United States
Environmental Protection
Agency
Office of Pesticides
and Toxic Substances
Washington, DC 20460
70019881
August 1988
Pesticides and Toxic Substances
Summary of State Commissioners Meeting on EPA Proposed
Strategy on Agricultural Chemicals in Ground Water
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U. S. Environmental Protection Agency
Summary of State Commissioners Meeting on EPA Proposed
Strategy on Agricultural Chemicals in Ground Water
Summary of Proceedings:
June 7,1988
State Commissioners Meeting
Washington, D.C.
List of Attendees:
Steve Ainsworth
Summer Fellow
EPA
410M.Street,S.W.
Washington, D.C. 20460
Charles Aller, Chief
Bureau of Groundwater Protection
Florida Department of Environmental Regulations
2600 Blair Stone Road, Twin Towers Building
Tallahassee, Florida 32399-2400
(904) 488-3601
Robert Amato, Assistant Director
National Association for State Departments of Agriculture
1616 H. Street, N.W.
Washington, D.C. 20006
(202) 628-1566
Diane Aye, Epidemiology Consultant
Connecticut Department of Health Services
150 Washington Street
Hartford, Connecticut 06106
(203) 566-2038
Robert Barles
EPA
Office of Pesticides and Toxic Substances
Crystal Mall #2,1115
Arlington, Virginia 22201
(703) 557-7201
James A. Barnes, Deputy Administrator
EPA
401 M. Street, S.W.
Washington, D.C. 20460
Theresa Benincasa, Associate Director
Association of State and Territorial Health Officials
(ASTHO)
6728 Old McLean Village Drive
McLean, Virginia 22101
(703) 556-9222
Dale M. Cochran, Secretary
Iowa Department of Agriculture
Wallace Building
Des Moines, Iowa 50319
(515) 281-5322
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U. S. Environmental Protection Agency
Dick Dewling, Commissioner
New Jersey Department of Environmental Protection
401E. State Street
Trenton, New Jersey 08625
(609) 292-2885
Robert Ehart, Executive Assistant
Office of the Commissioner
Wisconsin Department of Agriculture, Trade and
Consumer Protection
801 West Badger Road
Madison, Wisconsin 53713
(608) 267-9423
Michael "Mick" Finn, Assistant Commissioner
Minnesota Department of Health
717 Delaware Street, S.E.
Minneapolis, Minnesota 55440
(612) 623-5460
Dr. Richard Freeman, Toxicologist
Florida Department of Health and Rehabilitative Services
1317WinewoodBlvd.
Tallahassee, Florida 32399
(904) 488-2905
Dennis Grams, Director
Nebraska Department of Environmental Control
301 Centennial Mall Square
Lincoln, Nebraska 68509
(402) 471-2186
Mark Greenwood, Associate General Counsel
EPA
Pesticides and Toxic Substances Division
401 M. Street, S.W.
Washington, D.C. 20460
(202) 382-7505
Linda Hyman
EPA
Office of Pesticides and Toxic Substances
Crystal Mall #2,1115
Arlington, Virginia 22201
(703) 557-7102
Victor Kimm, Deputy Assistant Administrator
EPA
Office of Pesticides and Toxic Substances
401 M. Street, S.W.
Washington, D.C. 20460
(202) 382-2910
Thomas T. Irvin, Commissioner
Georgia Department of Agriculture
Agriculture Building, Room 204
Capitol Square
Atlanta, Georgia 30334
(404) 656-3600
Michael Jarrett, Commissioner
South Carolina Department of Health and Environment
Wade Hampton Office Building
Columbia, South Carolina 29211
(803) 734-5000
Kevin Kessler, Chief
Groundwater Management
Wisconsin Bureau of Water Resources
101 S. Webster
Madison, Wisconsin 53707
(608) 267-9350
John M. Lawrence, III, Commissioner
Rhode Island Division of Agriculture
22 Hayes Street
Providence, Rhode Island 02908
(401) 277-2781
Dr. Charles S. Mahan, State Health Officer
Florida Department of Health and Rehabilitative Services
1317WinewoodBlvd.
Building 1, Room 115
Tallahassee, Florida 32399
(904) 487-2705
Marian Mlay, Director
EPA
Office of Ground Water Protection
East Tower, 811
401 M. Street, S.W.
Washington, D.C. 20460
(202) 382-7077
John A. Moore, Assistant Administrator
EPA
Office of Pesticides and Toxic Substances
East Tower, 637
401 M. Street, S.W.
Washington, D.C. 20460
(202) 382-2902
Gary O'Neal, Director
Air and Toxics Division
EPA Region X
1200 Sixth Avenue
Seattle, Washington 98101
(206) 442-4762
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U. S. Environmental Protection Agency
