Open Forum:
In an attempt to promote free and open discussion of issues, The
Agrichemical and Environmental News encourages letters and articles
with differing views. To include an article, contact:
Catherine Daniels, Food and Environmental Quality Laboratory, Washington State University, Tri-Cities campus, 2710 University Drive, Richland, WA 99352-1671. Phone: 509-372-7495. Fax: 509-372-7491.
E-mail:
cdaniels@tricity.wsu.edu
In This Issue
The information is intended for growers, dealers and others who have an interest in on-line computer information. One may read (view), print, search and download the labels and MSDSs. DuPont will update the labels on a monthly basis so that the information will be as current as possible.
At present, only DuPont Ag Products labels and MSDSs are available.
Labels and MSDSs from Bayer (Miles), Rhone-Poulenc and others will become
available in the near future.
Pioneer is the world's largest seed company and maintains an extensive agricultural genetics and plant breeding program. Mycogen is a leader in plant transformation and Bacillus thuringiensis (Bt) gene technology for insect resistance in plants.
The collaboration will focus on transforming corn, soybeans, sunflowers,
canola, sorghum and other crops with Bt genes that cause the plants to
produce natural proteins that protect them against insect damage. Bt-based
insect resistance can reduce or eliminate the need for chemical insecticides.
Should you not receive your AENews, and you wish to continue your
subscription, please contact Eric Bechtel at phone: 509-372-7378, fax:
509-372-7460.
Information and answers to questions commonly asked about the EPA phaseout of methyl bromide are available from a methyl bromide World Wide Web home page and from an Ozone Protection Hotline.
The address for the World Wide Web page is: http://www.epa.gov/docs/ozone/mbr/mbrga.html#q2
Ozone Protection Hotline numbers are as follows:
toll-free: (800) 296-1996
direct dial: (202) 775-6677
fax number: (202) 775-6681
Bob Crawford, Florida's agricultural commissioner, had charged that benomyl (Benlate DF) was responsible for alleged widespread crop damage in the state. P. Michael Ruff, the Florida administrative law judge, ruled, however, that testimony from DuPont scientists was "more credible, persuasive and probative" than that offered by the state scientists; he ruled that the Florida Department of Agriculture's complaint against DuPont be dismissed. The ruling refutes the position of Crawford and others that Benlate was contaminated by sulfonylurea herbicides.
Central to Crawford's SU case was the testimony of Wendy King, the chief analytical chemist from the state's pesticide laboratory. Judge Ruff's ruling found King's testing and testimony to be unreliable, while finding more persuasive the testing by DuPont scientists and an outside laboratory, which found no SUs in Benlate.
Additionally, the administrative law judge ruled that there was no
contamination associated with DBUs, a product resulting from Benlate
breakdown.
Approval of H.R. 2099 by the Senate Appropriations Committee was noted in
the September 13 Congressional Record. Funding levels follow closely
recommendations by the National Academy of Public Administration.
No pesticide products within the scope of the regulation may be sold after Oct. 23, 1995, unless they are appropriately relabeled to be in compliance with the WPS. The relabeling statement must reference the WPS and certain practices to reduce or eliminate exposure to pesticides. EPA believes that most products were relabeled earlier to meet the April 21, 1994, deadline for making appropriate changes.
The pesticide regulation notice spells out in detail how to bring all
products into compliance. Information in the notice includes such items as
how to deal with products whose registrations have been canceled but which
can still be sold until a certain later date.
The general public can call the Communications Branch in the Office of
Pesticide Programs at 703-305-5017 for copies of the pesticide regulation
notice.
Research shows that, of the contamination that lands on a person's body during the mixing and loading process, 85% gets on the hands and 13% lands on the forearms. Most applicators know the importance of wearing gloves when mixing pesticides, but use inspections have found that many applicators are not protecting their forearms.
Applicators should dedicate a long-sleeved shirt to the sole purpose of
pesticide handling. This shirt should be included with an applicator's
other personal protective equipment and worn only for pesticide handling.
It should be washed separately from the family laundry. For products that
bear a "WARNING" or "DANGER" signal word, chemically resistant forearm
protectors are needed over long sleeves.
Return to Table of Contents
A. Children's dietary patterns differ from adults in both quantity and
types of foods consumed. In relation to body weight, children (particularly
preschoolers) eat more food than adults to meet their rapid demands for
growth. Also, children's consumption of certain types of foods can be
quite different from adults.
Both EPA and FDA evaluate dietary patterns as well as other differences
between children and adults before determining whether a substance should
be approved for use in or on food.
Q. Are children always more vulnerable than adults to the harmful effects
of substances?
