EPA PESTICIDE CANCELLATIONS/SUSPENSIONS:

      A SURVEY OF ECONOMIC IMPACTS
      Office of Pesticide Programs
  U.S1.' Environmental.. Protection Agency
         Washington* D.C.  20460
               March, 1980

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                               CONTENTS
                                                               Page-
INTRODUCTION AND SUMMARY                                         1

ECONOMIC IMPACTS                                                 4

     DDT Cancellation                                            4
     Aldrin/Dieldrin Suspension and Chlordane/Heptachlor
       Cancellation/Suspension                                   3
     Mercury Cancellation                                       12
     Kepone Cancellation                                        16
     Chlorobenzilate Cancellation                               18
     Endrin Cancellation                                        20
     DBCP Suspension/Cancellation                               23
     2,4,5-T/Silvex Suspension                                  26

REFERENCES                                                      29

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                 EPA PESTICIDE  CANCELLATION/SUSPENSIONS:

                     A  SURVEY  OF  ECONOMIC  IMPACTS



                        INTRODUCTION  AND  SUMMARY
     Pesticides are important  to  farmers,  homeowners,  industry and
government agencies.  They  are  used  to  control  harmful insects,
diseases, rodents, weeds, bacteria and  other  pests  that  attack man's
food and fiber supplies and  threaten his health and welfare.   About 1.1
billion pounds of pesticides are  used annually  in  the  U.S., at a user
cost of about $5 billion.  More than 30 thousand pesticide products
containing 1,400 different active ingredients are  registered  with EPA
for use against 21,500 pest  species.

     The purpose of this paper  is to  briefly  summarize the approximate
economic impacts of major pesticide  cancellation/suspension actions
taken by the Administrator since  EPA was formed in  December,  1970.
There have been nine such actio'ns announced and implemented to date:
DDT Cancellation-1972; Aldrin/Dieldrin  Suspension-1974;
Chlordane/Heptachlor Cancellation/Suspension-1974/75;  Mercury
Cancellation-1976; Chlorobenzilate Cancellation-1979;  DBCP
Suspension/Cancellation - 1977/79; Endrin  Cancellation-1979;  Kepone
Cancellation-1978; and 2,4,5-T/Silvex,  Suspension-1979.   Economic
impacts are estimated on the basis of data at the  time each of these
actions was taken and any other data  available  since that time.
Generally, the estimates are in terms of price  levels  for the mid to
late 1970's in line with price  levels at the  times  the various actions
were taken.
                                                           *

     Estimates of economic impacts (e.g.,  cost  and  market
production/price effects) are made for  each regulatory actifon for a
typical year immediately after  the regulatory action becomes  fully
effective, i.e., no leftover stocks.  Long term estimates are also  made
for the entire anticipated period of  impact.  The long term estimates
are straight line projections and assume that impacts  would decline
from the midpoint of the projected range in the initial  short term
annual impacts to negligible levels after  4 to  10 years.   This  method
was adopted to reflect trends in  such factors as:   declining  use of the
problem chemicals due to emergence of pest resistance, development  of
substitutes (which takes about  seven  years from discovery) and improved
use of pest control technology  due to integrated pest  management
projects and applicator training.

     The nine major pesticide cancellation/suspension  actions announced
and implemented by EPA since December 1970 have  involved  12 of  the
1,400 EPA registered active  ingredient  pesticides and  about 30-95

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million pounds of active  ingredient  used  per  year  (7-8%  of  U.S.  total).   The
total projected direct economic impact of  these  actions  is  about  $363
million ($1.65/capita) over  the period during which  impacts are  expected  to
occur (through about 1990).

     The breakdown of the  projected  impacts for  the  individual  regulatory
actions is as follows:
Action
DDT cancellation

Aldrin/Dieldrin -
Chlordane/Heptachlor
suspension/cane.

Mercury cancellation

Chlorobenzilate cane.

DBCP suspension/cane.

Kepone cancellation

Endrin cancellation

2,4,5-T/Silvex susp.
Typical yr immed.
  after action
   (Millions)
 $8.25 - 21.9



  9.5  - 19.0

  1.1  - 10.8

  0.2

 42.69 - 43.48

       0

  2.2

 13.3  -  75.9
No yrs. of
  impact    Overall U.S. impact
            Total  Per Capita
            ($ Mil.)  ($)

     7      $52.76    $0.24
     7

     4

    10

     7      150.8      0.69

     0        0.00     0.00

     7        7.7      0.04

     2       89.2      0.40

     Total  363.24     1.65
49.88
11.90
1.0
0.23
0.05
0.005
     These impacts, while significant, are nominal compared with  the
overall cost of pollution abatement programs  in  the U.S., which has been
estimated to be about $500 billion over the ten  year period 1978-87 (CEQ.
1979, Draft).  This overall cost approaches $2,300 per capita, compared with
about $1.65 per capita for major pesticides actions.

