United States
                      Environmental Protection
Prevention, Pesticides
And Toxic Substances
March 1997
                       EPA's Pesticide Environmental Stewardship Program #5
   The Pesticide Environmental Stewardship Program
   (PESP) held it's first workshop, "Making A
   Difference...The Next Steps", on November 18 & 19 at
   the Doubletree Hotel in Crystal City. The highlight of
   the workshop was the Awards Luncheon on Monday,
   November 18.  Administrator Carol M. Browner and
   Assistant Administrator for Pesticides, Pollution
   Prevention and  Toxics, Lynn R. Goldman, MD,
   addressed the audience and presented plaques to the
   PESP Charter Partners. In attendance were PESP
   Partners and Supporters and their EPA Liaisons.

   Charter Partner plaques were presented to the American
   Corn Growers Association; American Electric Power
   [Administrator Browner (left) and Assistant Administrator Goldman
   (right) receiving PESP mug from Janet Andersen (center); Director
   ofBiopestiddes and Pollution Prevention Division.]

   Service Corporation; California Pear Advisory
   Board; Carolina Power & Light; Delmarva Power;
   Duke Power; National Potato Council; New York
   State Gas & Electric; Pennsylvania Electric;
   Pennsylvania Power & Light; Pennsylvania Rural
   Electric Association; U.S. Apple Association; VA,
   MD & DE Association of Electric Cooperatives; and
   Wisconsin Public Service Corporation. [The
   organizations listed hi bold type had representatives hi
   attendance to accept their award.] The PESP
   Management Team also presented PESP mugs to
   Administrator Browner and Assistant Administrator
   Goldman in appreciation for then- support of the
   Stewardship  Program.

   During the workshop, four concurrent breakout sessions
   were held. The following issues were addressed:

    Food Quality Protection Act
    Stewardship Strategies
    PESP Grants
    Measuring  and Monitoring
        "I have been pleased to see the
         progress of utility companies
           pursuing integrated pest
      management to control weeds on
     their property, federal agencies such
         as the Department of Defense
     committing to a 50 percent reduction
     of pesticide use, and the golf course
         associations educating their
        members about how to reduce
      pesticide risk and pesticide use."

      Carol M. Browner, EPA Administrator
   The Partners and Supporters were accompanied by then-
   Liaisons to all of the sessions. The workshop was a
   success according to many of the participants, who
   provided such comments as "Excellent, worthwhile,
   educational, informative workshop which should be held
   annually;" "Getting to know EPA and other industry
   people was very valuable;"  and "It is good to gather
                                           Page I/March 1997

Liaisons together with their Partners more often to keep
the energy levels high."

Workshop Proceedings were mailed in March to all
Partners, Supporters, and other attendees. If you are
interested in receiving a copy of the proceedings, please
contact the National Foundation for IPM Education at
                   IN BPPD
Congratulations to the following organizations who have
shown a genuine interest in promoting environmental
stewardship by making a commitment as Partners in the
Pesticide Environmental Stewardship Program.

        American Association of Nurserymen
           Environ  "Pest Elimination" Inc.
         Global Integrated Pest Management
      Lodi-Woodbridge Wine Grape Commission
        Ne\v Orleans Mosquito Control Board
        Ne\v York Berry Growers Association
              Pacific Coast Producers
           Redi National Pest Elimination
               Reliable Pest Control
              Sanitary Exterminating
    South Texas Cotton and Grain Association, Inc.
           Sun-Maid Growers of California
U.S. Public Health Service-Centers for Disease Control
           Winter Pear Control Committee
       Wisconsin Ginseng Growers Association
We also welcome the International Pest Management
Institute and the Association of Applied Insect Ecologists
as new PESP Supporters.
EPA has registered six new biological pesticides in the
first quarter of Fiscal Year 1997, which ended
December 31, 1996.  The new pesticides are aimed at
controlling a wide variety of pests including
cockroaches, plant diseases, borers, nematodes, aphids
and other insects. These registrations reflect growing
trends toward greater reliance on biological pesticides.
Biopesticides are generally considered safer than
conventional pesticides because they are often more
specific to the target pests and pose little or no risk to
other organisms.  They also are valuable tools in
integrated pest management programs.  The following is
a description of the new products:

Woodstream Corp. of Lititz, PA, was granted a
registration for a pheromone (trade name: German
Cockroach Pheromone) to control German cockroaches.
It is used in boric acid bait stations as a cockroach
attractant.  Boric acid, on the body of the cockroach,
causes dehydration and death.  It is approved for
indoor, non-food areas of homes, restaurants, health
care facilities, educational institutions, factories,
garages, transportation and recreational vehicles, zoos,
kennels, utilities and sewers.

Agridyne Technologies of Columbia, MD, will produce
dihydroazadirachtin (trade name: DAZA), a
hydrogenated form of the naturally
occurring azadirachtin obtained from
the seeds of the neem tree, which is
native to India and Burma. It was
approved for use indoors against
numerous pests including ants, aphids,
beetles, caterpillars, crickets, sawfiies,
whiteflies, centipedes, and sowbugs.  Outdoors, it is
                                               Page 2/Maroh 1997

approved for use on bedding plants, flowers, potted
plants, foliage plants, plants grown hydroponically,
ornamentals, trees, shrubs, turfgrass, fiber crops,
forage and fodder crops.