A. Children differ from adults in terms of diet, metabolism, immunity,
exposure to substances in the environment and other factors. Current
scientific evidence indicates that such factors may influence whether
children are more, less or similarly sensitive as adults to adverse health
effects from certain substances. These factors may help explain, for
example, how young children can have a greater tolerance than adults to
acetaminophen, the most widely used over-the-counter drug for pain and fever
in the United States. The National Research Council report has examined this
question in greater detail and has determined its relevance in terms of
exposure to pesticide residues.
Q. Does EPA currently take children's risks into consideration before
approving specific pesticide uses?
A. To ensure that children are protected, EPA evaluates data from tests
on the most sensitive and relevant animal species. These findings are
combined with information on children's potential exposure to the substance
through diet. If special dietary analyses indicate that exposure to infants
or children is high enough that adverse effects may occur, then EPA will not
approve a tolerance.
Q. How does EPA estimate children's potential dietary exposure to pesticide
residues?
A. To estimate potential dietary exposure to pesticide residues, EPA uses
food consumption data gathered as part of the USDA's 1977-78 Nationwide Food
Consumption Survey. To help predict exposure estimates for children and
other potentially sensitive subgroups more accurately, EPA has also
developed a data base known as the Dietary Risk Evaluation System (DRES).
The DRES system provides information on food consumption for more than 300
food commodities for 22 different subpopulations. This system is expected
to be replaced by a more accurate system in the near future.
Q. Has EPA ever denied a tolerance because of specific dietary risks to
infants and children?
A. EPA carefully evaluates the health impact on various subpopulations for
each pesticide it approves. In the case of children, EPA has denied
tolerances because of specific dietary risks to children. For example,
in 1985 the agency denied a request for new uses of the pesticide fenvalerate
(Pydrin) on alfalfa and sorghum. EPA determined that the potential risks to
children from secondary residues in milk from cows eating such feed were
unacceptable, and the agency denied the request.
Q. What can parents do to ensure their children's food is safe to eat?
A. Regulatory officials and the food products industry are committed to
producing the safest food supply possible and are continually examining ways
to reduce pesticide risks to adults as well as children. But there are also
steps individuals can take to ensure the safety of their produce
selections: 1) select produce that is free of dirt, cuts, insect holes, mold
or decay; 2) wash produce in water and peel its skin or outer leaves; and
3) eat a variety of foods.
Q. Should parents limit their children's consumption of produce?
A. The American Academy of Pediatrics (AAP) states that, "despite the
theoretical risk of pesticide residues...a diet rich in fruits and vegetables
is the most healthful diet that children can consume." This year, AAP is
leading a national public education campaign to promote produce consumption
by children. The Surgeon General, American Dietetic Association, the
American Cancer Society and a wide array of other health and medical
authorities have all recommended that Americans increase their consumption
of fruits and vegetables.
It is difficult to imagine children eating too much produce. Produce is
a good source of dietary fiber and of many vitamins and minerals essential
for proper growth and development.
Q. Should parents buy organically grown produce to protect their children's
health?
A. Although there are no legal standards for the term "pesticide-free", it
suggests that no pesticide residues are present. There is no evidence,
however, that foods labeled "organically grown" are safer or more nutritious
than foods grown using conventional agricultural practices. Many organic
growers use pesticides, mostly those such as sulfur, nicotine and copper,
which are found in the environment. The relative risks and benefits of
applying naturally occurring pesticides versus synthetics have not been
determined. But, there is no evidence that foods labeled "pesticide-free"
are safer than foods grown conventionally.
Q. Are childhood cancers in any way linked to pesticide residues?
A. According to the American Cancer Society (ACS), there is absolutely no
evidence that any cancers in children are linked to diet. In 1991, ACS
revised its nutritional recommendations for all persons aged two years and
older. One of these recommendations calls for daily consumption of fruits
and vegetables and more consumption of fiber-rich foods, including fresh
produce.
The scientific consensus of the Surgeon General, the National Institutes of
Health, the American Medical Association, the American Cancer Society, the
American Academy of Pediatrics and numerous other health authorities is that
the health benefits of eating more produce far outweigh any possible
pesticide-related risks.
One frequently misunderstood analysis is the multiresidue screen, the
analysis of a sample for members of a class of compounds. Organophosphorus
(OP), organochlorine (OC) or carbamate insecticides as well as
nitrogen-containing or phenoxy herbicides are common candidates for screens.
When toxicity testing is performed with animal species, the feed and water
are screened to ensure against the presence of pesticide residues that would
interfere with or confound toxicity test results. In these cases, it would
be particularly important to insure that no pesticides similar to the one
being tested are present. When testing toxicity of an OP, for example, it
would be essential to ensure that there are no OPs in the feed or water. It
would be equally important to ensure that no carbamate insecticides are
present, as carbamates and OPs both impact the cholinesterase enzyme. The
same considerations are true of water used in aquatic toxicity tests.
