WASHINGTON, D.C. 20460
                                            MAY  12 '994
                                                                                   OFFICE OF
                                                                            PREVENTION. PESTICIDES AND
                                                                                TOXIC SUBSTANCES
      To All Workshop Participants and Interested Parties:
            Enclosed is the Report for the Pesticide Use/Risk Reduction Initiative Workshop (the
      "Workshop") held on  February  2-3 in Crystal City, Virginia and sponsored by the United
      States Department of Agriculture (USDA),  the United States Environmental Protection
      Agency (EPA) and the United States Food and Drug Administration (FDA). I believe the
      Workshop was a useful beginning to a process that will yield a comprehensive pesticide
      use/risk reduction strategy for both agricultural and non-agricultural uses of pesticides.  I
      greatly appreciate the  input we received from Workshop participants and we wish to thank all
      those who participated for their time and effort.

            In addition to providing  you with the Workshop Report, I also wanted to let each of
      you know where we currently stand on the  pesticide use/risk reduction initiative. Several
      things are worth noting:

             4  USDA  and  EPA have started a dialogue with several grower organizations
            regarding the development of commodity-specific pesticide use/risk reduction
            strategies for their crops. Participating grower organizations have stated their
            willingness to develop strategies designed to reduce use/risk where it is feasible  to do
            so. We anticipate being able to announce firm proposals from several grower
            organizations by October 1, 1994.

             4  EPA has started a dialogue with non-agricultural users of pesticides regarding their
            ability to reduce use/risk of pesticides.

             4  USDA, EPA and FDA  have begun work on the development  of an overall
            pesticide use/risk reduction strategy  covering agricultural and non-agricultural uses.
            We anticipate having a draft of  this  strategy ready for review and comment by
            interested parties by December  1994.

             4  The Office  of Pesticide Programs of EPA will hold a workshop on June 13-15,
KPA        1994 in  Crystal City, Virginia which will cover many pesticide program activities
'f31/       including a session devoted to this initiative and a discussion of topics relevant to the
'1994. -     development of an overall  strategy.
                                                                             Printed wtth Soy/Canoli Inkon paper that
                                                                             contains M IMM 50% recycled fiber

        4 EPA has established,  on its own initiative, an exemption from the requirement of a
       tolerance for residues of arthropod pheromones resulting from the use of these
       substances in retrievably sized polymeric matrix dispensers with an annual application
       limitation of 150 grams active ingredient per acre or pest control  in or on all raw
       agricultural commodities (RAC).

        4 EPA has registered acetochlor, a herbicide,  under standards that require the
       demonstration that it   ill reduce overall risk and use of all herbicides used on its
       registered sites.

        4 EPA has continued implementation of its reregistration fee deferral  policy for
       biological pesticides which enables safer biological pesticides to remain on the

        4 EPA has continued developing and implementing its "safer pesticides" policy
       which will speed up the registration process for safer pesticides.
       Finally, I want to reiterate that we view the initiative as an opportunity for affected
interests to participate in the development of pesticide policy and welcome comments on the
process, specific aspects of pesticide use or risk, or our efforts to date. If you do wish to
comment, please forward your comments to the individuals  named on the last page of the
enclosed Workshop Report.
                                         Very Truly Yours,
                                         Allen L. Jejmings, Director
                                         Biological and Economic Analysis Division

                    WORKSHOP REPORT

                     FEBRUARY2-3, 1994
                    CRYSTAL CITY, VIRGINIA

                            Held by:

                The United States Department of Agriculture
              The United States Environmental Protection Agency
              The United States Food and Drug Administration

         Workshop Report - Pesticide Use/Risk Reduction Initiative,  February 2-3. 1994
This Report is intended to summarize the views and opinions offered by participants in the
Pesticide  Use/Risk Reduction  Workshop sponsored by the United  States Department of
Agriculture (USDA), the Ur ;ted States Environmental Protection Agency (EPA) and the United
States  Food and  Drug Adm  listration (FDA)  held  on  February 2-3,  1994 in Crystal  City,
Virginia (the  "Workshop"). It  is not intended to represent any particular  policy consensus
reached by participants in the  Workshop.  Moreover,  because  this Report  is a summary
document, it may not capture each and every view or opinion offered. Rather, its intent is to set
forth the major themes, issues, and ideas outlined during the Workshop.


