A monthly report on pesticides and related environmental issues
Issue No. 130, December 1996

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: Alan Schreiber, Food and Environmental Quality Laboratory, 100 Sprout Road, Richland, WA 99352-1643, ph: 509-372-7324, fax: 509-372-7460,
E-mail: ebechtel@beta.tricity.wsu.edu or aschreib@beta.tricity.wsu.edu

In This Issue

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News and Notes

Note: The AENews is now accessible from the World Wide Web via the Pesticide Information Center On-Line page. The address for the page is: http://picol.cahe.wsu.edu
Enter this address carefully, paying close attention to punctuation and spacing (no spaces between parts of the address). Some readers may experience difficulties accessing the site. These are believed to be related to the Internet and to on-line services, not the web site. If you are having a problem accessing the web page, please inform Eric Bechtel (ph: 509-372-7378, fax: 509-372-7460, E-mail: ebechtel@beta.tricity.wsu.edu

WSCPR plans January meeting

The 10th meeting of the Washington State Commission on Pesticide Registration is scheduled for January 13 in Spokane at the Cooperative Extension Office at 222 North Havana. The WSCPR recently released its formal request for proposals. Proposals were due by December 20 for consideration at the January 13 meeting. Proposals are due by February 14 for consideration at the early March meeting of the Commission. A copy of the request for proposals is included in this newsletter.

Late blight costly to manage

Washington State University research and extension specialists recently completed a study on the costs of managing late blight in Washington state potatoes in 1995.

The number of fungicide applications made in 1995 to early and mid-season potatoes ranged from 5.1 to 6.3. In Washington's Columbia Basin, the number of applications on late-season potatoes ranged from 8.2 in the north to 12.3 in the south. The cost of applications and fungicides for early to mid-season potatoes ranged from $106.77 to $110.08 per acre. For late season potatoes, these costs ranged from $149.30 to $226.75. The total cost of managing late blight in potatoes in the Columbia Basin of Washington in 1995 was nearly $30 million.

For comparative purposes, the mean numbers of fungicide applications in 1994 (before late blight was a serious problem) were 2.0 and 2.5 for early to mid-season and late season potatoes, respectively. The costs of control were $26 per acre and $47.53 per acre for early to mid-season and late-season potatoes, respectively.

WSDA seeking Section 18 requests

Any commodity group planning to submit a Section 18 request should be preparing its request. The Washington State Department of Agriculture (WSDA) has asked that requests be submitted 120 days ahead of anticipated use. See FQPA Part IV -- New rules for Section 18s for more information.

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FQPA -- Part I

The Food Quality Protection Act (FQPA) President Clinton signed into law August 3, 1996, may be the most significant legislation to affect agriculture in the last decade. The intent of the legislation was to ensure that the Environmental Protection Agency bases pesticide registration decisions on sound scientific principles, while particularly emphasizing protection of infants and children.

Before FQPA passage, the EPA made registration decisions on a risk/benefit basis. Now, the Act specifically directs the EPA to make decisions on a risk only basis. The Act removes benefit analysis from the decision-making process in virtually every case.

EPA established the Food Safety Advisory Committee (FSAC) to aid development of policy guidelines for FQPA implementation. The Committee consists of representatives from environmental/public interest groups, the public health community, the chemical industry, agriculture/user groups, food processors, state regulators, and the general public.

The Committee met September 26, October 22 and 23, and November 14 and 15. To provide more specific guidance, the Committee is divided into work groups. These include Risk Issues, Minor Uses, Communications, Reduced Risk, IPM and Pollution Prevention, and Consideration of Pesticide Benefits.

Gowan Company representatives serve on the Risk Issues and Minor Uses work groups. According to Gowan representatives who participated in FSAC meetings and work group teleconferences, the Committee appears to have targeted many older pesticide products to be reviewed first.

At the October 22 and 23 meetings, the Committee specified organophosphates, carbamates, triazines, pyrethroids and B-2 carcinogens as the classes of chemistry it will scrutinize first as a part of EPA's stated intent to "attack the worst first". Many of these products have been safely used for decades and are fundamental components of integrated pest management and resistance management programs.

Under the FQPA, the EPA could revoke numerous tolerances, not only for these products but for many others as well. In cases where EPA representatives consider a toxicology data base to be incomplete, average daily intake may be reduced by 90%. The new law also obligates the EPA to consider combined effects of all chemicals with a common mechanism of toxicity (all cholinesterase inhibitors are such chemicals) and the combined effects from other non-occupational routes of exposure (such as use on lawns or in residential settings). The net result is that long standing uses are likely to be canceled.

Many of these products, which have been through reregistration or have nearly completed reregistration, have been proven safe, effective components of integrated pest management programs.

Contributed by Gary Melchior, Gowan Company

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FQPA -- Part II

In carrying out the reassessment of pesticide residue tolerances mandated by the Food Quality Protection Act of 1996, the EPA Office of Pesticide Programs (OPP) proposes to give top priority to organophosphates, carbamates and carcinogens.

At an EPA Food Safety Advisory Committee meeting November 15, the OPP outlined a schedule for the 10-year reassessment project.

The agency plans to reassess one third of all existing tolerances and exemptions by August 1999, another one third by August 2002, and the remainder by August 2006. EPA is to publish by next August a fully developed plan for completing reassessment of the roughly 8,300 existing tolerances.

The OPP proposal to place carcinogens, organophosphates and carbamates at the top of the reassessment agenda is in keeping with the FQPA requirement to start with the riskiest pesticides first. The organophosphates and carbamates are both included in the class of chemicals that affect the central nervous system, but the agency told the advisory panel that it plans to give organophosphates higher priority because adverse effects from the carbamates tend to be of shorter duration.

