OFFICE OF EN
EPA-330/1-77-002
JAT1ONAL PESTICIDE USE
OBSERVATION PROGRAM
Overview of EPA Studies
Conducted in 1976
ATIONAL ENFORCEMENT INVESTIGATIONS CENTER
DENVER,COLORADO
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ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF ENFORCEMENT
EPA-330/Z-??-002
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NATIONAL PESTICIDE USE
OBSERVATION PROGRAM
Overview of EPA Studies
Conducted in Z9?6
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NATIONAL ENFORCEMENT INVESTIGATIONS CENTER
DENVER, COLORADO
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CONTENTS
1.
INTRODUCTION..................... ~............................
Pesticide Use Patterns in the United States...................
EPA Pesticide Use Observation Program Goals...................
II. DESCRIPTION OF STUDIES........................................
Study Sites, Crops and Chemicals..............................
Observation Methods and Sampling Devices......................
III. DISCUSSION[[[
Evaluation of Observation Methods.............................
Observati on Fi ndi ngs. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
IV. APPROPRIATE AGENCY ACTIONS....................................
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1.
INTRODUCTION
PESTICIDE USE PATTERNS IN THE UNITED STATES
Modern agriculture has become dependent upon the use of synthetic
fertilizers and pesticides for maintaining and improving crop yield.
Moreover, with the need for increased food production in the world, the
use of pesticides in the United States is required for the control of
insects, fungi, weeds, and other pest species that plague crops.
Pesticides, valued at approximately one billion dollars, are used
1
annually to protect agricultural and forest products.
The U. S.
Department of Agriculture estimates that about 140 million acres of
crop-producing land, or approximately one-third of the farm land in the
1 ,2
United States, requires some degree of protection from insect pests.
All grain and cotton seed require chemical treatment to prevent plant
3,4
diseases.
Pesticides are generally the most effective and, in many
instances, the only weapon available to control pests that damage or
destroy crops, livestock, and forests, or endanger human health.
Not only do farmers use pesticides to control insects, but chemicals
are applied nationwide to control weeds on more than 70 million acres of
agricultural land annually at a cost of more than $272 million.
These
herbicides are applied principally to about 25 million acres of corn, 6
million acres of cotton, 3 million acres of soybeans, 20 million acres
1
of small grain, and 7 million acres of pasture and rangelands.
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The extensive use of large quantities of pesticides as dictated by
modern agricultural technology presents a continuing need for monitoring
activities designed to evaluate the effects of these chemicals upon
environmental quality and public health.
Currently~ a major problem that confronts pesticide regulatory
agencies is:
obtaining consent before entering onto private premises
to conduct a pesticide use study.. The problem is summarized in the
9
following statement from the EPA Pesticide Inspection Manual.
"Use investigations will be undertaken only with the consent
of the owner~ operator or agent in charge. Consent~ to be
legally sufficient~ must be voluntarily and freely given after
the intent and scope of the investigation has been explained.
The inspector should use tact and persuasion to obtain per-
mission to conduct the investigation and to elicit informa-
tion. If permission cannot be obtained~ or if during the
course of the investigation the person in charge indicates
that he no longer wishes to cooperate~ the inspector should~
if tact and persuasion fail ~ leave the premises."
This problem of access is not as insurmountable as it may seem~ for
these reasons.
Now~ more than in previous years~ agriculture is physically
associated with the general population -- largely due to changes in farming
practices and the infringement by housing developments and commercial
complexes upon farm land.
Thus~ as regulatory agencies develop their
pesticide programs~ more emphasis is being placed upon monitoring ambient
air~ drift~ etc. ~ in public areas than on private premises.
This outlook
indicates less need for entering onto private premises to conduct routine
pesticide monitoring studies.
One objective of all pesticide monitoring programs is to protect
health and the environment by ensuring that pesticides are used properly.
Although changes in rural communities may be inevitable~ and regulatory
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3
monitoring may not always require consent, the fact remains that the most
realistic way to ensure proper use of pesticides is with the complete
cooperation of the user.