     The intent of the above estimates is to  approximate general  magnitudes
of impact.  A high degree of precision is not possible because of  the  highly
variable nature of pest infestations, economic conditions and limitations  in
data available for analysis. This paper does  not attempt to rigorously
address the signficance of economic impacts on identifiable individual
economic sectors or groupings of economic units, nor possible secondary
impacts.  Neither does it consider other economic impacts or costs of  the
overall pesticides program—on industry, users and consumers.  It  is merely
an attempt to provide impact estimates of major  actions in order  to place
them into economic perspective with those of  other environmental  programs
and national economic parameters.
                                       -2-

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                   QUANTITIES  OF  ACTIVE  INGREDIENT IMPACTED
     EPA cancellation/suspensions have  involved  the  annual use of  about
80-95 million  pounds  of^ active  pesticidal  ingredients,  or about 7  to 8
percent of  the  U.S. total  (1.15 billion pounds).   The  approxiaate  quantities
of active ingredient  use per  year that  have  been cancelled/suspended in
these actions,  along  with  comparisons by type  of  pesticides,  are as
follows:

     Table  1     Summary  of Impact on Active  Ingredients  Resulting  from
                    Major  EPA Cancellations/Suspensions
Regulatory action
DDT cancellation
A/D cancellation
C/H cancellation
Chlorobenzilate cancellation
Endrin cancellation
Kepone cancellation
DBCP susp/cane.
Cancelled/suspended
use of active ingredient
mill. Ibs.

14 - 20
10 - 11
14 - 16
.1 - .2
.5 - .6
  neg.
30 - 35
         Total  insecticide/nematicides  69  -  33

Mercury cancellation
         Total  fungicides

2,4,5-T/Silvex  suspension                9  -  11
         Total  herbicides                9-11

Rodenticides  (no major actions)            0

            Total  pesticides            80  -  95
Percent!/

  4-5
  3
  4
   .1
   .1
   .1
 _9 _
 20 - 22
                   .3

                    2_
                    2

                    0

                   7-8
More detailed data on  the  relative  importance  of  cancelled  uses  are
presented and discussed below.

i'   Percentages computed  on  basis  of  approximate total .U..S.  annual  use
     in millions of pounds:   insecticides/nematicides  (350-400);  fungicides
     (100-200); herbicides  (500-600);  and  all  pesticides  (1,100-1,200).
                                         -3-

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                            ECONOMIC  IMPACTS

                            DDT  Cancellation

     DDT, for many years one  of  the  most  widely used pesticides  in the
U.S., was cancelled for most  of  its  remaining  uses,  effective January
1, 1973.  DDT had been widely used since  World.; War II,  reaching  a peak
of nearly 80 million pounds per  year in  the  late 1950's.   By  the early
1970's, its use had declined  greatly—to  14-20 million  pounds per year.
Most U.S. production of DDT at  that  time  was,  and continues  to be,  for
export.  By 1972, DDT was  the fourth ranking insecticide  used in the
U.S. in terms of pounds of  active ingredient.

     Detailed data on the  use of DDT, and impacts of the  regulatory
action are presented in Figure  1.  These  data  are summarized  from a
detailed retrospective review of the economic  impacts of  the  Decision,
as requested by the Congress  (EPA, July  1975a).

     Cotton, the major use  of DDT prior  to the cancellation,  accounted
for more than 80% of domestic DDT use.   It was used  on  about  one-sixth
of U.S. cotton farms (one-fourth of  cotton acreage)  at  the time  of its
cancellation. Its predominant use was in  the Southeastern U.S.,  among
the smaller-acreage cotton  growers.

     Costs of growing cotton  were affected by  the cancellation in two
regions of the Southeastern U.S.  In 1971/72,  DDT was used on more than
one-half (55 percent) of cotton  acreage  in the South Atlantic Region
(Fla., Ga., S.C., N.C., Va.,  W.Va.,  and Md.) and on  one-fifth of cotton
acreage in the East South  Central Region  (Ark.,  La.,  Miss.,  Ala.,
Tenn., and Ky.).

     Cost impacts of the cancellation were quite significant  in  the
South Atlantic Region, the  most affected  area,  as production  costs •<
increased by $630 per farm  on the average for  9,500  farms in  1973 and
1974.  Cotton insecticide costs  in this  region were  increased, due to
the DDT cancellation, by $6.22 per treated acre, over the 1971/72
average of $15.5*1 per acre.   Effects  on  insecticide  costs in  the East
South Central Region were much  less,  only about  $.28 per  treated acre
(EPA, July 1975a).  The cost  impacts  totalled  $7.75  million,
nationally, equalling slightly more  than  $1.00 per acre of cotton
treated with insecticides  (all  types) or  an  increase in total cotton
production costs of 0.5 percent  (EPA, July 1975a).

     Based on a linear programming analysis, (EPA, July 1975a)  the
impacts of the cancellation on cotton producers'  costs  are not
projected to generate large regional or national effects  in cropping
patterns for cotton and other major  agricultural crops.  Thus,  the
major economic impact of the  cancellation of DDT use  on cotton was  to
increase production costs  in  the Southeastern  U.S.,  causing  cotton to
                                   -4—

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be somewhat less profitable for affected growers.   Cotton  production
has been maintained adequately to meet market needs  since  the  DDT
cancellation, although yields may have been affected to  some extent
(EPA, July 1975b).

     The cancellation of other crop uses of DDT  has  been of minor
significance.  DDT was used on less than 3 percent  of  the  acreage  of
crops other than cotton which were contested in  the  DDT  Hearings.  The
increased cost of shifting to alternative controls  for these uses  was
estimated to be $460,700 nationwide (EPA, July 1975a).   Production and
yields of these other crops have been maintained without the.use of
DDT.

     Overall economic impacts of the DDT Decision are  estimated  to
range from $8.25 million to $21.9 million, averaging $15.07 million  for
a typical year immediately after cancellation and projected to decline
linearly to negligible levels after about 7 years (Figure  1).  Total
impact over 7 years would be $52.76 million ($15.07  million x  7/2),
equalling about 25 cents per capita.