Many market basket surveys and general tests performed on fruits and
vegetables use multiresidue screens. These ensure that pesticide residues
are within tolerances, and they can be used to estimate pesticide intake
levels in various segments of the population.
The specificity of a multiresidue screen depends on the instrumentation used,
which is in turn determined by the class of compounds examined. Gas
chromatography-mass spectrometry (GC-MS) can be used to look for compounds
from many classes. However, it is not a selective detector, and the analyst
usually must decide what compounds to include in the screen. As an example,
the analyst can choose to look only for DDT (an OC), parathion (an OP) and
atrazine (a nitrogen-containing herbicide).
One way to explain how screens work is to look at trees in a forest. In
this case, we have a forest but choose to look only for an elm, a fir and a
redwood tree, and they must be in a particular location (chromatographic
retention time). We go to a particular location and look for an elm. We
identify it as an elm by the way it looks (the mass spectrum). If it is
there, we measure how big it is (the concentration). Other pesticides may
be present in the sample extract but won't necessarily be identified (we may
have many elms in the forest, but if they aren't where we look, we don't see
them).
When a screen of this type is performed, the customer gets a list of the
pesticides included in the screen. If any of these pesticides are found,
their concentration in the sample is also given. For an added cost, the
customer may request additional pesticides in the screen, if the chemical
characteristics allow extraction and detection. If other pesticides are
present but not included in this list, they will not be looked for or
reported.
An example of a selective screen is one for OPs. All of these have a
phosphorus atom, and can, therefore, be selectively detected on a flame
photometric GC detector. This time, we are looking for evergreen trees,
and we wait until winter.
Trees with needles stand out, and we can see nearly all of them. We still
look at particular retention times for 5 - 10 common pesticides such as
malathion and chlorpyrifos. But other OPs respond as well, and an attempt
to identify these unknown compounds is made (we get out our field guide and
try to identify the unknown evergreens). These reports usually list the
individual compounds specifically looked for. In addition, a statement such
as "no additional peaks characteristic of OPs were detected at a level of
0.5 ppm" is added to the report.
Carbamate insecticides are also screening candidates. Unlike the OPs, these
insecticides cannot be detected by a GC-MS screen, because they are not
amenable to gas chromatography (you are in the wrong place - looking in the
forest for fish). Carbamates are detected with liquid chromatography after
chemical modification to form fluorescent derivatives. Detection is
selective, much like the OP screens. The phenoxy herbicides (2,4-D, MCPA and
others) must also undergo a chemical derivatization reaction before they can
be analyzed, but analysis in their case then proceeds by GC. Because of the
need for derivatization, these compounds would not be detected in a general
GC-MS screen unless the analyst specifically looked for them and performed
the necessary reaction (spray painting invisible trees).
There are several limitations to pesticide screens. Although many classes of
pesticides can be detected, there are large numbers of commonly used
pesticides that are not amenable to such a screen. Glyphosate, for example,
is only detected with a method specific for its analysis. Some members of a
class of compounds for which a screen exists are also not detected. Acephate
would not be detected in an OP screen, even though it is an organophosphorus
insecticide. Although a pesticide may be a member of the screened class,
its chemical characteristics (volatility, water solubility) may result in
poor extraction from the sample or poor chromatographic behavior. Both
problems exist for acephate.
It is most cost-effective to determine before sample submission exactly what
screens or individual analyses are most likely to provide needed answers. If
the problem is herbicide damage to plants, phenoxy or nitrogen-containing
herbicide screens may be appropriate, but neither screen will detect
glyphosate or the sulfonylureas. The plant symptoms should be used to
determine which analyses are most appropriate. If the problem is a wildlife
kill, herbicides are unlikely candidates, but OP and carbamate screens may
be appropriate.
Pesticide use records are helpful also. Pesticide screens are expensive and
are poor tools for problem solving, unless a great deal of thought goes into
their selection. They should be one of the final steps in a pesticide
incident investigation, with selection of screens and individual analyses
based on the nature of the problem and the damage found.
We chemists can be pretty good at finding the trees if we know where to look.
It is the customer's job to point us in the right direction.
The commission, created by the 1995 Washington state Legislature to obtain and maintain
pesticide registrations for critical pest control needs in Washington, has
12 voting members from different sectors of the agriculture, forestry and
pesticide industries. The departments of Agriculture, Labor and Industries,
Health and Ecology and Washington State University each contribute a
non-voting member.
The first commission meeting was organized as soon as members were appointed
in September by Governor Mike Lowry. Early appointment of commissioners,
requested by legislators, was intended to allow the commission time to
coordinate projects with the IR-4 Project in 1996. The commission will have
to provide a list of supported projects to IR-4 before mid-November.
