EPA PESTICIDE CANCELLATIONS/SUSPENSIONS:
A SURVEY OF ECONOMIC IMPACTS
Office of Pesticide Programs
U.S1.' Environmental.. Protection Agency
Washington* D.C. 20460
March, 1980
-------
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
-------
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
-------
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-
-------
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-
-------
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—
-------
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.
-------
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-
-------
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-
-------
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-
-------
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-
-------
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-
-------
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-
-------
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 $11.4 million, or about 5 cents per
capita).
-12-
-------
FIGURE 3
ECONOMIC IMPACTS OF
MERCURY CANCELLATION
A. REGULATORY ACTION:
B. EXEMPTIONS:
cancellation of the following
pesticide uses of mercury; as an
in-can preservative and/or
mildewcide for oil-based paints
(effective February 17, 1976);
for seed treatments and summer
diseases of turf after August
31, 1978, or following the
production of two years supply
of these products (based on
recent production data)
whichever occurs first; all uses
of mercury in plastics and as
medical disinfectants.
water-based paints, winter
diseases of turf, textiles and
fabrics for outdoor use, control
of brown mold on freshly sawn
lumber and Dutch elm disease.
C. EXTENT OF USE:
Oil-based paint;
Turf, esp. golf courses
for summer diseases:
Seed treatment:
D. SUBSTITUTES:
180,000 pounds active ingredient
mercurials were used in as many
as 45.05 million- gallons of
paint/year (1973).
43,600 pounds active ingredient
mercurial fungicides were used
on about 8,125 golf
courses/year 1973.
7,000 pounds active ingredient
used to protect various seeds
from fungi.
data presented in the mercury
hearings, indicated that a
number of effective alternatives
were available for most
applications in which mercury
pesticides have been used. For
oil-based paint, mercury
alternatives provide an adequate
level of control at an increased
cost ranging from 5.9$ to 11.0$
-13-
-------
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-
-------
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-
-------
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-
-------
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-
-------
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-
-------
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-
-------
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-
-------
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-
-------
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-
-------
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-
-------
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- •
-------
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-
-------
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-
-------
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-
-------
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-
-------
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-
-------
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-
------- |