Ron Oshima, Chief
Environmental Monitoring and Pesticide Management
Branch
California Department of Food and Agriculture
1220 N Street
Sacramento, California 95814
(916)445-7126
Hon. Dr. Martha E. Rhodes, Deputy Commissioner
Florida Department of Agriculture and
Consumer Services
The Capitol
Tallahassee, Florida 32399-0818
(904) 488-3022
Richard R. Rush, Director
Idaho Department of Agriculture
2270 Old Penitentiary Road
Boise, Idaho 83712
(208) 334-3240
Robert Schwarberg
Bureau of Chief Laboratories
Illinois Environmental Protection Agency
2200 Churchill Road
Springfield, Illinois 62706
(217) 782-2829
Lewis Shaw, Deputy Counsel
Environmental Quality Control
South Carolina Department of Health and Environment
Wade Hampton Office Building
Columbia, South Carolina 29211
(804) 734-5000
Gayle Smith, Director
Bureau of Drinking Water Sanitation
Utah Division of Environmental Health
288 N. 1460 West
Salt Lake City, Utah 84116-0700
(801) 538-6421
William A. Spratlin, Director
Air and Toxics Division
EPA Region VII
726 Minnesota Avenue
Kansas City, Kansas 66101
(214) 655-0104
L. Don Thurman, Acting Associate Commissioner
Texas Department of Health
1100 W. 49th Street
Austin, Texas 78756
(512)458-7542
John Torphy, Administrator
Wisconsin Division of Health
1 W. Wilson Street, Room 218
Madison, Wisconsin 53707
(608)266-1511
Lee M. Thomas, Administrator
EPA
West Tower, 1200
401 M. Street, S.W.
Washington, D.C. 20460
(202) 382-4700
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U. S. Environmental Protection Agency
DATE
EVENT
August 1986
July 1987
February 1987
February 1988 to
June 1988
June 1988
Fall 1988
Coolfont I: Agricultural Chemicals in Ground Water 1986
Pesticide Strategy Workshop
Coolfont II: Agricultural Chemicals in Ground Water 1987
Pesticide Strategy Workshop
Publication, of EPA's Strategy Document: Agricultural Chemicals
in Ground Water: Proposed Pesticide Strategy
Public Comment Period
Informal Conference of Selected State Regulators
Meetings to Discuss Agricultural Chemicals in Ground Water:
Proposed Pesticide Strategy
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U. S. Environmental Protection Agency
Table of Contents
Page
I. Introduction 7
II. The Florida Case History 10
in. The Wisconsin Case History 13
IV. Pesticides in Ground-Water Strategy 17
A. Approaches to the National Strategy 18
B. Intrastate/Interstate Coordination 20
C. Funding State Programs 21
D. Support States Want the Federal Government to Provide 21
E. Interaction with the Private Sector 22
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U. S. Environmental Protection Agency
fZ-£/( to rig/i/J /o>ui X. Moore, Lee M. Thomas, and Thomas T. Irvin hear concerns during the discussion on EPA's role in determining ground-water
protection strategies.
I. INTRODUCTION
As part of its efforts to solicit ideas and reactions to its
proposed new strategy of regulating pesticides to protect
ground-water resources, the Environmental Protection
Agency's (EPA) top officials met June 7,1988, with a small
group of top-level officials of state agriculture, public health,
and environmental agencies from around the country. The
meeting was held with the assistance of the National
Association of State Departments of Agriculture and included
formal presentations by delegations from the S tales of Florida
and Wisconsin, as well as a general roundtable discussion of
the pertinent issues involved in addressing this increasingly
important agricultural, environmental, and public health
concern.
At the meeting. Lee Thomas, EPA Administrator, noted
that a fundamental change in the approach to regulating
pesticides was being proposed. An approach that provides
an opportunity for each state to play a greater leadership role
in the management of pesticides to protect its ground-water
resources.
"We have been questioned about whether this
change, shifting pesticide management from
primarily a federal function to one more dependent
on an increasing management role by the states, is
appropriate. Is it realistic? What requirements
from EPA will be needed to assure state action, yet
not interfere unduly with each state's ability to
tailor its program to its ground-water conditions?"
— Lee Thomas, EPA Administrator.
This document is a summary of the discussions by the
meeting participants as they attempted to address these and
other questions posed by the EPA Administrator. The
document is divided into three parts: (1) a short opening
remarks section; (2) the presentations by the delegations
from the States of Florida and Wisconsin; and (3) a main
section that attempts to capture the roundtable discussions of
the key issues. The commentary has been somewhat
rearranged into topic areas in this presentation for clarity.
This was not EPA's first meeting on this broad topic nor
will it be the last EPA is reviewing and codifying comments
that were solicited and received on the proposed strategy for
protection of ground water from pesticide contamination
and expects to issue a revised strategy in December 1988.
The Agency is also planning a series of regional meetings
with state officials, both at the Commissioner level and the
working level. Additionally, EPA's proposed registration
decision on the pesticide aldicarb — published subsequent
to the June meeting—sets forth management measures that
fully incorporate the concepts and approaches put forth in
the strategy (i.e., implementation of state pesticide ground-
water management plans). EPA is seeking wide public
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U. S. Environmental Protection Agency
comment on the aldicarb proposal as well. It is EPA's intent
to continue to deal with the difficult questions of this concern
as openly and as fully as possible.
OPENING REMARKS
EPA's Administrator, Lee Thomas, began the session
by explaining that earlier meetings with state officials through
the National Association of State Departments of Agriculture
(NASDA) had clearly indicated that concern about pesticides
in ground water was one of today's more difficult issues
requiring coordination not only between federal and state
efforts but also between agencies representing agricultural,
environmental, and public health interests. The purpose of
today's session was to broaden input on this issue by inviting
a small group of state agency commissioners from around
the country representing all of these interests to discuss
concerns about pesticides in ground water.
• Is this proposed approach realistic; can it be
implemented?
• What would be required of the states to make it
work?
• What can EPA learn from the states' experiences?
John Moore, EPA's Assistant Administrator for
Pesticides and Toxic Substances, noted that, in dealing with
the concern over pesticides in ground water, "we are not
starting from ground zero;" in fact, there has been a significant
amount of activity by both EPA and the states in addressing
this concern. However, a cohesive plan is needed that will
help coordinate different program efforts and establish an
appropriate balance between national and state roles and
responsibilities. Increasing reports of pesticide detection in
ground water have spurred the desire fora national program.
At the same time, our increased understanding of the site-
specific nature of the ground-water resource and sources of
L. Don Thurman, Texas Department of Health, and Theresa Benincasa, ASTHO, participated in the round table discussion.
The Administrator noted that EPA's proposed strategy
for dealing with the ground-water concern pointed to a
fundamental shift in state and federal responsibilities;
specifically, the states will play an increasing role in pesticide
management decisionmaking. Recognizing that state
management plans are key components of a national pesticide
strategy, the Administrator stated that they could be a model
for other intergovernmental approaches to environmental
concerns. He raised three basic questions concerning the
states' role in the strategy:
potential contamination indicates that states must nave the
flexibility necessary to tailor management measures to
specific ground-water protection needs.
EPA has registered pesticide products and their uses
based on a national assessment of the risks and benefits of
each pesticide's application. In some cases, EPA denied
new pesticide products or uses or cancelled existing pesticide
uses based on these national assessments. For those pesticide
products registered, the Agency directed the user through
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U. S. Environmental Protection Agency
label instructions, and in some cases applicator training, on
the legal uses of the chemical. These label instructions were
uniformly applicable to all users across the country. EPA,
however, now recognizes that the potential for pesticides to
contaminate ground-water resources depends on site-specific
factors. In these cases, national assessments and uniform
label instruction may be less ideal than a more differentiated,
site-specific approach. For appropriate ground-water
protection, the Agency believes that pesticide management
measures need to be based on specific local protection needs.
EPA's strategy, therefore, encourages states to take the lead
role in tailoring pesticide management measures to protect
their ground-water resources.
Dr. Moore questioned what the federal role should be in
an approach that emphasizes strong state management
responsibilities:
• Should EPA define the "critical mass" required for
a successful state management plan?