A major portion of the meeting involved a presentation on the federal and
state pesticide registration processes and on the IR-4 process. A notebook
containing information on these processes was provided to each commissioner.
The remainder of the five-and-a-half-hour meeting was devoted primarily to
review of the commission's purpose and to organizational and educational
activities.
Richard Hutchinson, Senior Assistant Attorney General, was present to provide
legal counsel for commissioners. Hutchinson spoke about Open Meeting Law
compliance and organizational steps that the commission needs to take.
As part of its initial organization, the commission voted to make Alan
Schreiber of the WSU Food and Environmental Quality Laboratory temporary
chair until commissioners are ready to elect a permanent chair from among
the voting members. The commission voted to have WSU, specifically FEQL,
provide administrative support.
In a review of the legislation that established the commission, commissioners
were reminded of the following: 1) While each commissioner is nominated by
an organization representing a particular group of pesticide users,
a commissioner does not represent that group in commission business. Each
commissioner is to serve as a member at-large. 2) The commission represents
more than just minor crops. Any pest control problem in the agricultural,
forestry, aquacultural, structural or urban environments falls potentially
within the purview of the commission. 3) A minimum of 25% of commission
expenditures must be directed toward projects on crops that are not in the
top 20 commodities produced in the state, as calculated by the Washington
Agricultural Statistics Service. 4) The legislation states that the
commission is to work with grower organizations to encourage matching funds,
in-kind services and other types of support.
The WSU College of Agriculture and Home Economic's Agricultural Research
Center has established an account to which the commission's expenses will
be charged. The commission is to receive $1 million during the next two
years from WSU, the designated custodian of commission funds.
Larry Ganders, WSU Statewide Affairs Director, said that, while WSU is
mandated to provide the commission with the $1 million, the Legislature,
in what has been described as legislative oversight, failed to provide the
university with the necessary funding.
Ganders said WSU has received assurances from state legislative leadership
that the money will be provided to WSU in the 1996 legislative session. He
also said, if the Legislature does not provide the money, budget cuts will
be required to generate the money to support the commission. These cuts
will most likely come from WSU agriculture programs.
Commissioners were provided with a list of 15 projects to consider for
1996 IR-4 program funding. Of the 15 projects presented, two were
acted upon. The commission voted to provide up to $15,000 to fund laboratory
analytical costs necessary to pursue registration of glyphosate (Roundup)
on dry pea, chickpea and lentil. Progress toward registration, such as this
action, is a requirement for successful continuation of a Section 18
exemption for the use of Roundup on these crops in Washington and Idaho.
The commission effort was matched with $10,000 provided by the U.S. Dry Pea
and Lentil Association. The IR-4 Project will provide assistance by
developing study protocol and field data notebooks, conducting quality
assurance inspections and audits and developing and submitting the petition
for tolerance to EPA.
The commission voted to provide up to $10,000 to fund laboratory analytical
costs necessary to pursue registration of zinc phosphide on timothy. As in
the case of dry peas, progress toward registration, such as this action, is
a requirement for successful continuation of a Section 18 exemption for the
use of zinc phosphide on timothy in Washington. A condition of funding was
that the registrant provide matching funds. Tri-River Chemical agreed to
divide the cost of approximately $10,000 with the commission. The
Organization of Kittitas County Timothy Hay Growers and Suppliers also
provided $6,000 for this effort. As in the case of the dry pea/glyphosate
project, IR-4 is providing extensive assistance and support.
A group representing Washington lettuce growers appeared before the
commission to request its support in obtaining the use of captan.
Washington's annual production of lettuce is worth about $10 million, and
demand for Washington lettuce is expanding. However, production of lettuce
is limited by the presence of anthracnose, and the only known method of
control is captan, which is no longer registered. Although lettuce growers
are not represented by any organization and have no formal method for
collecting money, they expressed willingness to assess themselves
approximately three cents per box of lettuce, in order to generate as much
as $15,000 for matching funds. The estimated cost of field and laboratory
studies for registration of captan on head and leaf lettuce could be $24,000
to $36,000. The commission lacked sufficient time to act on the request.
The final action of the commission was to schedule its next two meetings.
The next meeting of the Commission on Pesticide Registration will be at
10 a.m. on October 30 in Room 230 West of the WSU Tri-Cities Campus in
Richland. The following meeting will be at 10 a.m. on December 1 in
Ellensburg. The specific location for the second meeting has not yet been
determined.
Governor Lowry listened to a plea from the agriculture industry to appoint
commissioners early, in order for the commission to have time to plan a 1996
field season. This was a clear example of responsiveness to a need. The
commissioners put aside whatever business in which they were engaged, to
attend the first meeting on very short notice. (Only two of the 12 voting
members were unable to attend.) The commissioners come from a diverse array
of agriculture, forestry and pesticide industry backgrounds. Both eastern
and western Washington are well represented. Four of the 12 voting members
are growers.
