Office of Pesticides
                                       and Toxic Substances
                                       Washington DC 20460         February 1990
                    Office of Pesticide Programs
<>EPA         Environmental
                    Fact Sheet
                    RISK/BENEFIT BALANCING UNDER THE FEDERAL
                    INSECTICIDE, FUNGICIDE, AND RODENTICIDE ACT


          The  Federal  Insecticide,  Fungicide,  and  Rodenticide  Act
     (FIFRA) governs  EPAxs  regulation of  pesticides.  FIFRA  requires
     that all  pesticides intended  for  use in  the  United States be
     registered  (licensed)  by EPA to ensure  that they  do not cause
     "unreasonable adverse effects on man or the environment".  FIFRA
     defines unreasonable adverse effects  as "any unreasonable risk to
     man or the environment, taking into account the  economic,  social,
     and environmental costs and  benefits of the use of any pesticide."
     Pesticides may pose  some  risk because they are meant to  kill or
     control insects,  weeds,  rodents, and other pests.  But even though
     pesticide use  entails  some  risk,  pesticides provide  substantial
     benefits  to  society.   Hence, FIFRA, unlike other  environmental
     statutes administered by the Agency,  requires EPA to balance these
     risks and benefits in the pesticide decision making  process.

          In  order to  be able  to balance risks and benefits,  EPA
     conducts complex risk and benefits assessments that employ the best
     scientific  and  economic  analyses  currently available.   FIFRA
     authorizes  EPA  to  conduct  such  full  and public  risk/benefit
     analysis of pesticides  through its Special Review process or under
     circumstances where data show that a pesticide may pose an imminent
     hazard  to human health  or  the  environment.   These reviews are
     initiated on the basis  of  adverse human or ecological effects data
     which -ome  to the Agency's attention subsequent to the  initial
     regis.  ^tion of  the pesticide.   A Special  Review may result in
     cancellation of some or all  uses of the pesticide, the imposition
     of  risk  reduction  measures  such  as  protective  clothing,  or
     continued registration with  no changes.

        This fact sheet describes both risk/benefit  analysis,  and how
     it was applied to a recent EPA decision on whether  or not to permit
     the continued use of a problem pesticide.

     RISK ASSESSMENT

          EPA*s  basic  approach  to  evaluating pesticide   risk  is
     conservative and protective  of public  health. These are four steps
     in  the  risk   assessment  process:     hazard   identification,

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dose/response   asessment,   exposure    assessment,    and   risk
characterization.

     Hazard   Identification   —   The   objective   of   hazard
identification is to assess the nature of any adverse health effect
that may be caused by  the  pesticide based primarily on the results
of laboratory studies  conducted with  animals.  For example, is the
chemical an eye irritant, does  it cause acute poisoning,  does it
cause birth defects, does it cause cancer?

     Exposure Assessment  — Once  the  type   of  hazard has  been
identified,  the  exposure must  be  assessed.     This  involves
estimating the level, duration,  frequency  and route of exposure.
For example:  Are people who often mix and apply large amounts of
a pesticide overexposed?  Is there risk to people who consume foods
and drink water containing residues of the pesticide?  Will use of
the pesticide  affect  non-target organisms,  including endangered
animal and plant species?

     Dose/Response  Assessment    —  The  dose/response assessment
explores  the  relationship between  a level  of exposure  and  the
occurrence of an  adverse  effect.  Since epidemiological  studies
with reliable quantitative data on exposure are rarely available,
the Agency must rely on  the results of experimental animal studies
to estimate dose/response relationships.  EPA  extrapolates  from
animal studies to potential effects on humans, and from exposures
at high doses in  those  animal  studies  to the substantially lower
doses to  which humans  are typically  exposed.   Obviously,  this
involves  uncertainties;  EPA is  quite  conservative  in  resolving
them.

     For almost all chemically-related toxic effects (such as birth
defects, reproductive,  or non-carcinogenic chronic effects),  the
highest dose  level at  which  the effect is  not observed  in  the
animal study (No Observable Effect Level or NOEL) is determined and
an uncertainty  factor  (typically  100  or  more)   is applied  to
establish  a human exposure level that will   pose  essentially no
human risk.  For  example, an animal study may show  that  at  1000
milligrams of the substance in  the daily diet  of a 1 kilogram body
weight test a   al  (1000 mg/kg/day),  the animal showed no adverse
effects.  By allying a 100-fold uncertainty factor, daily exposure
of a human to 10  milligrams per kilogram of  body  weight would be
considered to be acceptable for a human.  In conducting pesticide
risk  assessments,  EPA  makes   a  practice   of   evaluating   all
potentially toxic effects, but generally focuses its quantitative
risk/benefit balancing process on the effect observed  at the lowest
dosage level.

