THE DEVELOPMENT OF DATA
REQUIRED  FOR REGISTRATION OF  PESTICIDES
 FOR SPECIALTY AND SMALL ACREAGE CROPS
        AND OTHER  MINOR USES
              Report Prepared





                    By
       The University-EPA-USDA Ad  Hoc
              Subcommittee
               August 1973

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         THE DEVELOPMENT OF DATA
REQUIRED FOR REGISTRATION OF PESTICIDES
 FOR SPECIALTY AND SMALL ACREAGE CROPS
         AND OTHER MINOR USES
             Report Prepared

                   by
     The University-EPA-USDA Ad Hoc

              Subcommittee
               August 1973

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                                                                            11
                                ACKNOWLEDGEMENTS
The Executive Committee of the Subcommittee wishes to thank the many persons who
provided information, suggestions and other assistance which has been most useful
in the preparation of this report — those named on the committee as well as others
who gave of their time.

Outside the subcommittee itself, important contributions of Dr. J. V. Osmun (with
Cooperative State Research Service of USDA at the time) and Dr. J. E. Dewey of
Cornell University need special mention.  Dr. Dewey's report on minor use pesticide
problems in the state of New York provided many useful ideas for the subcommittee's
consideration.  Dr. Osmun chaired a USDA committee studying the minor use problem,
and he provided much valuable information to the subcommittee, especially regarding
the positions of the various services within USDA.

We also are deeply indebted to Dr. R. J. Sauer, who did an outstanding job of
coordinating, compiling and editing this report.  His dedicated efforts and high
professional capabilities resulted in a quality report which should prove useful
in the years ahead.

                              Executive Committee*

                        F. H. Tschirley   William Upholt
                             H. H. Wilkowske, Chairman
                              Subcommittee Members*
H.
V.
W.
R.
C.
J.

G.
H.
A.
C.
L.
E.

Alford
Freed
Gebhart
Riley
Smith
Swift
C. R.
C.
E.
G.
H.
R,
C.
Walker
C.
0.
M.
R.
N.
H.

Compton
Gangstad
Markel
Russell
Smith
Van Middelem

                                    Consultant

                          Dr. Richard J. Sauer
                          Department of Entomology
                          Michigan State University
                          East Lansing, Michigan  48823
*See Appendix I for titles and addresses

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                                                                     Ill
                        TABLE OF CONTENTS
                                                       Page
  I.   INTRODUCTION
      A.   Parent Committee ..............    1
      B.   Subcommittee ................    2
      C.   The Problem .................    2
      D.   Objectives  of This  Report ..........    3

 II.   PESTICIDE REGISTRATION  REQUIREMENTS .......    4

      A.   History of  the Development of Laws
            and Regulations ..............    4
      B.   Pesticide Registration Procedures ......    5
          1.   Why ...................    5
          2.   How ...................    5
          3.   Types of Registrations .........    6
          4.   How Many Petitions Per Year .......    8
          5.   How Many Applications for Registration
                Per Year ...............    8
          6.   Temporary Tolerance ...........    8
          7.   Clearance and Labeling .........    8
          8.   Public  Announcements and Dissemination
                on Information to Users ........    9

III.   IDENTIFICATION  OF THE PROBLEM ..........    9

      A.   The Problem in Agriculture .........    9
          1.   Why There Are Fewer Registrations
                for Minor Uses ............    9
          2.   The IR-4 Project ............   11
          3.   Agricultural Pesticide Uses and Needs
                in the States .............   11
          4.   Extent  of Pesticide Uses and Needs
                in the USDA ..............   18
      B.   The Problem Outside of Agriculture .....   23
          1.   U. S. Department of Defense .......   24
          2.   U. S. Army Corps of Engineers -
                Aquatic Herbicide Uses ........   25
          3.   U. S. Department of Interior ......   29

 IV.   CURRENT PROCEDURES AND  DEFICIENCIES .......   30

      A.   Agriculture in the  States ..........   30
      B.   USDA ....................   32
          1.   Animal  and Plant Health Inspection
                Service (APHIS) ............   32

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                                                                        IV
                                                           Page
         2.   Forest Service	33
         3.   Agricultural Research Service 	   33
     C.   Department of Defense	34
     D.   Corps of Engineers	34
     E.   Department of Interior	35

 V.  RECOMMENDATIONS	36

     A.   To Agriculture in the States	36
     B.   To USDA	37
     C.   To Department of Defense	37
     D.   To Department of Interior	38
     E.   To Corps of Engineers	39
     F.   To Environmental Protection Agency	39

VI.  SUMMARY	42

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                                 LIST OF APPENDICES


   I.    Membership of Subcommittee

  II.    History of Laws and Actions Affecting the Development of Agricultural
        Chemicals and Their Use on Food

 III.    The IR-4 Project Organization

  IV.    New York State's Minor Use Pesticide Needs on Food, Forage and Livestock

   V-A. Selected Minor Use Pesticide Needs in California

   V-B. Selected Minor Use Pesticide Needs in Michigan

  VI.    U. S.  Department of Agriculture, Secretary's Memorandum No. 1799

 VII-A. Pesticides Used and Needed in Domestic Programs of the Plant Protection and
        Quarantine Programs of APHIS But Presently Unregistered

 VII-B. Pesticides Used and Needed in Foreign Programs of the Plant Protection and
        Quarantine Programs of APHIS But Presently Unregistered (Part I) or
        Registered for Some Uses But Not All (Part II)

VIII-A. Major Forest Service Control Projects in FY 1972

VIII-B. List of Minor Use Pesticides Needed by Forest Service

  IX.    Department of Defense Pest Control:   Unregistered Pesticides and Unregistered
        Pesticide Uses

   X.    Minor Use Herbicide Needs for Aquatic Vegetation Management (Corps of Engineers)

  XI.    Selected Minor Use Pesticide Needs by U.  S. Department of Interior

 XII.    Agricultural Research Service Facilities Devoted Primarily to Pesticide Research

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                             THE DEVELOPMENT OF DATA
                     REQUIRED FOR REGISTRATION OF PESTICIDES
                      FOR SPECIALTY AND SMALL ACREAGE CROPS
                              AND OTHER MINOR USES*


I.   INTRODUCTION

    In recent years there has developed a significant increase in public awareness
    of our environment.   Of great concern is the overall  decrease in quality,
    especially when caused by things people do.  Indifference is gradually being
    replaced by the realization that we have only one environment.   Serious problems
    are being discussed and solutions sought.  Fortunately, thinking and concerned
    people do not just talk about problems;  they attempt  to bring about  solutions.
    And with only one environment for all,  people realize the importance of
    working together toward common goals for mutual protection and benefit.

    Pesticides,  which are absolute necessities to provide our growing population
    with high quality food in sufficient quantity,  are one area of concern.   Even
    though the scientific development and use of pesticides is one of the great
    contributions to the progress of mankind, their effects on the environment are
    being given much attention.   Research is underway to  find better and safer
    pesticides.   Laws and regulations are in force which  regulate the safe and
    proper use of pesticides in order to protect people,  plants,  animals and
    wildlife as well as  the overall environment.  A great deal of attention is now
    being given to pesticide related problems.  This subcommittee study  and report
    is directed at one aspect of the problem:  developing the data needed for the
    registration of pesticides for specialty and small acreage crops and other
    minor uses.

    A.   Parent Committee.

        An interdisciplinary committee, titled "The University-EPA-USDA  Coordinating
        Committee for Environmental Quality Research, Monitoring and Extension
        Education", was  organized and first met in April, 1972,   The committee
        consists of high-level administrative officials from the three organizations
        with Dr.  Leland  D.  Attaway of EPA as Chairman.  One of this parent committee's
        initial  objectives was to identify priority research and extension needs
        as well  as opportunities for further cooperation  and coordination amongst
        the three organizations.

        The committee came up with an initial list of 21  individual priority needs.
        Out of this list, four topics were identified as  high priority items for
        early action in  coordinating plans and programs,  and four ad hoc subcommittees
        were established to deal with these topics.   This study and report is the
        product  of one of those four ad hoc subcommittees.
 *The  term  "minor  use"  as  referred to herein is  defined as any essential use of a
 pesticide  that  is unprofitable for the producer or distributor to obtain a
 tolerance  for or  register for use.

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B.   Subcommittee.

    This subcommittee was established by the parent committee to consider the area
    of "research to develop the data required for registration of pesticides
    for production of specialty and small acreage crops".   A shorter title
    suggested in the charge was the "Specialty Crop Pesticide Subcommittee".

    The parent committee designated three people as representatives of the
    three organizations to constitute an executive committee of the sub-
    committee.  They are:  Dr.  Howard H. Wilkowske (Universities), Chairman;
    Dr. William Upholt (EPA);  and Dr. Fred H.  Tschirley (USDA).   Addition
    of other members to the subcommittee was left to the discretion of the
    executive committee.

    The subcommittee soon discovered that the problem of getting pesticides
    registered for specialty and small acreage crops is primarily a problem
    of it being unprofitable for the producer or distributor to obtain a
    tolerance for the pesticide or register it for use.  Thus, the subcommittee
    took on a study of this problem as it relates to all minor uses (defining
    minor use as any essential  use of a pesticide, agricultural or otherwise,
    that is unprofitable for the producer or distributor to obtain a tolerance
    for or register for use).   Accordingly,  the executive committee expanded
    the membership and broadened the base of the subcommittee (see Appendix
    1 for names and titles of subcommittee members).

    For purposes of this study and report the term pesticide includes any
    pesticidally active chemicals and/or other chemical materials for human,
    animal or plant pest or disease control  which requires legal clearances
    through registration as pesticides.   Examples are:   insecticides,
    herbicides, fungicides, bactericides,  acaricides,  nematocides, molluscicides,
    rodenticides,  pesticides (and drugs  used as pesticides) in fish and wildlife,
    plant and animal growth regulators,  hormones, attractants, repellents,
    dessicants, microbials, viruses,  biological controls and others.  This
    report will simply refer to all of the above collectively when the term
    "pesticide" is used herein, unless otherwise specified.

C.   The Problem.

    The basic problem with which this subcommittee study and report deals is
    the urgent need for establishing clearances of numerous minor uses of
    pesticides for efficient agricultural production and other special needs.
    The term "clearance" includes all efforts directed toward obtaining
    officially and legally approved pesticide registrations.  In other words,
    a pesticide is cleared after a tolerance or exemption from a tolerance has
    been established and a pesticide label registered.   These clearances must
    obviously comply fully with present  laws and regulations and at the same
    time provide maximum protection of commodities, the users and consumers,
    wildlife and especially the environment.

    A fundamental  objective of  registration is to insure that pesticides be
    used only for  those specific pest controls which they are designed to
    achieve.   Thus,  the benefits of registration far outweigh the potential
    risk of "unregistered" use  or non-use if needed for protection of resources.
    There is  a critical need to obtain not the minimum but the maximum number

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    of approved and legal registrations in order to reduce unregistered uses,
    since to be registered indicates requirements for safety and effectiveness
    have been met  (which may not be true when used illegally).

    The problem has been magnified as registration requirements have increased.
    To meet the added requirements, much greater expenditures of time,  manpower
    and funds are now required.

    At a time when the agricultural chemical industry, for various legitimate
    economic reasons, is contributing less to the clearance and registration
    of pesticides in minor uses, the public agencies have not fully evaluated
    the situation nor adequately taken on the responsibilities  of solving the
    problems.  As costs of new pesticide development and registration continue
    to grow, there are indications that the pesticide manufacturers and
    formulators are concentrating their efforts in those fewer  areas where
    profits are still possible, leaving more and more of the unprofitable
    registrations uncompleted.

    A major problem—lack of registered pesticides for many necessary but
    minor uses--is developing as a result of current trends and a shift of
    emphasis in the pesticide chemical industry.  Public agencies for the most
    part have been unable to muster the needed additional support to expand
    their research efforts in order to clear more pesticides for these minor
    uses, including many uses needed by the public agencies themselves.  The
    result is an increasing lack of needed registered chemicals, due to a
    severe backlog of needed toxicological data, metabolite studies, environ-
    mental impact information, field performance evaluations and residue and
    other data required for clearances and the establishment of tolerances.

    A sizable research effort is needed to provide the data required for
    registration of pesticides for minor uses, minor crops and  other specialty
    pest control needs.

D.  Objectives of this Report.

    The overall objective of the subcommittee's study and this  report is
    stated in the charge to the subcommittee from the parent committee:
    "to consider the problems associated with developing the data required for
    registration of pesticides for production of specialty and  small acreage
    crops and other minor uses."

    More specifically, the objectives can be stated as follows:

    1.   To identify the  nature and magnitude of the problems associated with
        obtaining pesticide registrations for minor uses, both  within and
        outside of agriculture;

    2.   To contrast the  problems with the procedures currently being used
        by the various public agencies and other organizations  to clear minor
        use registrations,  and assess any deficiencies in these current
        approaches;

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         3.  To consider alternative methods for solution of the problems; and

         4.  In the form of a written report, to make specific recommendations
             to appropriate agencies and organizations of actions they could
             take to aid in solving the problems.  The agencies and organizations
             to which this report is addressed are the state agricultural
             experiment stations., the U. S. departments of Agriculture, Defense
             and Interior, the Army Corps of Engineers and the U. S. Environmental
             Protection Agency.

 II.  PESTICIDE REGISTRATION REQUIREMENTS

     One cannot begin to appreciate the complexities of the problems involved
     with  developing the data necessary to clear pesticides for registration unless
     the requirements of (the laws and regulations relating to) pesticide registration
     are fully comprehended.  Thus, this report first devotes space to a brief
     history of the development of laws and regulations followed by a concise but
     comprehensive look at current pesticide registration procedures.

     A.  History of the Development of Laws and Regulations.

         In the United States we have had laws affecting pesticide development,
         sale and use for almost 67 years, dating back to the original Federal
         Food and Drug Act  (June 30, 1906).  Through these 67 years several
         subsequent laws were passed which resulted in stricter, more comprehensive
         and more specific regulations.  The most recent and most comprehensive
         of all is the Federal Environmental Pesticide Control Act, which was
         signed into law on October 21, 1972.  The major provisions of the bill
         are as follows:*

         -- will be administered by the Environmental Protection Agency;

         -- requires all U. S. pesticides to be Federally registered or approved;

         -- classifies pesticides for general or .restricted use, the latter--
            because of hazard to the individual or the environment--to be applied
            only by or under the supervision of certified applicators;

         -- establishes State applicator certification programs (with farmers
            certified as private applicators) and cooperative enforcement programs;

         -- prohibits the misuse of pesticides (any use inconsistent with the label
            is a crime, whether or not personal or crop injury results or residue
            exceeding the tolerance is found at harvest), adds civil to increased
            criminal penalties, and otherwise strengthens enforcement;

         -- shortens administrative review procedures;
*A brief chronological history of the pertinent laws  (from 1906 up to 1972)
affecting the development of agricultural chemicals and their use on food is
presented in Appendix II.

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    -- requires pesticide producing establishments to be registered and
       to regularly submit information on production and sales  volume;

    -- authorizes indemnification of certain owners of pesticides  which
       are suspended,  then cancelled;  and

    -- authorizes the  EPA Administrator to establish pesticide  packaging
       standards, regulate pesticide and container disposal,  issue
       experimental use permits,  conduct research on pesticides and
       alternatives and monitor pesticide use and presence in the  environment.

    All provisions of  FEPCA must be effective within four years, and a  task
    force to formulate regulations to implement the provisions  of  the Act
    has already been established by EPA.  All proposed regulations will be
    published in the Federal Register at which time comments  will  be
    solicited.

B.   Pesticide Registration Procedures.

    1.  Why.

        The law requires the registration of pesticides for two primary
        purposes:

        a.  to ensure  that the product will be effective for  the purposes
            claimed on the label when used in accordance with the  directions,
            and

        b.  to ensure  that the product will pose no safety hazards to humans
            or unreasonable adverse effects to the environment  when label
            directions and precautions are followed.

    2.  How.

        The various forms and data which are required by EPA of an applicant
        are discussed  in detail in "Guidelines for Registering  Pesticides  in
        the United States".  Copies of the latest printing of this document
        are available  from Pesticides  Regulation Division, Office of
        Pesticides Programs, EPA, Washington, D.  C. 20250.  It  will suffice
        just to highlight a few of the requirements here.

        Four basic types of data areas are normally required  in obtaining
        a clearance so that a tolerance may be established.  They  are:
        [1) performance data or field testing, including information on
        the pesticide  formulation, pests, crop and the exact  use;  (2) residue
        data,  including pesticide residue levels for the exact  use and
        metabolite studies with an analytical method suitable for  enforcement;
        (3) environmental data including residue toxicology information on
        wildlife and possible pollution in soil,  water and air; and (4)
        toxicology data, including acute and chronic toxicity studies on
        rats,  dogs and other organisms depending on the use of  the control
        agent.

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    Any person or manufacturer who has applied for registration of a
    pesticide under FIFRA submits a petition proposing establishment
    of tolerance levels for the particular pesticide.   The petition
    is accompanied by data in the four areas listed above.

    A tolerance is the maximum residue level allowed for a particular
    pesticide on a particular raw agricultural commodity.   The tolerance
    is based on the maximum residue expected from the proposed use.
    A tolerance level must be a safe level,  i.e.,  there must be a
    practical certainty that residues on the food within the tolerance
    level will impose no health hazard.

    Prior to December 2, 1970,  the Food and Drug Administration,  under
    the authority of the Federal Food,  Drug and Cosemtic Act,  was
    responsible for the establishment of tolerances (or exemptions
    from tolerances)  for pesticide residues in human food or animal
    feed intended for interstate shipment.   While EPA now establishes
    the tolerance, as prescribed by FEPCA,  FDA is still responsible
    for enforcing tolerances.

    Petitions are requests for the establishment or exemption (or
    revocation) of tolerances.   Tolerances  are established after review
    of petitions.  Most petitions are submitted by pesticide manufacturers,
    but they also come from formulators,  government agencies,  user
    groups,  or other interested parties.   Each petition must be accompanied
    by a fee as prescribed by the regulations.   However,  fees are
    usually waived for petitions submitted by universities or government
    agencies upon request.   The types of data required in a petition are
    spelled out in the guidelines.

    Once a tolerance has been established,  application for registration
    may be submitted for additional uses of the pesticide on the same
    commodity provided they do not leave residues in excess of the safe
    tolerance level.

3.   Types of Registrations-

    a.   New Registrations.

        Registration of new applications may be for two types of products:

        (1)   "New Chemicals":   products  comprised of,  in whole or in
             part,  chemicals not previously registered for any purpose.

             The level of review effort  for a new chemical product
             calls for maximum of 45-60  man-days of scientific review
             including safety,  efficacy and usefulness of the product
             and the  overall impact of the use of the product on the
             ecology.   Generally,  multiple  contacts with the company
             are required to assemble and clarify data.  This can have
             considerable influence on total review time.

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    (2)  The second classification of new products is one not previously
         registered for the particular company submitting the applica-
         tion, although similar or identical products have already
         been registered for other companies.

         Except where a new use is involved, products in this category
         need considerably less scientific review time than new
         chemicals because of the already documented safety and
         efficacy data assembled on similar or identical products
         already registered by other companies.

b.  Renewal Registrations.

    Regulations issued under FIFRA require registration renewal every
    five years.  Under these regulations 3,200 products become
    eligible for renewal in FY 1971, and nine thousand renewals were
    due in FY 1972 from an original eligible 11,200.  This activity
    was suspended during early 1972 due to restricted pesticides.
    These renewals are expected to be processed at the time of
    classification and re-registration of all products under the new
    legislation.  An expected registration lapse of 20 percent is
    expected each year.  Applications for renewal are subject to any
    new or revised standards since the product was registered and
    have not been applied to the registration during the period.
    Although the review may not always be as extensive as for a new
    product, it would include information not available with a new
    product such as use experience over the preceeding five years
    including accident and incident reports and information on
    environmental safety.  Follow-up investigational samples of
    these marketed pesticides for chemical and biological analyses
    which has been almost negligible in the past will be increased
    as pesticide field investigators are established in regional
    offices.

c.  Amendments to Existing Registrations.

    These include a variety of registration changes and may involve
    review time ranging from one-half a man-hour to several man-hours
    or man-days.