       On February 2-3, 1994, USDA, EPA and FDA  hosted the Workshop in an  effort to
obtain  input from a wide-range of interested  parties on the joint federal pesticide use/risk
reduction  initiative jointly  undertaken by USDA, EPA and FDA and announced in June 1993
(the "Initiative"). Workshop participants consisted of over  150 individuals from a wide-range
of sectors including federal and state governments, growers, food processors, public interest
groups, chemical manufacturers,  trade associations, researchers  and consultants.  Workshop
participants were invited  in  a  manner to insure  that  all  affected interests  would have  a
representational voice at the Workshop.

       The Workshop was structured to consist of four main substantive segments.  A complete
agenda for the Workshop and a list of attendees is attached to this Report as Appendix A. The
first segment consisted of plenary keynote addresses outlining the Administration's view of the
Initiative given by James R. Lyons, Assistant Secretary for Natural Resources and Environment,
USDA, Dr. Lynn Goldman, Assistant Administrator, Office of Prevention, Pesticides and Toxic
Substances, EPA, and Dr. Catherine Carnevale, Acting  Director, Executive  Operations Staff,
FDA on behalf of Michael Taylor, Deputy Commissioner, FDA. A summary of those addresses
is contained below.

       The second segment centered around a breakout session designed to elicit views and
opinions on the merits of the Initiative. Eight main facilitated breakout groups were formed to
provide such views and opinions through brainstorming.  Each breakout group was  constituted
to  provide diversity  in  its constituent members to  encourage dialogue among parties with
differing views and opinions. Following the work by the breakout groups, each group was asked
to present a summary of their views and opinions via a plenary reporting session. A summary
of the views and opinions offered by participants in the second segment is set forth below.

       The third  segment  consisted of a breakout session designed to identify the  essential
elements of a successful pesticide use/risk reduction strategy. Using the same breakout groups

         Workshop Report - Pesticide Use/Risk Reduction Initiative,  February 2-3, 1994
as in the earlier  session, each group was  asked to brainstorm the appropriate elements.
Following the breakout session, each breakout group presented a summary of their essential
elements to all participants in the Workshop via a plenary reporting session. A summary of the
identified essential elements is contained below.

       Finally, the fourth segment was another  breakout session designed to address specific
aspects of the Initiative. This time, the breakout groups were self-selected and addressed the
following topic areas:  Research, Measuring  Progress,  Alternatives,  and Incentives and
Disincentives. Like the earlier segments, each breakout group used a plenary reporting session
to report back to  the  participants in the  Workshop.  A description of the input received  in
connection with each topic area is  provided below.


       Assistant Secretary James  R. Lyons  gave the first address  and commented on  the
workshop as an example of the strong  working relationship among federal agencies that has
characterized the Clinton Administration's approach  to pesticide issues. Assistant Secretary
Lyons outlined several important ideas to be kept in  mind as USDA and EPA  work toward
developing use and risk reduction strategies. The primary objective of efforts should be on risk
reduction, with appropriate reductions in use  serving to accomplish the reduction in risk. Any
strategy adopted should be based on a whole  systems approach to ensure that reducing risks in
oie area  will not lead to increased risks in another area. Involvement of producers and producer
groups from the beginning and at each step in  the process is essential. Since reductions can only
take place as a result of decisions and actions by producers on their farms, they must be actively
involved  in the planning and implementation of this strategy. Just as important, is the need for
establishing  a public consensus on the  goals and process for  this strategy. The emphasis  of
USDA's  reinventing government  is renewed focus on  the needs of our customers,  both  in
agriculture and in the general public. Assistant Secretary Lyons noted that the workshop process
is part of USDA's larger effort to work with and on behalf of its customers in developing major