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A.  REGULATORY ACTION
B.  EXEMPTIONS:
C.  EXTENT OF DDT USE:

      Cotton:
      Other agric. uses;
      Other uses:
      Total cancelled uses:
D.  SUBSTITUTES
     FIGURE 1

ECONOMIC IMPACTS OF

 DDT CANCELLATION

   cancellation of remaining major uses of
   DDT (primarily cotton) and most minor
   uses, effective January 1, 1973.

   certain minor crop uses without
   substitutes (temporary, pending
   determination on availability of
   substitutes) and public health/
   quarantine uses by official government
   agencies.  Forest use was not addressed in
   the DDT hearings—use phased out earlier
   by USDA.
   S.E. U.S, only; 17% of U.S. cotton farms;
   25Z of U.S.  cotton acres; 20 and 60
   percent of cotton farms in two S.E.  U.S.
   regions,  respectively (18,700 farms);
   12-16 million Ibs active ingredient/yr.
                         i
   primarily peanuts, soybeans, potatoes and
   other vegetables; 1-2 million IDS active
   ingredient/yr; less than 3% of U.S.
   acreage.

   industrial,  governmental, home and garden;
   1-2 million  Ibs active ingredient/yr.

   14-20 million Ibs/yr. (equalling 4 to 5
   percent of total U.S. insecticide use).

   generally available for all uses but often
   more expensive and may require more
   applications; yield effects are possible
   against some pests but not well
   documented;  improved cultural practices,
   applicator training and integrated pest
   management programs minimize the need for
   chemical  controls.
                                  -6-

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S.  ECONOMIC IMPACTS:

      Cotton:
      Other agric. uses;


      Non agric. uses;

      All cancelled uses:
cotton production costs increased $7.75
million/yr. in 1973 and 1974 (an average
of about $400/fana in S.E.  U.S.); also
yield losses, although not clearly proven,
are possible in the range of 0 to 4
percent on land where alternatives do not
provide satisfactory performance (up to 31
million pounds, valued at $12.4 million at
1973 prices).  Probable range in annual
economic impacts - $7.75 million to $20.15
million (initial years of impact).

$250,000 to $1.0 million/yr.
 (largely cost effects).

$250,000 to $750,000/yr.

total impact of $8.25 to $21.9 million per
year during initial" years, declining to
negligible impacts after about seven
years.
                                 -7-

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                       Aldrin/Dieldrin  Suspension

                                  and

             Chlordane/HepCachlor Cancellation/Suspension

     The Administrator of EPA suspended  food  and feed uses  of
aldrin and dieldrin in October 1974, after  extended  cancellation and
suspension hearings.   In November 1974,  the Administrator of  EPA
announced his  intent  to cancel chlordane and  heptachlor uses  with the
exception of ground insertion for termite control and the dipping of
roots and tops of  non-food plants.   In July 1975, the Administrator
announced his  intent  to suspend  rather than cancel the same
chlordane/heptachlor  uses.   In December  1975,  the Administrator
suspended most uses of the compounds,  pending  the outcome of  the
cancellation hearings  (EPA,  August  1976).   In March,  1978 suspended
uses of chlordane/heptachlor were cancelled,  with a  phase-out period in
some instances.  For  example, seed  treatment  uses are to be phased out
by July 1, 1983.

     The full  economic significance  and  impacts  of the suspension of
aldrin and dieldrin uses depends on  whether chlordane/heptachlor is
available as a replacement.  For this  reason,  economic impacts of
actions involving  aldrin/dieldrin and  chlordane/heptachlor  are
estimated jointly  in  this paper.  Detailed  data  on the use  of these
compounds and  the  estimated  impacts  of regulatory actions have been
prepared by EPA economists and others  testifying in  public  hearings
(Aspelin, September 1975 and EPA, August 1976).   Figure 2 is  a summary
of the best available data and includes  impact estimates for  the years
immediately following a fully effective  regulatory actions  as well as
the entire projected  impact  period of  7  years.   These estimates are
solely those of the authors, based on all available  data and  analyses
including those of others who may believe that alternative  estimations
are more appropriate.

     Corn was  the  largest agricultural use  of  these  four insecticides.
Approximately 9.5 million pounds of  active  ingredient of aldrin and
dieldrin were annually applied to 7  million corn acres (about 9.5% of
the 1973/74 U.S. corn acreage).  Chlordane  and heptachlor were applied
to 2 million corn  acres in 1973/74  (about 1.5% of the domestic
corn acreage).

     Costs of meeting the domestic demand for  corn and other  major
food/feed grains were estimated  to increase by .06%  or about  $6.4
million annually after the regulatory actions  are fully implemented.
In addition to the above costs, an increased  inter-regional
transportation cost of $0.74 million was  estimated for a typical year.
The total cost impact to the corn sector for a typical year was
estimated to be $7.14 million immediately following  the full
implementation of  the regulatory actions.   In  a  typical year,  the total
cost impact could vary from  $5.0 to  $10.0 million.
                                  -8-

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     Ail other agricultural uses of aldrin,  dieldrin,  chlordane,  and
heptachlor accounted for 3 to 4 million pounds of  active  ingredient.
These uses were estimated to have annual  production  cost  increases  or
yield losses ranging from $1.5 to $3.0 million.