EPA PESTICIDE USE OBSERVATION PROGRAM GOALS
Personnel of the EPA Pesticide and Toxic Substance Enforcement
Division (PTSED), in conjunction with EPA Regions III, IV, VI, IX,
and the National Enforcement Investigations Center (NEIC), initiated a
joint effort to develop a National Pesticide Use Observation Program
in 1976.
The Program goals were as follows:
Ascertain through on-site monitoring whether pesticides
1.
are used in accordance with specified label requirements,
and, when properly used, that these chemicals do not
present undue risk to either man or his environment.
2.
Identify use evaluation techniques of value to EPA and
other pesticide regulatory agencies.
To accomplish these goals, the EPA solicited the support and
cooperation of state and local regulatory agencies, farmers and
applicators, and public interest groups.
The cooperative effort of
these groups resulted in the successful conduct of the four compre-
hensive pesticide monitoring studies described in this overview report.
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II.
DESCRIPTION OF STUDIES
STUDY SITES, CROPS AND CHEMICALS
The National Pesticide Use Observation Program was conducted by the
EPA from April to October 1976.
A series of observation studies was
performed at a potato farm in Magnolia, Delaware, and at cotton fields
in Morgan City, Mississippi, Imperial Valley, California, and Palmer,
Texas.
The Delaware, Mississippi and California studies involved the
evaluation of activities associated with the aerial application of
organophosphate insecticides on 50- to 200-acre food or fiber croplands.
The Texas study monitored the ground application of a chemical desiccant
on a 200-acre cotton field.
Study sites were selected by EPA personnel from Regional Pesticide
Offices in conjunction with state and local officials.
Selection was
made on the basis of past pesticide misuse or conditions believed to
have a high potential for environmental degradation.
Owners of the
selected farms and commercial applicators voluntarily consented to
on-site studies after EPA officials explained the intent and scope of
the National Pesticide Use Observation Program.
OBSERVATION METHODS AND SAMPLING DEVICES
A team of EPA observers conducted on-site audits of pre-application,
application
and post-application operations.
The team observed pesticide
storage, handling, application and disposal practices.
Acti viti es of
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the pesticide users were documented by the EPA inspectors in the form of
a written observation checklist [see Attachment].
Additionally, numerous
photographs were taken to document and sUbsequently review the observed
activities.
A variety of techniques were used to evaluate pesticide application
and spray drift characteristics.
Briefly, these included:
1) on-site
observations by trained pesticide inspectors, 2) use of a fluorescent.
tracer dye mixed directly with the sprayed pesticide, 3) spray droplet
cards and air filtering systems placed around the treated field to
determine drift, and, 4) analysis for pesticide residues in the air,
soil, water, sediment and biota.
Detailed descriptions of each technique
are presented in the EPA technical reports on pesticide use obser-
5,6,7,8
vations.
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III.
DISCUSSION
EVALUATION OF OBSERVATION METHODS
Of the methods and sampling systems used, those that proved to be most
useful were:
1) observers equipped with cameras, and 2) spray droplet cards
to detect pesticide drift.
To facilitate the comparison of the most useful techniques with the
other methods used, an evaluation of each is presented below.
Observers
Observation and photographic techniques are common practices of pesti-
cide inspectors (EPA and State).
The NEIC used both techniques successfully
to document the proper use of pesticides and to detect instances where use
of a registered pesticide was inconsistent with label instructions.
Because
these methods are detailed in EPA Use Observation reports 5,6,7,8 and in the
EPA Pesticide Inspection Manual39 no further discussion appears necessary.
Personal Monitors
Personal monitors (charcoal filter-vacuum pump units) were worn by EPA
teams while observing pesticide mixing and aerial applications.
Analyses
. .
of the charcoal in these monitors revealed trace amounts of pesticides in
the air near the mixing area during pesticide handling operations, and in
the air over the treated field eight hours after the aerial application.
Pesticide trapping efficiency of personal monitors was erratic.
The diver-
sity of results appeared to be caused by variations in air temperature,
vapor pressure, pesticide concentrations, and air movement.