       Assistant Administrator Lynn Goldman followed Assistant Secretary Lyons and stressed
the importance of achieving  real  and meaningful risk reduction while at the  same time
maintaining economically-viable crops for growers. Dr. Goldman stressed that it was important
for the federal government to strike a balance between risk reduction and cost-effective methods
of pest control. Further, she reiterated that the federal government was not merely seeking  to
reduce the volume  of pesticide use  across the  board but rather was tying the reduction in use to
a reduction  in  risk in  the context of maintaining economically-viable crop production. Dr.
Goldman also  stressed the importance of building  any  pesticide use/risk strategy with a
grassroots effort and that the federal government must change the way in which it regulates
pesticides. Finally,  she noted that  the federal government would be emphasizing commodity-

         Workshop Report - Pesticide Use/Risk Reduction Initiative.  February 2-3. 1994
specific pesticide use/risk reduction strategies in the near-term that would not be a "one size fits
all approach".

       Dr.  Catherine Carnevale  concluded  the  keynote  addresses  by  stressing that the
Administration's pesticide reform efforts are a truly cooperative venture among USDA, EPA and
FDA. She noted that pesticide use and risk reduction  is the key to.better protecting the public
health, and especially children. Dr. Carnevale pointed out that FDA, for its part,  has already
changed its pesticide residue monitoring program to include more children's dietary staples and
is working to set-up a centralized database to house residue data generated by federal agencies,
states and industry. She urged the federal government and workshop participants to be creative
and work together to develop new and old  ideas to reduce pesticide risks and uses.

       Issue:  What do you think of a pesticide use/risk reduction strategy? Identify the pros and
              cons. Set priorities.
       In the first breakout session, the eight breakout groups were tasked with addressing the
issues outlined above. The  groups generally thought that it was  worthwhile for the  federal
government to pursue a strategy that would address the role of pesticides in the United States.
However, a constant theme throughout the breakout groups was the necessity of defining whether
the strategy would be based  upon use reduction or risk reduction. For many participants, their
commitment to  supporting  the general  strategy depended on  the resolution  of this  issue.
Participants' views on whether the strategy should be driven by use reduction considerations or
risk reduction considerations differed. The following represents a summary of the advantages
and disadvantages outlined by the breakout groups of pursuing either approach:
A.     Risk Reduction

* Focuses attention on the ultimate goal of environmental and human health safety: reducing risk

* More incentives for chemical industry participation

         Workshop Report - Pesticide Use/Risk Reduction Initiative.  February 2-3. 1994

* Promotes the prioritization of pesticide risks

> Allows continued use of safer pesticides


* Difficult to measure risk

> Complexity of risk trade-offs makes overall risk reduction difficult

>May increase public apprehension about existing risks

B.     Use Reduction


* Ease of measurement

»• Clear baseline  and goals

> Reduces input costs to producers

»> Gives high priority to all  risks

»• Promotes non-chemical control methods

> If volume is the metric, may force substitution to higher-risk, lower-application-rate pesticides,
leading to an increase in risk

»• Disincentive to research/development of safer pesticides

*May increase economic  risk  to  growers  without  reducing  corresponding  health  and
environmental risks

»>May disproportionately impact minor use crops

          Workshop Report - Pesticide Use/Risk Reduction Initiative,  February 2-3. 1994
       Apart from the issue of use reduction versus risk reduction,  the breakout groups also
identified the pros and cons of a pesticide use/risk reduction strategy:

C.    Pros

* Encourages communication and coordination between federal agencies and affected interests

* Focuses attention on education

»Stimulates funding for and prioritizes research

» Reduces risks to humans and the environment

»> Increases public confidence in the food  supply

>• Encourages safer pesticides

* Supports sustainable agriculture and IPM practices

* Decreases input costs to agriculture

* Improves worker and applicator safety

> Comprehensive approach to pollution prevention and agricultural production

+ Opportunity to be proactive and gain public confidence

* Encourages more efficient use of pesticides

»Promotes alternative pest control methods/technologies

* Creates international trade advantages for U.S.  commodities

>U.S. will take a leadership role with respect to pesticide policy

D.     Cons

»> Decreases the tools to manage pest problems

* A national strategy may ignore local needs

         Workshop Report - Pesticide Use/Risk Reduction Initiative,  February 2-3. 1994
»Creates a strain on government resources