    Amendments include the following:

    a.  added or deleted uses

    b.  minor changes in formulation

    c.  changes in directions for use on a label

    d.  modifications in warnings and cautions in labeling

    e.  other modifications in labeling, i.e., company name,
        product name, etc.

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4.  How Many Petitions Per Year.

    During calendar year 1972,  over 320 petitions to establish tolerances
    were received by EPA.   The  backlog of petitions pending over 90 days
    was reduced from 88 at the  beginning of the year to one at the end
    of the year.   It is anticipated that petitions will continue to be
    received at a rate of between 20 and 30 per month.

5.  How Many Applications for Registration Per Year.

    Approximately 35,000 applications for registration  are processed
    each year.   As of the end of calendar year 1972, there were 32,223
    products registered by 3,372 registrants.   The backlog of applications
    pending over 90 days was drastically reduced during CY 1972:  at the
    beginning of the year, 463  such applications were pending as compared
    to 17 at the end.

    At present, there are no concrete projections for the amount of
    registration of intrastate  products which  will be required by the
    FEPCA.  It is assumed that,  excepting the  applications which will be
    generated by the new provisions of that bill, applications will
    average between 2,000 and 3,000 per month.

6.  Temporary Tolerance.

    A temporary tolerance or temporary exemption may be requested.
    These are usually granted for a period of  1 year to run concurrently
    with a temporary permit to  cover experimental use of the pesticides
    on a specified number of acres in specified geographic locations.
    The temporary permit allows  the petitioner to test  the pesticide
    on a relatively large scale  without destroying the  crop.  It also
    allows the treated crop to  be marketed legally.  Since consumer
    exposure will be quite limited, the toxicity and residue data required
    for the granting of a temporary tolerance  are usually less than for a
    permanent tolerance.

7.  Clearance and Labeling.

    Once a tolerance has been set, a pesticide is considered cleared
    for use on the particular crop against a certain pest as indicated
    in the application for registration.  However., before the chemical
    can 'be marketed and used it  must be labeled.  FIFRA requires that
    pesticide products be properly labeled prior to being introduced
    into interstate commerce.   And now, with the amendments contained
    in FEPCA,  products sold in  intrastate commerce must have a federal
    label as well.

    Labeling is generally defined as all labels and other printed or
    graphic matter attached to  or accompanying the pesticide product,
    or to which reference is made on the label or accompanying literature.
    The requirements to be met  for label approval are detailed in the
    "Guidelines for Registering  Pesticides in  the United States"-

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          8.   Public Announcements and Dissemination of Information to Users.

              Under FEPCA,  the pesticide user should have much more registration
              information available and options to act upon than in the past.
              The Act requires that the EPA Administrator publish several  kinds
              of notices, starting with the registration or denial of registration
              of a particular pesticide and including items such as any change
              in classification and any proposed cancellation.   The notices,
              by and large,  are required by the Act to be published in the Federal
              Register.

III.   IDENTIFICATION OF  THE PROBLEM

      A.   The Problem in Agriculture.

          Agricultural researchers are concerned with the ever-increasing  problem
          of food crop production, as well as with non-food crops that enhance
          our environment.   With the ever-increasing pressures of population  and
          decreasing amounts of tillable land, the Agricultural Experiment Stations
          (AES),  the United States Department of Agriculture (USDA) and the  State
          Departments of Agriculture (SDA) are faced with the potential problem of
          a decreased food supply.  To retain and/or increase our variety  of  food,
          feed and fiber the government or the public sector provides expert
          assistance through the AES,  USDA and SDA to both the large and small
          growers.

          More than ever the small growers or specialty growers need expert help
          in our complex society.   Overall, society would benefit significantly
          from the clearance of pesticides needed for minor crops.  Even with the
          large producers,  certain pesticide uses on major crops are very  minor and
          the manufacturers must limit their clearance expenditures in this area.

          Without pesticides the great variety of vegetables and other food products
          available to us would be in critically short supply and the cost would be
          exorbitant. The  basic need is for the production of wholesome food
          without losing the many different varieties we now enjoy.  Many  types
          of pesticides  are required under good agricultural practices to  produce
          a  wide variety of crops.  Agriculture requires pesticides because of
          the ever limiting space and the intensive type cropping which provide
          the opportunity for hostile attacks by pests.  Pesticides are often the
          most important pest management tools of a profitable grower's operation.

          1.   Why There  Are Fewer Registrations for Minor Uses.

              a.   Increasing costs of development of information for both  new
                  registrations and reregistrations for each use where new residue
                  and tolerance data is necessary has been one cause of fewer
                  registrations.

                  Prior  to  1966 many pesticides were registered on a "no residue"
                  basis  if  applied to  a non-food crop, to the non-food bearing
                  portion of the crop,  or to the soil.  Many herbicides and
                  fungicides were  registered on this basis.  In addition,  many

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                                                                  10
    herbicides and fungicides were thought to be "safe" as compared
    to insecticides and residue studies were not required even when
    the pesticide, was applied to the crop -- i.e.,  maneb, zineb,  etc.
    Residue and toxicity data for these uses are now necessary to
    establish the necessary tolerances.  Many registrations have  been
    dropped because of the cost of obtaining this information for a
    limited use, or to expedite the registration of other uses which
    would provide greater monetary returns to the registrant.

b.  More stringent standards and the longer time required for
    development has caused fewer registrations.

c.  The relatively low financial return in proportion to cost and
    time required to register may in some cases  cause the company not
    to register for a particular use.

d.  A disproportionate crop liability ratio in proportion to the
    amount of product used on the crop has also  been the cause
    for some registrations to be dropped.

    In some cases uses formerly registered and still listed (and legal)
    in the EPA Compendium of Registered Uses have been dropped from
    the label because of possible liability hazards which are out of
    proportion to the quantity of product used for that purpose.   For
    example, Diazinon for cabbage maggot, 2,4-D  wax bar for use in
    grape vineyards and dimethoate on many ornamentals are examples
    of uses restricted by the manufacturer.

e.  Expiration of patent rights and loss of protection afforded for
    return on investment, or public service patents which discourage
    commercial development unless some protection has been provided,
    have resulted in the loss of some important  pesticide uses.

    In some cases the patent rights on the product had expired and
    no one was interested in developing the information.  The use of
    rotenone on livestock for the control of ectoparasites was
    cancelled because of the lack of an adequate analytical method
    to determine residues.  This is a prime example of a material
    with a long record of safe use that has been lost.

f.  Insufficient room on the label for all uses  due to the large
    number of registered uses, or loss of space  due to increasing
    space required for other purposes (hazards,  storage, disposal,
    etc.) or uses providing greater sales and use of product have
    contributed to the loss of many minor uses.

g.  Loss of many registered uses resulting from  restriction of formerly
    widely used products has been a major contributor to the loss of
    many minor use registrations.  Materials such as DDT, aldrin,
    dieldrin,  maneb and zineb were effectively used against many
    minor use problems in addition to major uses.  The sudden loss
    of many of these minor uses has produced some situations more
    critical than the loss of the corresponding  major uses, because

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                  there  are  not  adequate  substitutes  for many  of  the minor uses
                  nor  much incentive  to find  substitutes on  the part of  industry.

          2.   The  IR-4 Project*

              Presently  the  Interregional  - No.  4  (IR-4) Project  is a public
              sponsored  vehicle  for assisting in obtaining pesticide clearances,
              especially for minor uses and other  specialty  needs.  The  IR-4
              Project, "Evaluation of Current Data and Needed  Research to Determine
              Tolerance  Limits of Chemicals for  Minor Uses on  Agricultural Products,"
              was  initiated  in 1964.  The  IR-4 Project Technical  Committee includes
              an experiment  station director  (administrative advisor) and a
              technical  representative from each of four regions  in the  United States,
              plus one representative from USDA-CSRS  and one representative from
              USDA-ARS.   There also is a  coordinator  and assistant coordinator located
              at the New Jersey  Agricultural  Experiment Station,  New Brunswick, and
              special  consultants from the State of California, Environmental
              Protection Agency  and the USDA  (Agricultural Research Service).  In
              order to have  this project  function  satisfactorily  on a national basis,
              one  individual in  each  state reserves as the IR-4 liaison  representative
              from his respective state.**

              The  IR-4 Project is unique  among the regional  and interregional efforts
              supported  by regional research  funds of the Hatch Act in that it is
              a research service effort with  the primary objectives of evaluating
              and  coordinating the assembly of necessary data  required by the
              Environmental  Protection Agency to obtain tolerances and label
              clearances for pesticides used  on  minor crops  and for minor uses of
              pesticides on  major crops.   The term "minor crops"  as referred to in
              the  IR-4 project title  may be defined as an essential use  of a pesticide
              that is  unprofitable for the producer or distributor to obtain a
              tolerance  for  or register for use.   In  addition  to  facilitating
              individual pesticide clearances for  minor uses,  the IR-4 committee
              is continuously evaluating more effective procedures for assembling
              essential  data in  order to accelerate future pesticide clearances.

          3.   Agricultural Pesticide  Uses  and Needs in the States.

              The  problem is simply that there are many critical pesticide uses
              and  needs  for  food crop protection which are not presently registered.
              These uses  are documented in more  detail in this section.

              a.   Types  of Pesticides.

                  The pesticides needed for these  uses fall  into  two categories:
                  non-proprietary compounds and  proprietary  compounds.   The latter
                  are under patent by the  private  sector (industry) while the
                  former are not.  As the  problems associated  with obtaining
                  registrations  for them differ, they will be  discussed  separately.
*Though not necessarily part of the problem as such, the IR-4 Project must be briefly
 explained here, as it is referred to several times in subsequent sections of the  report.
**A more detailed description of the IR-4 Project, including cooperating agencies
  and personnel, can be found in Appendix III.

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1)   Non-proprietary Compounds.

    Non-proprietary compounds  are  control  agents not under
    patent by the  private  sector.   They range  from newly
    synthesized chemicals  to currently used  ones which  have
    been around for a long time.   Anyone with  the  necessary
    registration data can  register a non-proprietary compound.
    But it is best to have the seller who  is the basic
    manufacturer,  formulator or distributor  register the
    use(s).   However,  the  public sector is often faced  with
    gathering the  necessary data for registration  if the  use
    is minor.

    The industry's interest in the new minor uses  of non-
    proprietary compounds  has  been marketably  depressed.
    Normally, industry will not clear a minor  use  as a  public
    service,  and many non-proprietary compounds are imported
    at a cheaper rate than at  what an American manufacturer
    can profitably produce them.   Even with  the 5  to 10
    completely new proprietary compounds being developed  as
    pesticides every year, growers still require many of  the
    older non-proprietary  pesticides.

    The extensions over the past 6 years provided  agriculture
    the opportunity to develop data for tolerances on the
    previously registered  non-proprietary  compounds.  Many
    of the old uses were cancelled but the ones required  by
    agriculture were extended  over the years until many were
    cleared by the IR-4 Project.

    An example of  one of these uses is the use of  DNOC  on
    apples as a blossom thinner.   This chemical has absolutely
    no value to the manufacturer but is very important  to
    the growers in the Northwest for use on  certain varieties.
    Each time additional data  were required  by the regulatory
    agencies, another year or  season's production  was required
    to gather it.   The last requirement (90  day feeding study
    on a non-rodent)  was received  from EPA in  May, 1972.  This
    requirement necessitated the development of funds and
    contracting with a commercial  toxicology laboratory.  The
    $14,000 has been obtained  and  the contract let to Hazleton
    Laboratories.   To develop  these required data  will  take
    6 months  (4 months to  conduct  the experiments  and 2 months
    to develop the report).  Even  with the extension time, the
    necessary development  of data  still must rely  on the
    limitation of  living organisms,  growing  seasons and good
    weather.   A poor crop  year will not give the necessary
    performance data required  for  a clearance.

    Other examples of minor use needs of non-proprietary  compounds
    and the  impact if the  uses are not registered  include:

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                                                              13
     (a)  Streptomycin   The use is essential on 2,000 acres
         of hops in Oregon and Washington.  Without this clearance
         2,000 acres of hops will not be produced during years
         of pest fungi pressure.  The growers must rely on every
         year as a good crop year in order to stay in business.

     (bj  Naphthalene acetic acid (NAA) - Its use is essential
         as a growth regulator in mandarin oranges and tangerines.
         NAA is a non-proprietary compound which is essential to
         control fruit set.  If not controlled, alternate years
         of production would yield small unmarketable fruit.  The
         growers are financially supporting the development of
         data to clear this use.

     (c)  Sodium chlorate - This material is used as a dessicant
         or harvest aid on sorghum and rice in the South.  The
         alternative to not having sodium chlorate cleared on
         sorghum was a $10 million loss in 1972.

         And the problem is further compounded by present general
         use of several items which are not registered specifically
         as pesticides or for the specific use even though they
         are used as such.  Most of these are in common use in
         non-agricultural operations and thus are available at
         any food or hardware store, but under FEPCA they must
         all be labelled as pesticides.  Examples of these are:

         -- HCN which is used on citrus as a fumigant.  Presently
            no manufacturer sells HCN as a liquid formulated
            pesticide but it is sold for mineral mining operations.

         -- Trisodium phosphate and sodium hypochlorite which
            are used as seed treatment materials.  These chemicals
            are manufactured for sale as laundry and cleaning
            aids, not as pesticides.

         -- Many ornamental uses of pesticides which are not
            presently registered.

         -- Petroleum solvents which are commonly used as herbicides
            These compounds can be bought at gas stations and
            other outlets where a pesticide label is not necessary.

2)  Proprietary Compounds.

    Proprietary compounds are control agents under patent by the
    private sector.   Industry does restrict the type of uses to
    be registered where economics,  liability or the public image
    may be endangered.   Where economics is the problem, many
    companies will allow registration of their product if all
    necessary data are developed by an outside agency.  Where there

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                                                          14


is a probability of a liable suit from the product's use,  the
company often will not allow the use to be registered.

Without the cooperation of industry, registration of a
proprietary compound cannot be obtained.  In such cases, the
public sector should be able to assume liability; develop
the necessary data and have a working agreement with industry
for the latter to produce the compound for the public sector use

Examples of minor use needs of proprietary compounds and the
impact if the uses are not registered include:

(a)  Producers of small fruits (blueberries, cranberries,
     elderberries, blackberries,  etc.) require various
     pesticides to continue production.  The small fruit
     grower has a large investment in the crop similar to
     apples which require many years before profitable
     production is realized.  The small fruit grower in many
     cases could not grow other crops, because of soil and
     climate (e.g.,  blueberries are grown on a sandy acid
     soil).  And growers have large investments in land,
     crop and equipment which would also restrict the small
     growers in substituting other crops.

(b)  Growers of forage crops grown for seed (e.g., Trefoil)
     could go out of business if data are not developed
     on certain insecticides and herbicides in the next
     year or two.

(c)  Crops limited mainly to specific areas (e.g., chili
     peppers and yams in Louisiana; sweet peppers in the
     Delmarva peninsula; spinach in areas where soil and
     climate and other conditions are favorable for
     production; mint in Oregon,  Washington and Indiana;
     and tropical fruits in Puerto Rico, Hawaii, Florida
     and California) are important, both socially and
     economically^ to the people of these areas.

(d)  Crops used for flavorings or condiments are minor
     crops used in very small quantities in our diet.
     Examples of condiment crops are anise, fennel, basil,
     caraway, garlic, celery seeed, coriander, dill, paparika,
     sage, thyme, tumeric, chives, leeks, mushrooms, horse-
     radish and mint.  The lack of legal pest control agents
     for these crops would decrease the yield and effect
     higher cost to the consumer.

(e)  Some tropical crops in Hawaii, Puerto Rico and parts
     of California and Florida are minor crops.  Examples
     are papaya, mango, avocado,  mangosteen and taro.  With
     the anticipated commercialization of these crops,
     pesticides are essential for maximum production per acre.
     Without pesticides, these crops will not come into
     commercial production.

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                                                        15
(f)   Oil crops such as apricot,  castor oil,  rape,  sesame,
     mustard,  plum, safflower,  sunflowers,  avocado and
     domestic  olive oil are minor yet important parts of
     our diet.  They all have pesticide needs which are
     presently unregistered.

(g)   Root crops such as rutabaga, parsnips,  carrots,
     bursock,  Jerusalem artichoke,  celeriac,  taro, yams,
     chufa,  water chestnuts,  Oyster plant,  radish,
     salsify and yautia are minor crops.   Many needs  for
     pesticide uses are associated with these crops.

(h)   Chinese vegetables such as  Pakchoc,  Kaichoy,  Chinese
     cabbage,  Garchoy, Chinese turnip, Gai Ian, Gow kee,
     Chinese pea, Ongtoy and Lobok, are minor crops and
     very important to the Chinese people.   There  are
     essentially no registered pesticide uses at present.

(i)   Most cole crops,  such as land and watercress, are
     considered minor and have critical pesticide  clearance
     needs.

(j)   Greenhouse vegetables are minor crops that need
     pesticide clearances, because the conditions  of  use
     are very different from uses in the field.

(kj   Metaldehyde is essential as a slug and snail  control
     agent.   In the humid Northwest slugs and snails  are
     destructive pests on many crops.  Strawberries could
     not be  produced without the foliage application  of
     metaldehyde.

(1]   Pesticides are essential in urban areas.  Household
     pests such as rats, bats,  roaches, ticks and  lice
     are potential health hazards.   Storage pests  destroy
     valuable  food and feed and provide avenues for other
     pests,  e.g., fungi and bacteria, to invade foodstuffs.
     Many of these pests present hazards to public health,
     yet the pesticide uses go largely unregistered.

(m)   Mushrooms are a minor part  of our diet.   The  mushroom
     growers were losing over $1 million a year due to a
     fungus.  IR-4 petitioned for the use of benomyl  and
     obtained  the clearance.   The alternative to not
     having  this essential use was a sizable drop  in  mush-
     room production and the partial disappearance of this
     minor but esthetically valuable crop from the market-
     place.

(nj   Commercial fish farmers are in need of several control
     agents.  The alternative is a decline in this
     increasingly importance source of protein-rich food.

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                                                                16
        (o)  In the non-food area,  ornamentals provide environmental
             and aesthetic value to the public.  There would be a
             great loss to the public if registered pesticide uses
             were not available for commercial growers of ornamentals.

b.  FEPCA of 1972.

    The 1972 Federal Environmental  Pesticide Control Act (FEPCA)
    provides that all labels presently registered by the State
    regulatory bodies must be registered by the federal government
    in two years from the effective date of the new law.  This
    poses a problem if the registrants, especially local formulators,
    delete many of these small uses from its label.  Since all
    uses must be registered by the  federal regulatory agencies,
    a great number of minor uses (especially ornamentals, seed
    treatments and other minor uses on minor and major crops) will
    be legally unavailable to the grower.

c.  Typical Costs of Clearance of Minor Uses.

    The development of a new pesticide costs industry up to
    $5 million and 6 years before it can be marketed.  A minor use
    problem usually involves the cost of collecting data up to
    the point of registration in order to get  a new use added
    for a chemical which has label  clearance for another use.

    IR-4 Project personnel have provided some  average cost figures
    that bear consideration.  The cost for a single food crop use
    where the toxicology is satisfactory normally runs $20,000.
    This would include the development of specific clean-up methods
    and metabolite identification and analysis for the particular
    crop situation.  Where the method is satisfactory, the develop-
    ment of the samples and analyses costs $5,000 to $10,000 depending
    on the crop.  In the nonfood area, costs vary but start at
    $1000.  The basic cost for every potential clearance is the time
    of the researcher in developing performance data by designing
    and setting out plots and collecting samples for analyses.  The
    analyst analyzes the necessary  samples at  a normal cost of
    $50 per sample.  Analysis for a normal use where all parts of
    the crops are analyzed in a sufficient statistical number would
    cost $5000.

    In some cases where toxicology  is required for a negligible
    tolerance, the development of toxicology data from a 90 day
    feeding study on rats costs $13,000 (minimum price) and on
    non-rodents--normally dogs--another $13,000 (minimum).

    All in all it adds up to a sizeable cost,  even if the chemical
    is previously registered for a  major use.

d.  Impact of Not Registering Essential Minor Uses for Agriculture
      From IR-4's Vantage Point.