Because of
these site-specific limitations, the use of personal monitors for routine
pesticide studies is not recommended.
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Spray Droplet Cards
Spray droplet cards were considered one of the most valuable tech-
niques for detecting pesticide drift because they involve inexpensive
supplies, minimal manpower and easily learned technology.
Three types
of spray droplet cards were used to detect and characterize pesticide
drift:
Thermofax 209 Copy-Type 640 (copy paper); Linagraph 480 (light-
sensitive chart paper); and Kromecote (photographic paper).
Droplet
cards made from Thermofax or Linagraph paper proved excellent at record-
ing spray droplet impressions.
However, Thermofax cards were considered
more desirable for two reasons:
pesticide droplet stains did not fade
(permanent brown spots against off-white background), and extraction
efficiency for pesticide residue analysis was superior.
Cards made from
Kromecote paper proved to be the least versatile for recording spray
droplets.
*
Of the chemicals tested. only drifting droplets of methyl
parathion permanently stained the Kromecote cards.
Dye Studies
Use of fluorescent dye (Rhodamine WT), mixed with the sprayed pesti-
cide to trace off-target drift. had limited success.
During the studies
in Delaware, 100 ~g/l of the tracer dye was added to a mixture of guthion
and dithane and sprayed on a potato field.
Mylar sheets (plastic used
by draftsman), placed around the target field, successfully collected
drifting droplets of the pesticide mixture containing the dye.
* Guthion 2-~, Dithane M-4~. Methyl Parathion 4E6ID. Galecron 4EtID
Azodrin ~, Parathion 6-3, NudrinQD. Fundal 4~
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In Mississippi, 200 ~g/l of tracer dye sprayed with a mixture of methyl
parathion and galecron was not detected on the mylar sheets placed off
the target field.
In Texas and California, 1,000 to 2,000 ~g/l of
tracer dye was added to chemical mixtures sprayed on cotton.
Analytical
results were erratic for the dye residue on the mylar sheets.
Air Sampling Devices
Two types of air sampling devices were used to capture pesticide
drift.
These were Greenburg-Smith impinger units (air scrubber) and
high-volume air samplers (vacuum-filter).
The high-volume sampler
proved more useful because it collects a larger air sample on a dry fiber-
glass filter.
The advantage of the dry filter as opposed to ethylene
glycol (as used in the impinger device) is twofold.
First, pesticide
hydrolysis is reduced when materials are collected on a dry media.
Second, residue analysis is simplified when extractions are made from
a dry filter.
One disadvantage of the high-volume system is that rapid
air movement through the filter may cause evaporation of volatile
pesticide materials.
Coated Droplet Slides
In general, glass slides coated with magnesium oxide were useful
in detecting drift and characterizing droplets.
In the Delaware,
Mississippi and Texas studies, pesticide spray droplets that drifted
beyond target fields were impacted on the coated slides.
Examination
of the craters formed by the impacting droplets allowed NEIC scientists
to determine the relative size and numbers of drifting particles.
Dur-
ing the California study, wind-driven dust impacted on the slide coatings
and obliterated any pesticide droplets that may have been deposited on
the slides.
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Residue Analysis
Chemical analysis for pesticide residues in selected samples of
air, soil, water, sediment, and biota was useful in confirming pesticide
drift onto non-target areas.
Environmental sampling revealed that air
transport (drift) and field water runoff (irrigation and rainfall) were
major modes of pesticide translocation from the treated fields.
The
analyses were also useful in determining the amount of residues in the
environment so that impact could be properly assessed.
In summary, with the exception of on-site observations and the use
of spray droplet cards to determine drift, no single device or set of
methods worked with equal success.
The variation in usefulness of the
methods was caused by site-specific differences in weather conditions,
pesticide mixtures, methods of application and application rates.
OBSERVATION FINDINGS
Several discrete operations were evaluated by the EPA observation
teams during the pesticide use studies.
Included were:
storage,
handling, application, cleanup, disposal and safety.