• To what degree should there be oversight by EPA
of state management plans once in place?
• Should the Agency involve itself in site-specific
reviews of state management efforts?
Dr. Moore pointed out that the real difficulty in dealing
with managing pesticides to protect ground water is in
determining the appropriate measures to be taken for the
"gray areas." Based on such key factors as local
hydrogeology, pesticide use, and other farming practices,
one could designate areas as being at high, moderate, or low
risk with regard to ground-water contamination by pesticides.
Areas at high risk are those where the danger is so readily
apparent to pesticide users to the degree such that
implementing protection measures will be accepted readily.
Areas at low risk are those wherecontamination problems
are probably minimal, so that the consequences of taking
inadequate measures to protect human health and the
environment are probably not significant. The medium risk
or "gray areas" are those sites where appropriate protection
measures will be the most difficult to determine, but where
the consequences of a wrong decision could be significant.
Further, such determinations may be the most needed since
it is likely that much of the Nation's agricultural lands will
fall into moderate risk designation. Clearly.itis the moderate
risk areas that will benefit most from management measures
tailored specifically to local needs.
Thomas T. Irvin, Commissioner of Agriculture for
Georgia and Chairman of NASDA's Subcommittee on
Ground Water of the Committee on Agriculture, reminded
the participants of the public's need for both clean water and
an adequate food supply and urged all to help EPA design a
realistic policy that clearly considers both of these goals. He
noted that responsibility at the state level for addressing the
problem of pesticides in ground water can rest with two or
more agencies with different missions, functions, and
expertise. In these cases, conflicting authorities can
potentially pose major institutional barriers to effective
program implementation. It is necessary to discuss possible
approaches to overcoming such barriers and to help promote
an Agency strategy that does not compound the problem.
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II.The Florida Case History
Dr. Martha E. Rhodes and Dr. Charles Mohan presented an Overview of Florida's activities in pesticide control and ground-water protection.
Officials from the State of Florida, representing the
three State departments concerned with the management of
pesticides and ground water, addressed the meeting and
presented an overview of the State's activities related to
pesticide control and ground-water protection. Presentations
were made by the Hon. Dr. Martha E. Rhodes, Assistant
Commissioner of the Department of Agriculture and
Consumer Services (DACS); Mr. Charles AUer, Chief of the
Bureau of Ground Water Protection, Department of
Environmental Regulation (DER); and Dr. Charles Mahan,
State Health Officer and Deputy Assistant Secretary for
Health and Rehabilitative Services (DHRS). Dr. Rhodes, on
behalf of the Florida delegation, presented an overview of
Florida's pesticides program and the coordinated efforts of
the three respective departments. Mr. Aller and Dr. Mahan
followed Dr. Rhodes and discussed the roles and activities of
their respective departments.
Background and Philosophy
Florida isa major agricultural state with 85 percent of its
land used for the production of food stuffs and forest
management As such, Florida's agriculture industry is a $5
billion per year business. The use of pesticides in agricultural
production is significant Additional pesticides are used in
mosquito control and other S tate pest management programs
and by private citizens. Environmental concerns about
pesticide usage in the State center on potential impacts on the
State's ground-water resources. Florida has been
characterized as a "sand bar connected to Georgia" because
of its highly permeable soils. The ground water in the State
is used as the source of drinking water for over 90 percent of
the State's population. The highly permeable soils and high
ground-water table make this valued resource vulnerable to
contamination by pesticides and other contaminants if these
are improperly used or not regulated. Concern about ground-
water contamination bypesticides has resulted inaheightened
awareness of the benefits and costs associated with their use.
Dr. Rhodes reported that Florida's current philosophy is
that ground-water protection and agricultural viability are
notmutuallyexclusiveinterestsbutrathermutuallyobtainable
goals. The development of Florida's pesticide control
program reflects this philosophy. Florida's DACS, DER,
and DHRS coordinate pesticide-related activities to protect
the ground water from pesticide contamination while at the
same time ensuring the continued success of agriculture
within the State. The State concedes that low levels of
pesticides in ground water may have to be tolerated. However,
the focus of the program must be on the prevention of
ground-water degradation to levels of potential health
concern.
State Legislative Action and Program
Responsibilities
Florida's current coordinated pesticide control effort
finds its roots in the EDB contamination discovery in 1982,
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although active regulatory programs existed in individual
agencies before that date. Documented EDB contamination
of ground water and food galvanized Florida to undertake
various activities aimed at detecting and remediating EDB
contamination and preventing further degradation of ground
water. In 1983, in response to a variety of ground-water
contamination concerns, the State passed the Water Quality
Assurance Act This Act established additional pesticide-
relatedpersonnelpositionsatallthreeagencies. The purpose
of this was to enhance the ability of the State to deal with
impacts of pesticides on ground water and their effects on
human health. The Act also established the Pesticide Review
Council and set up the Water Quality Assurance Trust Fund
for the clean up of contaminated ground water and associated
corrective measures. In addition, aGround Water Protection
Task Force was set up to investigate the contamination
problem. The responsibilities and respective roles of the
three State agencies concerned with the management of
pesticides and ground water and the appointed pesticide
groups are highlighted in the following discussion.
The Department of Agriculture & Consumer Services
has been designated the State lead agency for pesticides. In
this lead role, D ACS is responsible for pesticide registration,
dealer and applicator licensure, enforcement, and laboratory
support. DACS's Pesticide Registration Evaluation
Committee, composed of representatives of five State
agencies, reviews all special local need applications,
emergency exemptions, restricted use registrations, and
experimental use permits along with the State's review of
currently registered products as required or requested. Two
Memoranda of Understanding (MOUs), signed in 1985,
delineate the roles and jurisdiction of DACS, DER, and
DHRS. The memoranda recognize the importance of
interagency cooperation in addressing pesticide issues.
Additional MOUs exist with the Department of Natural
Resources, the Game and Freshwater Fish Commission, and
theresearch involved with the Institute of Food & Agricultural
Sciences at the University of Florida.
In support of the State's pesticide control program, the
DER is responsible for the classification of all ground
waters, the regulation of public drinking water sources, and
regulation of all discharges to ground water, which may
contain pesticides. These activities include the identification
and mapping of areas vulnerable to pesticides and other
ground-water contaminants. The DER is also responsible
for ground-water monitoring and pesticide remediation
activities, including the replacement of contaminated water
supplies, as directed by the Ground Water Protection Task
Force.