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                                                                17
    Without pesticides cleared for use on minor crops,  many
    speciality crop growers would be placed in a position of
    losing their crops and income every year that a pest outbreak
    is not contained (and eventually going out of business), or
    of using the pesticides illegally.  The social implications
    are overwhelming when segments of our population are restricted
    in the use of essential pest management tools because they are
    growing minor crops.  Furthermore, some of the minor crops are
    actually major factors in certain states' economies.

    It has often been said that farmers in the recent past have
    used many pesticides which were not cleared for the specific
    use in mind.  If this was ture, the farmer has now been placed
    in an even more difficult position.  And he has no control
    over registering a use except through other groups, such as
    industry or IR-4.  If the grower cannot control pests on
    specialty crops, and even on major crops in certain geographic
    areas, he is at a disadvantage with other sections of the
    country not having a similar pest problem.  If the grower cannot
    control the pest, a loss is expected for both the grower and
    for the consumer.  The cost for the clearance of a control
    agent is relatively small compared to a crop loss year after
    year.  If a crop is harvested after a uncontrolled pest outbreak,
    the returns are less, the quality is poor, storage capability
    is lowered and toxic substances are sometimes produced by
    the fungi and bacteria attacking the stored commodity.

    Due to the value of land, the grower requires maximum production
    to offset taxes and retain open space for agriculture and
    the public.  And with the higher cost of labor, pesticides are
    required to fill the labor void.  If a grower cannot grow a
    speciality crop or a major crop because of pest problems
    considered minor, he may be forced to quit growing crops and
    be socially incapable of doing urban work.

e.   Essential Minor Use Needs - Beyond IR-4's Vantage Point.

    The IR-4 Project has been effective and is now being expanded
    with the addition of a third staff member at Rutgers University.
    The problem is not with the IR-4 Project, but with the states
    who must develop the research information -- efficacy of
    control data,  toxicity data when the company cannot supply it,
    analytical methods if necessary, and the residue data.  It is
    often just as costly and time consuming to register a minor crop
    or minor use as it is a major one, and the potential monetary
    return to industry is much less.  The costs are equally great,
    if not greater, for government than for industry.  Efforts of
    experiment stations, like those of industry, tend to be directed
    toward the major uses.  Money and time are both critical, and
    the number of needed uses are increasing at a rapid rate.

    The IR-4 Project regional technical committee representatives
    are now compiling a complete list of required minor use clearance
    needs, with priorities, across the country.  When this list is com-
    pleted, as has recently been done in at least a couple of states,

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                                                                    18
        it appears that the size of the problem will  stretch  beyond
        most everyone's imagination.

        For example,  the staff of the College of Agriculture  and the
        Agricultural  Experiment Station at Cornell  University recently
        compiled a list of the minor uses  which are needed to
        control pest  problems on food,  feed,  forage and livestock in
        the state of  New York and comply with FEPCA under strict
        interpretations (See Appendix IV).   In addition to these 197
        food uses needing registration,  they estimate that there are
        approximately 230 needed but presently unregistered uses on
        trees,  shrubs and ornamentals.   Thus,  under strict interpretation
        of FEPCA and  following the tentative timetables,  the  state of
        New York has  approximately 425 minor uses which will  be needed
        but may not be available to the user in 1975.

        The above summarizes the situation in one state.   If  this
        detailed type of list were prepared for all 50 states,  it would
        no doubt dramatize the magnitude of the problem that  exists.

        As additional evidence,  Appendix V A details  some specific
        examples solicited from various specialists in the state of
        California.  It is by no means an  exhaustive  survey,  such as
        the one in Appendix IV for New York.   Appendix V B likewise
        lists the most important minor use pesticides needs,  largely
        for food crops, in Michigan.

4.   Extent of Pesticide Uses and Needs in  the USDA.

    a.   Animal  and Plant Health Inspection Service  (APHIS).

        In carrying out day-to-day operation,  the Animal and  Plant
        Health Inspection Service finds itself in the position of
        trying to meet the requirements of  the Federal Plant Quarantine
        Act, Federal  Plant Pest Act,  and the Animal Health Acts of
        May 29,  1884, February 2,  1903 and March 3, 1905, as  well as
        the requirements of the new Federal Environmental Pesticide
        Control Act of 1972.   As a regulatory agency,  APHIS fully
        understands and supports the Secretary of Agriculture's
        Memorandum No. 1799 dated February 1,  1973  (Appendix  VI).

        Occasionally, APHIS personnel find it necessary to use
        unregistered  pesticides in order to bring into compliance
        certain articles,  animals or animal products  moving in inter-
        national or interstate commerce.  These are pesticide uses for
        which there has been no opportunity to check  for tolerances
        or residues because of the rare or unusual  occurrence of
        the pest associated with the unrestricted items.   In  these
        instances,  inspectors must be guided by experience when treating
        these articles.  If some unusual pests are  found on an article
        and there is  nothing in the literature or if  there is no
        past experience with this pest, they may use  a fumigant such
        as methyl bromide which is known to kill a  similar type pest
        under similar conditions.

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                                                                 19
    There is no way of predicting exactly what pest will occur on
    any particular item; therefore, it will be necessary for APHIS
    personnel to occasionally rely on the emergency provisions of
    Section 18 of FEPCA  (short-term permission for an unregistered
    use) in carrying out their obligations.  However, if the pest
    problem occurs with  any frequency, an attempt will be made to
    clear a use specifically designed for the problem.

    Appendix VII lists the pesticides used and needed in Plant
    Protection and Quarantine Programs by APHIS personnel that
    are presently unregistered.  These are essentially all minor
    uses.  Domestic programs uses (infested product originating
    within U.S.) are found in Appendix VII A and foreign programs
    uses (infested product originating outside of U.S. boundaries)
    in Appendix VII B.

    Note that of the 38 pesticides presently used in PPQP's
    domestic programs, 12 are unregistered.  In the foreign programs,
    four pesticides are not registered at all while 19 others are
    registered for some but not all of the uses for which they
    are needed.

    APHIS prefers that the manufacturer or formulator request from
    the Environmental Protection Agency the label for the use for
    all materials used by APHIS.  However, in many instances, the
    use will be restricted primarily to APHIS personnel in the
    enforcement of the Acts under which APHIS operates.  This use
    may be infrequent, and it will not be economically feasible
    for a company to take the time or spend the funds in order to
    have the material registered.  Thus, such uses can be classified
    as minor and yet they are essential to protect our nation's
    agriculture from the introduction or unduly rapid spread of
    serious plant and animal pests.  APHIS is in a special category
    here.

b.  Forest Service (FS).

    1)  Extent of Forest Service Needs for Registered and Non-
        registered Uses of Pesticides   Major and Minor Uses.

        The Forest Service,  often in cooperation with the States,
        conducts programs designed to manage or regulate animal
        and plant pest populations.   These programs often involve
        the use of pesticides.   Where pesticides are required,
        it  is policy to use only materials which are registered
        for the specific use intended.  All too often, however,
        situations arise which require rapid action but for which
        there are no registered pesticides available.

        To  illustrate continuing major and minor needs, control
        projects carried out in fiscal year 1972 on National Forest
        lands,  other Federal forest lands and on State and private
        lands are shown in Appendix VIII A (Major Forest Service
        Control Projects in FY 1972) or described below.  The major

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                                                             20
    target pests were spruce budworm,  gypsy moth,  bark beetles,
    the tip moth/cone insect complex in pine seed  orchards,
    diseases in forest nurseries and unwanted vegetation in
    forested,  range,  and road/utility rights-of-way areas.
    Lesser quantities of pesticides were used for  controlling
    insects, unwanted vegetation and noxious arthropods in
    special use areas, fumigation of soils for weed,  nematode
    and soil pathogen control,  bird and rodent control, site
    preparation, aquatic weed control,  trash fish  control,
    and range improvement.

2)  Limited Uses of Registered or Non-registered Pesticides
    by the Forest Service.

    Outbreaks of native and/or exotic forest and range pests
    in the United States occasionally reach such levels that
    action must be initiated promptly to protect forest resources
    from significant  damage and at the same time avoid
    environmental degradation.   In some instances, a pesticide
    may be available  that is specifically registered for use
    against the particular  pest.  A number of alternative
    registered materials may also be available which permit
    the manager to select the most environmentally safe
    material.   In other cases,  however, registered pesticides
    may not be available for the pest involved, for the
    section of the country  in which it occurs, or  for the
    plant species which serve as host(s).   Ecological conditions
    may dictate that  normally acceptable registered materials
    or other control  methods be excluded from consideration
    (e.g.,  outbreaks  bordering waterways,  primitive areas).
    Under these circumstances,  alternative non-registered
    pesticides may be required to promptly and effectively
    deal with the outbreak  and to minimize potential resource
    losses.

    Examples of problems which require timely action include
    outbreaks of such introduced pests as the gypsy moth,
    balsam woolly aphid, and larch casebearer which tend to
    reach explosive population levels as they spread into new
    areas.   Among the native insects,  the Douglas-fir tussock
    moth and bark beetles  reach outbreak numbers  in 1-2 years.
    Severe infestations of  the latter pests may occur over
    extensive areas then decline rapidly after killing or
    reducing the growth of  thousands of trees.  Root or foliage
    diseases may develop rapidly in a forest tree  production
    nursery and threaten the death of millions of  seedlings
    scheduled for regeneration programs.

    Problems have arisen in dealing with these pests.  Lindane
    is registered for use in controlling balsam woolly aphid
    on individual trees from the ground.  However, spraying  of
    large areas appears impossible and is presently warranted
    only in accessible areas supporting relatively high-value
    trees.   Other practical controls are,  therefore, needed.

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                                                            21
    No chemicals are currently registered for control  of the
    Douglas-fir tussock moth.   Zectran has provided erratic
    results in field tests and other promising chemical  or
    microbial agents are not yet ready for operational use.

    The use of lindane or ethylene dibromide in a unilaterial
    approach to controlling bark beetles has been challenged
    on the basis of undesirable environmental effects  and lack
    of long-term effectiveness.  The use of alternative  toxicants
    integrated with other pest population manipulative techniques
    must be considered.

    These and other problems,  often involving relatively minor
    pesticide uses, are of continuing concern to the Forest
    Service and challenge its  responsibility to provide  both
    short- and long-term protection for the Nation's forest
    resources.

    The Forest Service is also responsible for the detection
    and evaluation of pest problems on the U. S. Department
    of Interior land.  However, USDA is responsible for  the
    actual suppression efforts (see below).

3)   Responsibility for Registration of Pesticides.

    The Forest Service feels that the primary responsibility
    for developing and presenting efficacy,  toxicological
    and labeling information to support the registration of
    pesticide uses rests with  the manufacturers or formulators
    of these materials.  Where companies hold patents  on specific
    chemical materials, they generally have sufficient incentive
    to register uses, particularly where large continuing market
    opportunities exist.

    It is recognized, however, that some uses of pesticides in
    forestry do not have the potential for providing a reasonable
    return to a commercial registrant.  Examples include limited
    or infrequent uses of pesticides for localized pest  outbreaks,
    minor uses of attractants, microbial agents and other highly
    selective materials, special uses in controlling vegetation
    and mammals,  and uses for  improving fish habitat.

    For these special uses,  the Forest Service will determine
    the values  at stake, the alternatives that are available
    and,  if necessary; may have to accept the responsibility
    for developing any or all  of the data needed to insure the
    availability to forest and rangeland managers of critically
    needed registered pesticides.   This may involve development
    of the necessary efficacy  and safety data to support the
    registered use of safe,  effective pest control methods and
    materials.

    If a commercial producer is unwilling to bear the  costs of
    a use (new or supplemental use) which is deemed important  to

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        the success of forest or rangeland management operations,
        the Forest Service might have to become the registrant.
        In such cases,, it might be desirable that, as a condition
        of registration,  operational uses of the pesticide be
        carried out by, or under the supervision of, Forest Service
        personnel or qualified personnel responsible for pest control
        programs on forested or rangelands.

        One need only to look at the list of minor use materials
        presently needed by the Forest Service (Appendix VIII B)
        to see the seriousness of the problem associated with
        satisfactorily managing forests and rangelands.

c.  Agricultural Research Service (ARS).

    The Agricultural Research Service has a broad responsibility for
    developing new and improved methods of pest control.  This may
    involve the use of currently registered pesticides, new
    formulations of registered chemicals or new chemicals with no
    known or established pesticidal activity.  Thus, problems could
    result if ARS research scientists are not recognized as a
    group to be distinct from growers and farm workers.  They need
    sufficient flexibility in using pesticides to develop the data
    necessary to secure registrations.  Technological innovations
    by ARS personnel have made major contributions to U.S. agriculture
    The flexibility to pursue such research must not disappear.

    ARS also operates regular farming operations in conjunction
    with several of its research facilities.  The pesticide use
    needs on these farms are no different from those on private farms.

d.  Extension Service (ES).

    Extension's role in registration of pesticides is one of general
    involvement rather than functioning in a primary way to
    actually gather the necessary data for securing registrations.
    Extension works as an information and education unit acting
    in a catalytic or liaison role.   It is concerned with creating
    a proper understanding of and need for the registration of
    pesticides and their use.  This involves coordinating activities,
    concerns and decisions of regulatory agencies, research, the
    chemical industry and other agri-businesses, users of pesticides,
    and the general public.   The following points briefly outline
    Extension Service involvement in pesticide registration:

    1)  Only in extreme emergency or disaster situations would
        Extension become highly involved or take any leadership
        in requesting registration of a pesticide.  Two examples
        of this are:  (a) initiating action to get clearance to
        use an insecticide for mosquito control during the Rapid
        City,  South Dakota flood, where a public health problem
        could have developed; and (b) obtaining clearance to use
        an insecticide for greenbug control in Oklahoma where
        farmers were faced with an epidemic outbreak with supplies
        of present registered materials becoming unavailable.  In

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                 both of these situations Extension used its personnel to
                 involve public and private agencies in getting response
                 to carry out a mission.

             2)  Extension has an obligation to represent agricultural
                 producers and other concerned individuals by reporting
                 the need for registration of a pesticide for a given
                 situation.  This request is directed to research and
                 private industry who gather the necessary information
                 and to regulatory agencies who approve registration.
                 This is especially important in minor uses or where
                 products should be reevaluated and registration reinstated.
                 An example is rotenone for cattle grub control on dairy
                 animals.

             3)  Extension has a responsibility to explain the purposes
                 and need for registration of pesticides to the general
                 public.  They must have an understanding of the Federal
                 Environmental Pesticide Control Act as it relates to
                 food production, public health and the environment, so
                 they are in support of those public and private agencies
                 involved in making decisions on pesticide use.

             4]  Extension has an obligation to users of pesticides
                 (farmers, other people in agribusiness and homeowners)
                 to assist them in keeping abreast of changes in registration,
                 interpreting and adapting practices, understanding limita-
                 tions and restrictions, and practicing proper pest manage-
                 ment programs.

             5)  Quite often, Extension encourages the responsible agencies
                 to register a pesticide in sufficient time to be available
                 for use when needed.  The seriousness of a situation is
                 so often only felt at the local level or source of the
                 problem, and concerned parties must be represented.  Natural
                 and man-made envrironmental conditions change and do not
                 wait for man-made procedural or legal decisions to be made.
                 As a result, more complex problems sometimes develop.  In
                 some cases the problem may be an adverse effect on the
                 environment.

             6)  Finally, Extension has a role in evaluating the implementation
                 of a registration practice or use of a registered pesticide--
                 to determine its practicability, feasibility or performance,
                 and to request clarification of definitions and modification
                 of application in order to make the use acceptable to all.

B.   The Problem Outside Agriculture.

    The problem of securing registrations of pesticides for minor uses
    (as defined at the bottom of page 1) extends far beyond agriculture and
    the USDA to involve other federal agencies.  As FEPCA is being implemented,
    some control situations requiring the use of presently unregistered

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pesticides by federal personnel are becoming critical.   These problems
are detailed in this section.

1.  U.  S.  Department of Defense (DOD).

    a.   General Information.

        Pesticides are used extensively by the various  services in
        the Department of Defense to protect the health and welfare
        of personnel and prevent damage and deterioration by the myriads
        of pests which occur worldwide  on installations.   A commonly
        quoted estimate is that approximately 30 pesticides in 100
        formulations are routinely used to control 800  pest organisms.
        The military, with more than 1000 installations staffed with
        civilian and military personnel and their dependents, has a
        multi-billion dollar investment to protect.

        All three services (Army,  Navy  and Air Force) maintain pest
        management programs.   While they vary from service to service,
        in general each service divides the responsibility so that
        the medical services are responsible for disease vector control
        and the engineering services are responsible for economic pest
        control and the operation of shops, equipment and pesticide
        application.  The services share responsibilities in training
        pest control personnel who are  required to become recertified
        every two years after initial certification. Under this
        system approximately 1300 pest  control personnel maintain
        shops and perform a full range  of pest control  operations:
        ordering, formulating and applying pesticides.   Operations are
        monitored for safety by monthly reports reviewed by area or
        command entomologists who guide installation programs and make
        annual onsite program reviews.   Pesticide selections are made
        from recommendations in a tri-service military  handbook, annual
        recommendations published by the Navy Bureau of Medicine and
        normal information sources as salesmen and product labels.

        Within the Navy, for example, approximately 200 stations
        perform pest control with a labor force of 570  personnel, mostly
        civilians.  In FY-72 they reported nearly a million manhours
        and a minimum of 25,000 pest control operations or applications.
        The quality of their training is such that 95%  of them could
        pass the existing state certification examinations (where they
        exist).

        Many types of pesticides are used by the military services.
        In addition to the traditional  uses of insecticides, fungicides
        and herbicides, avicides and rodenticides are used--both indoors
        and out.   Special problems exist in the western states with the
        control of ground squirrels, a  problem which is already critical
        since an executive order was issued to prevent  use of toxicants
        with secondary poisoning potential to non-target animals on
        federal lands.

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        Many of the pesticides having specific uses have lost their
        registration or are under review.   Alternatives  are not always
        available and significant damage may be incurred before another
        appropriate substitute is found.

    b.   Unregistered Uses.

        A number of unregistered uses currently in practice in DOD pest
        control programs are listed in Appendix IX.  The listing is
        followed by comments regarding each of the uses  to illustrate
        the seriousness of the problem.

2.   U.  S. Army Corps of Engineers (COE)  -  Aquatic Herbicide Uses.

    a.   The Need for Aquatic Herbicides.

        Excessively large or dense populations of aquatic plants may
        be highly detrimental and reduce the usefulness  of a water
        resource for purposes of navigation, flood control,  drainage,
        agriculture, fish and wildlife conversation,  public health,
        recreation and other purposes.  It is imperative for the
        operation of these resources to  obtain registration of aquatic
        herbicides to permit their use for vegetation management where
        needed.

        1)  Obnoxious Aquatic Vegetation.

            Morphological forms of aquatic vegetation range from
            microscopic plankton to large  vascular plants such as
            cattail (Typha spp.) and waterhyacinth (Eichornia crassipes
            (Mart.) Solms).   Under certain environmental conditions
            and water quality criteria,  all of the forms are capable
            of creating problems in water.

        2)  Problems Caused by Aquatic Vegetation.

            (a)  Agriculture.

                 A consistent, readily available supply  of water is
                 becoming increasingly important in agriculture, as
                 irrigation becomes more and more widespread.  There
                 are cases where vegetation has blocked  reservoirs and
                 irrigation canals, leaving growers without water until
                 costly;  time-consuming  repairs are made.  Algae and
                 other aquatic plants also lodge in water outlets,
                 siphons, pumps, sprinklers, trash racks and other
                 structures, causing lost  time, inefficient use of water,
                 and large maintenance expense.  According to statistics
                 from the Agricultural census, there are more than
                 2 million farm ponds and  reservoirs (many used for
                 irrigation), 189,000 miles of drainage  ditches, and
                 173,000 miles of irrigation canals in the United States.
                 A survey of weed problems on irrigation systems in
                 17 western states reported 63 percent of the 144,000
                 miles of irrigation canals infested with aquatic weeds.
                 Also,  more than 75 percent of 530,000 acres of canal

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     banks  were  infested with  a variety of weeds.  Similar
     weed problems  occur in  other areas of the United States.

(b)   Recreation.

