Jake Mackenzie, Office of Pesticide Programs
Jake Mackenzie is western coordinator in the Field and External Affairs Division of the Environmental Protection Agency's Office of Pesticide Management. This article reflects his personal views; it has not been reviewed by EPA.
What a long strange trip it's been! This January, I began a round of travel that's still in progress but is worth reporting on as an indicator of how life was in "FQPA-land" during the first quarter of 1998. These perambulations took me from Seattle to El Centro, from Yuma to Yosemite and from my home base of Sonoma County to Sacramento. The year 1998 started out up at the Western Washington Horticultural Convention, where I was on the program to talk about minor crops and new pesticide registrations as impacted by FQPA implementation. In an earlier issue of the Agrichemical and Environmental News, the debate had been joined much earlier by Alan Schreiber with his August 1996 article, "The Food Quality Protection Act: A Trojan iceberg" and in his succeeding October 1997 article, "The Coming Storm-FQPA." In reality, passage of FQPA and its amendment of both the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) and Federal Food, Drug and Cosmetic Act (FFDCA) brought about a "paradigm shift in the regulation of pesticides used on crops." All of a sudden, on August 3, 1996, there was a new legal standard, new risk evaluations, new procedures potentially involving ALL the parties at interest and, above all, a reassessment of ALL tolerances over a 10-year period. This was to start immediately and be superimposed over the then-imminent "reinvention" of the 800-strong Office of Pesticide Programs (OPP).
By January of 1998, the tip of the political iceberg with the potential to sink the Good Ship FQPA became visible, with the appearance of a newsletter from the Alliance for Reasonable Regulation of Insecticides (ARRI). In this newsletter dated January 16, 1998, there was clear evidence of great pressures that had been exerted in the fall of 1997 on the House Agriculture Committee and which had just started to be exerted on the House Commerce Committee. On that same day, a letter from the House Committee on Agriculture was sent to EPA expressing concerns about the use of default assumptions that would result in "numerous cancellations of tolerances beginning as early as 1998." So, as I was on the road in January discussing FQPA, gathering of use and residue information, and expecting that these data would help bring decisions on the first phase of tolerance reassessments, it was disconcerting to hear of the concerns with our implementation of FQPA.
When later that same month I had the opportunity to travel in the winter leafy vegetable production areas of Yuma, Arizona and the Imperial Valley, California, it was clear that concerns about the future of many pest management tools were on producers' minds. What stuck with me from that trip was the interest in development of reliable field data with regards to current practices. The need to figure out a clear mechanism to accomplish the transfer of this information from the field to the EPA decision-maker's desk has intrigued me since my days working in the field in the agrochemical business 30 years ago. It was clear that, at the experiment station level, research workers such as John Palumbo with the University of Arizona were gathering data useful not only to the growers in the Yuma area but also critical to a full evaluation of the impact of the potential loss of a standard compound such as methomyl in leafy vegetable production. The components of a pest management system based on imidacloprid can still include an older material as an essential part of delaying the onset of resistance to the newer material. It was also encouraging to find potential field residue data sources available through food processing companies such as Dole Fresh Vegetable.
The Imperial Valley segment of our tour highlighted lack of registration of newer herbicidal materials on minor crops, while the Nickerson operation out of Welton, Arizona gave an eye-opening look into the world of "boutique" leafy vegetable production with markets as widespread as Federal Express's ability to deliver by air. Again, the availability of components of a pest management system was on growers' minds. On my part, I was able to bring folks up to speed on creation of the Minor Use Team within OPP and with implementation of the National Pesticide Residue Data Base, designed by an Inter-Agency (federal and state) work group to provide risk assessors with available and reliable pesticide residue data.
Travels to Sacramento in January and to Phoenix in March, at the invitation of what has become the Western States FQPA Coalition, provided an interesting opportunity to hear first hand from Leonard Gianessi of the National Center for Food and Agricultural Policy. His description of the quality of use and use systems data being gathered by his organization under contract with EPA was also a plea for help in painting a more complete picture of how organophosphate insecticides fit into the modern day pest management scheme of things. At the same time, this nascent coalition was set to start work on the Pesticide Use Report (PUR) data available through California's 100% PUR program and correlations with both residue and pest management systems. Clearly, a coalition of powerful interest groups such as western growers and associations such as the Western Crop Protection Association can focus both attention and resources on the data problem. That clearly is their intent and one which the new coalition is pursuing actively.
March meetings in El Centro and Fresno with members of the California Agricultural Production Consultants Association (CAPCA) and others interested in continuing education credits under California's licensing regulations brought me into contact with yet another segment of the community impacted by FQPA. Here, the potential for impact on complex crop production systems is great. It was interesting to contrast the level of knowledge of FQPA in those areas with that of the Sonoma Valley Vintners Association across the hills from me here in Rohnert Park, California or that of the CAPCA North Bay chapter members in Santa Rosa at a very recent presentation. There, where the pesticide problems revolve around forestry weed control, park maintenance, and low-impact pest management in the vineyards of Sonoma County, there is less furor over the potential loss of certain OP or carbamate tolerances.
While the Good Ship FQPA has avoided hitting an iceberg, the next few months will clearly be a critical time of passage as the public process, laid out by Assistant Administrator Dr. Lynn Goldman in her March 11 response to the House Committee on Agriculture, continues. That process means that, " We will work with growers, the United States Department of Agriculture, the registrants and the research community to ease this transition." On April 8, a memorandum from Vice President Al Gore to Secretary Daniel Glickman and Administrator Carol Browner set the national direction for our implementation of FQPA over the months and years to come: EPA and USDA are to work together "to ensure that implementation of the law comports with [these] four principles: sound science in protecting public health, transparency, reasonable transition for agriculture and consultation with the public and other agencies." The stage is set for this passage. I'm looking forward to working with the rest of the crew to make it a successful voyage.
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