The DHRS and the State Health Officer, Dr. Mahan,
serve as the State's public health advisor. Originally more
oriented toward sanitation issues, the DHRS has broad
authority to protectpublic health andconsiders environmental
pollution as a public health issue. As such, DHRS has
instituted programs to control toxic substances and serves as
the State's environmental health review authority. DHRS
staff also collect environmental samples and provide
environmental chemistry laboratory support In addition,
the Department's large field staff can be mobilized quickly
to deal with environmental emergencies.
The Pesticide Review Council, established by the Water
Quality Assurance Act as an advisory body to the
Commissioners of Agriculture, is a central coordinating
group composed of representatives from DACS, DER,
DHRS, a lexicologist, an environmental scientist, a
hydrologist, an independent scientist, and representatives of
industry and environmental groups. The Council oversees
pesticide policy development within the State and is
responsible for the review of State pesticide programs;
development of recommendations associated with pesticide
issues and programs; the review of public health and
environmental effects associated with pesticides; and
participation in the pesticide registration process. The initial
focus of the Council was to perform an assessment of the
State's hydro-geologic and environmental conditions. This
assessment is continuously updated by DACS. As part of
this effort, the State, through Council member agencies, has
developed site-specific ground-water monitoring programs
at pesticide application sites. There is also a statewide
ground-water monitoring system that examines regional
water quality; the program includes the sampling of over
3,000 wells across the State. Wells in agricultural areas are
monitored for 65 pesticides. Council member agencies also
prepare pesticide assessments and conduct random, yearly
restricted-use surveys. The Council prepares an annual
report which summarizes its activities. This year the
legislature expanded the Council's powers to coordinate the
pesticide activities of the three departments as well as to
make comments to the Federal government, and to
recommend resources, studies, and other actions that are
required.
The legislature also made the Ground Water Protection
Task Force, initiated by the Governor in response to the 1983
discovery of EDB contamination,apermanentbcKly in 1984.
Florida's Current Pesticide Program Activities
The State has numerous ongoing studies and programs
related to the various pesticide monitoring, management,
and control issues. The Ground Water Protection Task
Force has completed most of its work related to EDB, except
for ongoing monitoring. The Task Force has focused its
activities on five predominantly citrus-growing counties
based on initial sampling efforts performed in all 67 counties.
The State and individual pesticide producers have provided
funds to support EDB corrective actions, including the
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installation of granular activated carbon (GAC) filters in
drinking water wells and connections to public drinking
water supplies. Several studies are being conducted under
the guidance of the Task Force, including a study to determine
the service life of GAC filters, an EDB aeration study, and
a congenital defects study. The Task Force has estimated
that approximately one million dollars will be required
annually to maintain previously installed GAC filters.
The DACS, DER, and DHRS are presently involved,
through its member agencies, in a number of pesticide
studies and monitoring programs and report these findings to
the Pesticide Review Council. In its latest annual report, the
Council reported that the DACS had performed 1,495
regulatory inspections and collected 1,525 samples in the
past year. DACS also issued 543 warning letters, 62 stop-
sale or hold actions, 13 administrative fines, and referred 51
cases to EPA for action. They review and monitor a
continuous surveillance program of commercial applicators
of aldicarb as well as a 30-county, long-range survey of wells
adjacent to high volume farms, representing roughly 91
percent of the State's agricultural production. Studies are
also being conducted on volatile fumigants, alternative
control methods including biological pest controls, field
packing water usage reduction and management practices,
and rinse water degradation methods. DACS also supervises
the annual restricted-use survey which examines the reported
application of restricted-use pesticides by types and quantities
of pesticides, methods of application, crops treated, and
dates and locations of application.
_*•
To date, approximately 15 to 19 pesticides have been
detected in Florida's ground water. The State's position is
that ground-water contamination by pesticides is a localized
problem that can usually be prevented or handled by
management plans and site-specific approaches. The State
has found only a few wells where pesticide levels exceeded
health-based standards or advisories. Excluding EDB, since
1985 only 11 ground-water samples have contained pesticide
concentrations at or above the MCL. The State considers its
aldicarb regulation to be a success. Aldicarb application
standards require a 300-foot set back from all potable wells
and a 1000-foot set back from shallow wells in sensitive
areas.
The discovery of pesticide contamination in the State
forced the applicable State agencies to work together to
prevent further contamination while ensuring the continued
success of agriculture in the State. The State representatives
indicated that while this was not always an easy task, the
success of the current program illustrates that interagency
cooperation and coordination can be achieved.
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The Wisconsin Case History
Three Agencies in the State of Wisconsin share
responsibility for protecting ground water and human health
from pesticide contamination. The program is coordinated
such that the Department of Health and Social Services
(DHSS) develops and proposes health-based standards, the
Departmentof Natural Resources (DNR) adopts these health-
based standards after scientific review and public hearings,
and the Department of Agriculture, Trade, and Consumer
Protection (DATCP) promulgates pesticide use regulations
and monitors compliance with the regulations.
Representatives from each of these agencies attended the
meeting and presented an overview of the State's activities
related to pesticide controls and ground water protection.
Dr. John Torphy, Administrator of DHSS's Division of
Health, discussed the standards setting process; Mr. Kevin
Kessler, Chief of DNR' s Ground Water Management Section
of the Bureau of Water Resources, presented the standard
adoption process and the DNR role in coordinating ground-
water protection; and Mr. Orlo Ehart, executive assistant to
the Secretary of DATCP, outlined his agency's regulatory
and outreach responsibilities.
Background and Philosophy
Ground water is Wisconsin's major source of drinking
water. All of the State's aquifers are used as drinking water
sources and over half the State's population is dependent on
private wells for its drinking water. Wisconsin also has a
large agricultural industry. Dairy farms, frozen foods, and
cranberries are important agricultural commodities.
Therefore, the State needed to develop a ground-water
protectionstrategy that ensured public safety while promoting
agricultural production. Wisconsin adopted numerical
ground-water standards to protect public health and welfare
in 1984, repealing the earlier "no detrimental effects - no
significant impacts" policy, to reflect the State's desire to
quantify unacceptable risks from ground-water contaminants.
The State realized early on that accepted agricultural
practices aimed at maximum production can have adverse
effects on the environment, causing both nonpoint and
ground-water pesticide contamination problems. The State
also realized that these problems are difficult to address. The
State asserted that outright bans on the use of specific
pesticides were not the best approach if there were alternative
ways of complying with the ground-water standards. Instead,
the State found it needed to emphasize site-specific
management plans and enforcement of pesticide use
provisions to prevent contamination.