     The nonagricultural uses of these four  insecticides,  accounted  for
6 to 8 million pounds of active ingredient,  which  was  mostly  chlordane
and heptachlor for termite control.  The  annual  increase  in pest
control costs were estimated to range from $3.0  to $6.0 million.^/

     The overall economic impact associated  with regulatory actions
taken against aldrin, dieldrin, chlordane, and heptachlor were
estimated to initially range from $9.5 to $19.0 million annually  with
a decline to negligible levels expected over a 7 year  time period.  The
total economic impact over the 7 year period was estimated at $49.88
million or about 24 cents per capita.
     Estimates of impact for other agricultural and nonagricultural
     uses were based on a sample of uses analyzed in detail plus
     extrapolations (for other uses evaluated in less detail)  in
     proportion to the pounds of active ingredient involved in  these
     uses.
                                 -9-

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                               FIGURE 2

              ECONOMIC IMPACTS OF CANCELLATION/SUSPENSION

              OF ALDRIN/DIELDRIN AND CHLORDANE/HEPTACHLOR
A.  REGULATORY ACTION:
3.  EXEMPTIONS:
C.
    EXTENT OF USE:

      Corn:
      Other agric. uses;

      Industrial/home garden & turf:

      All suspended uses;
      Non-suspended uses;
D.  SUBSTITUTES:
                                       food and feed uses of
                                       aldrin/dieldrin  (A/D) were
                                       suspended effective August 1974,
                                       as were similiar uses of
                                       chlordarie/heptachlor (C/H),
                                       effective July 1975.

                                       structural termite uses were
                                       exempted from both actions;
                                       phase-out periods of use were
                                       authorized for several uses of
                                       C/H.  The final phase-out dates
                                       range through July 1, 1983.
                                       A/D - 7 mil acres/yr (9.5% of
                                       U.S. corn acres); 9.5 mil Ibs;
                                       C/H - 2 mil acres/yr (1.5% of
                                       U.S. corn acres); 3 to 6 mil
                                       Ibs; 1973/74 data.

                                       3 to 4 mil Ibs/yr.

                                       6 to 8 mil Ibs/yr.

                                       A/D - 10 to 11 mil Ibs/yr (about
                                       3% of U.S. insecticide use).

                                       C/H - 14 to 16 mil Ibs/yr (about
                                       5% of Uj,S. insecticide use).

                                       6 to 8 mil Ibs/yr - mostly C/H
                                       for termite use.

                                       there are registered substitutes
                                       for all major suspended/
                                       cancelled uses of A/D and C/H
                                       but usually are somewhat more
                                       expensive (up to 50 percent in
                                       many cases) and may need to be
                                       repeated more often due to lack.
                                       of persistence
                                 -10-

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E.  ECONOMIC IMPACTS:
      Corn:
      Other agric. uses;
      Non-agric uses;
      All suspended uses
the A/D and C/H suspension
actions are evaluated in
combination because the two sets
of active ingredients have
overlapping uses and are ready
substitutes in many cases.

costs of neeting domestic demand
for corn and other major
food/feed grain increased by
0.06% or $6.4 mil/yr after
action would be fully in effect
(early 1980's); to these costs
are added 30.74 million per year
in inter-regional transport
costs  giving total increase of
$7.14 mil/yr for a typical year;
costs could be greater or less
in an individual atypical year
during the initial years of
suspension/cancellation, e.g.,
from $5.0 to $10.0 million.

increased costs and yield losses
ranging from $1.5 to $3.0
mil/yr.

increased costs of pest control
ranging from $3.0 to $6.0
mil/yr.

total overal economic impact of
$9.5 to $19.0 mil/yr, declining
to negligible levels after a
period of about 7 years.  Total
impact for 7 years is projected
at $49.88 million.
                                 -11-

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                          Mercury Cancellation

      The Administrator of EPA cancelled several major uses (paint,
 turf, and seed treatments) and most minor uses of mercurial fungicides
 and bactericides in early 1976.  Certain of these cancelled uses were
 reinstated later in the year after further review pursuant to requests
 by industry and user groups.  Detailed data on the use and the
 estimated impacts of regulatory action taken against the mercurial
 fungicides and bactericides are presented in Figure 3.

      In 1973, the largest cancelled use of mercurial pesticides was
 oil-base paint with 180,000 pounds of active ingredient.  The cost
 impact associated with paint manufacturing ranged from 5.9 to 11.0
 cents per gallon, which aggregated to a total annual impact ranging
 from $2.65 to $4.96 million for as many as 45.05 million gallons of
 oil-based paint affected by the cancellation.  The wide range of the
 annual impact is related to mercurials used either at relatively low
 concentrations as in-can preservatives or at higher concentrations as
 mildewcides, as well as the cost of alternative pesticides used.

      The annual use of mercurial fungicides on turf for control of
 summer diseases was about 43,600 pounds of active ingredient applied on
 approximately 8,125 golf courses.  The annual cost increase associated
 with the maintenance of greens was estimated to range from $650,000 to
 $3,055,000.  If this cost increase was totally passed on to 15.6
 million golfers, the annual cost per golfer would increase within a
 range of 4.2 to 19.6 cents.

      Mercurial seed treatments for fungal diseases were estimated to
 use 7,000 pounds of active ingredient annually.  Annual regulatory
 cost increases were estimated to range from 7.1 to 38.8 cents per
 treated acre for 300,700 acres.  The total annual impact was estimated
 to range from $21,000 to $117,000 or $38.80 for a farm that treated 100
 acres.

      The use of mercurial pesticides for plastics and medical
 disinfectants was minor and regulatory cost increases would be
 negligible.