     Most of the streams and natural  and  artificial water
     impoundments are  multiple purpose resources.  Swimming,
     water  skiing,  and pleasure boating are not  entirely
     suited to waters  managed  primarily for fishing or
     waterfowl production.   Aquatic vegetation is  a serious
     problem affecting recreational uses  of water.  While
     aquatic plants are a natural and essential  component
     of the aquatic environment, they can despoil  this
     environment simply by their presence in  excessive
     numbers and in areas where they  are  undesirable.

(c)   Property Values.

     Clear  weed-free or relatively weed-free  lakes and  streams
     have always had a high  priority  for  location  of waterfront
     homes  and vacation facilities.   Serious  infestation by
     aquatic weeds  subsequent  to development  of  such areas
     drastically reduces the desirability and value of  water-
     front  property.

     Property values may also  be affected by  the presence of
     mosquitoes  and other insects, snakes, vermin, dead fish,
     foul odors,  and other conditions associated with excessive
     growths of  aquatic vegetation.   Other examples of
     depreciations  in  value  and damage of property area are:
     clogging of navigable streams; washing out  of bridges,
     boat docks  and other structures; flooding and altering
     of water courses; and damage and loss of boats, motors,
     and other fishing equipment.

(d)   Wildlife Management.

     Whereas many species of aquatic  plants are  valuable food
     or habitat  for certain  mammals,  reptiles, amphibians and
     birds,  the  manipulation and control  of weed species with
     herbicides  is  basic to  wildlife  management.   Herbicides
     are used for creating open areas, manipulating species
     composition of ecotones,  controlled  secondary succession
     of particular  species,  and density of plant growth.
     Each form of wildlife has specific habitat  requirements
     and often certain aquatic plants may adversely affect
     its quality.

     Public use  of  wildlife  areas requires maintenance  of
     access routes,  boat landings, water  movement  channels,
     and canals;  and protection from  flooding, safety hazards,
     noxious insects,  and vectors of  diseases.   Beneficiaries
     of these wildlife management programs are hunters,
     bird watchers,  wildlife photographers, and  nature  walkers.

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(e)  Fisheries Management.

     Environmental quality dictates the existence of acceptable
     fisheries, and control of plant life is the fundamental
     basis for fisheries management.  Uncontrolled growth of
     vascular plants and algae can divert solar energy and
     nutrients from food chain organisms or other desirable
     plant life.   Excessive plant density adversely affects
     predator-prey relationships and can result in fish kills,
     block fish migration or inhibit distribution,  spawning
     failtures, and undesirable changes in water chemistry.
     Herbicides and algicides promote stabilization of
     ecological conditions and are essential in integrated
     systems of fishery management involving dynamic biological,
     chemical, and physical environmental factors.   Stagnation
     and degradation of water quality,  nutrient availability,
     and radiant  energy often determine the value of fishery
     habitats, the occurrence of desirable species  of fish,
     and the quality and economic values of recreation and
     fish products.  By the year 2000,  it is expected that
     the present  82 million acres of inland fishing water will
     increase to  92 million acres—primarily in the form of
     warm water reservoirs that are subject to the  greatest
     weed problems.  Thus,  even more intensive fishery
     management (and use of pest control chemicals) will be
     required.

(f)  Potable Water Supplies.

     Algae,  especially the blue-green species, commonly cause
     undesirable  flavors in potable water supplies.  Water
     treatment processes do not remove these flavors and the
     only recourse available to improve the palatability of the
     water is heavy chlorination.  Vascular aquatic plants
     also contribute to the poor quality of potable water.
     Death and decay of large masses of plants create pollution
     conditions similar to those of sewage and industrial wastes
     It has  been  estimated that the oxygen-depleting pollution
     load of one  acre of growing waterhyacinth is equivalent
     to the  sewage produced by 40 people.

(g)  Navigation.

     Interruptions of and inconvenience to navigation, except
     on a limited scale,  occurs primarily in waters of the
     Southern and Southeastern United States.   Inland waterways
     of the  coastal areas of these regions form an extensive
     network that is vital  to the transport of materials to and
     from the areas.  Considerable economic loss occurs when
     this traffic is delayed or stopped by accumulations of
     aquatic vegetation.   In addition to interference with both
     commercial and pleasure navigation, costly damage occurs
     to boats and bridges.   Drifting mats of waterhyacinth,
     when piled up against bridge supports, have been known to
     move and shift the entire structure.   Logs and other

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             obstructions concealed by the plants provided additional
             hazards to navigation.  It is estimated that without
             adequate control of aquatic plants,  navigation (and
             considerable land traffic) would almost cease in these
             waterways within a three year period.

b.  Aquatic Vegetation Management with Herbicides.

    The aquatic vegetation management problems and the chemicals
    need to adequately solve each problem are detailed in Appendix X.

c.  Alternative Methods of Aquatic Vegetation Management.

    Various non-chemical methods have been designed and tested in
    attempting to manage troublesome growths of aquatic plants.
    Space limitations prevent a detailed discussion of them in this
    report.  They are simply listed,  as follows:

    1)  Mechanical.

        (a)  Underwater cutters to sever submersed  vegetation.

        (b)  Devices for cutting swaths from floating vegetation.

    2)  Biological.

        (a)  Fish, snails and other aquatic animals.

        (b)  Insects.

        (cj  Pathogens.

        (d)  Competitive Vegetation.

    3)  Ecological Modification.

d.  Advantages and Disadvantages of Chemical Methods.

    There are few instances in which the efficacy of chemicals has
    not exceeded that of presently available alternatives for aquatic
    plant control.  Covering or enclosing irrigation distribution
    systems in pipe is an effective means of eliminating weeds in
    irrigation canals.  In the narrow band of the southern United
    States to which it is climatically suited, the Agasicles beetle
    has proved superior to chemicals for control of alligatorweed.
    However, outside this narrow range, populations of the beetle
    do not reach the levels necessary to hold alligatorweed in
    check.  Underwater cutters and harvesters are unable to clear
    more than a few acres of weeds per  day and are restricted to
    unobstructed areas.  Fixed wing aircraft, helicopters, and boat
    mounted sprayers are capable of treating many times this area.
    During mechanical removal of weeds, the plants are usually
    fragmented.  The fragments are often moved about by wind and

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        currents and initiate infestations in areas not already afflicted
        with troublesome growths of weeds.  Chemicals are for the most
        part nonselective in the plants removed.   Also, they are difficult
        to confine to specific areas,  and frequently partial treatment
        of a body of water results in  temporary but total removal of all
        the aquatic vegetation.   Water level manipulation,  as an
        alternative to herbicides, is  an effective control  measure.
        Unfortunately, water levels in few bodies of water or streams
        can be varied to this extent.   Weed growth in the shallows of
        some TVA impoundments can be eliminated by manipulating the water
        levels at certain periods.  Preventing eutrophication and
        reducing the levels of nutrients in water, while not effective
        in eliminating plant growth, would reduce the rates of growth
        of weeds and the total mass of plant material present in the
        water at any given time.  Most sources of nutrients are runoff
        from farmland, domestic sewage, and certain industrial wastes.
        It is unlikely that plant nutrients from these sources will be
        curtailed or elminated significantly in the near future.

        In spite of current alternative control measures, chemical control
        methods will be necessary as part of any realistic pest
        management program that involves integrated systems of mechanical,
        cultural, biological or ecological modification as  techniques.
        Thus, a continued source of effective, registered aquatic
        herbicides is vitally important, even though many of them fall
        into the minor use category as defined earlier.

3.   U.  S.  Department of Interior (DOI).

    The Department of Interior uses, in its operational pest control
    programs and with cooperating agencies, a number of chemical  pesticides
    The DOI is also responsible for assisting in the testing of chemical
    pesticides that may be used by the public to control damage caused
    by  vertebrate pests.   The listing  of areas where DOI uses chemical
    pesticides is long and varied for  it includes chemicals for
    controlling damage caused by birds, mammals,  fish and reptiles.
    It  also includes chemicals that are needed to control fish diseases
    and pest plants.  Specific DOI minor use pesticide problems are
    documented in Appendix XI.

    Up  to  the present, DOI's pesticide program has been limited mainly
    to  efficacious screening of chemicals for use as tools  in managing
    fish and wildlife.  Unfortunately, many DOI uses of these chemicals
    are considered by industry as "minor uses".  The DOI has no program
    designed to synthesize and discover new chemical pesticides and
    materials that are used or are the exclusive property of private
    industry even though  it has  cooperated in screening these for
    specific use as needed in resource management.  Therefore, commercial
    products have been used for the major portion of DOI's  pesticide
    applications.

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             Unfortunately,  the  cost  of  registration of  any compound is high, and
             in  the  case  of  minor use chemicals,  economic  incentive by private
             industry  is  often lacking regardless of the merits  the DOI sees
             in  a  use  of  the compound.   Many of these materials  are for specific
             uses  and  they may lack registration  or at best have old registrations
             that  will soon  be reviewed.  Reviews will show that much more  inform-
             ation is  needed before new  reigstrations can  be  granted and  it is
             doubtful  that private industry will  seek re-registration because of
             cost.

             Industry  is  presently meeting the DOI's need  for pesticides  in only
             a few instances.  Apparently, economic return dictates the amount
             of  interest  generated by industry and only  those problems that are
             broad in  scope  (commensal rat control and weed control on croplands)
             or  can  be solved with broad spectrum compounds that are registered
             for other uses  are  of interest.  In  addition, some  industries  refuse
             to  give the  DOI authorization to precede with the registration of
             the compounds even  though the compound appears to be  effective and
             more  selective.  Also, the  public often attaches in aesthetic
             stigma  to vertebrate pest control and aquatic uses  of pesticides
             ("pollution"),  and  many  private companies now avoid adverse
             publicity by refusing to register or supply needed  compounds.

             FEPCA will require  even  more detailed data  for registration  and
             make  this problem even more serious.  Thus, the  DOI anticipates that
             many  of the  minor use pesticides will no longer  be  available under
             commercial labels because of the investment required  by the  registrant.
             Accordingly, it will be  necessary for the DOI to do much of  the groundwork,
             and perhaps  even seek its own labels  if it  wishes to  continue  using these
             materials and/or register new ones.   This will create the same monetary
             pinch on  DOI that it has on industry.

IV.   CURRENT PROCEDURES AND  DEFICIENCIES

     A.   Agriculture in the  states.

         1.   Current Procedures.

             The present  mechanism for securing minor use  pesticide registrations
             to  solve  agricultural pest  control problems is the  IR-4 Project.  The
             IR-4  project operates on funds budgeted from  Regional Research
             Funds by  the Committee of Nine.  No  funds are allocated for  the
             development  of  residue performance data but only to coordinate
             acquisition  of  data by state and other laboratories.Limited
             funding which exceeds the IR-4 budget has been obtained for  various
             specific  clearances through grower organizations and  other sources.
             The cost  of  development  of  performance and  residue  data by the
             agricultural experiment  stations (AES) and  grower organizations
             far exceeds  the IR-4 budget.  IR-4 relies on  State  and Federal
             expertise to determine clearance needs; they  are in touch with
             extension, regulatory and grower needs at the local level.

             IR-4  attempts to assume  responsibility for  all pesticide clearance
             requests  received from the  AES and USDA.  Such clearances may  be  for

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    tolerances or exemptions.  Upon receipt it is necessary to determine
    the status of the chemical and the use.  Industry must be contacted
    to determine interest.  If industry will handle the clearance,
    IR-4 coordinates the activities between AES and industry.  If the
    compound can't be registered because it is a carcinogen or can't be
    registered except with a large expenditure, IR-4 notifies the
    requestor and attempts to provide knowledge on a pesticide that
    will control the same pest but which would require less expenditure.
    In some cases industry may have the necessary data on file but  would
    not submit it in a petition.  IR-4 determines if any other state or
    states requested the use.  Once the exact use required is determined
    by the requesting state or USDA, IR-4 will suggest a protocol after
    consultation with regulatory agencies for clearance purposes.  If
    funding is necessary, IR-4 will attempt to obtain a source.   Once
    the necessary data are received, IR-4 will proceed to develop the
    petition as prescribed by law and submit it to the regulatory agency.
    If any petition amendments are necessary in four months from the
    time of submission, IR-4 will proceed to answer the questions raised
    by the regulatory agency.

    Once a tolerance is established on a food crop use IR-4 proceeds
    to have industry register (label) the use.  No tolerance is
    necessary when a use is ruled non-food, but a registered label  is
    required.  The necessary data for a label includes toxicology,
    residue data including metabolites, phytotoxicity, organoleptics,
    environmental and efficacy information.  Essentially the same amount
    of data are required for minor uses as major uses.  Normally industry
    develops the data on all these areas to clear the major uses of a
    pesticide; therefore, the states normally provide residue (including
    metabolites), phytotoxicity and efficacy data on each formulation
    and use.

2.   Deficiencies in Current Procedures.

    Demands for registration of pesticides foE minor agricultural uses
    are not being met by industry or agriculture because of the lack
    of adequate residue, performance, environmental and toxicological
    data.   Presently agriculture's (IR-4's) primary need is for residue
    and performance data.  Agriculture is generally in need of minor
    use control agents which are already cleared on major uses;  there-
    fore,  the toxicological and environmental data are already available
    from industry (if they will release them).

    The research to develop the residue and performances data for minor
    uses is just not being conducted at the agricultural experiment
    stations, and funds from the public sector to support such research
    are limited.  At the same time, industry will not support this
    research because the costs and/or risks outweigh profits.

    If the seller of a proprietary pesticides does not want to accept
    the liability involved in registering a minor use, the grower is
    deprived of the use.  Anyone can register a specific pesticide use

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        with sufficient  data,  but  to  be  useful  a  manufacturer  or  formulator
        must eventually  place  the  use on his  label.   A  registered label must
        be obtained by the  manufacturer  in  order  for  the pesticide to be
        shipped and used in both interstate and intrastate  commerce.  Hence,
        registration without the cooperation  of the seller  is  meaningless
        unless the public sector can  accept the liability,  production and
        distribution requirements.

        Any formulator can  register a non-proprietary pesticide with the
        necessary data.   If no non-proprietary  pesticide is available for  the
        use and the manufacturer will not register the  proprietary pesticide
        which will do the job,  then another mechanism must  be  developed to
        remedy the problem.

        With the advent  of  the new regulations  in FEPCA, industry will proceed
        to do even less  in  clearing minor uses  for economic reasons.  Eventually
        if a chemical is not usable on either meat, corn, soybeans, or cotton,
        industry may not take  the  chemical  through the  necessary  tests for
        eventual clearance.

        Another area of  concern is the necessity  of clearing more than one
        pesticide to control a particular pest.   Agriculture shouldn't have
        to restrict itself  to  one  pesticide for a particular pest since
        resistance may develop.  The  protection of minor crops is in danger
        because of the limited number of cleared  pesticide  uses.   Each minor
        crop should have more  than one pesticide  for  each pest complex.  The
        total amount of  residue would not be  increased  because of the
        substitution.

        To increase the  problem of pesticide  uses being cleared by industry,
        chemicals will be used in  a more limited  quantity in the  future in
        some situations  because of increased  use  of integrated controls.
        And integrated control  programs  are designed  to minimize  the
        environmental  impact of pesticides.   If such  programs  are to succeed,
        however,  the registration  of  uses of  the  specific pesticides that
        are part of the  programs is all  the more  important.

B.   USDA.

    1.   Animal and Plant Health Inspection  Service (APHIS).

        a.   Current Procedures.

            APHIS prefers that  the manufacturer or formulator  request from
            the EPA the  label  for  the use for all materials used  by APHIS.
            In cases where  industry will not  pursue registration  of a
            "minor use"  needed by  APHIS,  APHIS  personnel take  the initiative
            to have the  pesticide  registered.

            If a product is registered by APHIS,  it is  preferred  that the
            label will indicate that  it  is  to be  used under the direction  of
            APHIS personnel only and  is  not to  be made  available  to the

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        general public.  APHIS prefers to have the approved use on the
        label of the pesticide.  However, if EPA wishes to maintain a
        file with the necessary information in the file and use APHIS'S
        manuals as part of the labeling this is acceptable.

    b.  Deficiencies in Current Procedures.

        If for no other reasons than economics and increased efficiency
        by avoiding unnecessary duplication, APHIS would like to use the
        IR-4 structure in securing registration for minor use pesticides.

2.  Forest Service (ES).

    a.  Current Procedures.

        Forest Service pesticide research and development activities
        are presently concerned with all classes of pesticides and span
        the range of tasks from screening and bioassaying candidate
        materials against specific pests to conducting operational
        programs.  Thus, it is sometimes able to provide most of the data
        needed to support registration.  However, it does not have a major,
        organized program effort to obtain such registrations.

        The U. S. Forest Service feels that IR-4 is presently inadequately
        staffed and financed to meet the needs of the Forest Service
        and other agencies in USDA for registering minor uses of both
        existing pesticides and of new classes of materials.  Financed
        through USDA funds administered by CSRS for regional research,
        IR-4 has functioned primarily in helping state and certain USDA
        agencies to obtain pesticide clearances.  The focus of attention
        has been on pesticide uses on agricultural crops where the monetary
        return from the sale of the pesticides has been too small to
        warrant the expense involved in developing data required to
        establish tolerances and register the use through regular industry
        channels.

    b.  Deficiencies in Current Procedures.

        In an increasing number of cases, outside assistance is being
        sought from other Federal agencies, universities, or other
        cooperators in obtaining data on chemistry, toxicology, or
        other aspects for which the expertise and/or equipment and
        facilities do not exist in the Forest Service.  Availability
        of funds limits the scheduling and intensity of this outside
        effort.   Thus,  there are potential opportunities for working
        with IR-4 to use data already available in their files or to
        obtain needed information from other sources, possibly at
        limited expense to the government, at least in terms of
        avoiding duplication.

3.  Agricultural Research Service (ARS).

        ARS currently carries out research to assist in developing the
        data necessary to secure minor use pesticide registrations.

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                                                                           34
            ARS facilities  devoted primarily to pesticide  research  are
            identified in Appendix XII.   (Note:   Since the compilation  of
            this information,  there has  been a reorganization within USDA.
            Thus,  some of the  research listed is not applicable to  the  minor
            use problem.)

        b.   Deficiencies  in Current Procedures.

            The main concern,  as FEPCA is being implemented,  is that ARS
            scientists have sufficient freedom,  flexibility and financial
            support to carry out the necessary research relating to minor
            use of pesticides.

C.  Department of Defense (DOD).

    The Department of Defense  and the various services do  not have  staff
    capabilities to register pesticides.   Where the need exists the only
    recourse available is for  a  tri-service body, the Armed Forces  Pest
    Control Board, to petition the Environmental Protection Agency  for
    specific exception.   It is doubtful  that this will continue to  be done
    with the greater concern and enforcement expressed by  the Federal
    Environmental  Pesticides Control Act of 1972.  Considerable research
    is funded for the military and conducted by the U.S.D.A.  at several
    laboratories.   Smaller  short term projects are sponsored by the various
    services through their  research groups but application to registration
    is not  likely.  In short,  a  procedure to secure minor  use pesticide
    registrations within  the DOD does not presently exist.

D.  Corps of Engineers (COE).

    1.  Current Procedures.

        As  with other agencies and groups, the COE would prefer that the
        manufacturer or formulator register the uses needed by the  COE.
        However, in cases where  industry would not pursue  registration
        of a needed minor use, the COE has taken the initiative to  attempt
        to  have the pesticide  registered.

        For example, the  COE (in cooperation with the DOI) has spent about
        $300,000 toward the registration of 2.4-D for use  in irrigation
        ditches, ponds,  lakes  and navigation systems.  Although residue
        tolerances have been established for certain uses  in irrigation
        ditches, further  work  is needed for the other uses.

    2.  Deficiencies in Current  Procedures.

        Though the COE has  been  pursuing some registrations, financial
        support for this  activity has been somewhat difficult to justify
        to  the COE's administrators.  In addition, it appears that  there
        is  considerable duplication of effort and expertise.  Could IR-4
        be  of assistance?

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                                                                          35
E.  Department of Interior (DOI).

    1.   Current Procedures.

        As stated before,  the DOI  does not have a program designed to
        synthesize or discover new pesticides.   Therefore,  it must rely upon
        industry for its supply of new compounds.  As they become available
        they are screened for biological activity most often by laboratories
        of the Bureau of Sport Fisheries and Wildlife.  If compounds show
        promise, agencies within the Department that would most benefit from
        the use of the compounds attempt to convince the owners of the
        compounds to conduct further research and development leading to
        registration.