Stine Microbial Products of Adel, IA was granted
registration for Burkholderia cepacia isolate (trade
name: Blue Circle) as a fungicide for controlling
damping-off disease on the roots of vegetables, fruits,
nuts, vine crops, spices, ornamentals, greenhouse
crops, turfgrasses, flowers, bulbs and field crops.  It
may be applied through irrigation systems, by drenching
roots of seedlings, or by incorporating into seedbeds at

Monsanto Co. of St. Louis, MO was granted final
registration for  Bacillus thuringiensis CryIA(b) delta-
endotoxin and the genetic material necessary for its
production in corn (trade name: YieldGard), a plant-
pesticide for controlling or suppressing the European
corn borer, the Southwestern corn borer and the corn
earworm.  EPA has limited annual use to 100,000 acres
in southern states.  In addition, the acreage may not
exceed five percent of the corn planted in any county
with more than 1,000 acres of cotton. These limitations
were imposed to mitigate the risk of corn earworm, a
pest of corn, cotton, and other southern crops,
developing resistance to Bt CrylA.

Ciba-Geigy Corp. of Greensboro, NC was granted
registration for Bacillus thuringiensis kurstald strain M-
200 (trade name: Able) for
controlling lepidopterous (larval
moths and butterflies) pests in
tree fruits, terrestrial small fruits
and vegetables, tree nuts, alfalfa,'
corn, cotton, soybeans, peanuts,
herbs and spices and cranberries.
It may be applied aerially or by ground equipment.

Ecogen Inc. of Longhorne, PA was granted registration
for Bacillus thuringiensis kurstaki strain EG7826 (trade
name: Lepinox) for controlling lepidopterous pests of
numerous terrestrial food crops,  ornamental plants, turf,
nursery stock, shade trees and forests. It may be
applied aerially or by ground equipment. The Bt in
Lepinox has been genetically modified to produce an
additional delta endotoxin.
             GRANT AWARDS
On February 28th, the National Foundation for
Integrated Pest Management Education awarded thirteen
grants to PESP Partners and
Supporters. The projects listed
below involve IPM research,
education and/or training.  IPM is a
sustainable approach to managing
pests by combining biological,
cultural, physical and chemical tools in a way that
minimizes economic, health and environmental risks.

The following projects were funded:

  New York Berry Growers Association:
   Development and Implementation of IPM
  Sun-Maid Growers of California: Alternatives in
   Preemergent Herbicides;
  Monroe County  Schools: Implementation of IPM in
   Indiana Schools;
  Gerber Food Products: Mating Disruption of
   Oriental Fruit Moth;
  Fann*A*Syst/Home*A*Syst: Environmental Risk
   Assessments for Corn & Potato Pest Management;
  NE Vegetable & Berry Growers Association:
   Quantitative Pesticide Use Assessment;
  Oregon Wheat Growers League: Reducing Non-
   Target Risk from Pesticide Drift Through Grower
  Bay Area Stormwater Management Association:
   IPM Demonstration Garden;
  Wisconsin Ginseng Growers: Disease Management
  Winter Pear Control Committee: IPM Adoption hi
   Pacific NW Pear Orchards;

                                                Page 3/March 1997

  Glades Crop Care: IPM Adoption in Florida; and
  California Table Grape Commission: Grape IPM
   Web Site.


               by Rocky Lurufy, MIRC

The Mint Industry Research Council (MIRC) is a non-
profit organization which represents the U.S. mint oil
industry.  It is comprised of mint growers, oil dealers,
and major end users. There are approximately 150,000
acres of mint (80 percent peppermint, 20 percent
spearmint) grown in the U.S. each year.
Annual sales of mint oil are
approximately 11 million pounds (8
peppermint, 3 spearmint), worth a farm
gate value of over $150 million. This
translates into a $4 billion domestic
market and represents over 70 percent
of the world's peppermint and spearmint supply.  These
11 million pounds of mint oil are used mainly as
flavoring. The percentage of oil used in mint-flavored
products ranges from 1-10 percent. The majority (90
percent) of the mint oil produced is used for flavoring
chewing gum and toothpaste with lesser amounts used in
the confectionery, pharmaceutical, and liqueur-flavoring
trades. One barrel of mint oil (55 gal.) weighs 400
pounds and can be used to flavor 5,200,000 sticks of
chewing gum or up to 400,000 tubes of toothpaste.

The MIRC became aware and involved in EPA's
Pesticide Environmental Stewardship Program in 1995.
The reasons MIRC became a PESP Partner are
numerous.  One reason, of major importance to the
industry, was strengthening  and improving relationships
with the EPA.  PESP provides its Partners with an
avenue and platform for effectively communicating
important pesticide and food safety issues. The
appointment of EPA Liaisons ensures these lines of
communication remain open.  The MIRC is also
committed and dedicated to the implementation of
integrated pest management (IPM) and an overall
reduction hi pesticide use.  The MIRC invests a large
portion of it's annual budget into IPM and alternative
pest control research.  This investment, over the last
several decades, has paid for a solid IPM foundation
from which to build and expand.