The EPA observers
reported that conditions ranged from exemplary to unsatisfactory.
Storage
In general, the storage of pesticides at all sites visited was
exemplary.
The toxic substances were arranged according to basic types
of compounds (e.g., herbicides, fungicides, insecticides), and at most
sites the pesticides were segregated into specific types and brands.
Applicators and farmers provided storage shelters that were well venti-
lated and secured at all times.
The storage facilities visited by EPA
observers were plainly marked to indicate that toxic substances were
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stockpiled and that smoking or unauthorized personnel were prohibited
in the area.
Handling
The largest variance in procedures occurred during handling.
People involved in pesticide mixing and spray tank loading were not
equally aware of the hazards of han~ling highly toxic pesticide concen-
trates, or the prescribed safety precautions.
The EPA observers found
that handling activities ranged from conducting the operation in a safe
and professional manner to an apparent unconcern about occupational
health hazards.
The exemplary operations observed were those in which work crews
followed the directions and precautions on the pesticide label.
These
workers were equipped with waterproof gloves, aprons, boots, a res-
pirator, a face shield or goggles, a hat, and long-sleeved coveralls.
The crews were well informed of the hazards of the pesticide in use
because they had read and understood the label instructions.
Addition-
ally, handling activities were well supervised.
The deficient operations
were those in which workers apparently had not read or did not understand
instructions on the pesticide label.
As a consequence, these workers
appeared to be unaware of the safety precautions that applied to the
pesticides they were handling; Unsafe practices were compounded by the
fact that foremen had apparently not given specific instructions to
laborers in the proper techniques for mixing and handling of highly
toxic pesticides.
In some cases, supervisors gave verbal instructions
to workers but infrequently checked back to see that the safety pre-
cautions were being followed.
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Application
During each of the studies, EPA officials often observed exemplary
application procedures.
In general, excellent weather conditions, well-
maintained spraying equipment, and good applicator judgment minimized
pesticide drift from the target field.
Furthermore, in most cases, the
applicator and his crew appeared fully aware of the proper use of chemicals.
The few exceptions to these findings involved the use of pesticides or
chemicals in a manner inconsistent with label instructions.
These in-
cluded aerial or ground application of pesticides (or chemical desic-
cants):
1) at an unapproved dosage rate, 2) while unprotected persons
were in the drift area, and 3) during irrigation runoff from the target
field or in areas where contamination of nearby bodies of water was
likely.
Although immediate problems, such as human illness and fish
kills, were not observed by EPA at the study sites, there are numerous
records showing that similar indiscriminate uses of chemicals have been
harmful to both man and his environment.
The EPA observation teams concluded that complete drift control
(no loss beyond the treated field) cannot be achieved with any device,
additive or system commercially available.
Even under ideal weather
and application conditions, an estimated 10 to 35 percent of the chemical
applied drifted beyond the target field.
Details of various systems
observed by the EPA during the National Pesticide Use Observation
Program are presented in other technical reports.5,6,7,8
Briefly,
findings showed the least amount of drift occurred during ground appli-
cations of chemicals.
Of the aerial applications observed (helicopter
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and fixed -wing aircraft), the most effective in minimizing drift were
the operations that sprayed coarse droplets at high-volume rates (300 ~m
droplets or larger at 5 gal/acre or more.
Cleanup and Disposal
With some exceptions, all cleanup operations practiced by applicators
closely followed procedures recommended by the EPA, namely: 1) equipment
used for the pesticide application was washed thoroughly, 2) all pesticide
containers were triple-rinsed, punctured and stored in a security area
for subsequent disposal, and 3) rinse water was disposed of in the pre-
scribed manner.
In one instance, the applicator refilled a spray airplane tank
without flushing the equipment; consequently, an unknown amount of a chem-
ical residue was mixed with the registered pesticides to be sprayed on
the target field.
In another instance, used drums and miscellaneous
materials contaminated with pesticides were piled beside a loading area..
None of these materials were rinsed, punctured and properly stored or
destroyed while EPA observers were present.