State Legislative Action
In 1984, the State legislature passed the "Ground Water
Law," which codified many of the existing and emerging
efforts of State agencies to protect ground water. This law
established the procedures by which the three State agencies
would cooperate in the establishment and enforcement of
ground-water standards. As a result of this law, in 1984 the
State initiated a program to establish numeric standards for
the presence of chemicals in ground water.
The legislative action directed the State to set and use
drinking water maximum contaminant levels or other Federal
drinking water health advisory levels as its enforcement
standards for ground water. It also defined the preventive
action levels that would provide objective levels for
prevention; these are expressed as a percentage of the
enforcement standard—if reached, the preventive action
levels would trigger remedial actions on the part of the State.
The legislation also established the institutional framewo±
in which the Statemust administer its ground-water program.
DHSS is responsible for developing health-based standards
based on EPA's maximum concentration level (MCL) and
the best available scientific evidence. In the absence of an
MCL or another "Federal number," DHSS must review the
literature and propose its own standard. DNR is responsible
for reviewing DHSS's proposed standards, soliciting public
comment and adopting the health-based standards. Both the
enforcementstandardandpreventiveaction level are adopted
by DNR. DNR is also responsible for routine ground-water
monitoring to assess problems caused by pesticides and to
forward to DATCP information on pesticides that are
exceeding the preventive action level. DATCP, the State
FIFRA lead agency, is responsible for initiating remedial
actions to mitigate the impacts of pesticides on ground
water. This may entail the promulgation of pesticide use
regulations such as restrictions on use or new management
practices.
Aldicarb in Ground Water
Wisconsin's approach to pesticide managementresulted
from the 1980 discovery of aldicarb in ground water. The
contamination resulted from the application of the pesticide,
according to label instructions, on the State's potato crop.
Wisconsin's intended use provision enabled DATCP to
identify aldicarb users and the approximate number of acres
under cultivation. DATCP was then able to issue an
emergency rule to restrict the use of aldicarb. This emergency
rule, and a permanent rule the following year, altered the
amount of aldicarb that could be applied as well as the timing
of the application to prevent further contamination of ground
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water. The rules also established use moratorium areas
where aldicarb can not be used. Moratorium areas are circles
with a one mile radius around wells where aldicarb had been
found above 10 ppb.
The presence of aldicarb in ground water provided the
catalyst for the development of Wisconsin's approach to
pesticide management. The State agencies were forced to
work together to develop a comprehensive approach utilizing
the strengths of each agency. As stated above, this approach
was adopted by the State legislature in the 1984 Ground
Water Law.
Wisconsin's Approach
The major steps in thedevelopmentof ground- water standards
are discussed in detail below.
The Departmentof Health and Social Services, Division
of Health, is responsible for developing the proposed standard.
DHSS utilizes a list of substances prepared by DNR and
arranged according to categories and rankings within the
categories. The DHSS develops the standards in accordance
with this priority list. Typically, DHSS develops
recommendations for about 12 substances per year. The list
includes new chemical substances for which standards do
not yet exist, as well as chemicals that have standards which
may need to be revised. If Wisconsin has adopted a standard
and EPA promulgates an MCL, DNR will reevaluate its
standard to determine if arevised standard should be adopted.
The standard development process typically takes 24
months once the chemical substance is placed on the State
list. DHSS evaluates the scientific evidence upon which
EPA's MCL and other States' drinking water standards are
based as well as any additional information that is available.
If there is an MCL for the chemical substance, DHSS
evaluates the information that has been developed since the
MCL was established. If no new information is available,
the MCL is typically proposed as the S tate standard. However,
if the review of the available information indicates that a
different standard is appropriate, DHSS will recommend an
alternative standard. For carcinogenic substances, DHSS
recommends a 10-6 risk level while, for non-carcinogenic
substances, a "no effects" level is proposed. The results of
the DHSS evaluation is documented in a preliminary draft
support document which is reviewed by the Department of
Natural Resources.
DNR is responsible for reviewing the support document
and providing comments and recommendations on the
standard to DHSS within 60 - 90 days. DHSS revises its
preliminary recommendation, if necessary, and prepares
recommendations for DNR consideration. DNR must
propose the DHSS recommendation for public hearings but
may adopt a different standard. The preventive action limit
(PAL) is set at 10 to 20 percent of the enforcement standard
for health-related substances, depending on carcinogenicity.
The PAL is used as the objective level for preventive
measures as well as a remedial action trigger by State
regulatory agencies, including DATCP. These two standards
are similar to EPA's "yellow light, red light" proposal. DNR
holds public hearings on the standard and reviews the
comments that are submitted. DNR is responsible for
modifying the standards, if necessary, and adopting the final
standards. The State legislature has an opportunity to review
DNR's decision before it becomes official.
Once the standard is adopted, all State agencies are
responsible for reviewing and, if necessary, modifying their
rules to comply with the new standards. One of the goals of
the DNR in developing the standards is to maintain
consistency between the ground-water standards and the
drinking water standards.
Richard R. Rush, director of Idaho Department of Agriculture, helped
determine what approach Slates favor by the federal government.
Wisconsin currently has standards for 50 substances of
which 12 are pesticides. There are an additional 14 standards
pending, including standards for atrazine and alachlor, the
two most widely used pesticides in Wisconsin.
When a contaminant for which a standard has not been
developed is found in ground water, DHSS may recommend
an interim health advisory limit to DNR. While the interim
numeric limit is not officially sanctioned and is not
enforceable, it provides a mechanism to guide DNR and
DATCP action and provides a measure against which the
public can assess whether a health risk exists.
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U. S. Environmental Protection Agency
Current State Activities
D ATGP has developed an application-based preventive
action program. Under this program, DATCP is identifying
and mapping crop and pesticide use throughout the State.
This action will assist the State in determining where
monitoring for specific pesticides should be conducted and
where use provisions may need to be developed. These
provisions are developed based on an understanding of the
agricultural uses, pesticides usage, and hydrogeology of the
area. A computer model of the State's hydrogeology has
been developed. This model allows the State to map the
flow of ground water and determine areas where monitoring
may be needed.
DATCP, as the lead FIFRA agency, is currently
emphasizing the development of best management practices
(BMP). DATCP is developing BMPs for the remediation of
pesticide effects on ground water as well as bulk storage
rules and secondary containment and design standards.