Enough work was completed at the first meeting for commissioners to approve
two projects considered vital to the production of two important Washington
crops. The commissioners are prepared to take action on over a dozen other
projects at its next meeting. In relatively short order, the Commission on
Pesticide Registration is taking the action necessary to address several of
Washington's worst pest control problems.
As someone intimately involved in this process, I am seeing the beginnings of
a very promising development. Unorganized commodity groups that have neither
collected money for research nor been involved in pesticide issues are
beginning to take action to address their critical crop protection needs.
Washington lettuce growers, hoping to obtain use of captan, plan to match any
commission funding with revenues generated through self assessment. The
Washington processed pea and pea seed industries are taking up a collection
to generate funding to match commission funding in support of a registration
for MCPA use on peas. Each pea processor and pea seed company is being
asked to kick in about $1,000 to generate $20,000 toward retaining the use
of MCPA on peas.
It is an exciting time to be involved in pest control in Washington state.
The Commission on Pesticide Registration is providing funding and leadership
in obtaining and maintaining pesticides. Washington State University has its
Food and Environmental Quality Lab available to help obtain pesticide
registrations and work on environmental problems associated with pesticide
use. WSDA has developed a minor crop registration assistance program.
After weathering a steady erosion in pest control tools, it looks like
Washington pesticide users can see the light at the end of the tunnel.
Aldicarb had been removed from use on potatoes, because some potatoes had
residues over tolerance due to applications made by gravity fed applicators.
The agency also had some concern about aldicarb making its way into
groundwater.
Review of the restrictions accompanying the new use can provide interesting
insight into EPA's approach to pesticide regulation.
Restrictions on aldicarb use
This is just one example of a trend in which pesticide registrations are
accompanied by restrictions. Another case of this is a recent
requirement that links registration of transgenic crops to development of a
resistance management plan.
In the case of aldicarb, a particularly noteworthy restriction is that the
product can be used only by applicators certified by the registrant. Also
noteworthy are the restrictions put in place due to the potential for
groundwater contamination.
It might be expected that restrictions such as these will be extended
eventually to other products that pose a threat to groundwater.
Although the EPA has final authority on pesticide registration and
determining appropriate tolerances, the FDA monitors the food supply and
enforces tolerances. The FDA has three types of monitoring programs:
Compliance/Surveillance, Incidence/Level, and Total Diet Study. The
Compliance/Surveillance program randomly collects commodities from farm
storage centers and wholesale retailers and then looks for violative
pesticide residues. Prior pesticide use history associated with production
of the commodity is not known. The Incidence/Level program targets analyses
at foods likely to contain specific pesticides deemed to be most prevalent
or of the greatest hazard in the diets of infants and children. The Total
Diet Study collects food representative of the typical U.S. diet from retail
stores in different geographical regions. The foods are prepared as a
consumer would prepare them for consumption and are then analyzed for
residues.
The FDA has published the results of its various monitoring programs in the
peer-reviewed scientific journal, Journal of the Association of Official
Analytical Chemists (JAOAC), for the last 20 years. In addition, results of
the FDA regulatory monitoring program are available by computer. Examination
of data published in the JAOAC can serve as a benchmark for the effectiveness
of the current regulatory system in protecting consumers from exposure to
hazardous levels of pesticide residues. The data also hold trends that could
blunt negative criticisms of FDA's performance.
The 1995 FDA report of regulatory monitoring claimed that more than 300
different pesticide active ingredients could be detected by the agency's
multiresidue analytical methods (See Analytical chemistry --
the forest and the trees. Thus, these methods detect the majority
of currently registered pesticides. Not every registered pesticide is
analyzed, however, particularly if a pesticide is used on comparatively few
acres. Spending money to analyze pesticides that have insignificant dietary
risk makes little sense.
The FDA analyzes an average 12,000 samples per year in its
Compliance/Surveillance monitoring program; in some years over 19,000
samples are analyzed. In addition to FDA monitoring, a consortium of states
contributes monitoring results from nearly 15,000 samples in a database
called FOODCONTAM.
Since 1987, the FDA has reported Surveillance/Compliance data in a manner
allowing an analysis of the proportion of samples in which either no
pesticide residues were detected, pesticide residues were detected at levels
below the tolerance, and residues were detected at levels above the tolerance
(i.e., violative). These data for 1987-1994 are shown in Figure 1 as the
percentage of samples in each category. Strikingly apparent is the near
constancy of the proportion of samples in all food categories that have
either no pesticide residues or residues within legal limits. The
FOODCONTAM data show similar percentages in each of the three categories,
further validating the FDA data as an accurate representation of residues
in the food supply.