Disposal of used pesticide containers appeared to be a major problem
at all study sites.
In some cases, pesticide-contaminated paper materials
were burned and the ashes were buried with the used pesticide cans at a
city dump.
The individual doing the burning stayed out of the smoke and
took other precautions to protect himself and others.
Applicators felt
these disposal practices were necessitated by the fact that environ-
mentally safe dump sites specifically for highly toxic chemicals and con-
tainers were not available locally.
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Although not directly related to disposal, one of the post-application
activities that concerned EPA observers was re-entry onto the sprayed fields
by farm workers, government inspectors and others.
There was a general
lack of knowledge concerning the need for .safety apparel if re-entry occurred
before the prescribed time interval for the chemical in use.
Review of the
pesticide label often revealed such. ambiguous statements as ". . . prohibit
re-entry until drift and vapor dissipate.1I
Furthermore, the review of one
methyl parathion label disclosed the following statement:
IIWorkers entering
treated fields within 24 hours of application should wear protective cloth-
i ng. II
The prescribed re-entry waiting period for methyl parathion is 48
hours according to EPAlo; consequently, the label appears to be in error.
Safety
It cannot be overstressed that handling highly toxic materials allows
no margin for error and requires strict adherence to safety precautions.
The consensus by EPA use observation teams after completing the 1976 pesti-
cide studies was that the following precautions are needed.
Complete pro-
tective clothing should be worn when handling highly toxic or concentrated
pesticides.
The clothing should consist of rubber or neoprene gloves,
water repellant shoes, coveralls, waterproof apron, a hat, face shield or
goggles, and a respirator that has been approved for the chemicals being
used.
First-aid supplies should be available to trained on-site personnel
in case highly concentrated materials are spilled on workers.
After
handling pesticides, a shower should be taken.
All pesticides should be
kept in a security area and empty containers should be disposed of by
proper methods which are outlined elsewhere in this document.
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IV.
APPROPRIATE AGENCY ACTIONS
Numerous actions were recommended by EPA observation teams following
the series of pesticide use studies in Delaware, Mississippi, Texas and
California.
The use observation techniques, summarized in this report and detailed
in other reports5,6,7,8 should be made available through the distribution
of these technical reports to all EPA offices involved in monitoring pesti-
cide use.
Furthermore, state and local regulatory agencies should be
advised of the value of these techniques to implement existing and planned
pesticide monitoring programs.
The EPA Regional Pesticide Offices should perform use observation
screening studies on a routine basis.
When comprehensive studies are
needed to document gross negligence in pesticide use, support (technical,
analytical and enforcement) should be provided by EPA Regional Offices and
the National Enforcement Investigations Center.
As part of the program for certification of pesticide applicators,
as well as inspectors, safety and occupational health training is needed
immediately.
This should include, but not be limited to, the ranking of
hazards, definition of protective apparel, the specification of precautions
(posting sprayed fields, proper use, protection, etc.) and first-aid in-
structions for treating possible cases of pesticide poisoning.
Furthermore,
the appropriate agency should require periodic monitoring of blood levels
for cholinesterase activity for pilots, farm laborers, inspectors and
others involved with commercial pesticide applications.
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Because the hazards of many pesticides are unknown or inadequately
described, the EPA must continue to be involved in obtaining, reviewing
and preparing detailed information on the precautions required when using
pesticides.
The Office of Pesticide Programs should review and revise labeling
of pesticides so that labels are comprehendable by laborers and consistent
with registration regulations.
State and local governments should establish environmentally safe
dump sites designed for the proper disposal of highly toxic compounds and
used chemical containers.
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REFERENCES
1.
Poisons and Pesticides.
2.
Florida State Board of Health. 1969.
Florida Health Notes~ 61(1):26 p.
H. L. Bell. Apr. 1974. An Appraisal of Pesticide Usage and Surface
Water Quality Effects in the United States. EPA. Office of Enforce-
ment. NEIC. Denver, Colo., EPA-330/1-74-003, 52 p.
3.