Robert Efiart, right, discusses his agency's responsibilities with Ron Oshima, California Dept. of Food and Agriculture.
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U. S. Environmental Protection Agency
IV. PESTICIDES IN GROUND-
WATER STRATEGY
EPA's proposed pesticides in ground-water strategy
was developed through a series of workshops, Federal
Register Notices, and analysis of public comments. This
document summarizes the comments of State Agriculture,
Environmental, and Public Health Commissioners who
participated in a discussion concerning EPA's proposal.
The meeting was sponsored by the Office of Pesticide
Programs (OPP) on June 7,1988. Commissioners from 15
states attended this meeting to discuss the strategy's effects
on their states and to learn from the experiences of Florida
and Wisconsin.
The development of EPA's proposed pesticides in
ground-water strategy benefited from a series of workshops
with officials from states and other federal agencies as well
as representatives from industry, farm, agricultural, and
environmental groups. The proposed strategy for formal
public review was published in the Federal Register on
February 16,1988. The public comment period ended on
June 27,1988.
The strategy has been developed to be consistent with
the Federal Insecticide, Fungicide, and Rodenticide Act
(FIFRA), to benefitagriculture and to address environmental
concerns. The strategy will be revised in light of the
comments received and the Agency will begin implementing
it during the coming year. Its implementation will result in
a fundamental change in the way EPA manages and regulates
pesticides and in the roles that state governments will play.
States will become responsible for developing management
plans to protect their ground water resources from pesticide
contamination. To ensure the strategy's success, EPA will
retain several important functions, such as the identification
of pesticides requiring management plans and review/
approval of the state plans. Where a state chooses not to take
a lead role in developing and implementing a management
plan, EPA will have to rely on its own assessments and
management measures to protect ground water in that state.
In such states, an EPA-directed approach may result in
county- or state-wide cancellations of pesticides that pose
ground-water concerns.
The following discussion presents a summary of the
major issues raised by the state commissioners during the
meeting.
• National Strategy
- Approaches
- EPA's Role
- Establishment of a "Level Playing Field"
Kevin Kessler (left) and Michael Finn represented the states of Wisconsin and Minnesota, respectively, in the meeting of state commissioners.
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U. S. Environmental Protection Agency
• Intrastate/Interstate Coordination
- Lead Pesticide Agency
- EPA Role as Facilitator/Coordinator
• Funding State Programs
- Federal Funding or State Funding
- User Fees/Registration Fees
• Support States Want the Federal Government to
Provide
• Interaction with the Private Sector
Approaches to the National Strategy
Two alternative approaches for a national strategy were
discussed by the state commissioners. The approaches
discussed were:
• A single national plan that would be adopted by
every state
• Individual state-specific plans.
The state commissioners agreed that a single national plan
would not be an effective approach. The hydrogeology, land
uses, and agricultural practices vary considerably across the
country, emphasizing that what might make sense in one
state might not necessarily make sense in another. The
commissioners generally felt state-specific plans would be
the most workable, although a regional or multi-state plan
could also be effective (see later discussion).
Dale Cochran, Secretary of Agriculture for the Slate of Iowa.
participated in the meeting.
A concern raised by one commissioner was that the
state-specific approach could lead to the banning of the sale
and/or use of a pesticide in one state and its continued use or
sale in a neighboring state. Under this set of conditions, a
fanner could obtain the pesticide from out-of-state sources
and continue to use it
Another important consideration raised by several state
commissioners concerned non-agricultural pesticide uses
that should be considered in the development of state
management plans. In several states, land used for golf
courses, turf farms, and right-of-ways may receive large
applications of pesticides but may not be considered
agricultural lands and, therefore, possibly omitted from the
state pesticide management plans. These commissioners
felt that in order to maintain consistency among the states
(e.g., a "level playing field") and to protect ground-water
resources, these and similar land categories need to be
included in the plans.
The commissioners also felt it was extremely important
to maintain maximum state flexibility and to allow the states
to develop pesticide management plans that would meet
their specific set of conditions. Several commissioners
suggested that EPA establish a set of minimum program
standards that the states must satisfy. This approach would
allow the states to develop programs that are more responsive
to their individual needs while providing some minimum
consistency to help ensure a "level playing field."
Several commissioners questioned how the state plans
would be enforced and what role EPA would play in
enforcement and oversight. One commissioner suggested
that EPA develop an approach to enforcement that can be
built into each state's pesticide management plan. The
commissioners felt that although national bans work (i.e.,
enforcement is relatively easy), they reduce the flexibility of
the states' management strategies and do not reflect the
differing vulnerability of ground water. Stateplans, however,
would require the states to initiate more site-specific
enforcement actions and possible enforcement of usage
requirements which is very difficult One commissioner
commented that you must have an effective enforcement
process, or it risks becoming "just another case of a program
without any teeth."
Establishment of the "Level Playing Field"
One of the most significant roles that the states are
looking towards EPA to fulfill, is ensuring that a "level
playing field" is maintained among the states. The state
commissioners expressed a strong sentiment that EPA
establish uniform requirements for the development of state
pesticide management plans and for the protection of ground
water. The establishment of a national set of requirements
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U. S. Environmental Protection Agency
Cayle Smith, Utah Division of Environmental Health, and Charles Aller, Florida Department of Environmental Regulations, discussed the proposed
strategy and its effect on their states.
will help to ensure that competitive advantages are not
afforded to any one state or region of the country. The
commissioners were concerned that without a uniform set of
standards, state responses to the presence of pesticides in
ground water would differ, depending on their own trigger
levels. The state commissioners felt that, while their plans
could establish more sensitive trigger levels than the minimum
federal requirements, EPA needs to establish the "yellow
light" level for each pesticide that would force states to take
preventive actions as well as the "red light" level.