PESP provides the mint industry an opportunity to
collectively exchange new ideas and information with
EPA and other Partners.  The objectives of PESP
parallel the goals of the MIRC: implementation of
IPM; reduction of conventional pesticide use; and
registration of new,  safer pesticides.

The MIRC believes that dedicated research, including
economic feasibility, and the dissemination of
information through education, are quintessential to
successfully accomplishing these goals.  The mint
industry was awarded a $30,000 grant to assist with the
production and distribution of educational materials
which illustrate the benefits of using certified planting
material and biological pest control.

In addition to research on the biological control of
weeds, nematodes, and insects, the MIRC is currently
funding IPM-related and non-chemical (cultural) pest
control studies.  Other ongoing data collection projects
include pesticide benefit and risk assessments, pest and
pesticide use surveys, herbicide resistance management,
and compilation studies.  Industry agronomists are also
rearing predator mites for mint IPM programs and
screening all pesticides registered in mint, present and
future, for their, effects on beneficials and the

To be active in research,  education, pesticide surveys,
IPM, and other PESP-related activities consumes a
considerable amount of what is already a limited
amount of tune and resources from a commodity or
pesticide user group. The mint industry is fortunate to
have a membership dedicated to accomplishing PESP
goals and objectives.  Regardless of commodity or
pesticide user group size and/or resources, the only
requirement of PESP is that a Partner do their part to
accomplish then: goals.
                                                Page 4/March 1997

There are many obstacles and barriers in the "real
world."  These obstacles and barriers are social and
economic in nature and, at times, seem insurmountable.
There are no easy solutions to many of them.
Philosophies and attitudes towards IPM and pesticide
use reduction must evolve.  This change includes the
research community. Research should also show when
not to spray.  Solutions to these complex problems
require multi-year, in-depth, interdisciplinary, and
systematically-approached studies.  Biotechnology may
offer solutions to many of these complex problems and
issues. By working together as partners, we can take a
concept and make it a reality.
              LIAISON NOTES
One of the greatest benefits of being a PESP Partner or
Supporter is having an EPA Liaison. Liaisons are
linked with the Partners/Supporters after they join
PESP. The Liaisons work with their Partner/Supporter
in developing an environmental stewardship strategy
and/or a project working towards risk reduction. Being
a Liaison provides an excellent opportunity for learning.
This column will feature experiences from our Liaisons
who represent our Partners and Supporters hi PESP.
Jim Boland, Liaison to the Cranberry Institute

They're "bogs" in Massachusetts and New Jersey,
"marshes " in Wisconsin, and "fields" hi the Pacific
northwest.  All are names for the places cranberries are
grown.  It just depends on where
one happens to be when you are
talking with growers about this
uniquely American crop!  There
are only 30,000 acres of
cranberry hi the U.S. Water is essential to the
successful cultivation of cranberry, it takes about 6-7
acre feet of water to support  1 acre of cranberry.  They
are not grown in water.  They can be dry harvested like
other crops, but the modern practice is to flood the
field, causing the fruit to float, where it can be gently
beaten off the vine and corralled (using a flotation collar
adopted from oil spill containment technology) and
lifted into trucks for transport to either a storage or
processing facility.

I am the Stewardship Program Liaison to the
Cranberry Institute. As such,  I have been fortunate to
have the opportunity to see how  cranberries are grown
and processed.  I also had the opportunity to visit with
growers hi New Jersey, Wisconsin and Massachusetts.
All took tune from their busy schedules to ensure my
thorough education in the agriculture of cranberry
production was balanced and complete.  Cranberry is
indeed a minor crop hi every respect. As such, growers
face some unique challenges hi production (urban
encroachment; wetlands issues) and pest management
(registration, IPM). Hopefully,  some of these issues
can be addressed through the PESP partnership by
fostering open communication and responsiveness to
commodity needs.

I think one of the most memorable instances I had with
this commodity was during a harvest tour in Wisconsin
in the fall of 1996. I was taking a picture of cranberries
being loaded from the "marsh" - remember, I was in
Wisconsin! - when my hostess said to the workers and
me, "Look!  There's a bald eagle!" Wow!
Joan Karrie, Liaison to the Gerber Products Company

On February 18th, 1997,1 attended Gerber Products
Company's Second Annual Agricultural Research
Update at then: headquarters hi Fremont, Michigan.
Gerber is a Supporter hi EPA's Pesticide Environmental
Stewardship Program.  Nine scientists from Michigan,
Wisconsin, and Illinois discussed ongoing research
which is funded wholly or  hi part, by the Gerber
Company.  In addition, John Bakker explained the goals
and processes of the Westcentral Michigan Crop
Management Association (WMCMA).  WMCMA is a
non-profit partnership between growers,
processors/packers, and Michigan State University
Extension Agents with the  primary goal of pesticide use
reduction through methods such as spray timing, pest
                                                 Page 5/March 1997

identification, enhancement of beneficials, and pest
threshold determination.