In scheduling the carcinogens to be covered during the first three years of the reassessment, OPP will focus first on the "probable" human carcinogens (classified as B-2), then tackle the "possible" human carcinogens (C compounds).

The OPP proposal noted that the FQPA requires that the reassessment of each tolerance take into account aggregate exposure to the pesticide, cumulative effects from exposure to pesticides with a common mode of toxicity, any special susceptibility of infants and children, and possible endocrine effects to humans.

To illustrate how these multiple requirements may be applied, the agency proposal included an example based on the reassessment of alachlor, a B-2 carcinogen for which a Reregistration Eligibility Decision (RED) is scheduled in FY 97:

Assume that alachlor has a common mode of toxicity with other chloracidanilides, include propachlor (Ramrod) (a post-84 pesticide), metolachlor (Dual) (a RED that was already issued), butachlor (Machete) (a pending registration application) and acetochlor (Harness, Surpass) (also a post-84 pesticide) and possibly some of the inerts.

To comply with the requirements of the FQPA, the cumulative effects from exposure resulting from all of the above will have to be considered, not only to determine the reregistration eligibility of alachlor, but also to reassess the tolerances of each chemical. Once completed, the tolerances for alachlor (Lasso), propachlor (Ramrod), metolachlor (Dual), acetochlor (Harness, Surpass), and butachlor (Machete) would be considered reassessed in accordance with the FQPA. Reassessment for Captan, another B-2 carcinogen, will also be scheduled for FY 97.

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FQPA Part III -- Section 18s

In responding to Food Quality Protection Act mandates, the Environmental Protection Agency Office of Pesticide Programs (EPA OPP) has increased scrutiny of FIFRA Section 18 requests for emergency exemption uses of pesticides. That may force a search for lower risk alternatives to traditional pesticides, according to some participants at a Food Safety Advisory Committee (FSAC) meeting November 15 in Fairfax, Va. On the other hand, grower group representatives said they thought "minor use" crops would become casualties of a more complicated Section 18 approval process.

The FSAC meeting was the third in a series EPA conducted to learn from affected parties how best to implement the FQPA.

As reported in the Pesticide and Toxic Chemical News, OPP Registration Division Director Steve Johnson said language within the FQPA calls for a higher standard for Section 18 approvals because of lingering impressions from environmentalists and farmworker groups that the agency never denied a Section 18. EPA Assistant Administrator Lynn Goldman affirmed that the insertion of more restrictive requirements for Section 18 approvals into the new law was deliberate. According to Goldman, "Section 18s in the past were based on a risk/benefit balancing process. We [now] have to have a real crisis, we have to have the data in hand, to approve these requests. There was a lot of criticism that people were using the Section 18s to circumvent the risk assessment process for pesticide registrations." She added, "The new law shifts the burden of proof towards the protection of the public. Since the law was passed, the level of study and risk assessment has increased."

According to Johnson, EPA evaluation of Section 18 requests in the early to mid-1980s involved the following elements: an assessment of environmental fate, an evaluation of the ecological effects and a comparison of dietary exposure with the Acceptable Daily Intake for the general population. He said that EPA evaluation in the 1990s of potential human health effects has expanded to also include a more sophisticated dietary exposure model able to calculate exposure to groups such as infants and children, as well as an evaluation of acute dietary risk and occupational exposure.

Johnson displayed a chart that compared approvals, denials, withdrawals and crisis exemptions for Section 18s during the last 15 years. The numbers appear fairly similar for each category, except for fiscal year 1982, when no Section 18 was denied and 473 were approved, including 148 crisis exemptions. The average denials for each fiscal year included in the chart ranged from 22 to 39 (except for FY 96, during which a serious threat posed by late blight inclined the agency to approve more requests). The average number of approvals ranged from 141 per year to 274. Crisis exemptions ranged from 30 to 66 each year.

Johnson said a number of pesticides that had been the subjects of Section 18 requests are progressing toward regular Section 3 registration approval. He noted that 42% of the Section 18s authorized by the EPA in FY 92 are currently registered.

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FQPA Part IV -- New rules
for Section 18s

The new Food Quality Protection Act (FQPA) signed into law on August 3, 1996, has had a significant impact on the Section 18 emergency exemption program.

According to the Washington State Department of Agriculture (WSDA), the requirement for the establishment of a time-limited tolerance for Section 18s is cause for immediate concern. EPA is currently working to establish criteria for screening Section 18 requests. However, to avoid any unnecessary delays in the interim, the EPA requests that the following information be included in all new submissions:

1. Drinking Water: Submissions should include discussion regarding the potential for the pesticide to transfer to or be found in drinking water. The discussion should include, but not be limited to, available information indicating the pesticide's persistence, mobility or both. This should include relevant product chemistry and available modeling.

Submissions should supply available information regarding state drinking water monitoring for the pesticide in question. This information should have answers to such questions as the following: Does the state routinely monitor for the pesticide? Has it been detected? What is the detection limit?

2. Residential Use: Are there residential uses of the pesticide active ingredient? If so, what are the sites, rates, and formulations used?

3. Common Mode of Action: Supply any information regarding a common mode of action with other pesticides.

4. Harvest Date: Include anticipated harvest dates for the crop in question.

Although FQPA requirements are not fully defined at this time, the WSDA anticipates a significantly longer review period at the EPA. For this reason, the WSDA requests that it be sent submissions AT LEAST 120 DAYS before the earliest use date.

Questions regarding the new requirements may be directed to WSDA Registration Services at 360-902-2030.

From a memorandum by Ted Maxwell, Program Manager at the Washington State Department of Agriculture.

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FQPA Part V --Section 18 workshop

This article was prepared by Cindy Baker, Gowan Company. Baker attended the November EPA Section 18 workshop.