National Academy of Sciences, 1975. Cotton Pest Control Vol. III,
An Assessment of Present and Alternative Technologies. Washington,
D.C., 139 p.
4.
U. S. Department of Agriculture, Nov. 1975. Control of Water Pollu-
tion from Croplands -- Vol. I. A Manual for Guideline Development.
Agr. Res. Ser., USDA. Washington. D. C., 111 p.
National Enforcement Investigations Center, Oct. 1976. Pesticide
Use Observations in Kent County, Delaware. USEPA, Denver, Colo.,
EPA-330/2-76-032, 41 p.
5.
6.
National Enforcement Investigations Center, December 1976. Pesticide
Use Observations in Leflore County, Mississippi. USEPA. Denver, Colo.
National Enforcement Investigations Center, Jan. 1977: Pesticide
Use Observations in Imperial Valley, California. USEPA, Denver, Colo.
7.
8.
National Enforcement Investigations Center, Jan. 1977. Dessicant
Use Observations in Ellis County. Texas. USEPA. Denver, Colo.
Pesticides and Toxic Substances Enforcement Division. April 1975.
Pesticide Inspection Manual, USEPA. Washington, D. C.
9.
10.
Code of Federal Regulations. 1975. Worker Protection Standards for
Agricultural Pesticides. Part 170. Title 40 [July] p 246-7.
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USE INVESTIGATION REPORT ~
1. PERSON INTERVIEWED
a. NAME b. ADDRESS
c. TELEPHONE
;
? APPLICATOR
la. NAME b. ADDRESS
c. TELEPHONE I . CERTIFICATION NO.
I
3-. SITE OF APPLICATION
a. NAME b. ADDRESS
c. TELEPHONE
d. TYPE OF BUSINESS e. CROP, AREA OR OBJECT TREATED f. SIZE OF TREATED
ACREAGE
. g. TARGET PEST h. DATE AND TIME OF APPLICATION
i. SURROUNDING ENVIRONMENT (adjacent croplands, pasture, residences, water
bodies, etc.) . .
j. WEATHER AT TIME .OF APPLICATION:
Source of information
wind direction
wind speed
relative humidity
"temperature at 8 ft
temperature at 32 ft
temperature, lapse rate
cloud cover
precipitation
other:
4. PESTICIDES.. APPLI ED
a. BRAND NAMES b. TRADE-NAME SYNONYMS
c. EPA REG. NOS. d. BATCH NOS. e. CLASS I FI CAnON
f. CHEMICAL TYPES OR CLASSES (OP, CH, carbamate, etc.)
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-g. PESTICIDE TYPES (herbicide~ ovacide~ miticide~ etc.)
h. SUMMARIZED LABEL PRECAUTIONS (drift~ toxicity, re-entry, etc.)
I
. . ...
i. TYPE OF FORMULATION
dust oil-base spray water-base spray Other (specify):
5. -..L-.---
RATE OF APPLICATION
a. METHOD OF APPLICATION (Specify equipment)
OGround 0 Aerial.
b. DILUTION RATE
c. DILUTED MATERIAL APPLIED PER UNIT (Gallons/Acre)
d. ACTUAL ACTIVE PER UNIT (Lbs/Acre)
SAMPLES COLLECTED (List sample numbers)
a. FORMULATION I b. DILUTED MATERIAL
c. RESIDUE
water
. sediment
soi 1
ai-y.- '
.
an i mal (specify)
plant (specify)
other (specify)
7. WERE THE LABELING INSTRUCTIONS FOLLOWED? OYesONo (If IINOII check and
explain)
o Target Pest ORate of Application [JReentry Interval
0 Method of Application OCrop Area or Object OAppl i cator. Certi fi ed
0 Dilution Used Treated 0 Preharvest Interval
[] Other: []Cautionary Labeling
8. CONSEQUENCES OF USE (List any unusual results or adverse effects from
treatment)
'.0.' -
I -.
~. REMARKS (see attachments)
10. DATE OF INVESTIGATION 11. TIME 12. INVESTIGATOR(Signature 13. TITLE
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