The researchers and there topics were: Mr. Philip
Schwallier, Michigan State University, Clarksville and
the Scab-Resistant Apple; Dr. Juwan Palta, University
of Wisconsin, The Ripening of Peaches Through the Use
ofLPE; Mr. John Rodgers, Michigan State University,
De-acidification of Peaches; Dr. Jun Song, Michigan
State University, Hexanal as a Post-Harvest Disease
Control Agent;  Dr. John Masuinas, University of
Illinois,  Weed  Control in Processing Squash;  Dr.
Schuyler Safi Korban, University of Illinois, Genetic
Advances in Disease Resistance of Apple; Dr.  Mark
Whalon, Michigan State University, The MSULow
Pesticide Input  Apple Project; Dr. John Wise, Michigan
State University, Mating Disruption Projects at the
Trevor Nichols  Station; and Dr. Bill Shane, Michigan
State University, Tree Fruit Evaluation at the

In addition to attendance at the Research Update, I was
able to visit the research facilities at Gerber, and on
February 19th.  tour the apple and stone fruit producing
areas of wcstccntral Michigan and meet a local farmer
whose fruit crops are destined for Gerber babyfood

I appreciate the opportunity that attendance at  the
Research Update afforded me to better understand the
foci of research and needs of the Gerber Company. I
know that this will strengthen the partnership ties
between Gerber and EPA as the information will allow
me to better anticipate future needs and interests of
Gerber with respect to my role as PESP Liaison. In
addition, I could see how much the researchers
themselves were interested in the work of the other
speakers, and expect that some further discussion and
cooperation may ensue.  I believe this  event was very
worthwhile, and wish to express my thanks to  the
Gerber Company for their invitation.

Kevin Costello Liaison to the Campbell Soup
On November 21, 1996, Kevin Costello joined Dennis
Larsen of Campbell Soup Company and researchers
from the Rutgers (NJ) Cooperative Extension Service in
an IPM tour of local carrot fields. Dr. Don Prostak,
Specialist in Pest Management at the Extension, led the
group to three carrot fields to describe the effort to
apply IPM to the control of carrot weevil, root
nematodes and dodder. Southern New Jersey is one of
several regions from which Campbell Soup buys carrots
for processing.

Kristian Holmstrom of the Cooperative Extension
demonstrated the use of wood-baffle traps to scout fields
for carrot weevil. These traps, which were developed
by a Canadian researcher, consist of a carrot placed
within a housing of closely-spaced
wood baffles. The traps are placed
at the edges of a carrot field hi the
spring before the crop has emerged
from the soil. If weevils are present
at the field, they should be found
between the wood baffles when the traps are collected
and disassembled. The presence or absence of carrot
weevils in these traps does not provide clues as to when
the weevils might be a problem. Rather, if scouting
with the traps indicates that there are no carrot weevils
present that season,  then the farmer can refrain from
spraying the field with insecticides to control them. All
three of the farms we visited have also instituted fall
and early spring soil sampling to scout for root
nematodes, which disfigure carrots and render them
unfit for processing. As with the weevil program, if
early scouting indicates that there are no nematodes at a
specific field, there is  no need to use pesticidal
fumigants that season. One of the farmers routinely
collects soil samples from more  fields than he needs to
grow carrots each year, in order to choose as many as
possible that will not require  pesticides for nematode

Finally, the Extension researchers are investigating the
advantages of early scouting for the control of dodder hi
carrot fields. If left untreated, dodder can spread across
carrot rows, harming the crop and spreading when
cultivating machinery  is dragged through the field. The
researchers are hoping that through early scouting and
                                                 Page 6/March 1997

spot-treatment with herbicides, dodder can be
eliminated in a field before it can produce seeds for the
next growing season.

The Stewardship Program has already paid dividends
for local carrot fanners by eliminating the expense of
unnecessary pesticide applications. In addition, it offers
companies like PESP Supporter Campbell Soup
Company the promise of reduced pesticide use in the
production of carrots they need for  processing.
In the last issue of the PEST SMART UPDATE,  an
announcement was made about the landmark pesticide
food safety legislation called The Food Quality
Protection Act (FQPA) of 1996. This article will recap
the signing of the legislation and discuss major issues in

BACKGROUND: On August 6, 1996,
Congress  unanimously passed landmark
pesticide food safety legislation supported
by the Administration and a broad
coalition of environmental, public health,
agricultural and industry groups.
President Clinton promptly signed the bill
and the Food Quality Protection Act of 1996 is now law
(P.L. 104-170, formerly known as H.R. 1627).