Representatives from the EPA Section 18 Review Section held a workshop November 21 and 22 in Washington, D.C. to discuss with stakeholders (state regulators, grower groups, and industry) changes occurring to the Section 18 process as a result of the Food Quality Protection Act. The workshop focused also on changes that have been discussed in meetings during the past year and a half. Jim Aidala and Steve Johnson of EPA opened the meeting November 21 with a discussion of the FQPA and its impact on Section 18s. Workshop participants then broke into four workgroups for breakout sessions on the following five topics: FQPA, issuance based on reduced risk, issuance based on resistance management, revising the criteria for significant economic loss, and issuance of multi-year exemptions. Following is a summary of the discussion resulting from each breakout session.

FQPA Implications

The new safety standard requires EPA to make a decision based on a reasonable certainty of no harm and to consider aggregate exposure. This creates four areas for EPA review: 1) cumulative effects (common mechanism of toxicity); 2) aggregate exposure; 3) sensitivities of major subgroups (such as infants and children); and 4) estrogenic effects. Johnson readily admits that, "We are not sure if we can group by common mode, but there are possibilities." He said, "It is not as simple as just cholinesterase inhibitors." For aggregate risk, EPA will consider the risk posed by the chemical from all routes of exposure. Dietary risk will be well characterized, to include the most sensitive populations. If the calculated dietary risk falls well below 100% of the reference dose (for chronic risks) or well above a margin of exposure of 100 (for acute risks), EPA will consider establishing a Section 18 tolerance. For drinking water, EPA is qualitatively characterizing risks. Agency personnel are looking at such risks as the potential for the chemical to leach. The law requires that EPA develop a screening program for estrogenic effects within two years, implement the program within three years and report to Congress within four years. Johnson said the agency has no idea how it will handle this.

EPA has established an interim process for Section 18s, in which states contact EPA and each request is handled on a case by case basis. For a crisis, EPA does a quick (one to two day) evaluation of the chemical/crop combination. If EPA is confident that a tolerance can be established, EPA informs the state that a crisis can be declared. Then EPA goes through the formal process of establishing a tolerance before the treated food moves into commerce. If the agency determines that a tolerance cannot be established, it informs the state and recommends that the state not issue a crisis. If the state issues the tolerance, only to have EPA review result in no tolerance being allowed, the crop must be destroyed.

EPA provided an analysis of the number of Section 18s granted by crop, by state and by geographic region. Section 18 activity since August 3, 1996, has been as follows: 53 requests, one action denied and six tolerances established. Several requests (particularly for avermectin and lactofin) have been withdrawn following discussion between EPA and the states. Twenty-one Section 18 requests remain to be reviewed. Several have been screened and given a tentative "green light".

Future Actions

EPA is completing a Section 18 rule document. The first draft should be done by December 30, 1996. The EPA plans to release the draft through publication in the Federal Register by April 16, 1997. There will then be a standard 30-day comment period. The agency expects to complete reviews in time to make the rule document effective on September 8, 1997. EPA must also consider whether a tolerance granted for a Section 18 will affect the "risk cup" and potential actions on pending Section 3s. The agency has not yet decided whether it will accept international data to support a Section 18 tolerance. In exposure assessments, EPA will consider using only the percentage of a crop that is treated and regional variations in groundwater concerns.

Revising Economic Loss Requirements

All workgroup participants agreed that more flexibility needs to be provided to the economic loss justification. Almost everyone agreed that the EPA could delegate this to the states. Workshop participants also agreed that marketable yield is a better measure of loss than is sales loss. Workshop participants received EPA support to revise the criteria and make it more flexible; there is a good chance that EPA will delegate this to the states.

Issuance Based on Resistance Management

Workgroup participants generally agreed that EPA should allow Section 18s based on resistance management, so long as very specific criteria are applied. There would first have to be documentation of resistance to the registered alternative. There would be flexibility in how that documentation would be accepted. For example, this documentation could be lab data, field data, pest history, data from USDA, expert opinion, data from IRAC, FRAC or HRAC, international data, or data generated by the registrants. Those who could demonstrate lack of season-long control with the registered alternative would have justification for use of another chemical. If there is a history of pest resistance to a chemical, EPA may consider providing Section 18s to two chemicals. The chemicals would have to have different modes of action, and the resistance would have to be documented by one of the methods listed previously. If a Section 18 were granted on the basis of resistance management, labeling restrictions would be put in place to address resistance concerns.

Issuance Based on Reduced Risk

EPA would grant a Section 18 for a reduced risk pesticide, when the registered alternative has greater human health or environmental risks. Not surprisingly, there was no general consensus on this topic. Registrants, states and grower groups all expressed concern about determining what constitutes a "reduced risk" pesticide. There was additional concern that very few pesticides have been certified by EPA to be "reduced risk" and whether the additional degree of safety is enough to justify a Section 18. Workshop participants discussed the idea of having EPA provide a list of pesticides that have been certified to date. The proposal received little support.

Issuance of Multi-Year Tolerances

This received almost unanimous support from the four workgroups. The basic position adopted would have EPA establish a three-year tolerance. States would then be delegated responsibility to renew the Section 18 registration on an annual basis after the first year, if a justifiable emergency still exists. EPA retains the right to cancel the Section 18, if new information surfaces about the chemical or if states abuse the renewal privilege.

Comments in Breakout Session

A tolerance is effective nationwide.

EPA will decide during the next few months whether a tolerance established for a Section 18 is eligible to be used for a 24(c). It will decide also what ramifications exist in regards to such issues as imported crops, crops that are not processed for long periods of time, experimental use permits, and rotational crop statements.

Nonfood uses, because of exposure, may affect the "risk cup".