     Where animal studies  indicate that  the pesticide chemical has
induced cancer  at  relatively  high  dose levels,   EPA ordinarily
presumes that there is no  dose  at which  some level of carcinogenic
effect would not  be observed.   (This presumption  sometimes could

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perhaps be overcome by  extremely  complex  and costly studies, but
usually  overcoming the  presumption  is practically impossible.)
Thus, EPA uses a mathematical model that assumes some effect could
be caused by any dose,  even one at a very  low level.  Such a model
expresses the worst-case qualitative carcinogenic "potency" of the
pesticide, or the worst-case probability that a given low dose will
produce a response in the animal species.

     As an index for regulatory decisions involving carcinogens,
EPA's stated policy is  that lifetime incremental cancer risks from
exposure to  a pesticide in the diet generally should  not exceed
one-in-one million  or  0.000001 (1 x 10-6)  —  meaning  one-in-one
million risk over and above the background cancer risk of 1 in 4.
This is the  concept of "negligible"  risk applied by EPA  and the
Food and Drug Administration.

     Risk Characterization  —  Finally, the  risk is characterized
by  integrating  the  above factors.     This  usually  involves
extrapolating exposure  in animals to humans.   It is scientifically,
legally,  and  ethically   impracticable   in  most   cases   to  do
experiments to show whether humans would have different responses
to  chemical  exposure than  test animals.   Thus,  EPA  ordinarily
assumes that human response is similar to that of test animals.

     EPA  seeks  to  express  a  risk  qualitatively  and,  where
appropriate,  quantitatively, and  to give  some  perspective to the
risk by summarizing the strengths  and weaknesses of the supporting
data and assumptions.   Through risk analysis,  the  Agency  is able
to determine  areas  where additional  data may  be needed or where
regulatory action may be warranted.

BENEFITS ASSESSMENT

     In  deciding whether  to  cancel  a pesticide,  EPA  conducts
benefits assessment. A benefits assessment follows guidelines that
take into account both biological and economic factors.  Biological
factors involve  information about target pests on each  site  or
crop.  Economic factorr   ^volve the effects of various pest control
strategies on the vari*. _. businesses which produce and distribute
commodities to the  consumer. Economic impacts are dependent on the
treated commodity  or registered  use  sights  of the chemical  in
question.  So that means that EPA must do a benefits assessment for
each  registered use  sight.    One  Special   Review chemical  can
therefore lead to dozens or even  scores of  benefits assessments.
Sometimes EPA must  tailor  its  general  approach to  the  particular
pesticide and market conditions encountered.  A benefits analysis
includes:

     Biological Analysis— Benefits are specific to each use site
— for example, corn, soybeans, or tomatoes, etc.  The estimation
of benefits derived from the use of a given pesticide is a multi-
step process.  The first step in this process is the identification

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of the pesticide's use  (i.e., agricultural, industrial/commercial,
or  home  use),  and  the   principal pest(s)  that are  controlled
through its application (e.g., insects, weeds, rodents).

     Next,  EPA takes  a  comprehensive look  at  the problem  by
developing a thorough  understanding of the  pest populations,  the
effectiveness  of chemical  and  non-chemical  alternatives,  the
geographic distribution of the pest problem, potential crop yield
impacts,  and  alternative  use practices which might  mitigate  the
risk.  In other words, the  process starts with  gathering basic
usage and product performance data in  order  to determine really
how important the chemical is  to the production of  any crop from
corn to mint.

     These  data  are  obtained through comprehensive  literature
searches, data bases created and maintained by EPA,  and extensive
communications  with   pesticide  users.     The   latter  involves
requesting information  from pesticide applicators,  other government
agencies (the Departments  of  Agriculture and Interior), scientists
from state land grant universities, and organizations representing
various user groups.  When little or no empirical data exist,  the
Agency relies  upon  the experience and observations  of pesticide
applicators,  scientists directly  involved  in studying pesticide
effectiveness,  and, to  some extent,  independent  agricultural
consultants.   These data are by  no  means  easy to  obtain  and
sometimes require literally  scores of  telephone calls,  etc.  But
the  Agency   is  committed  to obtaining  the  most comprehensive,
accurate, and up-to-date information possible.