Pesticides in the U.S. are regulated under two major
federal statutes.  Under the Federal Insecticide,
Fungicide,  and Rodenticide  Act (FIFRA), EPA
registers pesticides for use hi the United States and
prescribes labeling and other regulatory requirements to
prevent unreasonable adverse effects on health or the
environment. Under the Federal Food, Drug, and
Cosmetic Act (FFDCA), EPA establishes tolerances
(maximum legally permissible levels) for pesticide
residues in food. Tolerances are enforced by the
Department of Health and Human Services/Food and
Drug Administration (HHS/FDA) for most foods, and
by the U.S. Department of Agriculture/Food Safety and
Inspection Service (USDA/FSIS) for meat, poultry, and
some egg products.  For over two decades, there have
been efforts to update and resolve inconsistencies in the
two major pesticide statutes, but consensus on necessary
reforms has been elusive.  The new law represents a
major breakthrough, amending both major pesticide
laws to establish a more consistent, protective
regulatory scheme, grounded in sound science. It
mandates a single, health-based standard for all
pesticides in all foods; provides special protections for
infants and children; expedites approval of safer
pesticides; creates incentives for the development and
maintenance of effective crop protection tools for
American farmers; and requires periodic reevaluation of
pesticide registrations and tolerances to ensure that the
scientific data supporting pesticide registrations will
remain up to date in the future.

While there has not been tune for detailed or definitive
analysis of the new law and its legislative history, below
are brief descriptions of how major issues appear to be
addressed in the new legislation and how they will
likely impact current practices.


              PROVISIONS (FFDCA)

Issue:  General Standards for Tolerances

Previous Law and Practice: Previous law generally
required EPA to establish tolerances that will "protect
the public health." With respect to chemicals that pose
carcinogenic risks, EPA used a negligible risk standard,
except in cases where the Delaney clause of the FFDCA
applied, as described below. For effects determined to
have a "threshold," EPA used safety factors to ensure
that lifetime exposure would not exceed a safe level.

New Legislation: The new law requires that tolerances
be "safe," defined as "a reasonable certainty that no
harm will result from aggregate exposure," including all
exposure through the diet and other non-occupational
exposures, including drinking water, for which there is
reliable information. It also distinguishes between
"threshold" and "non-threshold" effects, consistent with
                                                Page 7/March 1997

EPA practice.

Implications: The new law establishes a single,
health-based standard for all pesticide residues in all
types of food, replacing the sometimes conflicting
standards in the old law. There are no differences in
the standards applicable to tolerances set for raw and
processed foods.  Additional provisions ensure
coordination with standards and actions under FIFRA,
for a more consistent regulatory scheme.
Issue: Resolution of the "Delaney Paradox"

Previous Law and Practice: If a pesticide that causes
cancer in man or laboratory animals concentrates hi
ready-to-eat processed food at a level greater than the
tolerance for the raw agricultural commodity, the
Delaney clause of the FFDCA prohibited the setting of
a tolerance.  This had paradoxical effects in terms of
food safety, since alternative pesticides could pose
higher (non-cancer) risks and EPA allowed the same
pesticide in other foods based on a determination that
the risk was negligible.

New Legislation: The new law provides that tolerances
for pesticide residues in all types of food (raw or
processed) will be set under the same provisions of law.
The standards apply to all risks, not just cancer risks.

Implications: This legislation eliminates the Delaney
Paradox.  The Delaney clause no longer applies to any
tolerances set for pesticide residues in food.  Rather, the
EPA must determine that tolerances are "safe," defined
as "a reasonable certainty that no harm will result from
aggregate exposure" to the pesticide. EPA and others
will be able to devote resources that have been
consumed by Delaney-related activities to higher
priority public health and environmental protection
Issue: Special Provisions for Infants and Children

Previous and Law Practice: EPA is currently addressing
some of the high priority issues identified in the 1993
National Academy of Sciences (NAS)
report on "Pesticides hi the Diets of
Infants and Children."  The Agency
routinely assesses risks by age group,
ethnicity, and region when setting
New Legislation: The new law explicitly requires EPA
to address risks to infants and children and to publish a
specific safety finding before a tolerance can be
established. It also provides for an additional safety
factor (up to tenfold, if necessary) to ensure that
tolerances are safe for infants and children and requires
collection of better data on food consumption patterns,
pesticide residue levels, and pesticide use.

Implications:  The potentially greater exposure and/or
sensitivity of infants and children will be explicitly
taken into account in all tolerance decisions. Placing
these specific requirements in the statute will help EPA
in its efforts to implement the NAS report and ensure
that risks to infants and children are always considered
in the future.
Issue: Consideration of Pesticide Benefits

Previous Law and Practice: EPA used to set tolerances
"to protect the public health" and to give appropriate
consideration "to the necessity for the production of an
adequate, wholesome and economical food supply."

New Legislation: Tolerances based on benefits
considerations would be subject to a number of
limitations on risk and more frequent reassessment than
other tolerances. All tolerances would have to be
consistent with the special provisions for infants and
children. In certain narrow circumstances, the new law
allows tolerances to remain hi effect that would not
otherwise meet the safety standard, based on the
benefits afforded by the pesticide. Pesticide residues
would only be "eligible" for such tolerances if use of
the pesticide prevents even greater health risks to
consumers or the lack of the pesticide would result La "a
significant disruption hi domestic production of an
adequate, wholesome, and economical food supply."
                                                  Page 8/March 1997

Implications: This provision narrows the range of
circumstances hi which benefits may be considered and
places limits on the maximum level of risk that could be
justified by benefits considerations.
Issue:  Endocrine Disrupters (Estrogenic Substances)

Previous Law and Practice: No specific provision in
law.  EPA is working with others in the. public and
private sector to develop appropriate testing strategies.