For data to establish a tolerance, GLP is preferred. EPA recognizes, however, that this cannot be generated quickly, so it will "look" at any data.

Aidala supports the idea of giving states a list of chemicals, or reference doses for chemicals, to help them make decisions on Section 18 submissions.

Registrants can become more involved in the Section 18 process, so long as they do not advertise their products to commodity groups and growers in an effort to prompt Section 18 requests.

EPA is leaning toward the issuance of multi-year (two to three year) tolerances.

EPA will prioritize tolerance review actions according to the time the crop will be harvested or entered into commerce, rather than use dates. The agency will provide tentative approval to proceed for rapidly approaching use dates.

Closing

All participants received the opportunity to comment at the end of the breakout sessions and summary session. Most thanked EPA for the opportunity to provide input and requested that EPA seriously consider all the feedback it received from the states and commodity groups. Jim Jones of the EPA reported at the end of the workshop that feedback from the breakout sessions would be compiled and presented to senior EPA management. Section 18 process changes approved by EPA management would be incorporated into the Section 18 rule that will be drafted by the end of December.

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WSDA committee to review
pesticide license recertification

The Washington State Department of Agriculture (WSDA) is reviewing its policy and rules regarding the pesticide license recertification program.

To review the program, WSDA has formed the Pesticide Recertification

Committee. The Committee mandate is to review and submit recommendations to the Director of Agriculture in the following three areas:

1. Review the RCW 17.21.128 of the Washington Pesticide Appli cation Act, "Renewal of Certificate or License-Recertification Standards," for equity and fairness.

2. Develop pesticide course accreditation standards (criteria for assigning credits to a course) for WSDA policy or adoption into WAC 16-224" General Pesticide Rules."

3. Means of improving pesticide continuing education (content, access, etc.).

The Committee held its first meeting November 18, 1996 and will continue its work until August 31, 1997.

The Committee consists of 18 individuals representing a broad array of pesticide applicators and other interests across the state.

Following review and editing, the Committee plans to conduct a pesticide recertification survey in early January to provide members of the pesticide/pest management industry a process to comment on Washington's recertification requirements and accreditation policy. This survey will provide the Committee with a foundation of client-based information regarding recertification. Washington State University is compiling a list of recertification requirements for all states for comparison to Washington's requirements. WSDA is compiling a list of pesticide recertification, testing, and license type and category information to provide the Committee with a broader base of knowledge.

The Committee identified several key tasks for evaluation. These include looking at alternative methods of recertification, evaluating course accreditation policy, providing more information to course sponsors, and creating a resource base for important future course topics.

The Committee will review federal regulations for state pesticide certification programs prior to the next meeting.

The second Pesticide Recertification Committee meeting is scheduled for March 3, 1997, in Ellensburg. For more information regarding the Committee, contact Hugh Watson with the Washington State Department of Agriculture Pesticide Management Division, hwatson@agr.wa.gov, phone: 360-902-2020.

Members of the WSDA Pesticide Recertification Committee

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WSDA proposes increased
license and registration fees

This news release was submitted by the Washington State Department of Agriculture Pesticide Management Division.

The Washington State Department of Agriculture will propose during the next legislative session that pesticide licensing and product registration fees be increased.

Without additional revenue, WSDA faces a difficult time meeting its commitments to you. Seventy percent of the pesticide budget for the Division comes from product registration and licensing fees. These fees remain in the agency. The down side is that fees are set by law and changing laws requires legislative action. As you can appreciate, this is not the best time to ask legislators to pass laws raising fees.

We need about $500,000 annually in additional funds to handle the increasing number and complexity of special use pesticide registrations, provide technical assistance - particularly in the area of ground water protection, and simply to keep up with the increasing costs of doing business. We need to add four people, meet required cost of living adjustments, replace vehicles, keep computer systems current and provide training. The proposed fee increases would generate about $385,000 additional from product registration and $112,000 additional from licensing.

Product registrations would cost $165 per product, and the $200 SLN fee would be revoked. License fees would increase by $2 to $28. The PIRT surcharge would be included in the fee.

These increased fees will pay for two additional people in registration, one additional person in field compliance staff and one additional person in clerical compliance staff. We have taken very seriously our stated goal of being effective and efficient in the use of public resources. Since the last major revision of fees in 1990, we have cut staff, redesigned the licensing mailout system, decentralized staff and held equipment and vehicle replacement to a minimum. Still, the relentless increase in business costs continues. Could you still operate your business on 1990 income with a significant increase in the required workload? We can't either.

We intend to move from a complaint-driven, enforcement mode to education and voluntary compliance. This requires that we change our way of working with you, our customers, and that you, in turn, no longer measure our performance by the number of complaints the Division receives about pesticide use. We view violations and complaints as a failure in the system, not a subjective measure of our workload. Regulated communities either had difficulty understanding, or departmental communications were unclear. Either way, we intend to encourage a credible compliance program with a wider range of approaches and measurable results no longer based on the number of complaints received.

We need to register better, safer and more effective products faster; obtain field staff, particularly for the Columbia Basin, to assist you; process paperwork better and faster; and have enough people to assist where needed and ensure that violations are corrected quickly.

We currently have 36 staff members for the entire state (about 10 fewer people than in 1990). Your local fast food facilities probably have this level of staffing at one restaurant. In an average year, our activities include the following:

• processing about 8,500 product registrations and issuing 25 emergency registrations and 50 new local needs registrations,
• issuing 25,000 licenses and offering 800 recertification classes,
• collecting and disposing of 190 tons of unusable pesticides,
• training hundreds of Spanish-speaking farmworkers,
• presenting numerous talks and writing a newsletter,
• monitoring permits,
• responding to 300 complaints and answering more than 18,000 phone calls,
• conducting inspections for EPA of marketplaces, import establishments and manufacturers,
• actively responding to requests from the public and the Legislature,
• participating on numerous committees

Will this fee increase solve all our financial problems for all time? Probably no more than a one-time raise or product price increase can be a permanent financial solution for any business. However, we anticipate that these increases will keep us financially sound for the expected work level through this decade. Fee increases passed by this legislative session do not result in funds to the department until 1998. A small surplus generated initially will be utilized to offset increased costs by the year 2000.