        When new compounds are under investigation, private companies
        initially assist in gathering information for registration.   The
        degree of assistance varies with companies but in general much of
        the basic laboratory information is provided by private industry.
        Information related to the efficacy of the compound is most  generally
        a joint effort with government and industry.   It is when residues,
        analytical methods,  environmental impacts, and human health  information
        is necessary that difficulty occurs.  Unless the compound has a major
        use, the owner of the compound is not generally interested in
        registration.  In these instances the Department must secure this
        additional information needed for registration and hopefully, the
        owner of the compound will then register the compound or allow the
        Department to do so.

        Much the same procedure occurs with registered compounds that can be
        put to new uses.  Information gathering and new use registrations of
        these materials is left up to the agency that would utilize  the
        compounds.

    2.   Deficiencies in Current Procedures.

        The need for registration  of new compounds or uses has not been met
        by industry or the DOI.  Industry does not meet this need because
        economic return is not great and the Department fails to meet the
        need because funding is limited and not specifically programmed
        for this activity.  Bureaus within the Department do use funds
        for registration but for the most part the Department has relied
        upon industry to discover; develop and register compounds used in
        agency programs.  This type of attitude has prevailed for many
        years and has resulted in  the development of those pesticides now
        currently available.   However, with more strict registration
        requirements and corresponding increases in costs,  industry has
        refused to register new compounds or uses for old compounds.  In
        addition, non-registered compounds could be and were used by
        governmental agencies under the old FIFRA amendment.  This will
        no longer be the case.

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                                                                              36
V.  RECOMMENDATIONS

    A.  Agriculture (in the states)  -  to state experiment station and extension
        directors:

        Recalling both the problems  identified in this  report and the mechanism
        (IR-4)  by which,  when appropriate information is developed,  registration
        can be  obtained,  the following recommendations  are made to state agricultural
        experiment station and extension directors:

        1.  Identify your local expertise in each category of data needed to
            clear minor use pesticides for registration.  There is some concern
            that there may not be enough expertise around the country to handle
            all of the needed research.   This information in turn should be
            compiled regionally and  sent to one national coordinating agency--
            perhaps the Cooperative  State Research Service of USDA.

        2.  Assemble an interdisciplinary group (residue chemists and appropriate
            pest control  and crop experts,  including extension specialists) in
            each state charged with  the responsibility  of systematically reviewing
            various crops and their  present and potential pest problems (this
            has already been initiated in some states).   This group would
            identify pest control measures that can be  applied,  including the
            use of chemicals.   When  an unregistered chemical is needed to solve
            a particular  pest problem,  the group could  develop a plan for a
            program by which the needed data would be obtained.   Having planned
            programs to achieve registration of the needed chemicals, priorities
            could be assigned depending on the seriousness of the problem and
            the probability of its early outbreak.*

        3.  Be  concerned  that your experiment station research scientists do not
            unduly shy away from applied research on minor crops because of
            the relative  lack of economic importance of the crops to the state's
            agricultural  production.   It would be unfortunate and disastrous for
            minor crop growers if each experiment station were to take the
            strictly cost/benefit approach that industry has taken.

        4.  Consider a regional approach to solving some minor use problems,
            involving agricultural experiment stations,  commodity groups and
            the chemical  industry from three or four adjacent states with
            common minor  use pesticide needs.  This would result in more
            efficient use of laboratory facilities,  experimental plots and,
            most important of all, station research scientists.   And commodity
            groups might  be able to  provide more significant financial support
            for minor use clearances if they could pool their resources.  The
            funds could be divided among the cooperating state experiment
            stations for  field work,  and a certain amount given to one state
            for the necessary residue  work.  With this  type of cooperation,
            the chemical  industry might be more likely  to contribute as well.

        5.  State Extension Directors  in particular should begin an educational
            program for growers in regard to the misuse of chemicals and other
*Some activity along these lines already has been requested of state agricultural
experiment station directors and state IR-4 liaison representatives by the Cooperative
State Research Service.

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                                                                          37
         implications of the new law.   (This already has been initiated in
         some states.)

    6.   Consider the feasibility of the IR-4 project being expanded to
         become a coordinating mechanism for all public sector pesticide
         registration activities.

B.  USDA - to top USDA administrators:

    1.   A crucial question is:

         To what extent should the USDA become involved in actually being
         the registrant for certain minor uses of pesticides, in cases
         where the manufacturer is not willing to register the use regard-
         less of who develops the necessary data for clearance?  Some
         decision will have to be reached regarding departmental policy.

    2.   The problem of coordinating USDA registration activities in
         the future (and perhaps all public sector activities including
         other federal agencies as well as those activities currently
         handled by IR-4) is a very real one.  What are the-alternatives?

         a.  Restricting the IR-4 project to requests from state agricultural
            experiment stations and handling USDA activities separately.
            Within this option, there are further alternatives:

            1)  Having the various USDA services (APHIS, FS, ARS) each
                handle their own minor use pesticide registration problems.

            2)  Coordinate these activities with the USDA, with one group
                of interservice personnel handling all requests.

            3)  Coordinate these registration activities with those of
                other federal agencies (DOD, COE, DOI) .  Perhaps an
                interagency coordination staff for pesticide registration
                activities could be created.

         b.  Expanding the role of and support for IR-4 to include all
            (at least all agricultural) minor use pesticide registration
            activities.  This choice is attractive, if it would permit
            more expeditious handling of requests for assistance in
            obtaining pesticide clearances (as well as reduce unnecessary
            duplication of qualified personnel).  APHIS, FS and ARS are
            willing to at least consider working with and supporting the
            IR-4 project.  This might conceivably lessen the need for the
            USDA to budget for all of the tasks needed to establish
            efficacy and safety and thus speed the registration of needed
            minor uses.  It might also eliminate some of the need for
            the USDA to become the registrant for a variety of minor uses.

C. Department of Defense - to top level administrators:

   The Department of Defense through the various services has a definite need
   for the continued registration of specific pesticide uses and new registration

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                                                                           38


    or exception for several other pesticidal  compounds.   In a few situations
    annual losses due to alternate methods  of  control  or  absence  of any control
    will amount to tens of thousands  of dollars and present  significant hazards
    to human health and welfare.

    DOD has no established capability to register pesticides,  but does  have
    a central body to coordinate  needs,  and requirements.  This body is the
    Armed Forces Pest Control Board (AFPCB).   Perhaps  registration actions
    could be coordinated by the Board and conducted by the USDA (but this
    point has not been discussed  with the Board at the time  of this writing).

    In view of the above,  it is recommended that:

    1.  A staff capability be established to validate  the registration  of
        current DOD pesticide uses.

    2.  The AFPCB consider the problem of unregistered uses  and develop a
        protocal for registering  materials  or  locating sources for having
        the work conducted.   Included in this  protocol should be  answers
        to the following questions:

        a.  To what extent should the DOD become involved in actually being
            the registrant for certain minor uses of pesticides,  in cases
            where the manufacturer is not willing to register the use
            regardless of who developes the necessary  data for clearance?

        b.  Should the DOD develop its own  staff to coordinate minor use
            pesticide registration activities,  should  it  develop  one jointly
            with other federal agencies,  or should it  support the expansion
            of the IR-4 project to coordinate  all U. S. requests  for minor
            use pesticide registrations?

D.  Department of Interior - to top level administrators:

    This report documents the seriousness and  consequences of the problem
    of obtaining registrations for minor use pesticides,  including those
    vital uses needed by the DOI.   Industry does not have incentive to
    to register minor use compounds,  a great majority  of  DOI oriented
    pesticide programs are minor  use  programs,  considerable  funds are
    needed to secure data for registration,  and the DOI will probably have
    to accept responsibility for  registration  of many  compounds.

    In view of the above,  it is recommended that:

    1.  The DOI program adequate  funding for pesticide registration. Perhaps
        this funding should be programmed at the Bureau level.

    2.  Since a program of discovery  does not  exist in the DOI, reliance
        still must be placed on industry to provide new compounds.  A
        system of this type, to be successful,  requires complete  cooperation
        between industry and the  Department.   Because  industry is the discoverer
        and owner of new compounds,  commitments must be made by industry to
        the Department before extensive .development is begun.  Three basic

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                                                                              39
            questions  must  be answered:

            a.   Will the  owner register  the  compound?

            b.   If not, will  he give  the DOI  the  right  to  register?

            c.   Will the  owner supply the material  and  give  the Department marketing
                rights if the compound is registered?

        3.   The  DOI should  also be  asking whether it should  maintain  its own staff
            to coordinate minor use pesticide registration activities, or develop
            one  jointly with  other  federal agencies or  support the expansion
            of the IR-4 project to  coordinate all U. S. requests  for  minor use
            pesticide  registrations.

    E.   Corps of Engineers  -  to top level administrators:

        The  recommendations under D.  above for the  Department of  Interior apply
        equally  well to the Corps of  Engineers.

    F.   Environmental  Protection Agency  - to  administrators  in the Office of Pesticides
        Programs:

        This report has generated several concerns  which can be translated into
        recommendations for the EPA.

        1.   EPA  should consider the extension of  tolerances  and registration to
            minor crops while reviewing  petitions from  basic manufacturers for
            related major crops.  For instance, while reviewing a petition for
            apples and pears,  EPA could  consider  quinces and, if  appropriate,
            establish  tolerances and  register the uses  on  apples, pears and
            quinces together.   Also,  already  established uses on  major crops
            should be  reviewed in order  to consider extensions to related minor
            crops.

            Many agricultural  scientists  would like to  see a modification of the
            requirement on  food and forage crops  that demands data for each
            specific use  on each crop.   This  would  allow group registration.
            A system of classification similar to those to classify foods into
            groups for common  tolerances  within the groups for pesticide residues
            might  be satisfactory.*  A number of  such group  tolerances already
            exist--beans, citrus, grasses, poultry, meat,  etc.  Tolerances within
            groups are often  established  at the same level for all commodities
            within groups.  In many cases the pest  problem is the same or very
            similar with  the  same pesticides  and  number of applications being used.
            If a group tolerance is satisfactory  in protecting the consumer, it
            would  seem equally logical that registrations  for use could also be
            similar without unduly  threatening the  user, the environment, or the
            consumer.   Such a  grouping of registrations would go  far  in resolving
            present problems  of registration  and  labeled uses for minor crops
            and  minor  uses.   In addition,  simplifying registration in this manner
*Mr. R. E. Duggan, retired Associate Commissioner for Compliance, Food and Drug
Administration, has conducted a study; under contract, to develop food classes for
pesticide residue tolerances.  The study is completed and is presently being evaluated
by EPA.

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                                                                      40


    would greatly relieve the problem for growers,  greatly reduce the
    developmental research load for the experiment  stations and the
    industry,  reduce the mass of paper work in EPA  and provide time for
    research work on problems of considerably more  impact and of
    higher priority to all of us.   Present methods  were acceptable for
    conditions at the time they were established, but time and requirements
    have changed.

    Another possible approach would be to consider  reorganization of
    the basis for registering food crops to one using total or average
    daily diet intake as a criterion.   Establish tolerances for each
    specific crop only on those crops comprising 70-80% of the diet.
    Group the remaining crops to expedite registration, yet still
    provide protection for the consumer.

2.   EPA should consider the feasibility of a mechanism for registering
    proprietary and especially non-proprietary compounds not intended
    for registration by the manufacturers.

    The problem is that even after registration is  obtained, industry
    may not choose to include the particular use on the label of their
    product because of the nature of the liability  problem.  If not
    on the label it might still be a misuse and subject to penalty;
    unfavorable publicity, etc.  Some mechanism must be found to cope
    with this problem.   Possibly some arrangement might be developed
    which would compel registration by the company  under some sort of
    an arrangement which might free the company from the liability
    risk.

3.   Although EPA has participated in the IR-4 program in the past to
    a limited degree, it could consider increasing  the emphasis which
    could help produce a more effective communication with the experiment
    station community.   Perhaps more scientists in  the Criteria and
    Evaluation Division and the Registration Division could participate.
    This would help bridge the flow of information  between the
    agricultural sector and EPA.

4.   EPA should consider and react to the possibility that one coordinating
    agency (such as the IR-4 project)  could perhaps handle all public
    sector registration requests.

5.   States will need more financial support to speed up the development
    of data for minor uses for which no chemical company has the
    incentive to do the necessary research.  Considerably more resources
    will be needed in existing AES analytical facilities for residue
    data on minor use pesticides.   Additional resources will also be
    needed to fund efficacy evaluations, toxicological studies (especially
    for biological control agents such as parasites and pathogens) and
    the processing of data for pesticide clearances.

    A clarification is needed of how state experiment stations and...land     **
    grant colleges can support work necessary for registration.  Requirements

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                                                                      41
    are federal, is support funding to be federal?  Funding is an
    essential patt of the resolution of many minor use registration
    problems.  The states are receiving less USDA research funding.
    Without funding,  information for registration by the states cannot
    be accomplished.   Perhaps it is feasible that EPA could encourage
    grants for the development of data for minor uses.

6.  Consider establishment of standards for meeting environmental
    requirements.  Once these have been met, permit registration for
    ornamental trees, shrubs, turf and other non-food use on a broad
    category basis without residue data.  In most cases it will be
    almost impossible to include specific pests for each species of
    tree or shrub on the label because of the space requirement.  Additional
    label attachments get lost, misplaced and generally have been
    unsatisfactory.

7.  Consider using pesticides classified in the safest category of our
    labeling classification system (Category IV - no signal word
    required) to provide broad uses on food and forage crops, ornamentals,
    etc., without labeling for each specific use.  This could be done
    after standards for safety for the user, consumer or environment
    have been met.  This would go one step further than 6.  Either,
    both, or a similar category, would go far to relieve the problem
    of minor uses registration and without undue hazard to man, animals,
    or the environment.

8.  Finally, some immediate needs should be studied as they will at
    least help resolve the complicated problem of minor uses.

    a.  Clarification of time schedule relative to:

        1)  Conversion of state registrations to federal registrations.

        2)  Registrations on trees, shrubs and ornamentals where all
            present registrations cannot be determined because there
            is no complete summary and where the uses are so numerous
            that it will be impossible to obtain the necessary
            registrations within two years tentatively being considered.

    b.  Clarification of what is meant by "inconsistent with the
        label".

        1)  If it means only uses on the label, are all uses to be
            listed?  Parathion has 1528 registered uses and carbaryl
            has 1147  registered uses listed in the EPA Compendium as
            of March  19, 1973.  Complete listing appears impractical
            because of the difficulty of the user finding the
            information needed.

        2)  If it means uses do not have to be on the label, how will
            the user  know whether his use is "inconsistent"
            with the  label?

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VI.   SUMMARY
                                                                              42
                3)   If  a  use  is not  listed  on  a particular proprietary product
                    label but is  known to be labeled on a similar product which
                    is  not  immediately available,  is user to be deprived of use?

                4)   Some  products are packaged and marketed under different names
                    for different markets but  the product is otherwise the same.
                    Is  the  user to be forced to purchase  (at possibly higher
                    prices) the product with the use listed on the  label?

                Clarification of  the status of a registration presently listed
                in  the  EPA  Compendium and formerly carried by a company on its
                product label, but which now has been dropped from  the label
                because of  liability risks  which the company deems  out of
                proportion  to the amount and value of the product sold for that
                particular  use.   And some special effort is needed  to recall
                all outstanding labels and  make the appropriate corrections.

                Recognition of the impossibility of having meaningful labels
                that are  going to meet every contingency, and provide for the
                necessary flexibility to permit the handling of problems which
                may arise on  short notice such as short supply of a registered
                product;  a  new insect, disease, or weed; the development of
                resistance, etc.   In providing this flexibility, parameters
                should  be established for the  states to protect the consumer
                and processor from excessive residues, and the environment
                from undue  threat of pollution or hazard.

                The flexibility to control  new pest problems through quarantine
                and regulatory work  is also needed by APHIS.  Regarding Section
                24  of FEPCA,  APHIS personnel must be allowed to use materials
                which might be banned in a  particular State where an emergency
                occurs.   It  appears that there are provisions under Section 18
                for a Federal  Agency to use a  pesticide under these conditions.
                This point  should be spelled out in the regulations issued by
                EPA under Section 24 so as  to  avoid problems or misunderstandings
                when emergencies  occur.
     This report   is  the  result  of  a  study by  an  ad hoc  interagency (University-
     EPA-USDA)  subcommittee  assigned  to  consider  the problems  associated with
     developing the data  required for registration of  pesticides  for the
     production of specialty and small acreage crops and other minor uses.   Non-
     agricultural  as  well as agricultural uses are considered.  The problem has
     been magnified as  registration requirements  have  increased,  particularly with
     the passage  of the 1972 Federal  Environmental Pesticide Control Act.   To meet
     the added  requirements,  much greater expenditures of time, manpower and funds
     are now required.  And  the  result is fewer and fewer registrations of pesticides
     for minor  uses.

     There are  actually several  reasons  why  the agricultural chemical industry
     is registering fewer minor  uses.  Perhaps number  one is economics.  The

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                                                                        43
relatively low financial return in proportion to cost and time required to
register is more and more resulting in lack of registration.  Also,
disproportionate crop liability in proportion to the amount of product used
on the crop has been a reason for some registrations being dropped.  Further,.
many of the pesticides for which registrations have expired or are expiring
are non-proprietory compounds.  There is very little incentive for industry
to obtain the data necessary to reregister these materials.

At a time when the chemical industry is contributing less to the clearance
and registration of pesticides for minor uses, the public agencies have not
fully evaluated the situation or at least have not taken on the responsibilities
of solving the problems.  Public agencies for the most part have been unable
to muster the needed additional support to expand their research efforts
in order to clear more pesticides for these minor uses, including many uses
needed by the public agencies themselves.

Within agriculture at the state level, a mechanism (the IR-4 Project) exists
for assisting in obtaining clearances for minor uses.  The problem seems not
to lie with the IR-4 Project but with the states who must develop the research
information—efficacy of control data, toxicity data when the company cannot
supply it, analytical methods if necessary, and the residue data.  The research
is not being conducted at the necessary level.

Outside of agriculture at the state level, a variety of attempts are being
made within different federal agencies (U.S. Departments of Agriculture,
Interior and Defense, and the Army Corps of Engineers) to improve their
ability to clear minor uses of pesticides, both for their own intragency
use and for the general public.  There seems to be a significant lack of
interagency coordination and a resulting considerable amount of duplication.

The problems can be solved only by the combined efforts of the several
groups and agencies involved, and several specific recommendations for action
are made to:  state agricultural experiment station and extension directors,
and to top level administrators of the U. S. departments of Agriculture,
Defense and Interior, the Army Corps of Engineers and the U. S. Environmental
Protection Agency.