New Legislation:  The new law requires the
development and implementation of a comprehensive
screening program for estrogenic and other endocrine
effects within three years of enactment.

Implications: EPA must develop a screening program
within 2 years of enactment, implement it within 3
years of enactment, and report to Congress within 4
years. This is a very ambitious schedule.  Little is
known about mechanisms of endocrine disruption and
possible synergistic effects. This is a high priority for
Issue: Other Factors to be Considered in Setting

Previous Law and Practice: EPA already considers
many of the factors in the new law, although they were
not all required under the previous law.

New Legislation: The new law requires EPA to
consider the validity, completeness .and reliability of
available study data; the nature of potential toxic
effects and available information on the relationship of
study results to human risk; dietary
consumption patterns and variations in
the sensitivities of major identifiable
subpopulations; cumulative and
aggregate (dietary and nondietary)
effects of exposure to the pesticide and other substances
with common mechanisms of toxicity; effects on the
endocrine system; and scientifically recognized
appropriate safety factors. These considerations are in
 addition to the special provisions for infants and
 children.  In assessing potential risks, EPA may also
 consider exposure to actual residues expected on foods
 (which are often far lower than tolerances) and the
 percent of a crop treated with the pesticide, but these
 assessments must be re-evaluated periodically to ensure
 they are still valid. EPA is given new authority to
 require data under FFDCA, if the data cannot otherwise
 be obtained under FIFRA or the Toxic Substances
 Control Act.  Finally, there must be a practical method
 for detecting residues hi food before a tolerance can be

 Implications:  As scientific understanding of potential
 cumulative and aggregate effects advances, it is likely
 that additional data will be required for EPA decisions,
 along with more information on subpopulation exposure
 and risk.  In most cases,  EPA will be able to use
 existing FIFRA authority to require this information.
 The additional data will enhance the scientific basis and
 protectiveness of pesticide regulations.
Issue:  Consumer "Right to Know" Provisions

Previous Law and Practice: No comparable law or
practice at the federal level.

New Legislation: The new law requires EPA to publish
a short pamphlet containing consumer-friendly
information on the risks and benefits of pesticides, any
tolerances that EPA has established based on benefits
considerations, and recommendations for reducing
exposure to pesticide residues and maintaining a healthy
diet. This information would be distributed each year
to "large retail grocers for public display."  In addition,
petitions for tolerances must include informative
summaries that can be published and made publicly

Implications: EPA must coordinate with USDA and
Health Human Services in order to accomplish this.
While the Agency has general information materials
that describe how to reduce pesticide exposure,
developing materials to reach consumers at the
supermarket level is a new departure, particularly with
                                                 Page 9/March 1997

respect to substitute foods.
Issue:  Re-evaluation of Existing Tolerances

Previous Practices: EPA has been reassessing tolerances
in connection with its ongoing reregistration review of
chemicals first registered before November, 1984.
Pesticides approved after that were not subject to
reregistration requirements.

New Legislation: While transitional provisions
maintain existing tolerances in place upon enactment,
the new law requires review of all tolerances on the
following schedule:

     -33% within 3 years
     -66% within 6 years
     - 100% within 10 years

Priority will be given to pesticides that may pose the
greatest risk to public health.

Implications: All tolerances will be required to meet
the new safety standards, which should increase
assurance that they arc protective of all American
consumers, including infants and children. The
magnitude of this task is considerable; well over 9000
tolerances are currently  in place.
Issue:  International Standards for Pesticide Residue

Previous Law and Practice: EPA considered
international standards for maximum residue
levels (MRLs) established by the Codex
Alimentarius Commission as part of its
reregistration tolerance reassessments for
chemicals first registered before
November, 1984.  There is no presumption in favor of
accepting international MRLs.

New Legislation:  The new law requires EPA to publish
for public comment whenever the Agency proposes a
tolerance that differs from an established Codex MRL.
Implications: This requirement furthers the goal of
international harmonization of pesticide residue limits,
to the extent that international MRLs meet U.S. food
safety standards.
Issue:  National Uniformity of Tolerances

Previous Law and Practice:  Previous law allowed
states to set tolerances that were stricter than EPA

New Legislation: Generally, the new law preempts
states from establishing tolerances that differ from EPA
tolerances first established or reassessed after April 25,
1985.  States may petition EPA for exemptions to this
provision if there are compelling local conditions that
justify  the exemption.

Implications: As a practical matter, states have rarely
set tolerances that differ from EPA's, and the protective
safely standards  in the new law will probably decrease
the incentive to do so even further.  States will continue
to have authority to establish tolerances stricter than
those EPA may set based on benefits considerations,
and to  require warning or other statements about the
presence of pesticide residues (such as those  required
under California's Proposition 65).
Issue: Residue Monitoring and Civil Penalties

Previous Law and Practice:  No comparable provisions.
FDA and USD A monitor pesticide residues as resources

New Legislation: The new law provides an additional
authorization of $12 million for increased FDA
monitoring in Fiscal Years
1997-1999.  It also  establishes
substantial civil penalties for
introducing foods with violative
pesticide residues into interstate
commerce.  The penalties do not
apply to growers.
                                                  Page 10/March 1997

 Implications: If Congress were to appropriate
 additional funds under this authority, FDA would be
 able to increase monitoring.  Penalty provisions should
 be a deterrent to violations.