We will still have unmet needs. We would like to revise the licensing and recertification and registration programs to allow for complete electronic access. We must address increasing concerns about possible groundwater contamination from use of pesticides and fertilizers. We need to offer increased technical assistance from well-trained staff. The list can go on and on. However, we are requesting only what we need to function.

We need your support. Our request will go to the Legislature. We depend on its approval for any fee increase. Those wishing additional information, or those wishing staff to make a presentation before an industry, environmental or committee meeting, may contact John Daly, Assistant Director, WSDA at (360) 902-2011 or Mary Beth Lang, Assistant to the Director, at (360) 902-1812.

Submitted by the Washington State Department
of Agriculture Pesticide Management Division.

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The importance of 2,4-D

The National Agricultural Pesticide Impact Assessment Program recently completed an analysis of the biological and economic importance of 2,4-D. The assessment discusses the use of phenoxy herbicides (the family to which 2,4-D belongs) on more than 65 crops and numerous non-cropland uses. Usage of all phenoxy herbicides in the U.S. was estimated at 55 million pounds of acid equivalent (47 million pounds were 2,4-D) with a retail sales value of $171 million during 1992.

The estimated net societal loss from banning 2,4-D in the U.S. would be $1.683 billion; whereas, banning all phenoxy herbicides would result in a loss of $2.559 billion annually. Approximately 37% of this net societal loss represents increased weed management costs from the use of more expensive alternative herbicides or non-chemical weed control methods. Decreased crop yields make up 35% of the aggregate loss. Higher retail commodity prices, a net loss to consumers, make up the remaining 27%. Decreased crop yields would occur more often with minor acreage crops, where alternative herbicide choices are more limited than with major acreage crops.

Presently, 2,4-D is one of the least expensive herbicides for broadleaf weed control in the U.S.; it helps keep the retail price of substitute herbicides competitive. In Minnesota, for example, the median price of 2,4-D amine for broadleaf weed control in spring wheat is $1.59/A, non-phenoxy herbicides for broadleaf weed control average $5.05/A, and herbicides for grass control average $15.58/A.

For some minor crops such as almond, blueberry, cranberry, grape, nectarine, pear and strawberry, 2,4-D is the only broadleaf herbicide registered. Its loss would adversely affect the production of these crops.

Other reasons for using 2,4-D and other phenoxy herbicides include the following:

The management of more than 100 noxious weeds would be much more difficult without phenoxy herbicides; annual net societal loss resulting from the management of these weeds would total $180 million.

Without 2,4-D, the general public would face increased costs for many foods. Increased lawn and turfgrass management costs would total $691 million annually.

The value of all phenoxy herbicides (2,4-D, MCPA, MCPB) to dry peas is $600,000. The value of all phenoxy herbicides to green pea production is $8 million.

For more information on the NAPIAP assessment of 2,4-D, contact Orvin Burnside, 2,4-D NAPIAP Task Force, Department of Agronomy and Plant Genetics, University of Minnesota, St. Paul, MN 55108.

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How does pesticide toxicology
affect your business?

...Allan Felsot

Growers face the dilemma of needing to protect crop yield and quality while having fewer pesticides available in an environment of increasing regulation. Many pesticides once registered for use on minor crops are gone from the market because of manufacturer refusal to support costs associated with the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) mandate for pesticide reregistration. Pest resistance limits the effectiveness of some currently registered pesticides.

Growers know well the advantages of using pesticides. Pesticides control a wide spectrum of crop pests, and because they act quickly, they offer immediate relief against crop damage in emergency pest control situations. Furthermore, integrated pest management (IPM) theory has historically considered use of nonpersistent pesticides a tool to complement biological methods of control.

Despite the advantages growers realize from using pesticides, governmental policy has reflected a public desire for reduced pesticide use. Pesticides have a poor public reputation perhaps due to past use of DDT and the downfall of that chemical's use precipitated by Rachel Carson's Silent Spring. Bad publicity for pesticides continues, despite modern pesticides being biodegradable, generally safe for beneficial insects, and reflecting greater selectivity for pests than older suspended pesticides.

Perhaps the public views all pesticides through blinders constructed from past experiences with DDT. Another hypothesis may be that the public misunderstands data generated from toxicological studies. If toxicological studies, required by law before and after a pesticide is registered, contribute to current public perception of pesticide hazards, then one might consider that toxicology directly affects growers.

In addition to creating certain perceptions of pesticide hazards, toxicological studies affect policy, possibly causing increased restrictions in pesticide use. The Food Quality Protection Act of 1996 (FQPA), for example, now requires consideration of other modes of exposure in addition to dietary intake when setting food tolerances. This requirement affects all growers, not just those producing food commodities. Food tolerances appear to have little relevance to regulation of pesticides used on nonedible ornamental crops, for example, but nearly all pesticides are used on edible commodities. Establishment of food tolerances, therefore, indirectly affects the ornamental industry. One FQPA provision, requiring testing of pesticides for endocrine system disrupting effects, has as yet unknown consequences for growers. However, numerous frequently used pesticides have been identified as possible hormone mimics. Further toxicological scrutiny will likely identify even more. Such identification likely will influence US EPA decisions about pesticide registrations.