*May create unrealistic expectations or achieve unintended results

* Decreased quality and yields of certain commodities

*• Loss of alternatives for minor use crops

+ Complexity of issues makes implementation difficult

>May increase economic risks to growers, processors,  and consumers

f Possibility of limiting variety of food supply

••Complexity of measuring risks makes  risk reduction difficult

•>Conflicting environmental concerns (e.g.,  soil conservation vs. reduced pesticide use)

»• Necessitates risk trade-offs or transfers

i* Consumer resistance to reduced cosmetic quality


       Issue: What are the essential elements of a successful use/risk reduction strategy?
       The breakout groups identified many elements of a successful use/risk reduction strategy
in a number of areas including: goals, measurements, process, policy, education and technology
transfer, economics and research and development. Set forth below is a summary of the elements
that the breakout groups identified:
A.     Goals
 -Demonstrable reduction in risks/use
 -Set realistic, concrete short- and long-term goals

         Workshop Report - Pesticide Use/Risk Reduction Initiative, February 2-3, 1994

B.     Measurements

>• Identify baseline pesticide usage

>• Develop comprehensive pe %ide usage database and require broader reporting

* Develop risk indices for human health  and environmental endpoints

^Design a comprehensive program for measuring and evaluating progress
C.     Process

>• Design strategy based upon input of affected interests:

              public interest groups
              food processors
              chemical industry
              non-agricultural users (homeowners, institutions, etc.)
              extension agents
              land owners
              insurance industry
              financial institutions

* Create mechanism for communication and participation of affected interests

»Establish and clarify role of federal/state agencies  in the development, implementation, and
enforcement of the strategy

>• Communication and coordination  between federal departments and agencies

»> User (grower and non-agricultural user) buy-in to strategy

         Workshop Report — Pesticide Use/Risk Reduction Initiative, February 2-3, 1994

D.     Policy

* Strategy should include both agricultural and non-agricultural uses

* Specify and prioritize risks to be addressed

*• Identify viable production practices that may reduce use/risk

>• Define role of IPM and fund IPM education/training

* Define what "safe"  means

>• Address regional and local needs, differences in ecosystems and  agricultural practices, pest
resistance, and public health needs

*• Include government and market-based incentives for users and manufacturers

>• Government must lead by example; government pesticide practices must be consistent with

»> Incorporate agricultural support programs into strategy

>• Include commodity-specific strategies for agriculture

> Address registration issues: promote faster review of safer pesticides; deregulate certain classes
of pesticides (GRAS); streamline overall process to support strategy

> Identify and address international trade concerns

>Include non-chemical and natural biological  controls

»• Identify sources of funding for overall strategy

E.     Education and Technology Transfer

* Technology exchange/transfer

> Education and training of growers in practices and technologies that reduce use/risk

»• Promote public education of the consumer on cosmetic appearance


         Workshop Report - Pesticide Use/Risk Reduction initiative. February 2-3. 1994

F.     Economics

>• Financial support for growers in transition period

»• Strategy should maintain long-term economic viability for growers

G.     Research and Development

>Prioritize and fund research for chemical and non-chemical alternatives and technologies that
reduce use/risk

* Research should be focused on developing safer, cost-effective control methods

       During Breakout Session #3, self-selecting breakout groups were asked to provide input
on specific areas impacting pesticide use practices  in the United States. The areas that were
addressed included: Research and  technology;  Incentives/Disincentives;  Alternatives;  and
Measuring Progress. The following represents the ideas generated by those breakout groups:
A.     Research and Technology Transfer
1.     Priorities

* Research should be problem-based

* Integrate national framework and specific regional needs, i.e.,
to reach national goals, priorities should be based on regional needs and problems

*> Develop incentives for technology transfer

>  Establish  mission/purpose  based on  risk  factors,  use  factors,  and extent of  need for

* Grower needs, problems, and input essential

         Workshop Report - Pesticide Use/Risk Reduction Initiative.  February 2-3. 1994
 »•  Public/private participation and input

 »-  Evaluate current status of specific pest problems, lack of tools, risk concerns, available
 resources, and need for training

 i-  Include international  work in  terms  of affecting markets and technology transfer where
 applicable to U.S.