     Economic Analysis —  The  next  step of  a benefits assessment
is to express  the biological impacts of yield loss,  reduced crop
quality,  and  alternative  pest  control  methods in economic terms.
The key  question  here  is  will it cost more  to  produce the crop?
EPA normally evaluates several types  of economic impacts.   The
first step is  to  determine the relative cost of alternative pest
control  strategies.    In  some cases,  EPA  finds  that  there  are
relatively   minor  economic   impacts,   because   cost   effective
substitutes  (chemical  and non   emical)  exist  and are  readily
available.  However, in other ea_^s equally effective alternatives
do not exist.   In this scenario  users may have  to  modify their
current use practices,  changes which often result in higher costs
of production for relevant agricultural and non-agricultural goods
and services.

     An  increase  in  production   cost  can  be   passed  down  to
intermediate processors and ultimately  to consumers in the form of
higher food prices or more costly control of pests in the home.
In  determining economic  impacts,   EPA takes  into   account such
influences such as agricultural subsidies, quotas, or allotments,
supply and demand factors, and international trade issues.

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     The Agency estimates both short- and long-term impacts at the
user  level.    This  analysis  accounts  for  the  net impacts  to
producers/suppliers  by  examining economic  effects  on  users  and
nonusers of the pesticide under review.  Based on this information
short-  and  long-term  effects  in  down-stream  markets  (i.e.,
processors,  distributors,  consumers)   can  also  be  estimated.
Potential local/regional  impacts are  also identified as  part of
this analysis.   These local effects may result  from movement of
economic activity  to foreign markets,  or  to other  areas  of  the
country where  pest infestation  is  not  a problem  (and  therefore
pesticide availability is relative unimportant).


AN ILLUSTRATION OF RISK/BENEFIT BALANCING — DIN08EB

     To illustrate this highly complex process,  consider the case
of the herbicide, dinoseb.   In October  1986,  EPA issued a formal
notice of intent to cancel and deny all registrations  for pesticide
products  containing  dinoseb.    Simultaneously,  EPA  issued  an
emergency suspension order to immediately stop dinoseb use during
the  time  to  complete  the  cancellation  proceedings.    These
regulatory  actions  were  based  on the  risk/benefit  balancing
scenario described below.

     Hazard Identification  —  In assessing  the  risks of exposure
to dinoseb, the first step involved identifying the hazard, based
on the results  of animal studies.  The hazard evaluation of dinoseb
focused on animal test results that it may cause birth defects in
females exposed  to  dinoseb during pregnancy, and may  also cause
sterility or decreased fertility in males,  acute toxic poisoning,
and other potential adverse effects  on health and the environment.

     Dose/Response — In  assessing  the  test-animal  dose response
for birth defects, EPA used an oral feeding study with rabbits to
provisionally  set  a NOEL  at 3  milligrams  per  kilogram  of  body
weight per day (mg/kg/day)  — meaning that adverse effects in test
animal offspring were apparent in all oral exposure levels higher
than 3 mg/kg/day, the lowest dose admini   red.

     Exposure Assessment — EPA estimated potential human exposure
based on either actual data or surrogate data.  Surrogate exposure
data is simply data from studies of exposure to other pesticide
chemicals (surrogates) that are of similar formulation to, and are
applied in the  same way as, the pesticide in question.  Appropriate
adjustments in the calculations are  made to reflect differences in
the rate of active ingredient applied per area,  per hour, etc. In
the case of dinoseb, three exposure scenarios were identified:

     - Possible dietary exposure to the public through
       consumption of food or drinking water containing
       residues of dinoseb.

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     - Occupational exposure to workers who mix, load,
       and apply dinoseb.

     - Secondary or coincidental exposure to bystanders,
       farmworkers, and others who could be exposed
       to dinoseb through spray drift, contact with
       residues in treated fields, or even contact with
       contaminated clothing or farm equipment immediately
       after dinoseb application.


      Risk Characterization — For dinoseb the main risk of concern
was  the  3  mg/kg/day NOEL  for birth  defects  in  rabbits.   EPA
compared this  NOEL from  laboratory  studies with  expected human
exposure levels  to obtain  numerical  margins of  exposure (MOE).
(NOEL divided by exposure equals margin of exposure).

     Even when certain "worst case" assumptions regarding dietary
exposure levels were factored into these calculations, the MOE for
the risk of birth  defects occurring  from  eating foods from crops
treated  with  dinoseb  was  found to  be  ample   —  over  2700.
Similarly,  from consumption of drinking water, the  MOE was roughly
2430.    However,   for  worker  exposure,   in many   instances  the
estimated worker exposure levels were  equal to or greater than the
NOEL of 3 mg/kg/day  —  leaving  essentially  no margin of exposure
against the hazard of birth defects  in the  offspring of pregnant
workers handling the pesticide.