      The overall annual economic impact associated with the cancelled
 uses of mercurial fungicides and bactericides was estimated to range
 from $2.65 to $4.96 million in the first two years following the
 regulatory action.  The cost impact would increase to a range of $3.30
 to $8.13 million following the imposition of the cancellation order on
 the use of mercurials for summer diseases of turf and seed treatments.
 The annual economic impact is expected to decline to negligible levels
•in about four years (totalling $11.4 million, or about 5 cents per
 capita).
                                   -12-

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                               FIGURE  3
                          ECONOMIC IMPACTS OF
                         MERCURY CANCELLATION
A.  REGULATORY ACTION:
B.  EXEMPTIONS:
cancellation of  the following
pesticide uses of mercury; as  an
in-can preservative and/or
mildewcide for oil-based paints
(effective February 17, 1976);
for seed treatments and summer
diseases of turf after August
31, 1978, or following the
production of two years supply
of these products (based on
recent production data)
whichever occurs first; all uses
of mercury in plastics and as
medical disinfectants.

water-based paints, winter
diseases of turf, textiles and
fabrics for outdoor use, control
of brown mold on freshly sawn
lumber and Dutch elm disease.
C.  EXTENT OF USE:

      Oil-based paint;
      Turf, esp. golf courses
       for summer diseases:
      Seed treatment:
D.  SUBSTITUTES:
180,000 pounds active ingredient
mercurials were used in as many
as 45.05 million- gallons of
paint/year (1973).
43,600 pounds active ingredient
mercurial fungicides were used
on about 8,125 golf
courses/year 1973.

7,000 pounds active ingredient
used to protect various seeds
from fungi.

data presented in the mercury
hearings, indicated that a
number of effective alternatives
were available for most
applications in which mercury
pesticides have been used.  For
oil-based paint, mercury
alternatives provide an adequate
level of control at an increased
cost ranging from 5.9$ to 11.0$
                                   -13-

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E.  ECONOMIC IMPACTS:

      Oil-based paint;
      Summer turf:
      Seed treatment:
      Other uses:
                                       per gallon,  depending  upon  the
                                       mercury  substitute  used.  For
                                       turf  the efficacy of
                                       nonmercurials  (equal or superior
                                       to mercury  compounds)  has been
                                       indicated in the control of
                                       summer turf  diseases,  but are
                                       generally more expensive to  use
                                       ($400 for the  season per
                                       course).  For  seed  treatments,
                                       the cost differential  of
                                       nonmercurial over the  mercurial
                                       compounds is slight, ranging
                                       from 7.l£ to 33.8£  per acra.
cost increases of 5.9$ to 11. Ot
per gallon in as many as 45.05
million gallons; equivalent  to
an aggregate increase ranging
from $2.65 to $4.96
million/year, depending upon the
number of gallons treated and
the alternative pesticide used.

cost increase for control of
summer disease of turf - 8,125
golf courses ranging from
$650,000 to $3,055,000/year  .
(4,2£ to 19.6£ more/year for
15.6 million golfers), after
August 31, 1978, or after the
production of two years supply
of mercurial turf fungicides.
                    I
cost increase of 7.it to 38.8?
per acre on 300,700 acres,
totalling $21,000 to $117,000
($7.10 to $38.80 per farm on a
farm with 100 acres treated).

the use of mercury compounds in
other pesticidal applications
(plastics and medical
disinfectants) is minor.
Substitutes are available which
have been used for years.
Cancellation of other uses would
have no ineasureable impact
either on firms or on medical
practice.
                                    -14-

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All cancelled uses;               total impact of $2.65 Co $4.96
                                 million/year during the first
                                 two years of cancellation,
                                 increasing to $3.30 to $8.1
                                 million/year following the
                                 imposition of cancellation upon
                                 summer turf disease uses (after
                                 August 31, 1978, or after two
                                 years' volume of production of
                                 mercurial turf fungicides).
                                 Impacts are expected to be
                                 negligible four years after
                                 effective cancellation.
                               -15-

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                          Kepone Cancellation
     The Administrator of EPA cancelled all  registrations  of  products
containing Kepone, effective May 1,  1978.  Kepone  use  at  the  time of
notice of cancellation was limited  to the  stock  on hand of  certain
formulated products.  The manufacturer of  Kepone had previously ceased
production and requested a voluntary cancellation  of all  Kepone
registrations with the use of remaining stocks  to  be allowed.   A review
of the impacts of the cancellation  action  found  that numerous
subs-Citute products were available  at comparable costs to  Kepone
products.  No economic impacts were  thus expected  as a result  of this
cancellation action.  Figure 4 summarizes  the  regulatory  action taken
on products containing Kepone.
                                     -16-

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                               FIGURE 4

                          ECONOMIC IMPACTS OF

                          KEPONE CANCELLATION

A.  REGULATORY ACTION:         cancellation of all registered  products
                               containing Kepone, effective May  1,
                               1978.

B.  EXEMPTIONS:                use of existing stocks of all
                               inaccessible products was permitted
                               until such stocks are exhausted.

C.  EXTENT OF USE:

      Domestic Dwellings;      approximately 1,000 Ibs active
                               ingredient remained when Allied Chemical
                               Corp. ceased production with a  request
                               for voluntary cancellation provided use
                               of existing stocks was permitted.  A
                               portion of the quantity in accessible
                               devices was not allowed to be sold.

D.  SUBSTITUTES:               numerous substitutes are available to
                               replace Kepone.  Substitutes are
                               comparable or better in control and many
                              . have lower costs.

E.  ECONOMIC IMPACTS:          None
                                     -17-

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                     Chlorobenzilace Cancellation
     In February 1979, Che Administrator of EPA announced  the  intent  to
cancel all non-citrus uses of the miticide, chlorobenzilate.   Figure  5
summarizes the regulatory action on products containing  chloro-
benzilate.  The sites to be cancelled included primarily cotton,
fruits, nuts, melons, and,.turf grass.  The cancelled uses  accounted for
about 120,000 pounds active ingredient out of the  approximate  total of
1.1 million pounds active ingredient of chlorobenzilate  used annually.
The remaining 1.0 million pounds active ingredient on  non-cancelled
uses are applied to citrus crops in Florida, California, Texas, and
Arizona.