The issue of establishing the reference point or trigger
level to determine when state action is required, received
considerable attention. Several state commissioners
presented their state's approach which ranged from 1) action
if a pesticide was detected in ground water, 2) action if the
pesticide was detected at S to 10 percent of the MCL or other
applicable standard, and 3) action once the pesticide was
detected at the MCL. Most commissioners felt that in order
to maintain consistency among the states, a minimum action
level or a "yellow light" level was needed. One commissioner
pointed out that even if EPA established a national action
level, each state should have the right to set a more protective
action level. Most state commissioners agreed that the
"yellow light" should be set below the MCL to prevent
pesticide concentrations from reaching the MCL. There was
also general agreement that the detection limit could be too
low in many cases to be an appropriate "yellow light"
trigger. However, the commissioners did not feel that there
was sufficient information, analytical methods, or quality
assurance data available to determine the appropriate
reference point
Most state commissioners indicated that they refer to
EPA's MCL as the base reference point in their decision-
making process. According to one commissioner, the MCLs
are suitable because they have been developed through due
process procedures. In contrast, the health advisories issued
by EPA are not nearly as useful. Other commissioners
disagreed, arguing that the health advisories provide guidance
to the states in the absence of published MCLs. Florida
defers to the MCLs when they are available, but Wisconsin
has developed its own program to promulgate ground-water
standards. Deference is given to the MCL if one has been
published, but Wisconsin reserves the right to set a more
stringent standard. If an MCL is developed after the
Wisconsin standard has been published, the state standard is
reviewed if the pesticide is added to the state action list
Several commissioners suggested that, when establishing
action levels, the focus be on preventing pollution rather
than on permitting pollution. In particular, there was concern
that using the MCL as the level that would trigger initial
action would encourage pollution up to that level.
Several commissioners pointed out that Florida's and
Wisconsin's programs were initiated in response to
contamination rather than in an attempt to prevent
contamination. Most agreed that it is often easier to develop
a program in response to a problem that has already occurred
(e.g., EDB, aldicarb) as opposed to a proactive program.
In order to ensure that the emphasis of the program is on
prevention rather than response, the commissioners suggested
that each state be mapped according to the potential for
ground water contamination. The commissioners agreed
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U. S. Environmental Protection Agency
with the EPA that the states should be mapped according to
high.medium.andlowground water contamination potential.
They also suggested that the teachability of each pesticide be
reviewed in addition to its physical and chemical properties.
States need to concentrate their efforts on areas were these
pesticides are applied in the highest amounts. However, one
commissioner observed that the highest levels of pesticide
contamination in ground water are often associated with
spills or mishandling at the mixing site and not with the
routine field application.
While special attention should be given to areas
considered to be highly vulnerable, it is also important to
monitor wells to determine what is happening in the "gray
areas." The "gray areas" were defined as the sections of the
country that have a medium probability of being affected by
pesticides. These are the most critical areas and should be
studied to determine the potential impacts because there is
not sufficient information available to determine if a problem
will occur. The states also do not have the necessary
information with which to develop programs to alter the use
of a pesticide and thus prevent it from continuing to leach
into ground water. One commissioner suggested that if it is
not possible to predict the potential impact of the pesticide,
then it may be necessary to ban the use of the pesticide in all
areas except those with very low vulnerability potential.
Intrastate/Interstate Coordination
Another key issue discussed by the commissioners was
the need to encourage intrastate coordination as well as
coordination among the states. A critical component of the
intrastate coordination issue was whether it is necessary to
identify a lead agency for addressing pesticides in ground
water. Based on the experience of Florida and Wisconsin,
several commissioners suggested that it was premature to
designate a lead agency. These commissioners felt that it is
more important to build consensus among the various state
agencies than to designate one lead agency. According to the
commissioners, each agency represents a different
constituency and, therefore, has a different agenda and
mission. In order to build support within a state, from the
governor to the legislature to interest groups and citizens,
each relevant agency must be brought into the process.
Identifying a lead pesticide agency too early in the process
could disenfranchise one group and impede the development
of a cohesive and integrated state plan.
"The biggest challenge facing the state in the
development of management plans is rendering an
organizational consciousness that pesticides in ground water
are a big problem and that the state agencies need to work
together before itbecomes a turf battle and before it becomes
a public health problem."
The commissioners felt that EPA could facilitate
cooperation among state agencies by initiating interagency
dialogue. The commissioners generally agreed that a lead
agency would eventually emerge through the development
of the state management plan, although all of the state
agencies would have a significant role.
One commissioner questioned, however, the ability of
his state to initiate development of a pesticide management
plan without a significant motivating factor. This
commissioner felt that only the threat of a ban would force
state agencies to take action. Several commissioners were
concerned about which EPA program would be the most
effective driving force, pesticides or water. EPA agreed with
the commissioners that, in order to force state action, general
or specific use limitations or bans would need to be imposed
and, therefore, the pesticide program would be the driving
force. The commissioners from Florida and Wisconsin
confirmed that a pesticide contamination problem was,
indeed, what had initiated action in their states, forcing the
state agencies to work more closely together than they had
in the past Money and resources were made available to
address the problem only following its identification and
subsequent public concern.
The development of regional management plans was
also discussed in relation to intrastate/interstate coordination.
One question raised was whether states should adopt a
regional approach in the management of pesticides in ground
water. Most commissioners agreed that regional cohesion
would foster consistency among management programs and
promote the concept of the "level playing field." Such
consistency would aid in enforcement because users would
have fewer opportunities to buy, from a neighboring state,
products banned in their own state. Furthermore, residents of
one state would not be placed at a competitive disadvantage
if an entire region were subject to the same ban or restriction.
One commissioner suggested that the regions might not be
close geographically, but rather, could consist of states that
view one another other as comparable.
A regional approach would also facilitate the
development of an information exchange network. States
could pool their resources and share, for example, the results
of studies tracking the fate of pesticides in different soils.
One commissioner pointed out that such a network would
provide greater incentive for industry to engage in research
efforts because the results could be transferrable over four or
five states,thus increasingpotentialmarketsize. Furthermore,
industry would likely support a regional network, because
compliance with ten or fifteen management plans would be
much less expensive than compliance with 50 such plans.
For example, certain states such as New York, New Jersey,
and Pennsylvania, could work together to develop a regional
plan, as their agricultural practices and hydrogeology are
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U. S. Environmental Protection Agency
relatively similar. In addition, if one state already had a good
program in place, surrounding states would be likely to use
that program as a model for their own management plans.
Another commissioner pointed out that regionalization could
also capitalize on regional thinking that is already evident in
legislative arenas. The commissioner indicated that several
states have identified other states that are outside their
geographic region that are used as comparisons in developing
and evaluating legislative and regulatory programs. These
states could coordinate the development of pesticide
management plans. Finally, most of those present agreed
that there was a need for standard, region-wide training
programs that would instruct fanners on how to follow label
instructions and provide them with information necessary to
make knowledgeable decisions.