 i"  Goals should be feasible, achievable

 "•  Integrate pest management with other production practices and with ag/ecosystem research

 f  Improve  coordination and  cooperation of state and  federal government,  extension agents,
 industry, and national growers organizations

 »  Greater emphasis and  effort on  outreach/extension (public and private)
2.     Funding

i>  Funding should be adequate to support essential risk/use reduction research projects

*  Sources of funds: reallocation of current resources and new funds from public/private sectors

»  Efforts should be funded by: commercial development, federal government and states, tax on
I>esticides and consumers, and commodity check-off programs

»•  Invite public/private input in funding decisions
3.     Use/Dissemination of Results

f Strengthen and broaden support for  information and application delivery system

» Expand, improve, and  link national  research data bases

»• Open up research data  bases to public

> Implementation of promising  research results through education, training, and  technology


       Workshop Report - Pesticide Use/Risk Reduction Initiative. February 2-3, 1994
Roles of Public/Private Sectors
>• Identify and define roles

* Government must lead by example, e.g., research must include federal land

* Roles and relationships tailored at national and regional level

* Suggested tasks of private and public sectors:


           MARKET DRIVEN
                & FEDERAL GOVERNMENT
           NEW MARKETS

         Workshop Report - Pesticide Use/Risk Reduction Initiative. February 2-3, 1994

 B.     Incentives/Disincentives

 1.     Incentives


 *•  Streamline the registration process by reducing fees, green  labeling,  reducing timeline,
 deregulating GRAS, and ensuring an  effective/reliable cancellation process

 >  Incentives for development of pest controls for minor use crops

 »>  Deregulate non-chemical  controls

 »  Consistency of state and federal regulations, and possible consolidation

 »•  Remove commodity program constraints

 »•  Expedited  regulatory process for "lower".risk pesticide products

 »>  Integrate federal  procurements (e.g. WIC, school lunch program) with  reduced  use/risk

 »• Decoupling of commodity support programs

 * State/federal/international harmonization for R&D incentives

 »• Crop insurance and guaranteed loan programs supporting reduced risk/use  technologies and

 f Tax breaks for R & D

  Grower tax breaks for new pesticide reduction technology

  Labeling options for consumer end-products

  Liability insurance for pest control advisors


         Workshop Report - Pesticide Use/Risk Reduction Initiative, February 2-3. 1994
 »> Green labeling (product, pesticide)

 * Support creation of local farmers' markets

2.     Disincentives


 > Taxes:  mill tax and toxicity tax

 * User fees

> Stronger regulatory enforcement mechanisms and funding

> Pesticide labeling of environmental  impact

* Phase out riskier pesticides coupled with introduction of replacements

* Develop criteria for non-registration

C.    Alternatives

1.     Criteria for Selection

* Cost

 * Performance

 > Risk

 »• Feasibility

 > Labor

 * Externalities such as water pollution, social costs, soil erosion, air pollution, wildlife/ecology,
and health costs

         Workshop Report - Pesticide Use/Risk Reduction Initiative,  February 2-3. 1994
>• Energy

i" Regional/local differences

>• Consumers

»• Market competition

»• Grower transition costs

>• Loan programs tied to commodity programs

»• Reassurance of banking community

2.      Alternative Controls

>• Integrated Pest Management and Integrated Farm Management

>• Mating disruption

>• Crop rotation

>• Biological control agents

»• Microbial pesticides

»• Softer chemicals

>• Semiochemicals

>  Organic production management

>• Cultural practices such as seed diversity and tillage practices

>  Accessing alternatives through models

>  Resistance management

>  Increased use of dynamic thresholds


          Workshop Report - Pesticide Use/Risk Reduction Initiative, February 2-3. 1994

 >• Alternatives that preserve beneficial insects

 > Information delivery system

 » Technology transfer and training

 * Gaining more knowledge of multiple pest complexes in crop production systems (i.e., of inter-
 relationships, population genetics,  crop production models, and component pest models)