     All cancelled uses of chlorobenzilate have registered available
alternative chemical controls.  The use of these alternative chemicals
is anticipated to maintain yield or mite control at the  current levels.
Production costs of some commodities may increase  somewhat where
alternatives are more costly to use.  The total cost increase  is
expected to be less than $200,000 per year for all sites on which
chlorobenzilate was cancelled.  The cost increase  effect is expected  to
decline to negligible levels over a 10 year span as new  chemicals  are
developed for those uses.  Economic impacts are not expected to be
evident beyond the producer level because of the relatively minor
extent of chlorobenzilate usage on the cancelled sites.
                                    -18-

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                               FIGURE 5

                          ECONOMIC IMPACT OF

                     CHLOROBENZILATE CANCELLATION
A.  REGULATORY ACTION:
B.  EXEMPTIONS:
C.  EXTENT OF CHLOROBENZILATE USE:
      Other uses:
      Total cancelled uses:
      Total non-cancelled uses:
D.  SUBSTITUTES:
cancellation of registrations of
chlorobenzilate for all uses other
than citrus.

registrations for citrus with
modifications of terns or
conditions of registration.
primarily cotton, fruits, nuts,
melons, and turf grasses; about
120,000 Ibs active ingredient
applied over 24,000 acres.

120,000 Ibs active ingredient

about 1.0 million Ibs active
ingredient used on citrus.

all cancelled uses have available
alternatives with no yield changes
anticipated.  Changing to
alternatives may increase
production costs of individual
commodities slightly.
E.  ECONOMIC IMPACTS:
      Other uses:
      All cancelled uses:
less than $200,000/yr in increased
cost of production.

less than $200,000/yr.
                                   -19-

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                          Endrin Cancellation

      In July 1979, the Administrator of EPA announced  the  intent  to
cancel registrations for use of the  insecticide  endrin  on several
sites.  Figure 6 summarizes the regulatory actions  announced  and  their
expected impacts.  These sites included cotton east of  Interstate
Highway #35; use on small grain except, for control  of army  cutworm,
pale western cutworm, and grasshoppers; use in apple orchards in  •
Eastern states to control meadow voles; use on sugarcane to control  the
sugarcane borer; and use on ornamentals.  All other uses of endrin were
continued with modifications to application instructions designed  to
minimize human and environmental exposure.

      The cancelled uses of endria totaled about 600,000 pounds of
active ingredient on an annual basis.  The non-cancelled uses account
for about 300,000 pounds active ingredient annually.  The cancelled
uses comprise about 0.2% of current  insecticide  use in  the  United
States.

      The cancelled uses of endria generally have alternative chemicals
available for use.  Some increases in production costs  for  cotton  and
small grains are expected since some alternatives to endrin are higher
in cost.  The increases in production costs are  $1.0 million  and  $1.2
million annually for cotton and small grains respectively.  The
development of new chemicals and the possibility of resistance  to
endrin on the part of some pests leads to the assumption that the
effect of the cancellation on production costs would decline  to
negligible levels over a seven year  period from  the effective date of
cancellation.  The total impact would thus be about $7.7 million.
Economic impacts are not expected to be evident  beyond  the  user level.
                                  -20-

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A.  REGULATORY ACTION:
B.  EXEMPTIONS:
C.  EXTENT OF ENDRIN USE:
      Cotton:
      Small grain;


      Apple orchards:


      Other uses;



      Total cancelled uses;
     FIGURE 6

ECONOMIC IMPACT OF

ENDRIN CANCELLATION

      cancellation of the use on cotton in
      all areas east of Interstate Highway
      #35; use on small grains to control all
      pests other than aray cutworm, the pale
      western cutworm, and grasshoppers; use
      on apple orchards in Eastern states to
      control meadow voles; use on sugarcane
      Co control sugarcane borer, and use on
      ornamentals.

      remaining uses with modifications to
      terms and conditions of registrations
      including:  use on cotton west of
      Interstate Highway #35; use on small
      grains to control army cutworms and
      pale western cutworms; use on apple
      orchards in Eastern state to control
      pine vole and in Western states to
      control meadow vole; use on sugarcane
      to control sugarcane beetle; use for
      conifer seed treatment, and use in
      enclosed bird perch treatments.
      about 600,000 Ibs. active ingredient,
      primarily in combination with methyl
      parathion, largely east of Interstate
      #35

      cancelled uses on small grains < jcotal
      about 1,500 Ibs. active ingredient.

      cancelled uses will have no appreciable
      impact on endrin use on this site.

      all other cancelled uses would total
      less thant 1,000 Ibs. active
      ingredient.

      slightly more than 600,000 pounds
      active ingredient.
      Total non-cancelled uses: about 300,000 Ibs. active ingredient  on
                                small grains and about  1,500 Ibs.
                                active ingredient for other uses
                                including forest seed treatment and
                                bird control.
                                 -21-

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D.  SUBSTITUTES:



E.  ECONOMIC IMPACTS:

      Cotton:
      Small grains;
      Apple orchard use
      Other uses:
      All cancelled uses;
alternatives are generally available
for significant cancelled uses of
endrin.
the cancelled uses on cotton will have
small impacts on growers with an
expected impact of $2.0 million
increase in production costs.

cancelled uses on wheat will cause
negligible increase in production costs
as a result of switching to higher cost
alternatives.
the cancelled uses on apple orchards
will result in no expected losses and
negligible cost increases.

no expected impacts for other cancelled
uses.

total impact of up to $2.2 million
during initial years, declining to
negligible levels after about seven
years.
                                -22-

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                   DBCP Suspension and Cancellation

      From September 1977 through October 1979, several notices of
intent and orders of cancellation and suspension were  issued  concerning
the nematicide DBCP.  The culmination of this series of notices and
orders is that all uses of DBCP except for pineapples  in Hawaii have
been suspended and all uses are subject to pending cancellation.
Figure 7 summarizes these regulatory actions and their anticipated
economic impacts.