Questions and answers
about pesticides and children's health
Note: Information for this article was taken from an article prepared
by the International Food Information Center
Q. In general, are children different from adults in terms of dietary risk?
Return to Table of Contents
Analytical chemistry -- the forest and the trees
Now that the Food and Environmental Quality Laboratory is up and operating, it seems appropriate to return
to a discussion of some of the occasionally obscure aspects of analytical
chemistry.
Return to Table of Contents
Available Reports
Return to Table of Contents
Commission holds first meeting
The Washington State Commission on Pesticide Registration met for the first time October 4 at
the Washington State University Tri-Cities campus.
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Editorial
...Alan Schreiber
The Commission on Pesticide Registration
I have been quite involved in the development of the Washington Commission
on Pesticide Registration. I also expect to receive commission support to
conduct research and other activities related to pesticide availability, so
I could be perceived as having a vested interest in the commission. Having
made these admissions, I wish to provide my opinion on commission activities
that have occurred thus far.
Return to Table of Contents
Aldicarb (Temik) use
EPA has given Rhone-Poulenc the green light to allow use of aldicarb
(TemikO) on potatoes. The EPA approval, however, comes with numerous
restrictions that will greatly limit the use of the compound on potatoes.
reintroduced on potatoes
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Adequacy of current regulations
The adequacy and effectiveness of current regulatory policies and programs
for protecting consumers against hazards of pesticide residues in food have
been criticized in two National Academy of Science (NAS) reports and in
highly publicized reports from advocacy organizations. While
the latter reports essentially declared the food supply unsafe for children
and predicted excessive cancer risks, the NAS reports stated that our current
food supply is safe, although regulations needed fine-tuning. The
numbers of samples monitored by the Food and Drug Administration (FDA) have
been criticized as inadequate, and the choice of samples has been thought
not to accurately represent the foods children predominantly eat. One
advocacy organization has also pointed out that not all
registered compounds were analyzed.
in protecting the food supply
 | Figure 1. Percentage of
foods analyzed contaminated with pesticide residues under the Compliance/
Surveillance regulatory monitoring program. Data are shown for domestic samples only. |
The significance of the similarity in results from the 1987-1994 regulatory monitoring program is that increased numbers of samples analyzed will not necessarily improve accuracy in residue incidence or levels detected, because the database represents repeated random sampling from a known population over many years. Analysis of the precision of results shows little annual variation, despite the large number of samples collected from wide ranging geographical locations.
The consistently low percentage of violative residues suggests also that the current regulations are working effectively with respect to pesticide users' practices. Because tolerances are set after consideration of application practices that produce high residues, the data indicate that, for the most part, pesticide users are following label instructions with respect to application rates and practices. The FDA has attributed many of the violations to pesticide residues for which no tolerance has been established.
Strictly speaking, tolerances on any one commodity are not safety standards. They are set in part to account for agricultural practices that produce high residue levels. But consideration is also given to the sum of all proposed tolerances. This calculation, called the theoretical maximum residue contribution (TMRC), must be below the acceptable daily intake (ADI). A residue level that subsequently exceeds an established tolerance is not hazardous, because of the 100 to 1,000 fold safety factor that is used to calculate the acceptable daily intake (ADI). Thus, the combined tolerances for any one pesticide viewed in the light of all commodities for which it is registered can arguably be considered a surrogate safety standard. For example, if a manufacturer wanted to establish a new food use for a pesticide, the proposed tolerance could not exceed the TMRC for all other food uses. In this sense, the tolerance setting process ensures that the ADI will not be exceeded and that safety will be maximized.
In response to criticism of the FDA's apparent lack of monitoring residues
in foods eaten commonly by infants and children, an examination of the
published scientific literature shows that FDA has established a record of
monitoring residues in food consumed by infants and children. The data
overwhelmingly show that infants and children, like adults, are infrequently
exposed to pesticide residues. When they are exposed, the levels are far
below the ADI (data for teens and adults are shown in Figure 2). The
residue levels in foods consumed by all population subgroups are so far
below the ADI, that even if an extra 10-fold safety factor were placed on
the no-observable-effect level (NOEL) to consistently build a 1,000-fold
safety margin into the ADI, the residues would still be 10 to 100 times
lower than the ADI.
 | Figure 2. Daily dietary intake of the pesticides malathion and captan by teens and adults between the years 1976 and 1990. Malathion is the most commonly found residue in the Total Diet Study. Captan is a commonly found residue deemed oncogenic by the EPA. Note that dietary intake has remained essentially stable for both pesticides (i.e., no trend apparent); the tolerance levels for each pesticide are shown by dashed lines. |
In conclusion, an historical examination of FDA's data for pesticide residues
in food validates the safety of the food supply. The low proportion of
samples with illegal residues suggests that pesticide users are complying
diligently with labeling instructions. Consumers are undeniably exposed to
pesticide residues in food, but the levels are up to 1,000 times less than
the acceptable daily intakes, which are already 100 to 1,000 times less than
the doses at which adverse effects are observed in test animals.