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                                                            1-1
                    APPENDIX I
            MEMBERSHIP OF SUBCOMMITTEE
                Executive Committee
Dr. H. H. Wilkowske, Chairman
Assistant Dean for Research
Florida State Agricultural
     Experiment Station
University of Florida
Gainesville, Florida   32601

Dr. Fred H. Tschirley
Assistant Coordinator
Environmental Quality Activities
Science and Education Staff
U. S. Department of Agriculture
331-E, Agriculture Administration Bldg.
Washington, D. C.   20250

Dr. William Upholt
Deputy Assistant Administrator for
     Pesticides Programs
Environmental Protection Agency
Rm. 1037 E
401 M St., S.W.
Washington, D. C.
                Additional Members
Dr. H. G. Alford
Assistant Director for Registration
Pesticide Research Division
Agricultural Research Service
U. S. Dept. of Agriculture
Washington, D. C.   20250

Dr. C. C. Compton
IR-4 Coordinator
134 Blake Hall
Rutgers University
New Brunswick, New Jersey   08903

Dr. Virgil H. Freed, Head
Dept. of Agricultural Chemistry
Oregon State University
Corralis, Oregon   97331

Dr. E. 0. Gangstad, Chief
Aquatic Plant Control Planning Division
Division of Civil Works
Corps of Engineers
Dept. of the Army
Washington, D. C.   20314

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                                                             1-2
Mr. William A. Gebhart
Entomologist
Biological Sciences  Staff    101B2
Naval Facilities Engineering Command
Washington, D. C.    20390

Mr. G. M. Markel
IR-4 Assistant Coordinator
134 Blake Hall
Rutgers University
New Brunswick, New Jersey    08903

Dr. R. C. Riley
Plant Sciences Research Program
Cooperative State Research  Service
U. S. Dept. of Agriculture
Washington, D. C.    20250

Mr. H. R. Russell, Chief
Entomological Section OCE
Forrestal Bldg., Room IE224
10th and Independence
Washington, D. C.    20250

Dr. C. L. Smith
Pesticides Regulation Division
Environmental Protection Agency
U. S. Dept. of Agriculture's South  Bldg.
Washington, D. C.    20250

Mr. Richard N. Smith
Bureau of Sport Fisheries   and Wildlife
U. S. Dept. of Interior
Washington, D. C.  20242

Dr. J. E. Swift
Statewide Coordinator of Pesticides
University of California
2200 University Ave.
Berkeley, California  94720

Dr. C. H. Van Middelem
Dept. of Food Sciences
University of Florida
Gainesville, Florida  326'01

Mr. C. R. Walker, Chief
Branch of Pesticide  Control Research
Divison of Fishery Research
U. S. Dept. of Interior
Washington, D. C.    20242

                     Consultant

Dr. Richard J. Sauer
Dept. of Entomology
Michigan State University
East Lansing,  Michigan   48823

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                                                                        II-l
                               APPENDIX II

                 HISTORY OF LAWS AND ACTIONS AFFECTING THE
                  DEVELOPMENT OF AGRICULTURAL CHEMICALS
                          AND THEIR USE ON FOOD
 June 30, 1906 - Original Federal Food and Drug Act.
                 This act was intended to prevent the manufacture,  sale,
                 or transportation of adulterated, misbranded,  poisonous,
                 or deleterious foods, drugs, medicines and liquors.
                 Administered by Food and Drug Administration of Dept.
                 of Health, Education and Welfare.

April 26, 1910 - Original Federal Insecticide Act.
                 An Act to prevent the manufacture, sale or transportation
                 of adulterated or misbranded insecticides and fungicides.
                 Administered by USDA.

 June 25, 1938 - The revised Federal Food, Drug and Cosmetic Act.
                 Enacted to prohibit the movement in interstate commerce
                 of adulterated and misbranded food,  drugs, devices and
                 cosmetics, this law charged the Food and Drug Administration
                 (FDA) with the responsibility of keeping poisonous
                 insecticides, as well as insects, out of food products.
                 It included provisions for setting tolerances for
                 poisonous ingredients, if they could be justified, but
                 the procedure was cumbersome and often time-consuming
                 and expensive.

                 The law did not provide for advance clearance of safety
                 of food additives.  It left it up to the FDA to discover
                 their use, and to make tests to prove them "poisonous
                 or deleterious" to the satisfaction of the court when
                 action was required to remove them from the market.

 1945 and 1946 - Many new insecticides (organic) appeared on the market.
                 Legal tolerances were not announced, indicating to many
                 that the ponderous tolerance procedures of the Food,
                 Drug and Cosmetic Act could not handle the flood of
                 new materials.  In addition, the labeling requirements
                 of the 1910 Insecticide Act were obsolete.

 June 25, 1947 - The Federal Insecticide, Fungicide and Rodenticide Act
                 (FIFRA).
                 This act extended the scope of the 1910 Act to include
                 rodenticides and herbicides and required for the first
                 time premarketing registration of products to be shipped
                 interstate.  It thus set up the system of label claims
                 and registration.  It provided that a complete copy of
                 the label and a statement of all claims to be made for
                 the material must be submitted to the Secretary of

-------
                                                                         II-2
                   Agriculture  and must be approved before the material is
                   registered for sale  (in interstate commerce).   It also
                   provided  a system  of fees  to  support the procedures
                   involved.  The act was enforced by the USDA, Agricultural
                   Research  Service,  Plant Pest  Control Branch, Pesticide
                   Regulation Section.

            1950 -  The continued flood of new materials emphasized the need
                   for residue  tolerances.  According to the provisions of
                   the 1938, supporting evidence for the tolerances had to
                   be  established at public  hearings.  Accordingly,
                   hearings  were started on January 17, 1950, and  were
                   completed in September 15, 1950.  Such a mountain of
                   evidence  was presented that several more months were
                   required  to  digest it.

            1951   Growing public concern over the addition of chemicals to
                   food products led  to the appointment of the Delaney
                   Committee, known formally  as  the House Select Committee
                   to Investigate the Use of  Chemicals in Foods and Cosmetics.

      June,  1952   The Delaney  Committee submitted its report to the 2nd
                   session of the 82nd Congress.  The report was in three
                   parts:   (1)  a majority report, indicating that  present
                   laws were inadequate and new  laws were needed,  (2) a
                   minority  report, indicating that present laws were
                   adequate  but needed streamlining, and  (3) a supplementary
                   report indicating  that one of the most important hazards
                   involved  was in the use of pesticides in the home garden,
                   on materials intended for  home consumption.  It was
                   pointed out  that this particular hazard is beyond the
                   reach of  law and is susceptible only to education of the
                   general public.

  November,  1952 -  The Food  Protection Committee of the National Research
                   Council published  a comprehensive report, dealing with
                   the use of chemicals in food.  This report considered
                   the present  and future food needs of the nation and
                   stressed  the vital role that  chemicals play in  meeting
                   these needs. It pointed out  that the  losses from hazards
                   involved  in  using  chemicals are rather minor compared to
                   the losses involved in not using them.

  March 26,  1953 -  Rep. A. L. Miller  introduced  a bill, H.R. 4277, which
                   provided  for the regulation of pesticides and tolerances.
                   This bill was heralded by  the industry as a basis upon
                   which a workable law could be built.

January 11,  1954 -  Rep. Miller  submitted a new bill, H.R. 7125,  (a revised
                   H.R. 4277 of the previous  session).   It was referred to
                   the House Committee on Interstate and Foreign Commerce
                   and became known as the Miller Pesticide Residue Amendment,
                   since it  was introduced as an amendment to the  Federal Food,
                   Drug, and Cosmetic Act.

-------
                                                                           II-3
    July 22,  1954 -  The Pesticide Chemicals Amendment  (The Miller Pesticide
                    Residue Amendment),  amended  the Federal Food, Drug
                    and Cosmetic  Act  to  provide  for a  system of fees to
                    support the procedures  involved, became Public  Law 518
                    of 83rd Congress.   It became effective for new  chemicals
                    a year  from the date of signing, and was effective
                    for tolerances established as a result of the 1950 and
                    subsequent  hearings.

                    It established new and more  expeditious procedures for
                    obtaining tolerances for  exemptions for pesticide chemicals.
                    Though  administered  by HEW,  it specifically assigned to
                    the Secretary of  Agriculture the determination  of
                    usefulness  of a chemical  for all,  any or none of the
                    uses for which tolerances or an exemption are sought.
                    And it  required the  USDA  to  express an opinion  as to
                    whether proposed  tolerances  are reasonable and  whether
                    residues are  likely to result from proposed patterns of
                    use.

September 6,  1958 -  Food Additives Amendment  to  the Federal Food, Drug and
                    Cosmetic Act  (Public Law  929 of 85th Congress).
                    It established procedures, principles and appeals
                    procedures  for obtaining  regulations from HEW prescribing
                    safe conditions of use  for food additives.  A food
                    additive was  defined as any  substance the intended use
                    of which may  reasonably be expected to result directly
                    or indirectly in  its becoming a component of or otherwise
                    changing the  characteristics of any food.  The  law
                    specifically  excluded pesticide chemicals, pesticide
                    residues on crops (raw  agricultural commodities) and
                    pesticide residues in processed food when such  residues
                    result  from legal uses  of pesticides on crops.  These
                    pesticides  are regulated  under Public Law 518  (The Miller
                    Amendment).

                    This food additives  amendment included the Delaney clause
                    on carcinogens:  no  additive shall be deemed safe if it
                    is found to induce cancer when ingested by man  or animals.

   March 27,  1962 -  Declaration of Certain Forms of Plant and Animal Life and
                    Viruses to  be Pests.  Thus,  it extended the scope of the
                    Federal Insecticide, Fungicide and Rodenticide Act to
                    cover some  kinds  of  pesticides not previously  subject
                    to the  Act.

     May 12,  1964 -  An Amendment  to FIFRA eliminating  registration  under
                    protest.  This amendment  provided  that the registrant
                    could request an  advisory committee or public hearing
                    when registration of his  product was refused,  cancelled
                    or suspended.   The Secretary of Agriculture was also given
                    the authority to  require, by regulation, the USDA registration
                    number  of the label.

-------
                                                                          II-4
October 21, 1972   The Federal Environmental Pesticide Control  Act
                   (FEPCA)  of 1972.
                   It significantly amended the FIFRA of 1947 and is
                   administered by the Environmental Protection Agency
                   (EPA).   The major provisions are summarized  on pages 8-10
                   of the text of the report.

-------
                                                                      III-l
                              APPENDIX III

                     THE IR-4 PROJECT ORGANIZATION

                        Box 231 - 134 Blake Hall
        Rutgers University - The State University of New Jersey
                    New Brunswick, New Jersey 08903
1.  PROJECT:  IR-4 Evaluation of Current Data and Needed Research to
              Determine Tolerance Limits of Chemicals for Minor Uses
              on Agricultural Products

2.  COOPERATING AGENCIES AND PRINCIPAL LEADERS:

                          TECHNICAL COMMITTEE

    Technical Advisory Committee                         Region

    Dr. C. H. Van Middelem, Chm., Florida             Southern
    Dr. V. H. Freed, Oregon                           Western
    Dr. G. E. Guyer, Michigan                         North Central
    Dr. B. R. Wilson, New Jersey                      North Eastern
    Mr. K. C. Walker, USDA-ARS

    Administrative Advisory Committee
                (States)

    Dr. H. H. Wilkowske, Chm., Florida                Southern
    Dr. W. C. Kennard, Connecticut                    North Eastern
    Dr. J. P. Mahlstede, Iowa                         North Central
    Dr. L. W. Rasmussen, Washington                   Western

               USDA

    Dr. R. C. Riley: USDA - CSRS

           Consultants

    Dr. John W. Swift, California
    Dr. W. D. McClellan, USDA-ARS-PSRD
    Dr. K. R. Hill - USDA-ARS-ENT
    Mr. C. L. Smith   EPA - Labels
    Mr. D. M. Baker, Jr., EPA - Tolerances

         Project Leaders

    Dr. C. C. Compton, Rutgers   N. J.   Coordinator
    Mr. G. M. Markle, Rugers - N. J. - Asst. Project Coordinator
                                        (Recording Secretary)

In addition to the Technical Committee a State Experiment Station  Staff
member appointed by the Experiment Station Director for each of the 50 states
and Puerto Rico  serves as a liaison person for the IR-4 Project at the  state
level.

-------
                                                                           IV-1
                                    APPENDIX  IV

                                 NEW YORK STATE'S
                             MINOR USE PESTICIDE NEEDS
                        ON FOOD, FEED FORAGE  AND LIVESTOCK

                       PRIORITY SUMMARY SHEET (APRIL  6,  1973)
 Insecticides
 1
                     Uses
                   Required
     chlorpyrifos
       (Dursban)      3
 2.   endosulfan       2
 3.   carbofuran      15
 4.   dimethoate       7
 5.   Diazinon         7
 6.   Dylox            3
 7.   parathion        4
 8.   phosalone
       (Zolone)       1
 9.   Phosdrin         3
10.   TEPP             8
11.   methyl parathion 1
12.   carbaryl         1
13.   Guthion          2
14.   Kelthan          2
15.   malathion        2
16.   demeton (Systox) 1
17.   rotenone         2
18.   ethion           1
19.   B.  thuringiensis 4
Livestock Insecticides

1.  Ciodrin           3
2.  Vapona            2
3.  ronnel            3
4.  Rabon             2
5.  methoxychlor      1
6.  carbaryl          1
7-  rotenone          1
8.  dimethoate        1
Fungicides

1.  benomyl          13
2.  Dexon             1
3.  chlorothalanil
      (bravo)         4
4.  Kocide            6
5.  maneb             8
6.  zinc-ion-maneb    2
7.  Morestan          3
8.  Terrachlor        1
                        Uses
Fungicides (Cont'd.)  Required
9. sodium hypo-
chlorite
10. Difolatan
11. Botran
12. Streptomycin
Herbicides
1. dinoseb
2. 2,4-DB
3. silvex TP
4. 2,4-D
5. CIPC
6. terbacil
7. simazine (Princep)
8. amitrole
9. diuron
10. 2,4,5-T
11. Eptam
12. dalapon
13. trifluralin
14. TOK
15. Paraquat
Growth Regulators
1. neodecanoic acid
(onion top killer)
2. endothall
3. Rindite
4. silvex (TP)
5. Evik
6. gibberellins
Rodenticides

1
1
1
8

14
6
6
7
5
1
5
1
3
4
1
1
1
1
1


1
1
1
1
1
2

                                                  1.  zinc phosphide

                                                  TQTAL

                                                  NR   no action  taken
                                                  Ext., IT, or  Pet. filed
                          173
                           24
                          197

-------
                                                                          IV-2
                                 KEY TO SYMBOLS
NR = not registered
Reg or R = registered on crop; but not for specific use requested
Pet. filed = petition filed
IN = already submitted
IT = interim tolerance
Tol. Est. = full tolerance established

-------
                                  INSECTICIDES
                                                                          IV-3
chlorpyrifos
(Dursban)
endosulfan
(Thiodan)
carbofuran
(Furadan)
diraethoate
(Cygon)
              CROP
              beans

              crucifers
              onions
              endive
              grapes
PEST
seed corn maggot

cabbage maggot
onion maggot
aphids
grape phylloxera
              Brussel  sprouts
              carrots
              Chinese  cabbage
              blackberries
              raspberries
              strawberries
              birdsfoot  trefoil
REGISTRATION
NR, need seed treatment
slurry
NR
NR
NR
Reg. on grapes;
  phylloxera
                NR for
              crucifers (cole
               and rootj

                cabbage
                cauliflower
                broccoli
                Brussel sprouts
                kale
                kohlrabi
                turnip greens
                Chinese cabbage
                turnips
                rutabagas
                radishes

              potatoes

              alfalfa

              birdsfoot
                trefoil
              crownvetch
cabbage maggot,
flea beetles
NR
nematodes

snout beetle
plant bugs
plant bugs
aphids, cabbage maggot
aster leafhopper
cabbage maggot
tarnished plant bug
tarnished plant bug
tarnished plant bug
plant bugs, leafhoppers,
  aphids
NR; pet. filed on
    potatoes 6/29/71
Reg on alfalfa; NR for
    snout beetle

NR
NR
NR
NR
NR
NR
IN
IN

NR

-------
                                                                          IV-4
Insecticides (Cont'd.J

              CROP

Diazinon
              cabbage

              cucumbers

              melons

              pumpkins
              rutabagas
              squash
              birdsfoot trefoil
Dylox
(trichlorfonj
parathion
              onions
              birdsfoot trefoil

              crownvetch
              asparagus
              parsley
              parsnips

              birdsfoot trefoil
phosalone
(Zolone)
Phosdrin
TEPP
grapes


endive

escarole

birdsfoot trefoil
              cole (general')
               broccoli
               Brussel sprouts
               cabbage
               cauliflower
               kale
               kohlrabi
               turnip greens
               Chinese cabbage
                  PEST


                  cabbage maggot

                  seed corn maggot

                  seed corn maggot

                  seed corn maggot
                  cabbage root maggot
                  seed corn maggot

                  cutworms, leafhoppers,
                    aphids, plant bugs
                  onion maggot
                  cutworms, plant bugs,
                    leafhoppers
                  cutworms, plant bugs,
                    leafhoppers
                  Asp beetles  (2 sp.)
                  aphids
                  aphids, leaf feeding
                    worms
                  aphids, leafhoppers,
                    plant bugs
                                mites
                                aphids, leaf feeding
                                  worms
                                aphids, leaf feeding
                                  worms
                                aphids, plant bugs
                  aphids
                  aphids
                  aphids
                  aphids
                  aphids
                  aphids
                  aphids
                  aphids
REGISTRATION
Reg. Not on label for
  seed furrow
NR for maggot; reg. on
  cucumbers
NR for maggot; reg. on
  melons
NR
NR
Reg. on squash; NR for
  maggot

NR
NR

NR

NR


NR
NR

NR

NR



NR; reg. in California



NR

NR
NR
NR
NR
Ext. with IT
Ext. with IT
NR
NR
NR
NR

-------
                                                                          IV-5
Insecticides (Cont'd.J

              CROP

methyl parathion
              birdsfoot trefoil
carbaryl
(Savin)
Guthion
Kelthane
malathion
birdsfoot trefoil



currants

gooseberries
                  PEST
                  aphids, plant bugs
                                cutworms, plant bugs,
                                  leafhoppers
                                gooseberry, fruit worm,
                                  imported currant worm
                                gooseberry, fruit worm,
                                  imported currant worm
currants
gooseberries

parsnips

birdsfoot trefoil
two spotted mite
two spotted mite

aphids, leaf feeding
  mites
aphids
demeton
(Systox)
endive
rotenone rhubarb
ethion leeks
Bacillus thuringiensis
aphids
curculio
maggot

              Brussel sprouts
              endive
              escarole
              parsley
                  loopers, worms
                  leaf feeding worms
                  leaf feeding worms
                  aphids, leaf feeding
                    worms
                          REGISTRATION
                          NR
                          NR



                          NR

                          NR
                                                          NR
                                                          NR
                                                          NR
                                                          NR
                                                          NR

                                                          NR

                                                          NR
                          NR; Tol est 2/28/73
                          NR
                          NR

                          NR

-------
                                                                            IV-6
                                    LIVESTOCK
Ciodrin
dichlorvos
(VaponaJ
ANIMAL


Horses

calves

dairy cattle
              Horses

              calves
                                PEST
                                biting flies,
                                  face flies
                                cattle lice

                                cattle lice
                  biting flies,
                    face flies
                  cattle lice
REGISTRATION
R for emergency use only
R for cattle; NR for calves
  under 6 mo.
R for cattle; NR mist
  application
R for emergency use only
R for cattle: NR for calves
  under 6 mo.
ronnel
Rabon
methoxychlor
carbaryl
Rotenone
dimethoate
(Cygon)
              Horses
              sheep
              poultry
              poultry

              poultry
              Horses
              poultry
              livestock,
                cats, dogs
              livestock
                  biting flies,
                    face flies, lice

                  keds, lice
                  Northern fowl mites,
                    lice
                  Northern fowl mites,
                    lice
                  house fly, little
                    house fly
                  biting flies, face
                    flies,  lice
                  Northern fowl mite,
                    lice,  mites
                  grubs,  lice, fleas
R on horses; NR for flies,
  lice
R on sheep; NR sprinkling can

NR
R for poultry; NR mist
  application
R for poultry; NR low
  gallonage machine
  larviciding
                                                          NR
                                                          Ext on eggs; No IT
NR
                  stable flies
R for agricultural buildings;
  NR on label for stable
  flies.

-------
                                                                         IV-7
                                   FUNGICIDES
benomyl
(Benlate)
Dexon
              CROP
              beans (lima)
              beets
              Brussel  sprouts
              cabbage
              celery
              lettuce
              onions

              pumpkins
              black raspberry
              blackberries
              blueberries
              grapes
              raspberries
              beets
chlorothalanil
(Bravo)
Kocide
maneb
              lettuce
              onions
              radish
              rhubarb
              broccoli
              Brussel  sprouts
              cabbage
              cauliflower
              parsnips
              spinach
              dill
              horseradish
              parsnips
              radish
              rhubarb  (not  GH)
              rutabagas
              Swiss  chard
              grapes
PEST
white mold
root rot; Rhiz., Pyth.
sprout rot
post harvest application
Septoria blight
Rhizoctonia
Botrytis leaf blight,
  root disease
powdery mildew
powdery mildew
Botrytis fruit rot
mummy berry
powdery mildew
powdery mildew
root rot complex
Rhizoctonia
Botrytis leaf blight
downy mildew
leaf spot
black rot
black rot
black rot
black rot
leaf spot
bacteria soft rot
                Tol est 12/7/72
            REGISTRATION
NR
NR
NR
NR
NR;
NR

NR
NR
NR
NR
NR
NR;
NR
                Pet filed 1/26/72
            Reg on beets; NR for
              root rot
            NR
            NR
            NR
            NR
            NR
            NR
            NR
            NR
            NR
            NR
white rust
leaf blight
downy mildew
leaf spot
downy mildew,
mildew
downy mildew
            NR
            NR
            NR
            NR
            NR
anthracnose NR
            NR
            Reg. on grapes;
              NR for downy mildew

-------
                                                                          IV-8
Fungicides (Cont'd.)