 >• Lower risk, lower rate chemicals

 * Growth regulators

 >• Genetic engineering

 » Irradiation for crop storage

 + Applicator training in alternative control methods

 > Application technology

 >> Cultural practices including crops to attract/trap beneficials,  orchard floor management, cover
crops, crop rotation, physical barriers, economic pest thresholds, parasite/predators, sterile males

 »• Breeding for host plant resistance/increase diversity

3.     Issues

 * Enhancing ability to register new products, i.e., streamline regulatory process, educate public
about regulatory process, reduce cost and time of registration

 * Inclusion of farm economics into the assessment of reduced risk potential of alternatives

 »• Subsidies for IPM adoption

 + Economic feasibility of alternatives

 » Resistance tracking monitoring

        Workshop Report - Pesticide Use/Risk Reduction Initiative.  February 2-3. 1994

»• Maintain variety of chemical classes as alternatives to reduce risk

>• Research funding for alternatives

* Incentives for development of alternatives

4.     ComplicatingFactors

* Prioritization of risks, i.e., economic, environmental, and human health

> Alternatives are not always substitutes

D.    Measuring Progress

1.     Measures

* Full Pesticide Use Reporting

           AG & NON-AG
                 ACRES TREATED

* Acute Human Health Reporting System

>• Integrated Pest Management

           % ACRES UNDER IPM

* Alternatives

           EXTENT OF USE


         Workshop Report - Pesticide Use/Risk Reduction Initiative, February 2-3, 1994
 2.     Monitoring Impacts of Use

 * Ecosystem Effects


 * Human Health Impacts


 * Economic/Efficacy Impacts on Users
3.    Measuring Risk Reduction

* Define and measure baseline risks; develop risk indices to measure changes (human health and
environmental endpoints)

>> Risk/Hazard defined by studies (toxicity, environmental,  residues)

> Incidents (but must be evaluated to determine causes)

      The Workshop concluded with a wrap-up session in which Douglas D. Campt, Director
of the Office of Pesticide Programs, EPA and Larry Elworth, Special Assistant to the Assistant
Secretary for Natural Resources and the Environment, USDA gave concluding remarks.  Mr.
Campt noted that the workshop generated a lot of good ideas and raised several issues that the
federal government must deal with earnestly if it is serious about a pesticide use/risk reduction
initiative. Mr. Campt then outlined  some of the major  themes  and open issues  that were
identified by the participants. He noted that:

      • the issue of risk reduction versus use reduction is real and there are differing opinions.
      The federal government must be clear to define exactly what it means when it  says
      pesticide  use/risk reduction and that the policy it pursues achieves its commitment to
      reducing  risks  to humans and  the environment  while maintaining cost-effective  pest


         Workshop Report - Pesticide Use/Risk Reduction Initiative, February 2-3, 1994
       control methods for growers.

       •  the need  for communication between the  federal government and stakeholders is
       important in two respects. First, the pesticide use/risk reduction strategy should be based
       upon the input of  affected stakeholders and  second,  the federal  government  must
       communicate with stakeholders on a regular basis, to let them know about its proposals
       and to obtain input/feedback from them.

       • interagency communication/coordination is important to laying the groundwork for a
       successful strategy.

       •  the federal government  must  change the way it does  business; it must  integrate
       pesticide use/risk reduction policies into everyday programs and it must reform existing
       programs to support the goal of pesticide use/risk reduction.

       • the federal government should lead  by  example with respect  to  any  strategy with
       respect to its programs and uses of pest management techniques.

       Mr. Elworth then concluded the Workshop by thanking participants for their input and
reiterated that the input received would be of great value to the Administration in its efforts to
develop an appropriate pesticide use/risk reduction  strategy. He reminded participants that the
development of a strategy  was an on-going  effort and that continued input would be  welcome
following the Workshop.

       Additional written comments about the Workshop, this report or the pesticide use/risk
reduction initiative should be addressed to:  Martin S. Lewis, Special Assistant, Biological and
Economic Analysis Division, Office of Pesticide Programs, US EPA, 401 M Street, S.W.,
Washington,  D.C.   20460;  or Larry  Elworth,  Special  Assistant,  Natural  Resources and
Environment, USDA, 14th and Independence Avenue, S.W., Rm. 217E,  Washington, D.C.