      Prior to EPA actions, approximately 32.7 million pounds active
ingredient of DBCP were applied annually to several crops  including
soybeans, almonds, vegetables, vineyards, peanuts, cotton,  peaches,
pineapple and citrus.  DBCP uses accounted for about 9% of  all
insecticide/nematicide pesticides used annually in the United States.

      Pending final outcome of cancellation proceedings, EPA  has
estimated the economic impact of EPA suspension and cancellation
actions to be about $43 million.  This figure does not include impacts
in California (other than certain vegetable uses), which suspended all
uses of DBCP in 1977.  This estimate reflects revisions of  certain
impact estimates presented in the suspension hearing during 1979
(soybeans estimates were revised to reflect a realistic pattern of
usage similar to that which ocurred in cotton from 1977 to  1979;
soybean and certain vegetable treatment cost data were revised to
improve consistency with analyses of the other uses).
                                   -23-

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                               FIGURE 7
                          ECONOMIC IMPACT OF
                     DBCP SUSPENSION/CANCELLATION
A.  REGULATORY ACTIONS:
B.  EXEMPTIONS:
C.  EXTENT OF USE:
      field crops;
      fruit/nuts
      vegetables;
      other;

      total suspended/
        cancelled uses:
      pineapple;
      all uses;

D.  SUBSTITUTES:

      field crops;


      fruits/nuts;



      vegetables
began Sept. 1977 with notice to suspend
and conditionally cancel some..uses of
DBCP.  Actions continued through July
1979, when notice of intent to suspend
all uses was issued.
Oct. 1979  :  Suspension of all uses not
suspended in Nov /77:  cotton; soybeans;
citrus; grapes; pineapples (except
Hawaii); peaches; nectarines; plums;
almonds; commercial okra; lima beans,
snap beans, and southern peas; berries
(black, blue, logan, dew, boysen,
raspberry); strawberry nursery stock;
apricots; cherries, figs; walnuts;
bananas; turf; ornamentals,  also:
Notice of intent to unconditionally
cancel DBCP.

all uses except pineapple (HI) now
suspended; all uses subject to
cancellation notice.

Prior to EPA actions:
   Ibs. a.i. applied/yr (1,000)

             18,272
              9,732
              3,392
              1,079
             32,475
                225
             32,700
D-D, EDB, dichloropropene, carbofuran
fensulfothion, ethoprop, fenamiphos

preplant:  D-D, EDB, dichloropropene
postplant:  none for bearing trees,
            bushes or vines

D-D, EDB, dichloropropene, Vorlex
                               -24- •

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      turf ornamentals:        diazinon, fensulfothion, EDB, methyl
                               bromide, dichloropropene

      home garden;             none postplant

      pineapple;               EDB
E.  ECONOMIC IMPACTS:          Effects due to EPA suspensions/
                               cancellations (millions):

      field crops;                         $23.09-23.48
      fruits/nuts;                           3.81- 4.21
      vegetables;                              14.09
      other;                                    1.7
      total suspended uses;                 $42.69-43.48
                                   -25-

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                     2,4,5-T and Silvex Suspension

      On February 28, 1979, the forestry,  rights-of-way  and  pasture
uses of both 2,4,5-T and silvex were suspended.  At  the  same
time several other uses of silvex were also suspended, viz., home and
garden, commercial/ornamental turf, and aquatic weed  control/ditch
bank.  The suspension will remain in effect until a final decision
regarding cancellation is reached, approximately two  years after  the
suspension.  Some uses were not suspended  but the risks  and  benefits
associated with these uses will also be evaluated during the
cancellation hearings.  Figure 3 summarizes the regulatory action  and
its estimated impacts.

      The economic impacts of suspending 2,4,5-T and  silvex  are
generally limited to increased control costs, although some  yield
reductions may occur in the forestry industry.  The projected  impact
for all uses is approximately $90 million  for the two-year suspension
period.  Forestry will realize estimated impacts of $46-$56  million
during this two-year period.  Rights-of-way impacts are  estimated to
range from $2.6-$67.8 million for two years and average  about  $35
million, while pasture impacts are estimated at $5 million for two
years.  Minor increases in control costs may occur for other uses of
silvex, but these costs have not been estimated.
                                -26-

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                               FIGURE 8
                          ECONOMIC IMPACTS OF
                     2,4,5-T AND SILVEX SUSPENSION
    REGULATORY ACTION:
B.  EXEMPTIONS:
    EXTENT OF USE:
      Forestry:
      Rights-of-way;
      Pasture:
      Other silvex uses:
      Total suspended uses:
suspension of forestry, rights-of-way
and pasture uses of both 2,4,5-T and
silvex; additionally, suspension of home
and garden, commercial/ornamental  turf,
and aquatic weed control/ditch bank uses
of silvex, effective February 28,  1979
until a final decision regarding
cancellation is reached.

rice, range, and non-crop uses of
2,4,5-T and silvex; additionally,
sugarcane and orchard uses of silvex;
to be included in FIFRA section 6(b)(2)
cancellation hearings.
used in conifer production primarily in
South and Pacific Coast regions; 0.23%
commercial forest acres treated annually
with 2,4,'5-T; 2.6 million Ibs. active
ingredient 2,4,5-T/yr.; less  than 1,000
Ibs. active ingredient silvex/year since
1977.