Surely growers must shudder at the plethora of toxicological studies, knowing that these studies will never proclaim pesticides absolutely safe. Ironically, the same efforts bringing the bad news also create the products in the first place. They help explain how the pesticides work and improve their efficacy, management, and safety. Furthermore, growers benefit directly from toxicological studies because hazards are better defined, allowing growers to use appropriate precautions during pesticide application. Because toxicology is fundamental to the development of pesticide technology, affecting every aspect from efficacy of chemicals to regulatory policy and public perceptions, growers should find it worthwhile to understand what it is, how it affects their business, and how it can benefit them.

Toxicology is the interdisciplinary study of the injurious effects of chemical and physical agents. Biologists and chemists study these effects in a variety of organisms, by examining adverse alterations in structure, function and response. Toxicology helps characterize the hazard of a substance, defined as the potential to cause harm under the specific conditions of use or exposure. Toxicologists recognize that risk is actually the probability of harm and that that probability can never be zero.

Both during and after pesticide registration, scientists employ risk assessment to determine the potential of a substance to cause harm to human health or the environment and the probability it will do so under the conditions of its use. Risk assessment evolves from a scientific process of hypothesis testing, where well- designed experiments generate required information without consideration of social and political factors. Risk assessment is distinctly different from risk management, which is a decision-making activity involving the evaluation of alternative risk control practices and the selection and implementation of alternatives. Risk management is influenced by consideration of economics, politics, and sociological factors, as well as science. For example, the EPA decision to allow or prevent emergency use of a non-registered product (one not registered on a specific commodity) depends not only on toxicological information developed in scientific experiments, but also on whether the product would replace other more hazardous substances and the economic consequences of not using the product. Chemical manufacturers also use risk management; assessment of product safety in toxicological studies is probably less important than potential survival in the marketplace.

The primary objectives of risk assessment are the determination of a compound's no observable effect level (NOEL) and characterization of exposure. Basic toxicological studies play their biggest role in determination of the NOEL or a threshold for response. Exposure assessment depends on environmental chemistry. Modern toxicology encompasses both toxicity assessment and environmental chemistry and is driven by the maxim that "dose makes the poison." A typical experiment for determining the NOEL involves feeding rats increasing amounts of chemical and determining the dose at which no effect is observed. From these data, a dose-response curve is drawn and the LC₅₀ (the dose or concentration causing adverse effects or death in 50% of the test population) can be generated. While we tend to think of toxicological studies as generating information useful for predicting human hazards, the same procedures help determine effective doses for controlling insects, weeds, and pathogenic organisms.

An examination of the testing requirements for pesticide registration reveals how toxicology in the broadest sense contributes to not only our knowledge of hazards, but also to effective use and management. FIFRA requires many different kinds of tests in eight testing areas. These are listed as follows:

• Product chemistry
• Residue chemistry
• Environmental fate
• Hazards to humans and domestic animals
• Spray drift studies
• Field re-entry protection studies
• Hazards to nontarget organisms
• Product performance

Data generated under product performance requirements and testing for hazards to nontarget organisms are particularly beneficial to growers. By requiring companies to submit efficacy data, for example, growers have available an authentic record documenting control potential that can serve as a basis for comparison when registered products lose efficacy or fail to work as expected. Nontarget plant toxicity characterization is required under the mandate for testing hazards to nontarget organisms. Growers can be assured that products used to control a pest will not adversely affect their crops.

During product development, toxicological studies serve a dual role. Studies of the hazards to humans and nontarget organisms define how a chemical is metabolized and excreted and also how it causes toxicity. Similar studies are conducted on the target pest. Defining how a particular chemical structure causes a biochemical reaction inevitably leads to synthesis of new products with similar but altered molecular structures that make them more selective for pests. This helps reduce the amount of chemical to be used and improves environmental safety over all. Indeed, the development of environmentally benign chemicals has been dubbed "green chemistry." Such developments will progress through increased understanding of how chemical structure relates to toxicological behavior.

Growers know better than anyone that pesticides can directly affect their health and that of their workers. Toxicologists agree that occupational exposure to pesticides represents the greatest hazard of pesticide use. High dose testing of rats helps provide understanding of hazards to farmworkers. Such testing, scientists generally recognize, has much less relevance to consumer exposures through food and water.

Environmental chemistry studies help describe potential exposure of workers. For example, past studies have shown that about 5% to 20% of a pesticide applied in a greenhouse actually reaches the crop, while 25% to 50% escapes through the greenhouse ventilation system. Up to 50% of the applied residues could be considered potentially available to worker exposure, either by direct contact during application, through inhalation after spraying, or by touching sprayed plants.

A recently published study on potential worker exposure from fungicide use in a greenhouse operation shows how toxicological studies can protect pesticide users. Air and leaf residues of the fungicides vinclozolin (Ronilan) and triadimefon (Bayleton) were measured in a greenhouse after the chemicals were sprayed on cucumbers. Air residues of Bayleton were undetectable, and surface residues remained low within two hours after application; the study authors considered Bayleton of little concern to worker health. On the other hand, air residues of Ronilan were high for a few hours after application but declined to very low levels in about three days. Residues on leaf surfaces and the greenhouse floor also remained high for several days, suggesting potential for worker exposure after spraying. Wearing of protective clothing during harvesting operations three days after spraying reduced potential exposure to levels equivalent to the acceptable dietary intake. Perhaps most useful to greenhouse operators was data showing that low volume sprays created more residues (and more hazard) than high volume sprays.

In conclusion, toxicology encompasses many different kinds of biology and chemistry studies. Because toxicology helps characterize hazards and estimate probability of harm, it serves policy makers who propose regulations likely to further restrict growers' use of pesticides. On the other hand, toxicology is a bona fide scientific endeavor that serves to make more effective and safer products.