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WSDA investigates complaints thought to be related to label violations, while
WDOH investigates complaints thought to be related to human exposure.
The WSDA received 174 complaints related to drift in 1993. These included
128 cases in eastern Washington and 46 in western Washington. Ninety-three
cases involved herbicides; 61 involved insecticides; 11 involved fungicides;
no pesticides were involved in seven complaints; and six complaints were
labeled as unknown.
The most implicated causes were 2,4-D (50), unknown (21), azinphos-methyl
(Guthion) (11), glyphosate (Roundup) (11), none (8), chlorpyrifos
(Lorsban, Dursban) (8) and diazinon (5). Sites of drift most commonly
implicated were residential (36), wheat (33), Horse Heaven Hills area (25),
orchards (30), unknown (27) and miscellaneous agriculture (20). WSDA action
has been taken or is pending in 52 cases. Actions taken by WSDA were no
action indicated (122), advisory letter (3), warning letter (20), violation
(11) and pending actions (17). Counties with the most complaints were Benton
(37), Yakima (26), King (17), Grant (11) and Walla Walla (10).
When actions are contested, WSDA has a 98% success rate before an
administrative law judge. WSDA fines associated with pesticide violations
total about $45,000 to $60,000 annually.
From 1992 through 1994, WDOH received 168 drift complaints. Of these, WDOH
determined that 37 cases, or 22%, were definitely or probably related to
pesticide exposure. The 37 cases were grouped as ground applications (22),
aerial applications (10) and indoor applications (5).
Eleven of the 22 ground application drift complaints involved farm workers;
the other eleven were simply classified as non-farm workers. Examples of
farm workers thought to be definitely or probably drifted upon included;
some farm workers pruning an orchard, a nursery worker exposed to an
application, and a water truck driver who was exposed to pesticide blown back
into the face by wind during an application.
Examples of non-farm workers thought to be exposed to pesticide drift
included a situation where a pest control operator 's (PCO) application
drifted on a neighbor, builders were exposed to an adjacent field
application, a PCO application drifted into an open window, a septic tank
pumper was exposed to adjacent field application, and a maintenance worker
was exposed to a co-worker's application.
Seven of 10 aerial application cases involved farm workers. Examples of farm
worker exposure included nursery workers exposed to aerial application and
workers exposed to application made to an adjacent field. Non-farm worker
exposure examples included students on an athletic field who were exposed to
a neighboring application, a motorist exposed to an aerial application, and a
couple exposed to an application made on an adjacent field.
Examples of individuals exposed to indoor drift included food preparation
workers exposed to an automatic insecticide dispenser, a custodian exposed
to an indoor fogger, a nurse who inhaled an application for fleas by a
maintenance worker, and an office worker who was exposed to a co-worker's
application to a plant.
The consensus of PIRT Panel members is that there is no particular trend or
situation apparent from a review of drift cases. Most human exposures caused
mild to no health effects, and most health effects were addressed by washing
or topical treatments. In some situations, it appears that preexisting
chronic health conditions can be exacerbated by pesticide drift.
The profile of the food industry and land-grant universities and colleges
shows that more women and ethnic minorities are enrolling in food and
agricultural higher education.
Women now make up 38 percent of the undergraduate enrollments, while
minorities account for 11 percent. In 1982 women accounted for only 32
percent of students, while minorities accounted for only 3.8 percent.
The agriculture board's report also indicates the United States spends
$3.2 billion a year on agricultural research and extension. About $2 billion
of this is for research, the rest is for extension work.
Between 1987 and 1992, research funding grew by 8 percent. Most of the
money is funneled through the land-grant schools. While research funding
has not taken any big jumps, the totals have remained steady in recent years.
The colleges are no longer relying mainly on the U.S. Department of
Agriculture for funding.
...Information for this article was taken from The Packer
Pesticide drift
The Washington State Pesticide Incident Tracking and Reporting Panel, which
has been gathering information on pesticide drift cases, heard reports on
pesticide drift complaint investigations at its September meeting from
Washington State Department of Agriculture and Washington Department of
Health representatives.
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Institutions thrive, farms decline
College enrollments in food and agriculture number more than 100,000
undergraduate and graduate students, according to a new profile by the
National Academy of Sciences' Board on Agriculture.