 Issue:  Periodic Review of Pesticide Registrations

 Previous Law and Practice: Under amendments to
 FIFRA 1988, EPA is in the process of conducting
 reregistration reviews for all pesticides first registered
 before November 1984 and their associated tolerances,
 although tolerance reviews were not specifically
 required by the law. This review would bring the
 science base supporting registrations and tolerances up
 to current standards, but on a one-time only basis.

 New Legislation: In addition to requiring tolerance
 reassessments, the new law requires EPA to establish a
 system for periodic review of all pesticide registrations,
 aimed at updating them on a 15-year cycle. If new data
 are needed for these reviews, or for any other review,
 EPA may require them under FIFRA's "data call-in"
 authority in Section 3(c)(2)(B) or other statutory

 Implications: This ensures that all pesticides continue
 to meet up-to-date standards for safety testing and
 public health and environmental protection.  EPA
 retains authority to require data and take action if
 needed in the interim, but at a minimum registrations
 should be updated on a 15 year cycle.  Although other
 provisions of the new law provide for continuing  fees to
 support the reregistration effort through 2001,
 additional resources may be needed to sustain periodic
 review efforts beyond that date.
Issue: Emergency Suspension Authority

Previous law and practice: EPA could not suspend a
pesticide's registration unless a proposed notice of intent
 to cancel the registration had been issued or were issued
 simultaneously.  This could delay suspensions when
 there is an emergency, imminent threat to public health
 or the environment.

 New Legislation: The new law allows EPA to
 emergency suspend a pesticide registration immediately.
 A notice of intent to cancel must be issued within 90
 days, or the  emergency suspension would  expire.

 Implications:  EPA can now move quickly in situations
 that warrant immediate and decisive action to prevent
 serious risks to human health and the environment,
 while preserving the rights of registrants in the
 cancellation process.
 Issue:  Extension of Reregistration Fee Authority

 Previous Law and Practice: EPA had authority to
 collect  fees to implement the
 reregistration program (covering
 pesticides first registered before
 November, 1984) until September
 30, 1997.

 New Legislation: The new law extends fee collection
 authority through September 30, 2001.  It provides for
 the collection of $14 million/year to support the current
 reregistration program and the expedited processing of
 applications for substantially similar "me-too"
 pesticides, with an additional $2 million per year to be
 collected in 1998, 1999 and 2000. It also requires a
 annual independent audit to ensure performance goals
 are met and specifies that tolerance fees will be
 available to carry out the requirements of the new law.

 Implications:  If fee authority had been allowed to
 expire in 1997, EPA would have completed only
 approximately one-half of its ongoing reregistration
program.  Many of the pesticides for which review
would have been delayed are chemicals used on foods
most often eaten by infants and children. The extension
of fee authority will help EPA review these pesticides
more quickly and keep the current reregistration
program on track.
                                                 Page 1 I/March 1997

Issue: Minor Use Pesticides, (including Public
       Health Uses)

Previous Law and Practice: Minor uses of pesticides are
generally defined as uses for which pesticide product
sales do not justify the costs of developing and
maintaining EPA registrations.  In the aggregate, such
"minor"  crops are very important to a healthy  diet, and
include many fruits and vegetables.  For agricultural
pesticides, the Inter-regional Research Project No. 4
(IR-4), administered by USDA in cooperation with state
land grant universities, has been working to develop
needed data.  There was no corresponding program for
public health uses.

New Legislation:  The new law enhances incentives for
the development and maintenance of minor use
registrations  in a number of ways. These special
provisions do not apply, however, if the minor use may
pose unreasonable risks or the lack of data would
significantly  delay EPA decisions. The legislation also
establishes a  USDA revolving grant program and a
program for  support of public health pesticides,
analogous to  the ER-4 program for agricultural uses, to
be implemented jointly by the Public Health Service and

Implications: While maintaining safeguards for public
health and environmental  protection, these provisions
will enhance efforts to ensure that effective pest control
products are  available to growers and for public health
Issue:  Review of Antimicrobial Pesticides

Previous Law and Practice: There were no special
provisions for antimicrobial pesticides under previous
law.  EPA and FDA shared responsibilities for some
products, and EPA reviewed applications consistent
with Agency priorities, resources, and the timing of

New Legislation:  The new law amends the definition of
pesticide under FEFRA to exclude liquid chemical
sterilants,  which are to be regulated exclusively by
FDA.  It also reforms the antimicrobial registration
process, with the goal of achieving significantly shorter
EPA review tunes.

Implications: While the review times set out in the new
law will be difficult to achieve, EPA believes they are
attainable and will strive to develop a program to meet
them.  Ending dual regulation and establishing more
specific regulatory requirements will benefit
Issue:  Expediting Review of Safer Pesticides

Previous Law and Practice: EPA had established
policies that give priority to applications for pesticides
that appear to meet reduced risk criteria.