Allan Felsot is the environmental toxicologist at the Food and Environmental Quality Laboratory.

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WSU pesticide education

The winter training schedule for Washington State University pesticide education programs is completed. Brochures were mailed October 9, 1996 to individuals with a current pesticide license. Both Pre-license and Recertification courses will be offered this winter. A Spanish recertification class was offered in November. A pre-license aquatic session will be offered January 23, 1997. Registration is $40 per day, unless postmarked 14 days prior to the program, in which case it is considered early registration at $30 per day.

In response to comments regarding the Integrated Plant Health Workshop held last season in Puyallup, WSU has scheduled two workshops this year -- one in Spokane and one in Puyallup.

More information regarding winter training or registration may be obtained by contacting Cooperative Extension Conferences at 509-335-2830, the WAPP World Wide Web site at http://www.wsu.edu:8080/~ramsay or E-mail: ramsay@wsu.edu.

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Officially Unofficial

...Alan Schreiber

"Officially Unofficial" is a regular feature that may include information considered inappropriate by some.

• The Washington State Attorney General's Office is very close to a settlement with at least two pesticide companies regarding their overcharging of pesticide users.
  
• Based on a large scale illegal use of methyl parathion for insect control INSIDE of houses in Mississippi, EPA internally considered cancelling all registrations of the EC formulation. However, following an intense series of negotiations, the base manufacturer, Cheminova, has agreed to add valeric acid (a stenching agent that smells like old socks or a locker room), use a barcoding system to track the product, conduct an education program, package all products in returnable, refillable closed system containers, and recall all existing products. The only sticky point in the agreement is the schedule for phasing in returnable/refillable containers. Several individuals have been arrested for the illegal application of methyl parathion in Mississippi.
  
• I was told recently by a USDA official in Washington, D.C. to start assessing the impact of the complete loss of organophosphate and carbamate insecticides. There is some discussion in Washington, D.C. about a potential total or near total loss of these compounds as a result of the Food Quality Protection Act.
  
• I have reviewed EPA's draft Section 18 guidelines and, while the draft holds no surprises, it is obvious that it will take more time and much more effort to obtain an emergency exemption than before the FQPA was passed. Washington and other states will be unable to obtain some of the exemptions they have received in the past.
  
• Zeneca has stopped making fonofos (Dyfonate). All existing supplies have been allocated to dealers, and the company has no plans to make the product in the future. Zeneca is willing to sell rights to the product to another company, but that company would have to come up with a manufacturing plant that can make the technical material.
  
• The Federal Trade Commission has given its approval to the proposed merger of Ciba and Sandoz. In order for the merger to go forward, Sandoz has agreed to sell dicamba (Banvel) and dimethenamid (Frontier) herbicides to BASF. Sandoz is also selling additional animal/vet and pharmaceutical products. The new company will be named Novartis AG. It will be the second largest pharmaceutical and the second largest agricultural chemical company in the world, with annual sales of $26.5 billion. The merger will result in the loss of 12,000 jobs, 1,400 in the U.S.

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Production cost per acre
for dry peas, lentils and chickpeas

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Washington State Commission
on Pesticide Registration

Request for Proposals 1997

The 1995 Washington legislature created the Washington State Commission on Pesticide Registration (WSCPR) to assist users of pesticides in obtaining and maintaining pesticide registrations for minor uses in Washington state. As instructed by the Legislature, Washington State University (WSU) has made funds available specifically for studies and activities regarding pesticide registration as approved by the WSCPR.

Intent:

The purpose of this request for proposals is to fund studies and activities that will result in pesticide registrations for minor uses in Washington. A minor use is defined as a pesticide use pattern that is so limited in volume that the cost of obtaining or maintaining the registration is greater than the expected return to the registrant. Only proposals for projects that are expected to result in obtaining or maintaining a pesticide registration will be considered.

General Information:

Projects requiring two years funding may be submitted, but a second year of funding will depend on availability of funds and satisfactory progress toward meeting project objectives. WSU researchers who submit proposals must obtain prior budget approval from Tom Kelley of the CAHE Business Office. Submit one proposal per project.

No indirect costs or overhead are allowed.

Generally, the WSCPR does not provide funds for equipment purchases. If purchase of equipment is a necessary component of a project and WSCPR funds are to be requested for that use, the equipment and estimated cost of the purchase should be clearly identified in the proposal budget with an explanation. The WSCPR reserves the right to retain ownership of the equipment once the project funding period is completed.

Proposals must originate from the affected pesticide user community. The request may be made by an individual, company or organization on behalf of a particular user community. Requests will not be accepted from pesticide manufacturers, dealers and distributors. Funded projects can be carried out by qualified university or USDA specialists, private researchers or laboratories. Individuals and organizations in other states may submit proposals or work collaboratively with Washington researchers. Additionally, since pesticide residue data generated in Idaho and Oregon can suffice for Washington in the registration process, researchers in those states may submit proposals that are of sufficient importance to Washington and the Pacific Northwest region. Submittors are encouraged to suggest field and/or laboratory researchers or other individuals to carry out project activities; however the WSCPR reserves the right to select the individual or organization to complete WSCPR funded projects.

Project requests should be limited to five pages, not including budgets and attachments, and should state who will conduct the work, their qualifications and the time frame for project completion. Names, addresses and phone numbers of individuals involved in submitting and conducting the work should be included. Any project that involves generation of pesticide residue data in support of a registration must include provisions for use of Good Laboratory Practices (GLP). Anyone preparing a proposal that would require GLP research must contact the WSCPR prior to proposal submission.

If appropriate, assurance of the manufacturer to permit registration resulting from the successful completion of projects should be included as part of the proposal. Name, address and phone number of appropriate contact at the manufacturer should also be included. It is the responsibility of the researcher or grant recipient to obtain any necessary state or federal permits, such as state experimental use permits.