Key Universities
The main universities in terms of fruit and vegetable research are:
Source:National Academy of Sciences
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**There is an interesting debate developing on genetically altered plants. Can transgenic plants be considered organic? Currently, genetically engineered produce is not allowed in organic standards. These standards prohibit use of enzymes produced by recombinant DNA techniques. This is quite an interesting issue, because in many cases the interests of genetic engineers and organic growers overlap; each wants to produce food with minimal reliance on pesticides. **My prediction for the next big pesticide issue in Washington is groundwater contamination. The US Geological Survey is about to release a report on pesticides occurring in the groundwater of the Columbia Basin. A number of pesticides were commonly found in samples in the Basin. **In the regulated community, there is quite a crowd cheering for EPA budget cuts. This crowd believes that the agency is receiving its comeuppance after years of overregulation. In reality, the budget reductions will mean slower response on emergency exemptions and registration of much- needed pesticides. **The reregistration of pesticides is not expected to be completed until the year 2004. **Just a few years ago, Washington State University employed five weed scientists. One position was cut, and two others are currently vacant while the university decides what to do. The two positions represent all WSU teaching of weed science and much of the university's extension and research program.
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2. Containers must be clean and dry inside and out, with no apparent odor.
3. Hard plastic lids and slip-on lids must be removed.
4. Glue-on labels may remain.
5. The majority of the foil seal must be removed from the spout. A small amount of foil on container rim is acceptable.
6. Half pint, pint, quart, one and two and one half gallon containers will be accepted whole.
7. Special arrangements MUST be made for 30 and 55 gallon containers, by calling (509) 457-3850 prior to collection.
WPPCA Plastic Pesticide Container Recycling Program
November 1995
Collection Sites
| Date/Time | Location | Sponsor and Contact |
| 11/2 | Yakima | Yakima County Mark Nedrow, Phone: 509-575-4076 |
| 11/7 8-12 | Mattawa Windflow Fertilizer |
Windflow Fertilizer Maurice Worgum, Phone: 509-932-4685 |
| A=adjuvant | D=desiccant | D/H=desiccant, herbicide | |
| F=fungicide | FA=feed additive | G=growth regulator | H=herbicide |
| I-insecticide | N=nematicide | P=pheromone | V=vertebrate repellent |
| Chemical* | Petitioner | Tolerance (ppm) |
Commodity (raw) |
| (F) Cinnamaldehyde | IR-4 | Exempt | all raw agricultural commodities |
| (F) Gliocladium virens GL-21 | WR Grace & Co. | Exempt | terrestrial food crops grown outdoors |
| (H) Pendimethalin | American Cyanamid | 0.1 | peas (except field peas) |
| (I) Bacillus thuringiensis CryIA (c) delta- endotoxin & genetic material necessary for its production | Monsanto | Exempt | when used as a plant pesticide in cotton |
| (I) CryIA & CryIC & derived delta- endotoxins of Bacillus thuringiensis encapsulated in killed Pseudomonas fluorescens | Mycogen | Exempt | in or on all raw agricultural commodities |
| Chemical Name | Case No. | Chemical Review Mgr. | Phone | |
| Chloro-m-xylenol | 3045 | Yvonne Brown | 703-308-8073 | Brown.yvonne@epamail.epa.gov |
| Dowicil CTAC | 3069 | Ron Kendall | 703-308-8068 | Kendall.ron@epamail.epa.gov |
| Fosamine Ammonium | 2355 | Kathy Davis | 703-308-8156 | Davis.kathy@epamail.epa.gov |
| Piperalin | 3114 | Barbara Briscoe | 703-308-8177 | Briscoe.barbara@epamail.epa.gov |
| Polybutene | 4076 | Mark Wilhite | 703-308-8586 | Wilhite.mark@epamail.epa.gov |
| Terbuthylazine | 2645 | Virginia Dietrich | 703-308-8157 | Dietrich.virginia@epamail.epa.gov |
| (z)-9-Tricosene | 4112 | Tom Myers | 703-308-8074 | Myers.tom@epamail.epa.gov |
Note: The source for this reregistration information, the Reregistration
Notification Network, is a cooperative effort of USDA-NAPIAP, Interregional
Project No. 4 (IR-4), U.S. Environmental Protection Agency (USEPA), and the
American Crop Protection Association (ACPA).
For additional information on any reregistration notification, contact the
individual(s) listed or contact:
Alan Schreiber
WSU Pesticide Coordinator
100 Sprout Road
Richland, WA 99352-1643
phone: 509-372-7462
fax: 509-372-7460
Contributors to the Agrichemical and Environmental News:
Alan Schreiber, Allan Felsot, Catherine Daniels, Mark Antone, Carol Weisskopf, Eric Bechtel
If you would like to include a piece in a future issue of the Agrichemical
and Environmental News or subscribe to the newsletter, please contact Catherine Daniels, Food and Environmental Quality Laboratory, Washington State University, Tri-Cities campus, 2710 University Drive, Richland, WA 99352-1671. Phone: 509-372-7495. Fax: 509-372-7491.
E-mail:
cdaniels@tricity.wsu.edu
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