New Legislation:  The new law requires EPA to
develop criteria for reduced-risk pesticides, and
expedite review of applications that reasonably appear
to meet the criteria.

Implications: These provisions give a statutory mandate
for expedited consideration of applications for safer
pesticides, thereby enhancing public health and
environmental protection.  EPA will develop formal
criteria and procedures for expedited reviews.
Issue: Maintenance Applicator and Service
       Technician Training

Previous Law and Practice:  No specific comparable

New Legislation: The new law
creates a category of
 "Maintenance Applicators" and
 "Service Technicians," to include
janitors, sanitation personnel,
general maintenance personnel,
and grounds maintenance personnel who use or
supervise the use of structural or lawn pest control
agents (other than restricted use pesticides). States are
                                                  Page 12/March 1997

 authorized to establish minimum training requirements
 for such individuals.

 Implications: States have explicit authority to require
 training.  EPA is authorized to make states understand
 these provisions on minimum training requirements.

 NOTE: For more information on FQPA, see EPA's
 Office of Pesticide Program's website on the internet at
               EPA REGIONS:
   The Other Part of the Pesticide
It's easy for people that usually deal with the Office of
Pesticide Programs in Washington to overlook an
essential part of die program. There are small outposts
of the Pesticide Program located in each of EPA's ten
regional offices. These offices serve a function that
cannot be handled from Washington.

Some of the most important functions of the program
occur in almost all states and tribal territories in the
U.S., and the EPA regional offices oversee these
  The states and territories have primacy; they have
   accepted the responsibility of enforcing the use
   provisions of FIFRA.
  The states provide this function under a cooperative
   agreement (grant) with the EPA regions.
  The Regions manage these agreements and pass
   critical information to the grantees in support of
   their efforts.

Under the grants, the states and tribes:
  Enforce federal laws and, at the same time, enforce
   state laws; maintain pesticide laboratory operations;
   certify and train commercial and private applicators;
   implement worker protection standards which
   includes training and enforcemen; write and
   implement ground water state management plans;
    and negotiate arid implement endangered species
    protection plans.

 The Regions also work with the states and other
 partners to conduct programs and projects to reduce
 pesticide risk and promote safe handling and disposal of
 pesticides. These activities are all done in conjunction
 with the states.  It may seem to the casual observer that
 the Regions have very little to do other than simple
 oversight.  This is not the case.  Not all work can be
 delegated to the states/tribes. Other activities include:
    Training federal and state/tribe inspectors that
    conduct the FIFRA inspections.
    Conducting laboratory audits to ensure that labs
    follow Good Laboratory Practice (GLP)  procedures.
   Investigating and prosecuting high-profile or
    sensitive federal violations.
    Collecting and recording FIFRA Section 7 (pesticide
    production) data and enforcing this reporting
    Experiencing numerous encounters with the
    inquisitive public and, yes, responding to those
    Congressional inquiries.
    Assisting some wayward registrants and send others
    to Headquarters with problems.
    Dealing with the U.S. Customs Service and
    maintaining a pesticide import surveillance program.
    Holding workshops for states, tribes and  the public
    to implement ground water strategies program and
   the worker protection programs.
    Continually providing Liaison between the
   public/state officials/regulated industry and Office of
   Pesticide Programs and EPA's Office of
  , Enforcement and Compliance.
   Interacting with other EPA regional programs to
   provide a FIFRA-perspective to community-based
   environmental problems.
   Attending and speaking at public meetings to
   represent and explain the Program.

All  of these activities, and more, are maintained with
small staffs of dedicated, hard working individuals that
care about the environment and want to see pesticides
used correctly to ensure a safe and abundant  food
                                                Page 13/March 1997



     The activities in EPA's Regional Offices are moving
     toward a more multi-media approach.  A team of
     Federal inspectors today are just as likely to inspect a
     facility for violations of the Water and Air Programs, as
     well as, programs that regulate the production and
     release of toxic chemicals. This trend is designed to
     save the federal government time and money and still
     maintain an enforcement presence. The regional
     pesticide programs have always been an integral part of
     the Program and have served the agricultural
     community and the general public well over the years.

Office Location
Boston, MA
Edison, NJ
Philadelphia, PA
Atlanta, GA
Chicago, IL
Dallas, TX
Kansas City, KS
Denver, CO
San Francisco, CA
Seattle, WA

General Phone
     Note: Article written by John Tice in cooperation with
          PESP contacts in the Regions.
The Campbell Soup Company, Del Monte Foods and
Sun-Maid Growers, along with two other groups,
received the California Department of Pesticide
Regulation's coveted "IPM Innovators" award.

Each of the organizations is proactive in leading the
way for adopting IPM techniques and reducing the risk
from pesticides. The awardees either effectively
reduced the usage of pesticides, expanded application of
pest monitoring, reduced worker exposure to pesticides,
or, took other actions that earned recognition, according
to the IPM Innovators Program.

To learn more about the IPM Innovators Program, visit
then- web site at: html://cdpr.ca.gov
          For More Information on PESP
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