              CROP              PEST                      REGISTRATION

zinc-ion maneb
(Dithane M-45)
              onions            seed treatment            Reg on onions; NR for
                                (in furrow)                 seed treatment
              radish            downy mildew              NR

Morestan
              black raspberries powdery mildew            NR
              grapes            powdery mildew            NR
              raspberries       powdery mildew            NR

Terrachlor
              lettuce (GH)      Botrytis rot              NR

sodium hypochlorite
              peppers           seet treatment            NR

Difolatan
              blueberries       Fusicoccum canker         NR

Botran
              endive            Botrytis grey mold        NR

streptomycin
              broccoli          seed treatment            NR
              Brussel sprouts   seed treatment            NR
              cabbage           seed treatment            NR
              cauliflower       seed treatment            NR
              lettuce           seed treatment            NR
              pepper            seed treatment            Ext with IT
              potato            seed treatment            Ext with IT
              tomato            seed treatment            Ext with IT

-------
                                   HERBICIDES
                                                                         IV-9
              CROP
                  PEST
REGISTRATION
dinoseb
(DNBP,  Premerge)
              cucumber
              melons
              pumpkins
              squash
              alfalfa
              barley
2,4-DB
silvex
2,4-D
                  weeds
                  weeds
                  weeds
                  weeds
                  weeds
                  weeds
birdsfoot trefoil weeds
clovers           weeds
crownvetch        post-emergence
  (seed crop only) weeds
oats              weeds
wheat             weeds
forage grasses
  timothy         weeds
  brome           weeds
  orchardgrass    weeds
              barley
              oats
              wheat
              forage grasses
                timothy
                brome
                orchardsrass
              apples
              pears
              forage  grasses
                timothy
                brome
                orchardgrass
              pasturegrass
              cherries
              peaches
              strawberry
              pasture grasses
              forage  grasses
                timothy
                brome
                orchardgrass
                  weeds
                  weeds
                  weeds

                  weeds
                  weeds
                  weeds
                  specific weeds
                  specific weeds1

                  weeds
                  weeds
                  weeds
                  weeds
                  specific weeds
                  specific weeds
                  specific weeds
                  weeds

                  weeds
                  weeds
                  weeds
Ext with IT
Ext with IT
Ext with IT
Ext with IT
Ext with IT
Ext with IT
Ext with IT
Ext with IT

Ext with IT
Ext with IT
Ext with IT

NR
NR
NR
NR
NR
NR

NR
NR
NR
Ext with IT
NR

Ext, No IT
Ext, No IT
Ext, No IT
Ext, No IT
NR
NR
NR  (has negligible res. tol)
Ext with IT

Ext with IT
Ext with IT
Ext with IT

-------
                                                                           IV-10
Herbicides
CIPC
(Cont'd.)

   CROP
                                 PEST
Terbacil
 (Sinbar)
 simazine
 (Princep)
amitrole
diuron
(Karmex)
2,4,5-T
Eptam
(EPIC)
dalapon


trifluralin
               lettuce            weeds
               onions             weeds
               alfalfa            chickweed
               birdsfoot  trefoil  chickweed
               red  clover
               strawberries
              rhubarb
              elderberries
              grapes
                     specific  weeds
                     broadleaf weeds
                     weeds
                     weeds
              birdsfoot trefoil
                 (seed only)     perennial weeds
              crownvetch        perennial weeds
              potatoes  (seed)   potato volunteers
              cherries
              grapes

              peaches
              forage grass
                brome
                orchardgrass
                timothy
              pasturegrass
              crownvetch
  rhubarb
              eggplants
                     specific weeds
                     weeds

                     specific
                    weeds
                    weeds
                    weeds
                    weeds
                    weeds
quckgrass
                    weeds
                          REGISTRATION
                                               NR
                                               NR;  Pet  filed
                                               Ext;  No  IT
                                               Ext;  No  IT
                                               NR
                          NR
                          NR
                          NR
                          Reg. on grapes; NR on
                            grapes under 4 years

                          NR
                          NR
                                              NR
                          NR
                          Reg on grapes; NR on
                            grapes under 4 years
                          NR; Tol Est 11/29/72
                          Ext; No IT
                          Ext; No IT
                          Ext; No IT
                          Ext; No IT
                          NR
NR
                          NR

-------
                                                                          IV-11
Herbicides (Cont'd.)

              CROP

TDK           parsnips

Paraquat
PEST
weeds
              crownvetch        quackgrass
               (seed crop only)
neodecanoic acid
(Onion Top Killer)
              onions
endothall
Rindite
silvex (TP)
Evik
gibberillins
              potatoes
              apples
              beans
              peaches
              pears
                                GROWTH REGULATORS
top killer
vine dessicant
              potato seeds      break dormancy
                          REGISTRATION
NR
                          NR
NR; Pet filed 3/16/72
NR; Tol Est 12/8/72
                          NR
preharvest drop control   Ext with  IT
defoliant
NR
                          NR
                          NR
ainc phosphid
              grapes
                                   RODENT1CIDES
                                rodents
                          NR

-------
                                                                         V  A-l
                                APPENDIX V A

                     SELECTED MINOR USE PESTICIDE NEEDS
                                IN CALIFORNIA


California has many minor crops for which there are definite pesticide usage
problems, due to lack of an established tolerance and registration.

1.  Food Uses

    a.  Insecticides § Miticides

        Virtually all of the vegetable seed crops (cruciferous seed  plants,
        carrots, table beets, chard, celery, lettuce and onion seed  plants)
        are minor crops which lack the necessary registered insecticides
        and miticides.  Practically no new chemicals are registered  for
        these seed crops, leaving only a few of the older established
        chemicals on a few of them - such as malathion, parathion, systox
        (one crop), lindane  (one cropj toxaphene and trichlorfon.

        Safflower, a major vegetable oil crop,  has a few presently registered
        insecticides that can be recommended, namely malathion,  trichlorfon,
        endosulfan, lindane  (seed treatment) and dimethoate. However, growers
        also need oxydemetonmethyl for aphids and methidathion (Supracide vS/ )
        for lygus, thrips and mites.  Performance and residue data for these
        latter two chemicals has been obtained and forwarded to the  companies,
        Dr. Swift  (California Pesticide Coordinator) and the IR-4 Project,
        with no results to date.

        Sunflower is a very important minor crop in California,  grown
        primarily at present for the edible seed market but being researched
        extensively for future production as an oil crop.  The sunflower  moth
        is the major pest and the only insecticide registered to date for
        use against it is endosulfan.  California needs a tolerance  and      ffi\
        registration for the very effective chemical, methidathion  (Supracide
        for which they have also forwarded considerable performance  and residue
        data to IR-4.

        California grows about 11,500 acres of Globe artichokes, almost
        100% of the U. S. production.  Insect control at the present revolves
        around the application of parathion at one pound of actual material
        per acre every two weeks for practically the entire year.  During
        1972, many of the applications were made without any noticeable control,
        It is still unknown whether the problem is resistance or an  inadequate
        application method.

        During the past four years, California entomologists have been
        unable to get any other material registered for artichokes.   Artichoke
        is a minor crop, yet one with a rather major pesticide use.

-------
                                                                     V  A-2
b.  Herbicides

    The following are major needs for herbicides in minor crops in
    California:
            Crop

    established asparagus


    direct seeded asparagus


    peas
    onions

    spinach

    orchard crops
    (almonds,  walnuts,  peaches,  pears,
     apples, apricots,  cherries, prunes,
     plums, etc., approx.  one million
     acres]
2.   Non-food Uses

    a.   Insecticides
                   Miticides
              Crop

        ornamental  oak  trees



        Christmas trees


        Ornamental  Acacia


    b.   Herbicides

        Container ornamentals
        (only one chemical  registered
         at present)
                                                     Chemical(s) Needed

                                                     2,4-D  amine
                                                     terbacal

                                                     chlorobromuron
                                                     terbacal

                                                     chloroxuron
                                                     tenoran

                                                     tenoran

                                                     phenmedipham

                                                     2,4-D  acid, O.S.
                                                     amine  or  amine
                                                 Chemical (s) Needed

                                                 carbaryl,  Orthene
                                                 and Gardona (for control
                                                 of defoliating caterpillars)

                                                 Plictran (for control of
                                                 Oligonychus spider mites

                                                 dimethoate (for control of
                                                 Psylla uncatoidesj
                                                 Treflan, Ronstar,  Lasso
                                                 & Dacthal
    In general, all low acreage, high risk crops face the same problem.
    Even if herbicide residues are not a consideration (container grown
    ornamentals),  there often is not a registration of a herbicide for
    these uses.  In container-grown ornamentals, for example, an acre of
    gallon containers might cost $150,000 whereas $30 of herbicide might
    be sold per acre.  How can any company take the risk of injuring an
    acre let alone 250-300 acres of a grower's ornamentals?  Yet these
    growers need herbicides.

-------
                                                                           V B-l
                                   APPENDIX V B

                       SELECTED MINOR USE PESTICIDE NEEDS
                                   IN MICHIGAN
Crop

Apple

Apricots


Asparagus


Blueberries
Cherries
Chemical

Silvex

Dursban


Lannate
Lenuron

Benlate

Cygon  (Am.Cy.)

Difolatan

Sodium Pentachloro-
 phenate

Dursban
Maple, Beech  Carbaryl*
              Trichlorfon*
Mint Oil
Lannate**
Nectarines    Dursban
Onion


Oak



Oats



Peaches
Parathion*
Diazinon*

Carbaryl*
Malathion*
Trichlorfon*

Carbaryl
Propuxur
  (BaygonJ

Dursban
Pest

weeds

Lesser Peach Tree
 borer

Cutworms
weeds

Mummyberry
 disease
Aphids

Fusicoccum §
 Phomopsis canker
Mummyberry disease
Lesser Peach Tree
 borer
Saddled Prominent
Saddled Prominent

Loopers § Flea
 beetles

Lesser Peach Tree
 borer
Onion maggot
 adults

Red Humped Oakworm
Red Humped Oakworm
Red Humped Oakworm

Cereal Leaf Beetle
Cereal Leaf Beetle
Lesser Peach Tree
 Borer
Comments
Handgun drench treat-
ment to trunk

Bait
ground application,
 seasonal program
ULV air and ground
 application
ground application

Pre-bloom application
Handgun drench treatment
 to trunk and scaffold
 limbs

Aircraft
Aircraft

Foliar application
Handgun drench treatment
 to trunk and scaffold
 limbs

Foliar application
Aircraft
ULV Aircraft
Aircraft

Foliage spray
seed treatment
Handgun drench  treatment
 to trunk and scaffold
 limbs

-------
                                                                           V B-2
Crop

Plums



Scotch Pine



Radish

Snap beans
Chemical
Dursban
Azinphosmethyl*
Furadan*
Temik*

Nitrogen

Sevin (carbaryl)
Sweet
 potatoes     Thiodan

Strawberries  Dursban (Dow)
Taxus
Furdan*
Pest
Peach Tree Borer
Pine Needle Scale
Pine Shoot Borer
Pine Shoot Borer

weeds

Corn borer and
 green clover worm
Aphids

Strawberry Weevil
 (Clipper)

Black Vine Weevil
Comments

Handgun drench treatment
 to trunk and scaffold
 limbs

Aircraft
Granular
Granular
Foliar application
Foliar application

Pre-bloom ground
 or air applications

Granular
*Supportive research or research data are available for Michigan conditions.

**IR-4 obtained a tolerance in mint hay but mint oil is equally (or more) important
  Clarification is needed.

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                                                                       VI-1
                                 APPENDIX VI
                  UNITED STATES DEPARTMENT OF AGRICULTURE
                           Office of the Secretary
                          Washington, D. C.   20250
                                                       February I, 1973


                       SECRETARY'S MEMORANDUM NO. 1799

                     U. S. D. A. Policy on Pest Control


It is the policy of the Department of Agriculture to practice and encourage
the use of those means of practicable, effective pest control which result in
maximal protection against pests, and the least potential hazard to man, his
animals, wildlife, and the other components of the natural environment.

Nonchemical methods of pest control, biological or cultural, will be used and
recommended whenever such methods are economically feasible and effective for
the control or elimination of pests.  When nonchemical control methods are not
tenable, integrated control systems utilizing both chemical and nonchemical
techniques will be used and recommended in the interest of maximum effective-
ness and safety.

Where chemicals are required for pest control, patterns of use, methods of
application and formulations which will most effectively limit the impact of
the chemicals to the target organisms shall be used and recommended.  In the
use of these chemicals, the Department has a continuing concern for human
health and well-being and for the protection of fish and wildlife, soil, air,
and water from pesticide contamination.

In keeping with this concern, persistent pesticides will not be used in
Department pest control programs when an equally safe and effective nonresidual
method of control is judged to be feasible.  When persistent pesticides are
essential to combat pests, they will be used in minimal effective amounts,
and applied only to the infested area at minimal effective frequencies.

In carrying out its responsibilities, the Department will continue to:

          -- Conduct and support cooperative research to find new,
             effective biological, cultural, and integrated pest
             control materials and methods;

          -- Seek effective, specific, nonpersistent pesticides and
             methods of application that provide maximal benefits and
             are least hazardous to man and his environment;

-------
                                                                         VI-2
         -- Cooperative with other public and private organizations and
            industry in the development and evaluation of pest control
            materials and methods,  assessment of benefits and potential
            hazards in control operations,  monitoring for pesticide
            residues, and dissemination of pesticide safety information.

All users of pesticides are strongly urged to heed label directions and exercise
constant care in pesticide application, storage, and disposal for the protection
of people, animal,  and our total environment.

The Department commends this policy to all  who are concerned with pest control.
                                             Earl L.  Butz
                                             Secretary of Agriculture
With this issuance,  Secretary's Memorandum No.  1666,  dated October 29, 1969,
is hereby superseded.

-------
                                                                      VII A-l
                            APPENDIX VII A

PESTICIDES USED AND NEEDED IN DOMESTIC PROGRAMS OF THE PLANT PROTECTION
      AND QUARANTINE PROGRAMS OF APHlS BUT PRESENTLY UNREGISTERED*
Pesticide

Aldrin

BHC

Carbaryl



Dibrom


Dieldrin

Dimethoate

Ethylene dibromide-
  434

Hydrocyanic acid

Malathion


Sevin-4 oil


Treflan

2,4,5-T
Used for Following Pests

Mormon cricket

Whitefringed beetle

Giant African snail, West
Indian sugarcane root borer, and
whitefringed beetle

Mediterranean fruit fly. Melon
fly, and Oriental fruit fly

West Indian sugarcane root borer

Citrus blackfly

Japanese beetle


Pink bollworm

Beet leafhopper; black grass-
bug, and khapra beetle

West Indian sugarcane root
borer

Witchweed

Witchweed
*0f the 38 pesticides presently used in PPQP's domestic programs,
 12 (listed here) are unregistered.

-------
                                                                         VII B-l
                               APPENDIX VII  B
   PESTICIDES USED AND NEEDED IN FOREIGN PROGRAMS OF THE PLANT PROTECTION
    AND QUARANTINE PROGRAMS OF APHIS BUT PRESENTLY UNREGISTERED (PART__I_)
              OR REGISTERED FOR SOME USES BUT NOT ALL (PART II)
PART I
     Pesticides

     Acrylonitrile

     Formaldehyde

     Mercuric chloride

     Sulfuric acid
Used on Following
PART II
     Aluminum phosphide



     Captan

     Carbon disulfide


     Carbon tetrachloride


     Chloropicrin



     Copper sulfate--Lime

     DDT/Carbaryl

     Ethylene dibromide
Barley, corn, millet, peanuts,
oats, rice, rye, sorghum, and
wheat

Nursery stock dip

Barley, corn, oats, popcorn, rice,
rye, sorghum  (milo), and wheat

Barley, corn, oats, popcorn, rice,
rye, sorghum  (milo), and wheat

Barley, buckwheat, corn  (including
popcorn), oats, rice, rye, grain
sorghum, and wheat
Micronized dust--aircraft

Barley, beans  (string), bitter melons,
cantaloups, Cavendish  bananas,  cherries,
citrus fruits, corn, cucumbers,  guavas,
litchi fruit,  litchi nuts,  longan  fruit,
mangoes, oats, papayas, peppers  (bell),
pineapples, plums  (fresh prunes),
popcorn, rice, rye, sorghum (milo),
wheat, and zucchini squash

-------
                                                                    VII B-2
Pesticide
Ethylene dichloride
Ethylene oxide
Hydrogen cyanide
8-Hydroxyquinoline
  sulfate

Mercuric chloride

Methyl bromide
Used on Following

Barley, corn, oats, popcorn, rice,
rye, sorghum (milo), and wheat

Black walnut meats, copra, and
whole spices

Allspice, almonds, anise, barley,
basil, bay, beans  (dried), black
pepper, buckwheat, caraway, cashews,
cassia, celery seed, chili, cinnamon,
cloves, cocoa beans, coriander, corn
[including popcorn), cumin, dill,
ginger, mace, marjoram, milo  (grain
sorghum), nutmeg, oats, oregano,
paprika, peanuts, peas  (dried),
pecans, poppy, red pepper, rice,
rosemary, rye, sage, savory, sesame,
thyme, tumeric, walnuts, wheat,
white pepper
Alfalfa hay- almonds, apples, apricots,
asparagus, avocadoes, barley, beans,
beans (green), beans (lima), beans
(snap), black-eyed peas, Brazil nuts,
bush nuts, butter nuts, cabbage,
cantaloupes, carrots, cashew nuts,
cherries, chestnuts, cipollini bulbs,
citrus citron, cocoa beans, coffee
beans, copra, corn, cottonseed,
cucumbers, cumin seed,  eggplants,
filberts  (hazelnuts), garden beets
(roots), garlic, ginger roots,
grain sorghum (milo), grapes, grapefruit,
hickory nuts, honeydew melons, horse-
radish, Jerusalem-artichokes, kumquats,
lemons, limes, mangoes, muskmelon,
nectarines, oats, okra, onions, oranges,
papayas, parsnips  (roots), peaches,
pears, peanuts,  peas, pecans, peppers,
pineapples, pimentos, pistachio nuts,
plums (fresh prunes), pomegranates,
popcorn, potatoes, pumpkins, quinces,
radishes, rice,  rutabagas, rye,
salsify roots, soybeans, strawberries
(from use before harvest), sugarbeets
(roots), summer squash, sweetcorn,
sweet potatoes,  tangerines, timothy
hay, tomatoes, turnips  (roots), walnuts,

-------
                                                                    VII  B-3
Pesticides

Methyl bromide
 (continued)

Nemagon
Pyrethrum mixtures

Sulfuryl fluoride

Zineb
Used on Following

watermelons, winter squash,
yams, and zucchini squash

Almond hulls, almonds, apricots,
bananas, blackberries, boysenberries,
broccoli, brussels sprouts, cabbage,
carrots, cauliflower, cherries,
celery- citrus fruits, cottonseed,
cucumbers, eggplants, dewberries,
endive  (escarole), English walnuts,
figs, grapes, lettuce, lima beans,
loganberries, melons, nectarines,
okra, parsnips, peaches, peanuts,
peppers, pineapples, plums  (fresh
prunes), radishes, raspberries,
snap beans, soybeans, strawberries,
summer squash, tomatoes, turnips

G1152/G1701  (aerosol spray)
Nursery stock dip

-------
                                                                      VIII A-l
                            APPENDIX VIII A
           MAJOR FOREST SERVICE CONTROL PROJECTS IN FY 1972
Pest organism
 or problem
Location and extent
    of problem
Pesticide and extent
   of treatment
Spruce budworm


Gypsy moth
Tip moth/cone
insect complex

Bark beetles
Fusiform rust


Brown spot


Unwanted
vegetation
Maine - 3 million acres
Northeastern States -
1.342 million acres
Seed orchards in
Southern States

Localized areas in
Western and Southern
States

Forest nurseries in
Southern States

Localized areas in
Southern States

Management units on
National Forest System
lands
Zectran - 500,000
acres

Carbaryl   111,600
acres in Pa.,  N.J.,
and N.Y.