Eastern and Northwestern U.S. primarily;
percent acres treated with 2,4,5-T:
electric - 9.4%, railroad - 6.6%
pipeline - 4%, highway - 0.8%; minimal
silvex usage - less than 2% of R-O-W
firms; 3.8 million Ibs. active
ingredient 2,4,5-T/yr.; negligible
quantity of silvex.

primarily South Central U.S.; 1% of
total U.S. pasture acreage treated with
2,4,5-T; less treated with silvex;
500,000 Ibs. active ingredient
2,4,5-T/yr.

home and garden, commercial/ornamental
turf, aquatic weed control/ditch bank;
2-3 million Ibs. active ingredient
silvex/yr.

seven million Ibs. active ingredient
2,4,5-T/yr.; 3 million Ibs. active
ingredient silvex/yr.
                               -27-

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D.  SUBSTITUTES:
E.  ECONOMIC IMPACTS:

      Forestry:
      Rights-of-way;
      Pasture:
      Other silvex uses:
      All suspended uses:
generally available for rights-of-way,
pasture, home and garden,
commercial/ornaaental turf, forestry
site preparation and some aquatic uses
at comparable or slightly higher cost;
few available for forestry release and
other aquatic uses.
control cost and yield impacts from
2,4,5-T suspension — $10-$17 million in
first year, $36-$39 million in second
year; negligible impacts from silvex
suspension.

increased treatment cost of $1.3 million
annually or, if treatment cycle is
shortened from four to three years,
increased cost of $33.9 million/yr.
(less than 0.1% of total operating
expenditures); negligible impact from
silvex suspension.

$2-$3 million annually from 2,4,5-T
suspension (increased costs); unmeasured
but small.from silvex suspension.

no quantitative estimates; probably
minor increase in control costs.

impact of $13.3-$75.9 raillion/yr. from
2,4,5-T suspension; negligible impacts
from silvex suspension.
                               -28-

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Andrilenas, Paul and Eichers, Theodore.  Evaluation  of  Pesticide  Supplies
  and Demand for 1976, Agricultural Economic Report  No.  322,  Economic
  Research Service, U.S. Department of Agriculture,  Washington, D.C.
  April 1976.

Aspelin, Arnold L., Economic testimony in chlordane/heptachlor suspension
  hearings, Exhibit S-26, Washington, B.C., September 1975.   (See:  EPA
  Actions to Cancel and Suspend Uses of Chlordane and Heptachlor  as
  Pesticides—Economic and Social Implications, EPA-540/4-76-004, U.S.
  Environmental Protection Agency, Washington, D.C., August 1976, Part II).

Council on Environmental Quality.  The Economic Impact  of Environmental
  Programs^ Executive Office of the President, Washington, D.C.,  November
  1974.

National Academy of Sciences.  "Volume 1 Contemporary Pest Control Practices
  and Prospects:  The Report of the Executive Committee."  Pest Control;
  An Assessment of Present and Alternative Technologies , Washington, D.C.  1975.

Stanford Research Institute.  New Innovative Pesticides:  An  Evaluation
  of Incentives and Disincentives for Commercial Development  by Industry,
  prepared for Office of Pesticide Programs of the Environmental  Protection
  Agency, Washington, D.C., March 1976 (Draft).

U.S. Department of Agriculture and U.S. Environmental Protection  Agency.
  Economic Analysis of DBCP Cancellation on Selected Agricultural Crops. 1977.

U.S. Environmental Protection Agency.  DDT;  A Review of Scientific and
  Economic Aspects of the Decision to Ban Its Use as a  Pesticide, Washington,
  D.C., July 1975a.

U.S. Environmental Protection Agency, Briefing on DDT:  A Review  of
!'Scientific and Economic Aspects of the Decision to Ban Its  Use  as a
  Pesticide, prepared for the Committee on Appropriations,. U.S. House of
  Representatives, Washington, D.C.,. July 1975b.

U.S. Environmental Protection Agency.  EPA Actions to Cancel  and  Suspend
  Uses of Chlordane/Heptachlor as Pesticides;  Economic and Social Impli-
  cations , Washington, D.C., August 1976.

U.S. Environmental Protection Agency.  Preliminary Benefit Analysis of
  Chlorobenzilate.  Economic Analysis Branch, CED, OPP, Washington, D.C. 1977.

U.S. Environmental Protection Agency.  Preliminary Benefit Analysis of Endrin.
  Economic Analysis Branch, CED, OPP.  Washington, D.C., 1977
                                -29-

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U.S. Environmental Protection -Agency.  Preliminary Benefit Analysis of  Kepone  for
  Control of Ants and Cockroaches in Domestic Dwellings.  Economic Analysis  Branch,
  CED, OPP.  Washington, D.C. 1979.

U.S. Environmental Protection Agency.  Pesticide  Industry Sales and Usage.   1979
  Market Estimates.  Economic Analysis Branch, BFSD, OPP.  Washington,  D.C.,
  1979.

United States International Trade Commission.  United States Production and
  Sales of Pesticides and Related Products, Washington, D.C., Annual  issues
  1970 through 1975.

Wechsler, Alfred E., Joan E. Harrison, and John Neymeyer.  Evaluation of
  the Possible Impact of Pesticide Legislation on Research and Development
  Activities of Pesticide Manufacturers, prepared for Office of Pesticide
  Programs of the U.S. Environmental Protection Agency, Washington, D.C.,
  February 1975.
                               -30-

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