Users of pesticides on sites or crops not in the top 20 agricultural commodities produced in Washington are especially encouraged to submit proposals; the current top 20 commodities in Washington are apples, milk, cattle and calves, wheat, potatoes, farm forest products, hay, nursery and greenhouse, pears, hops, sweet cherries, eggs, chickens and broilers, onions, grapes, asparagus, sweet corn, field corn, mint oil and Christmas trees. Proposals dealing with use of pesticides on a wide variety of sites may be submitted, including, but not limited to the following areas: agriculture, forestry, aquaculture, structural pest control, rights-of-way, noxious weeds, nursery, landscape, ornamentals, rangeland and mosquito control districts.

Assistance:

Pursuing pesticide registrations is a complex, expensive and difficult process. Developing a proposal to fund activities that will support a pesticide registration can be challenging. Anyone in need of assistance in preparation of proposals is encouraged to contact a commission member or Catherine Daniels, Food and Environmental Quality Lab, WSU Tri-Cities, 100 Sprout Road, Richland WA 99352-1643. Contact numbers are: 509 372-7492 (phone); 509 372-7460 (fax); or E-mail: cdaniels@beta.tricity.wsu.edu. Examples of funded proposals are available on line (http://picol.cahe.wsu.edu) or from the WSCPR upon request.

Match:

Although proposals are not required to include matching support, submittors are encouraged to provide matching funding, in-kind services or materials for laboratory studies and investigations. Matching contributions should be clearly described and the value of match should be provided. When in-kind contribution are included as all or part of a match, include an estimated value of the service, product or assistance. If the WSCPR provides project support, the requesting user group must provide the match to the WSCPR or provide some documentation that the match was used in support of the project.

Description of Problem:

Each proposal should contain a brief description of the affected industry and a detailed description of the pest problem using as many as the following appropriate criteria:

1. crop farmgate value; state the estimated per acre value of the site or crop

2. per acre/unit impact, include potential monetary losses if appropriate

3. acres impacted

4. aggregate impact to the industry; include aggregate value of the site or crop in the state

5. effect of the pest problem on the industry

6. effect of the pest problem on consumers, society, environment, non-target species or human health

7. description of why alternative control measures are not effective, or provide any additional information on the specific need

Evaluation and Selection Criteria:

All proposals received will be acknowledged. Each proposal will be reviewed for compliance with WSCPR guidelines. Proposals not adhering to these guidelines will be returned to submittors; additional guidance will be extended for any returned proposals. All accepted proposals will be reviewed by WSCPR. Proposals will be judged by the following criteria:

1. Relevance to stated WSCPR areas of emphasis

2. Overall merit and quality of proposal

3. Feasibility of completing project objectives within stated time frames

4. Appropriateness of requested budget

5. Adherence to WSCPR guidelines

Areas of Emphasis:

(Unranked in order of importance)

Importance to economy. The WSCPR will consider proposals dealing with pest control problems having an adverse economic impact to a user community or local economy. Pest control problems of a severe nature in a limited area, such as one causing up to a 50% loss on a few hundred acres, or a less severe problem on a more widespread area will be considered.

Importance to human health. The WSCPR will consider proposals dealing with pest control problems that pose some risk to human health. Potential projects in this area would be studies that would result in registration of a pesticide that would reduce the risk associated with a pesticide use pattern which poses a chronic or acute risk to human health. Acute risk issues could involve farmworker or mixer/loader/applicator safety. Chronic risk issues could include such areas as carcinogenicity, mutagenicity or neurotoxicity.

Importance to the environment. The WSCPR will consider proposals dealing with pest control problems that pose adverse risks to the environment. Examples include studies that would result in registration of a pesticide that reduces the risk associated with certain use patterns posing significant risk to some aspect of the environment. Environmental risk issues might include ground or surface water contamination, harm to wildlife or degradation of aquatic ecosystems.

Deadlines:

Two formal requests for proposals are issued each year; however, proposals are accepted at any time. Submit one hard copy original of each proposal along with an electronic copy identifying the word processing program used to Catherine Daniels, Food and Environmental Quality Lab, WSU Tri-Cities, 100 Sprout Road, Richland WA 99352-1643. Contact numbers are: 509 372-7492 (phone); 509 372-7460 (fax); or E-mail: cdaniels@beta.tricity.wsu.edu. Proposals will be reviewed by the WSCPR at the next regularly scheduled meeting. Submittors should be available to make a brief presentation and respond to questions from commissioners at that meeting. A final report should be submitted to the WSCPR within one month of project completion.

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Federal Issues

Tolerances

EPA granted these tolerances since November 1996. Labels may not have been registered for these uses. These pesticides must not be used until a label is registered with EPA or a state department of agriculture.

*Key

(a) Time limited tolerance expires November 15, 1998.

(b) Time limited tolerance expires November 29, 1997.

(c) Time limited tolerance expires November 30, 1997.

(d) Time limited tolerance expires October 31, 1998.

(e) Time limited tolerance expires November 8, 1997.

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Contributors to the Agrichemical and Environmental News:

Alan Schreiber, Allan Felsot, Catherine Daniels, Mark Antone, Eric Bechtel

If you would like to include a piece in a future issue of the Agrichemical and Environmental News, please contact Alan Schreiber. To subscribe to the newsletter, please contact Eric Bechtel.

Contributions, comments and subscription inquiries may be directed to: Food and Environmental Quality Laboratory, Washington State University, 100 Sprout Road, Richland, WA 99352-1643, ph: 509-372-7378, fax: 509-372-7460, E-mail: ebechtel@beta.tricity.wsu.edu.

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