and ornamental professionals and other professional applicators of pesticides. FQPA uses new criteria to define an acceptable level of total pesticide exposure. This amount accounts for the combined exposure of pesticides in the environment, food and water, and is called a “risk cup.” New methods of calculating exposure and safety factors fill up the cup quickly. Exposures that cause the cup to overflow must be eliminated. In the past, acceptable exposure was the total amount of a single pesticide a person could be exposed to from a given source to every day for 70 years without experiencing health risks. Now, EPA is charged with establishing new residue tolerance levels for more than 9,700 pesticides. The deadline for reevaluating the first class of chemicals — carbamates and organophosphates — was last month. Standards set for reassessing these chemicals will be used to evaluate all subsequent pesticides. Future deadlines are 2002 and 2006. Because limited scientific data exists on pesticides’ aggregate and cumulative exposure levels, the EPA is relying on “default assumptions” to help define the risk cup. Industry insiders say these assumptions exaggerate risk with potentially dire results. Inflated indoor pesticide exposure levels, for instance, would result in a disproportionately large share of the risk cup. The pest control industry could lose products since manufacturers must cut risks and eliminating a structural pest control product makes more fiscal sense than reducing the use of that active ingredient in the lucrative agriculture market. Two bills are in the works now that would require Congress to force EPA to use “sound science” and accurate data when reevaluating chemicals under FQPA. THE PEST CONTROL INDUSTRY SPEAKS OUT. Representatives from a number of industries, trade associations and government agencies testified at the Congressional hearing on Aug. 3. Bob Rosenberg, director of government affairs for the National Pest Control Association (NPCA) and Allen James, executive director of Responsible Industry for a Sound Environment (RISE), testified on behalf of the pest control industry. Others who testified before the committee included Richard Rominger, deputy secretary, U.S. Department of Agriculture; Peter Robertson, acting deputy administrator, EPA; and Dr. Jerome Goddard, medical entomologist, Mississippi Department of Health and clinical assistant professor of preventative medicine, University of Mississippi Medical School. The committee (which is made up of 19 U.S. House of Representative members) listened to expert witnesses throughout the day as they entered their statements into the Congressional record and fielded questions from committee members. This subcommittee meeting marked the first time the structural pest control industry had been given an opportunity to speak out about FQPA at a Congressional hearing. Members of the committee say they appreciated the insights provided by pest control industry representatives and others testifying before the committee. During his testimony, NPCA’s Rosenberg spoke to the needs of the structural pest control industry regarding FQPA and made the following comments:
“PCOs won’t mind losing a product if the process is science-based and fair,” Rosenberg says. “But right now, EPA is using phony numbers and that’s wrong.” Dr. Jerome Goddard of the Mississippi Department of Health testified that valuable insecticides must not be sacrificed for political reasons. “We must have pesticides readily available for use. Not only do we need pesticides, we need a wide variety of them with various labeled uses,” he said. “Even the ‘older’ generation pesticides — such as organophosphates (OPs) — are needed. Pesticide resistance is developing to many of the newer synthetic pyrethroid compounds; keeping the OPs gives pest controllers, farmers and vector control personnel another option in managing/preventing insecticide resistance. “Furthermore, registrations for many pesticide uses are considered ‘minor’ by the EPA and chemical companies, and thus, not much attention is paid to them. In fact, many of these minor uses are being dropped totally. We need all legitimate pesticide registrations to remain in effect as part of our repertoire of weapons against insect pests,” Goddard said. George Wichterman, chairman of the Public Health Pesticide Working Group, American Mosquito Control Association and Senior Entomologist, Lee County (Fla.) Mosquito Control District, agreed with Goddard’s assessment of the OPs. He argued that if certain pesticides were taken away, public health would be compromised. “(We have) only five organophosphates to use with mosquitoes. Some mosquitoes are malathion resistant,” he explained. “If we do lose an organophosphate, we’re at a loss. There could be an epidemic caused by mosquitoes.” So what’s next for EPA? The Agency will announce additional OP decisions shortly. Most likely, three to five organophosphates will be reevaluated each month through the spring of 2000, with all remaining 39 OPs to be reevaluated by next spring, according to Rosenberg. Those to be reevaluated include chlorpyrifos, diazinon and DDVP, all widely used chemicals in the structural pest control industry. EPA will evaluate the remaining chemicals using the same process it used with the first two organophosphates, although they may not come to the same conclusions. EPA NEEDS TO USE SOUND SCIENCE. Every expert who testified to the subcommittee had one common sentiment: Congress should require EPA to use sound science when evaluating chemicals for FQPA. They all agreed that no one wants a chemical to be used that is harmful to humans, especially children. But when EPA rushes through an evaluation process just to reach a political deadline (which is what most at the meeting agreed they did), many more people are hurt. “When EPA rushes to judgment, more mistakes will be made,” James said. NPCA, among others who testified at the subcommittee hearing, believes that EPA is making decisions based on improper data. “It’s a case of a government agency making judgments without reliable data,” Rosenberg said. “Two things are going to happen: 1) there’s going to be loss of product or, 2) if you don’t lose a product, you’re going to have risk mitigation to the point of having to wear moon suits when you’re making applications and you’re not going to be able to use products as often or at levels at which they are effective.” EPA MISTAKES? As of Aug. 3, EPA had completed 3,290 tolerance reassessments, according to EPA records. “All of EPA’s tolerance reassessment decisions are based on current, sound science. EPA brings the latest scientific methods, data and policy to bear in a complete examination of each existing standard,” said James Aidala, associate assistant administrator, EPA’s office of prevention, pesticides and toxic substances. “Because tolerance determinations did not explicitly include a detailed assessment of residential exposures prior to enactment of FQPA, EPA’s databases and exposure assessment methodologies in this area are less robust than for dietary exposures,” he testified. “We have, however, been working for a number of years to improve our understanding of these issues, and the explicit FQPA mandate to consider aggregate exposures is resulting in rapid development of more sophisticated, refined approaches to residential exposure assessments by EPA, the pesticide industry and commercial users of residential pesticides.” NPCA and manufacturers are both gathering indoor residential exposure data, information that doesn’t exist now. Some of that data is several years away from being collected. In addition, many are worried that when push comes to shove, manufacturers will be forced to choose between individual pest control markets. “I don’t want chemical companies to choose between corn and turf,” James said. And if that happens (as industry representatives expect), the first products on the chopping block likely will be specialty chemical uses, because the market is so much smaller than the agricultural market. Quite simply, that means the potential loss of product for PCOs. The bottom line right now is that pest control products are at risk — products PCOs rely on daily for controlling their customers’ pest problems. But many of those conclusions may be reached with insufficient or incomplete data. “This is a case of public policy creating science ahead of its time,” Rosenberg said. “But even if all the I’s are dotted and the T’s crossed in the assessment of agricultural chemicals, EPA still doesn’t know how to evaluate non-agriculture chemicals.” And what that means for PCOs remains to be seen.
The author is associate editor of PCT magazine.
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