     The benefits  assessment of dinoseb  was driven by  the  risk
factors described above. Based on data  from the U.S. Department of
Agriculture and other sources, EPA conducted an assessment of the
benefits of dinoseb by calculating the short-and  long-term economic
impacts expected to occur if dinoseb were unavailable for certain
registered uses*   Dinoseb use  sites  included  soybeans,  peanuts,
cotton, snap beans, potatoes,  green peas, grapes, alfalfa, almonds
and walnuts, berries,  and hops.   For both  short- and  long-term
scenarios,  the largest user impacts were projected for potato and
peanut growers.  The overall impacts of removing    noseb from the
marketplace were estimated  at the  user level in ...e range of $80
to $90 million.

     The Agency  quantifies both risks and  foregone benefits for
several  regulatory  options.     Economic  impacts  are  typically
quantified  in  the monetary terms  described above.   In deriving
policy,  annual  costs  are  compared  to  the  positive health  or
environmental  effects  achieved through the  various option.   By
analyzing  risk reduction  and  subsequent  costs  (i.e.,  foregone
benefits)  for  each policy  option, the Agency  can determine and
implement the most feasible and protective regulatory action.

     In the case of dinoseb, EPA determined that the risks of birth
defects  from  occupational and  secondary  exposures to  dinoseb

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presented significant risk to developing fetuses.  There was also
convincing  evidence  exposure  to  dinoseb  under  both  exposure
scenarios posed additional risks of  adverse reproductive effects
in males  and acute toxic poisoning.   EPA considered a  range of
measures to reduce the risk,  which included additional protective
clothing, protective farm equipment,  lower application rates, and
product reformulation.  EPA determined that none of these measures
could reduce the risks to reasonable levels.  Therefore, though the
benefits of dinoseb were substantial in terms of monetary value,
EPA concluded that risks of exposure to dinoseb clearly outweighed
its  benefits,  not  only in  the long-term  but  also during the
interval  of   time  required   to   conduct   usual   cancellation
proceedings.  Thus, in October 1986 the Agency opted for the most
drastic  remedial  option  available  under  FIFRA  —  emergency
suspension calling  an immediate halt  to the  sale  and use  of a
pesticide while cancellation proceedings are conducted.

     However,  in  reaching   a  decision to  immediately  suspend
dinoseb, EPA did not attempt to evaluate the economic benefits from
use of dinoseb for each affected crop  in each geographic region.
Rather, the Agency focused on national impacts and on those crops
involving the largest  amount  of  use  and  perdent  of the  crop
treated.  A more  extensive analysis would not have been consistent
with the  Agency's concern  about the imminent  hazard to pregnant
women exposed to dinoseb.

    As  a result,  growers  of  certain  minor  crops  grown  in the
Northwest sued  EPA,  asserting that the suspension  was  invalid
because EPA did not properly conduct its benefits  analysis and that
there  were   modifications  to  use practices  less  drastic  than
suspension that  would have  sufficiently reduced the risk.   The
growers also complained that  EPA could have delayed the suspension
of use  of dinoseb on their crops,  which would not  have occurred
until several months after the suspension order was issued, while
EPA  completed the  benefits  assessments for  their  uses.    (The
suspension  of the major  uses  of  dinoseb,   such as  peanuts and
potatoes, was never challenged.) A district judge agreed with the
plaintiffs and issued an order allowing the use of dinosel-    i the
minor crops if a series of use precautions were observed.

     An appeals court later  ruled that  the  district judge had no
authority to modify the suspension order by imposing conditions of
use, but  by then the use had already occurred.   Meanwhile, EPA
completed its assessment of  the benefits of  all  dinoseb uses in
preparing  for  the  cancellation  hearing.     However,   all  the
registrants  of  dinoseb  eventually  agreed  to  withdraw  their
registrations, making both a cancellation proceeding and further
court proceedings moot.

       Some  of  the  other  cases  interpreting  the  suspension
provisions of FIFRA are not  consistent with the results  in the
Northwest dinoseb suspension  case.    However,  if  FIFRA  is not

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amended or clarified, the  need  to fully assess economic benefits
prior to  emergency action could  prevent EPA  from  taking timely
action to protect human health.  Under President Bush's food safety
plan announced in October 1989,  EPA would have the flexibility to
order a suspension when there is substantial risk to human health
without consideration of economic benefits.

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