Given the consensus that regional thinking was necessary
in this policy area, the next concern addressed was how to
establish such a cooperative approach. Most participants
agreed that regionalization would be best fostered if EPA
took an active role in bringing states together to discuss their
approaches to management of pesticides in ground water.
Those present suggested that the federal role be confined to
that of facilitator and/or coordinator. Participants also
recommended that the EPA sponsor a series of workshops
and discussions as a first step in the development of
management plans. EPA could assist each state by identifying
issues and sharing the experience of other states, thus limiting
the scope and complexity of management within each state.
Several participants emphasized that EPA should be goal-
oriented and not document- or regulation-oriented. Thus,
EPA should help the states develop individual or regional
programs and not force a national program upon them. One
participant asserted that the primary mission of the federal
government should be to ensure that there is a common goal
among the states.
Funding State Programs
Throughout the meeting, sources of funding for state
programs were discussed. At a very basic level, most
participants felt that individual state funds were insufficient.
Many commissioners cited examples of having to wait until
disaster struck to obtain funding from the state legislature. In
other instances, state programs that were in place became
defunct when the state legislature did not appropriate
additional funds or appropriated existing monies to other
state programs. Most commissioners recognized that EPA
funds to support the state programs were limited and that the
states would have to look for alternative funding sources to
support their programs.
Many commissioners suggested that fees be used, in
part, to support the state pesticide programs. Several
commissioners proposed that a National registration fee be
used to fund programs at the state level. The success of fee
programs already instituted at the state level was also
discussed. These programs ranged from a flat fee on each
product registered to a tax on the volume of pesticides. One
commissioner emphasized the need for equity in the fee
structure in order to maintain the "level playing field."
Several commissioners, however, pointed out that in
their states, any fees collected went directly to the states'
general treasury. The states could not target the fees and,
therefore, the pesticide program could not be assured of
receiving any of the money. These commissioners also
pointed out that the state legislature controlled the fees, and
if they wanted to end the program, they could simply reduce
or eliminate the fees.
Generally, the commissioners agreed that fees were
more acceptable and thus, easier to impose, if part of the
money went to support research and education as well as to
support program development, implementation, and
enforcement In addition, legislatures more readily
appropriated money in response to an existing problem
rather than for the initiation of a prevention program.
The impact of fees on state agriculture and on the
registration of pesticides was also discussed. Commissioners
in states with fees indicated that there was initial resistance
to the imposition of fees. After several years, however,
industry and farmers generally accepted the fees. "When we
raised fees, some 2,000 products were not re-registered, but
by the end of two years we were back to roughly the same
8,000 registered products."
Support States Want the Federal Government
to Provide
The state commissioners suggested several areas in
which EPA could be providing support Most requests
emphasized the need for the transfer of research and
technology. Research into alternative crops and pest
management practices was requested so that farmers could
reduce their dependence on pesticides. In addition, safer
pesticide application practices (e.g., application rates, timing
of application) and nonchemical alternatives were requested.
Commissioners also expressed a need for research on the
fate and effects of pesticides in the environment. S tates want
to be able to look at the physical/ chemical characteristics of
the pesticides and develop strategies to reduce the risk of
exposure.
Commissioners from several states requested that EPA
develop a national data base that would enable the states to
model and graph their soils, ground water, pesticide, and
crop information. The states would like to be able to overlay
geological information with soils, aquifer and crop/pesticide
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U. S. Environmental Protection Agency
data in order to determine high, medium, and low potential
impact areas and predict areas that need either specific
management action or monitoring. The commissioners felt
that this capability wouldleadtoamoreconsistentapplication
on a national basis and enable them to identify sensitive
areas requiring special attention in their management plans.
Request for information transfer also included
technologies. Several commissioners requested that EPA
sponsor research into and develop standards for the safe
handlingandapplicationofpesticides. These commissioners,
noting that spills are a significant source of contamination,
requested that EPA develop design standards for pesticide
mixing and loading areas. The development of a national
training and certification program for pesticide applicators
was also suggested by several commissioners. These
commissioners indicated that the lack of a national program
caused inconsistencies among the states.
The state commissioners also suggested that EPA expand
its current national survey in order to develop a national
understanding of the extent to which ground water is
contaminated and to identify the major pesticides of concern.
Several commissioners suggested that in order to support
their ongoing monitoring programs and to ensure the
compatibility of data among states, EPA should assist the
states by developing inexpensive and simple analytical
laboratory methods and quality assurance/quality control
techniques for the most common pesticides found in ground
water.
The commissioners also suggested that EPA continue to
prepare health advisories for pesticides for which MCLs
have not be published. Many of the commissioners felt that
it was important to be able to provide their citizens with some
health and environmental impact information whenapesticide
was detected in ground water. One commissioner, however,
felt that the health advisories complicated the situation
because they provide a range rather than a single numeric
standard, while the state is required to develop a numeric
standard. Several commissioners wanted EPA to speed up
the process of promulgating MCLs.
There was a general feeling among the commissioners
that EPA needed to make the information they collected
from the pesticide industry more available to the states. One
commissioner commented that although the states may be
able to obtain the information from industry, doing so would
deprive them of the benefit of EPA's analysis. Furthermore,
state access is often limited because most of the information
is considered Confidential Business Information (CBI) which
preempts the state's requirement to make all of their
information public. The commissioner suggested that EPA
look into ways in which this information could be made
more readily available.
Most commissioners felt that education was a key
component of any future program. There is a need to educate
the farmers, applicators, and the public as well as the state
legislatures. The most effective method of educating the
farmers andapplicators would be to conduct trainingprograms
through various agricultural agencies such as the extension
services. The goal of this training program should be to
improve pesticide application and management practices. In
contrast, the public and legislature education programs
should be targeted towards building support for the state
programs and the development of funding mechanisms.
Interaction with the Private Sector
Several commissioners indicated that, in order to ensure
that state programs to control pesticide impacts on ground
water are successful, the states will have to work with private
industries. One commissioner commented that many
manufacturers are actively involved in research programs,
including field studies conducted jointly with the state and
the universities. Industry has also assisted the states by
sponsoring monitoring programs to determine whether their
pesticides are leaching into ground water. Another
commissioner said that he expected industry to assist in the
development of the state's management plan since often, the
company had a major stake in seeing the continued use of its
pesticide. However, he cautioned that in states where there
is only minor use, industry may not be as willing to assist
This could place a potential financial burden on the state.
Therefore, in order to maintain the "level playing field" the
states should not have to depend on industry to pay for the
development of the state pesticide management plan.
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