Dimethoate
322,800 trees

BHC, lindane,  EDB -
66,900 trees
Ferbam - 90,000
trees

Bordeaux mixture -
6,000 trees

2,4-D; 2,4,5-T;
2,4,5-TP - 172,000
acres

-------
                                                                      VIII B-l
                               APPENDIX VIII B

                   LIST OF MINOR USE PESTICIDES NEEDED
                            BY FOREST SERVICE
Fungicides or fumigants

Benomyl

Bordeaux and other
copper fungicides

Bus an

Captan

Daconil 2787

Difolatan (captafol)

Maneb

Methyl bromide

Peniophora gigantea

SMDC  (Vapam)

Thiram


Herbicides

Amitrole

Amizine

Bromacil

Cacodylic acid

Cotoran (fluometuron)

Dicamba

Dichlobenil  (Casoron)

Dichlorprop

Diquat

EPTC  (Eptam)
                Use

Nursery diseases, wilt diseases

Foliage diseases


Seed and seedling diseases

Seed and seedling diseases

Foliage diseases of seedlings

Foliage diseases of seedlings

Foliage diseases

Building, greenhouse, soil fumigation

Biological for annosus root rot

Nursery soil fumigation

Seed and seedling diseases




Road rights-of-way

Soil sterilant, weed control

Weed control

Timber stand improvement work

Grass and weed control

Brush and noxious weed control

Weed control in nurseries

Site preparation

Aquatic weed control

Weed control

-------
                                                                        VIII  B-2
Herbicides  (Cont'd)

Linuron

MH-30  (Maleic Hydrazide)

MSMA  (Silvisar 550)

Paraquat

Picloram


Picloram + 2,4-D + 2,4,5-T


Prometone (Pramitol)

Simazine

Sodium cacodylate

Trifliiralin  (Treflan)

Trysben (trichlorobenzoic acid)

234-D and Tandex (karbutilate)


Insecticides

Aldrin
Bacillus thuringiensis
(Dipel, Thuricide HPC)
Az inphosmethyl
(Guthion)
             Use

Grass and weed control

Brush control

Timber stand improvement work

Weed control in nurseries

Weed and brush control  (inc. areas
grazed by domestic livestock)

Timber stand improvement work,
road rights-of-way

Grass and weed control

Weed control in nurseries

Weed control

Grass and weed control

Weed control

Brush control
           Use!/
Native subterranean termites,
pales weevil

Bagworm, fall cankerworm, spring
cankerworm, eastern tent caterpillar,
forest tent caterpillar, gypsy moth,
elm spanworm, fall webworm, Great
Basin tent caterpillar, redhumped
caterpillar, California oakworm

Aphids, oystershell scale, Putnam
scale, cone midge, cone moth
(Dioryctria spp.)> European pine
shoot moth, Nantucket pine tip moth,
black pine-leaf scale, European elm
scale, juniper scale, slash pine
seedworm, mimosa webworm, spruce
spider mites

-------
                                                                        VIII  B-3
Insecticides (Cont'd)

Carbaryl (Sevin)
Diazinon
Dimethoate (Cygon)
Disulfoton (Di-SystonJ




Dursban

Gardona
Aphids, bagworm, elm leaf beetle,
willow leaf beetle, boxelder bug,
fall cankerworm, eastern tent
caterpillar, forest tent caterpillar,
lacebugs, birch leaf miner, oak leaf
miner -  gypsy moth, saddled prominent,
mimosa webworm, Great Basin tent
caterpillar, western tent caterpillar

Aphids, bagworm, eastern tent
caterpillar, forest tent caterpillar,
cottony cushion scale, fall webworm,
mimosa webworm, Great Basin tent
caterpillar^ western tent caterpillar,
hemlock chermes, European pine shot
moth, loblolly pine sawfly, pine
needle scale

Bagworm,  juniper scale, fir cone
midge,  European pine shoot moth,
Nantucket pine tip moth, Zimmerman
pine moth, loblolly pine sawfly,
pinyon needle scale

Aphids, elm leaf beetle, birch leaf
miner,  holly leaf miner, European
elm scale, mimosa webworm, Nantucket
pine tip moth, spruce spider mites

Bagworm

Aphids, elm leaf beetle, fall cankerworm,
forest  tent caterpillar, spiny elm
caterpillar^ oak leafroller, birch
leaf miner, European elm scale, oak
leaf tier, juniper webworm, mimosa
webworm,  pine sawflies (?)
Imidan
Gypsy moth, elm spanworm, spring
cankerworm, birch leaf miner

-------
                                                                        VIII B-4
Insecticides  (Cont'd)

Malathion  (Cythion)
Trichlorfon  (Dylox)
Zectran
Repellents

Anthraquinone

Endrin + Arasan

Thiram (Arasan)
         Use!/
Aphids, bagworm, western budworm,
eastern spruce budworm eastern
tent caterpillar, forest tent
caterpillar, birch leaf miner,
hemlock looper, larch casebearer,
European pine shoot moth, European
pine sawfly, red-headed pine sawfly-
oyster shell scale, pine needle
scale, pine tortoise scale,
Saratoga spittlebug, lodgepole
needle miner- pine needle
sheath miner

Bagworm, forest test caterpillar,
gypsy moth, Nantucket pine tip
moth, Zimmerman pine moth

Aphids, western budworm, eastern
spruce budworm, eastern tent
caterpillar, forest tent
caterpillar, spiny elm
caterpillar, yellow-necked
caterpillar, birch leaf miner,
Great Basin tent caterpillar,
jack-pine budworm, European pine
shoot moth, red pine sawfly

              Use

Bird repellent
               2/
Seed protectant—
Seed protectant and animal
repellent
_!/  Registered ornamental and/or forest was irrespective of host or
    geographic limitations.

2/  Presently registered for use as an insecticide, not for protection
    of seed against rodent depredation.

-------
         DEPARTMENT OF DEFENSE  PEST  CONTROL:   UNREGISTERED PESTICIDES AND UNREGISTERED PESTICIDE USES
Item

 1
 3

 4

 5

 6

 7
 9

10

11


12



13



14
Department Target Pest
1
Navy
Army , Navy
Army
Army , Navy ,
Air Force
Army , Navy ,
Air Force
Air Force
Army , Navy
Navy
Army
Army , Navy ,
Air Force
Army , Navy
Wood chucks
Gophers
Powder post beetles
Drywood
termites
Clover mites
German and Ameri-
can cockroaches
Subterranean
termites
Mosquitoe larvae
Bed bugs
Mosquitoe larvae
Web worms
Pigeons
Ground squirrels
Pesticide
Aluminum
phosphide
Aluminum
Phosphide
Baygon
Diazinon or
Baygon or
Malathion or
Dursban
Paris green
Paris green
granules
Diazinon
Abate
Bacillus
thuringiens is
Fenthion
1080
NOT REGISTERED
for target
pest
X
X


X
X
X

X
X

Method
burrow
fumigation



tube
treatment
aerial

plaster
briquettes

Grease
formulation

Site
Pacific

Interior
food hand-
ling areas




on pecans


Other









Experimental
registration
suspended
Registration
suspended
T)
T3
tfl
Z
a
i—i
x
                                                                                                                         t—I
                                                                                                                         X

-------
                                                                        IX-2
     Item 1.   In the Pacific area, the Navy has found aluminum phosphide
to be a very good rodenticide for burrow fumigation.  The dosage is
usually one tablet per burrow and then cover the hole to prevent the
escape of the phosphine.  Soil moisture is usually adequate to initiate
the reaction.   It would seem that this application would be useful for
rats and other burrowing rodents as well throughout the United States.
Although CACN is registered and suitable, there is an advantage to
handling one tablet vs a long handled tablespoon.  The Navy alone conducts
more than 264 man days annually on burrow fumigation with cyanide.
Any acceptable method for improving this operation would be desirable.

     Item 2.   Control of powder post beetles and drywood termites is currently
done with MB or perhaps sulfuryl flouride.  It would be an advantage
to have AlPh available too.

     Items 3 and 12 are very minor in terms of total use, but desirable
for program fexibility.

     Items 4,  5, 6 and 7.  The use of these residual materials in food
preparation areas is not registered, but in comparison to other types of
pest control,  it is the most important.  Treatment of food preparation
areas - galleys, mess halls and associated facilities, is necessary to
reduce the population of German and American cockroaches.  To be effective,
and to stay within the registered uses, continual treatment would be
required.  Current practice is to remove food, cover utensils and food
preparation surfaces and spot treat.  Flushing agents may be used
simultaneously or immediately after laying down the residual.  The galleys
are "washed" down daily which negates the use of residuals in some
situations.  Loss of these materials for use in food handling areas
would have considerable impact on military pest control costs.  It is
estimated that the Navy alone expends more than 100,000 man hours or
$1.2 million on this type of control annually.  In many situations, no
alternative chemicals would be employed due to the cost and the insects
would increase significantly and almost immediately.  Timed dispensers
have been used in a few situations, but are not favored due to higher
cost and the factor of constant exposure.  Use of dusts and bait granules
would not be able to achieve sufficient control.

     Item 8.   Paris green has been effective in controlling subterranean
termites by introducing a small amount of the insecticide into the tubes.
This use is one of the main methods of control in Hawaii and other
Pacific areas.  Its use is minor but effective and safe for both the
applicator and non-target organisms.  Loss of this use would immediately
multiply the cost of termite control by ten to twenty fold although soil
poisoning has  a longer service life.

     Item 9.   Paris green is useful in mosquito control programs for treat-
ment of sanitary fill areas.  Aerial application of granules is effective
in getting the control agent into the cracks in the ground.  Alternate
materials require considerable care to avoid harmful effects on aquatic
organisms.

-------
                                                                        IX-3
     Item 10.   The use of diazinon for bedbugs has  been extremely
effective.   The material is spot treated on the bed frames,  springs,
cracks, and other areas where the insects take shelter.  The residual
is necessary to provide control for subsequent hatchs  of eggs.   Loss  of
this use would require immediate substitution of another material
because military housing and barracks are frequently infested with bedbugs.

     Item 11.   Abate plaster briquettes and other forms of slow-release
for mosquito control are very suitable at military installations.  The
Army Environmental Health Agency at Edgewood, Maryland has done considerable
study on compounding insecticide in rubber pellets.  The savings in labor
costs alone make this operation valuable.  At one Navy installation the
PCO spots and treats shallow inaccessible ponds by dropping briquettes
from a helicopter.  The practice is not quite so suitable for large
mosquito programs, but appears environmentally sound.   Procedures for
making the blocks have been developed by Navy entomologists.

     Item 12.   (See Item 3).

     Item 13.   Under military situations where PCOs are (aj trained,  (b)
highly supervised, and  (cj maintain tight security over various sites the
use of fenthion can be safely used for control of pigeons.  An experimental
product, "Queletox", was available a few years ago but has since lost its
registration.   It was highly effective and in a few cases was the only
suitable material.  The product is needed for use where pigeon problems
exist and certified PCOs are available to put down the toxicant, watch it
and remove residues along with the affected birds.   Bird control is highly
specialized and each situation is different so it is difficult to assess
the value of using fenthion in this manner.

     Item 14.   Considerable study has been carried out on the use of 1080 for
the Beechey ground squirrel in California.  It has been found that the
squirrel is a real threat to military operations, base maintenance,
agricultural losses and human health.  Annually, several California
military installations suffer from power outages, broken springs on
vehicles, reservoir damage and failure, claims for crop destruction and
road subsidence and pavement repair.  All from the burrowing and feeding
habits of ground squirrels.  Dollar value is estimated to be between
$40,000 and $100,000.  No value can be placed on inconvience and loss of
recreational use, etc...  Several installations have ground squirrel
populations with endemic plague.  Plague at an Army base required the
reencampment of several hundred soldiers and their equipment when the
epizootic was found in a local squirrel population.  The cost of the
subsequent burrow dusting program (one mile square) is unknown but can
be imagined.

Ground squirrels prey heavily on leaf, grain and nut crops.  The military
base commander is in an awkward position when squirrels living on
military property damage adjacent agriculture and he has at best, only
partially effective control methods available to him.   The reason for
this situation is the loss of the use of 1080 on federal lands by
executive order.  Originally intended to remove 1080 from predator control.
this action has put a clamp on one of the most useful, effective and,
under proper supervision, environmentally safe control programs available.
Alternate methods either have similar risks or totally impractical labor
costs.

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                                                                           X-l
                                    APPENDIX X

                          MINOR USE HERBICIDE NEEDS FOR
                          AQUATIC VEGETATION MANAGEMENT
                              (CORPS OF ENGINEERS)
    1.  Copper Sulfate   Copper sulfate is widely used for control of algae
        in almost all situations requiring chemical control of these pests.

    2.  Dichlone   This compound (2,3-dichloro-l,4-napthoquinone) is effective
        primarily on blue-green algae.

    3.  Dichlobenil - The macroscopic alga Chara is especially susceptible to
        dichlobenil (2,6-dichlorobenzonitrile).

    4.  Other Herbicides   Other herbicides that will eliminate all or certain
        species of algae are acrolein, aromatic solvent, diquat, and endothall.
        These are broad spectrum herbicides and are usually used to control one
        or more species of vascular weeds.  The control of algae is for the
        most part incidental to this use.

B.  Floating Weeds.  Floating weeds are particularly troublesome in the
    Southern States.  The most serious problem species such as waterhyacinth
    alligatorweed, waterlettuce (Pistia stratiotes L.j, and waterferns
    (Azolla spp., Salvinia rotundifolia Willd.)  are for the most part from
    the tropics or subtropics.  They do not die back during the winters,
    although their rates of growth decrease.  Hindrances to navigation arise
    primarily from the excessive growth of floating weeds.  With the possible
    exception of alligatorweed, they are more easily controlled than most
    submersed vegetation.

    1.  2,4-D - This herbicide ((2,4-dichlorophenoxy)acetic acid) can be used
        to control most of the species of floating aquatic weeds.  Waterhyacinth
        is particularly susceptible; alligatorweed is most resistant and treat-
        ment rates may be increased.

    2.  Silvex - While silvex  (2-(2,4,5-trichlorophenoxy)propionic acid) may be
        used widely for control floating vegetation, its principal use is as
        a substitute for 2,4-D in control of alligatorweed.  Field tests have
        shown that silvex will provide longer lasting control of this weed.

    3.  Diquat - Where circumstances make it undesirable or unsafe to use
        2,4-D, diquat (6,7-dihydrodipyrido (1,2-a:2',1'-c)=pyrazinediium ion)
        may be used to control duckweed, waterhyacinth and waterlettuce.

C.  Submersed Weeds.

    1.  Irrigation Canals and Ditches - Aquatic vegetation in irrigation
        conveyance systems is difficult to control.  The water  is constantly
        flowing (usually at a fairly high velocity) which results in the transport

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                                                                      X-2
    of herbicide chemicals  from the  site  of  application.   In order to provide
    adequate contact  time for  lethal dosages to be absorbed by  the vegetation,
    herbicides  must be applied continuously  to the water  for periods known to
    be effective.  Consequently,  large volumes of water must be treated  at
    considerable expense.   In  addition, herbicides must usually be applied
    to water that  will in a short  time be diverted onto cropland.  In
    irrigated areas,  water  is  a scarce commodity and not  be wasted.  During
    the time of season when weeds  are most troublesome, the canals of water
    required to satisfy the needs  of the  farmers.  Thus,  it is  impractical
    to interrupt the  flow of water to cropland by shutting down the flow in
    the canals  or  by  denying diversion of water to crops.

    a.  Acrolein.  Acrolein is usually used  as a contact  herbicide in large
        irrigation canals where aromatic  solvents do not  perform well.

    b.  Aromatic Solvent.   Aromatic  solvents (almost exclusively xylene
        of not  less than Grade B)  have been  used in irrigation  canals of up
        to 100  cfs of flow  for more  than  25  years.  Aromatic solvents,  like
        acrolein,  are contact  herbicides  and are effective on algae as
        well as vascular aquatic weeds.

    c.  Copper  Sulfate. The continuous-feed method of using copper sulfate
        for control of submersed aquatic  plants has been  used only rarely;
        and mainly on experimental bases.

    d.  Diquat  - This herbicide has  had limited use in irrigation systems,
        being restricted to situations where there is  virtually no movement
        of the  water.   Diquat  is ineffective in turbulent water and in water
        containing appreciable quantities of suspended solids.

    e.  Endothall.  The restrictions concerning the use of the  sodium and
        alkylamine salts of endothall (7-oxabicyclo=(2.2.l)heptane-2,3-dicarboxylic
        acid) are  the same  as  for  diquat.

    f.  Monuron.  This herbicide (3-(p_-chlorophenyl)-1,1-dimethylurea)  is not
        useful  for control  of  aquatic weeds  in the main channels of irrigation
        systems.  Its principal use  is for control of  vegetation in lateral
        ditches that  carry  water intermittently and directly to irrigated
        fields.  Since herbicides  used in these ditches are not linked  directly
        to other water systems, they are  only of secondary importance.

    g.  Diuron.  The  use of diuron (3-(3,4-dichlorophenyl)-l,1-dimethylurea)
        is the  same as for  monuron.

2.   Drainage Ditches    Many of the factors and conditions governing the  uses
    of herbicides  in  irrigation canals and ditches apply  equally to drainage
    ditches.  In some drainage ditches fish  may be of  considerable importance,
    in others they may be nonexistent or  of  little importance.   Also,  some
    drainage ditches  may have  sizable water  flows, while  others have  essentially
    no flow during much of  the year. Drainage ditches commonly empty  into '
    water impoundments or into streams.   Water from drainage ditches  is  also
    used occasionally for irrigation.  In treating drainage ditches for  control

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                                                                       X-3
    of vegetation,  the precautions that must be observed are dependent
    upon the circumstances that apply to the specific  situation.

    a.   Acrolein.

    b.   Aromatic Solvent.

    c.   Copper Sulfate.   May be used infrequently in drainage ditches where
        the vegetation is predominantly algae.

3.   Lakes,  Ponds,  and Reservoirs - It is in lakes,  ponds,  and reservoirs
    that aquatic vegetation problems are most numerous;  and it is  from here
    that we can anticipate much greater demand for  improvement in  the
    environment through management of aquatic plants.   The nation  is
    experiencing wholesale development of almost all available waterfront
    property.   In many areas where natural bodies of water do not  exist,
    they are being constructed as integral parts of residential developments.
    At the  same time, recreational uses of water have  increased greatly.
    For various reasons, the quality of water in lakes,  ponds, and
    reservoirs has deteriorated and continues to become poorer.  Algae
    problems now exist in waters where they were never observed previously.
    Vascular aquatic weeds frequently pollute and reduce the usefulness
    of waters valued for generations as favored fishing and other  recreational
    sites.   Awareness of the problems, and knowledge that  methods  are
    available that may be used to alleviate these even temporarily or in
    part, will undoubtedly result in pressures to improve  the aquatic
    environment through vegetation management.   Permanent  solutions, if
    there are any,  must include measures to prevent pollution and  enrichment
    of the  water.

    a.   Dichlobenil.   When used as a broadcast treatment on exposed bottoms
        or  over the water surface, the granular formulation of dichlobenil
        provides excellent control of vascular aquatic plants and  Chara.

    b.   Diquat.

    c.   Endothall.   The various derivatives of endothall are broad spectrum
        herbicides.  The disodium and potassium salts  are  active on most
        submersed species of aquatic plants.  They  are notably ineffective
        on  elodea.

    d.   Fenac.  Present uses of fenac ((2,3,6-trichlorophenyl)=acetic acid)
        are limited to situations in which water can be drawn down to expose
        the bottom soil of ponds and lakes.

    e.   2,4-D.  Various derivatives of 2,4-D are used for  control  of  submersed
        aquatic vegetation.

    f.   Silvex.  The potassium salt of silvex is applied as a liquid  or
        used occasionally in granular or pelleted formulations.

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                                                                       X-4
    g.  Other Herbicides.   Other herbicides used infrequently for control
        of submersed weeds in ponds,  lakes, and reservoirs are acrolein and
        aromatic solvents.  Because of their toxicity,  they are normally
        used for spot treatments in these bodies of water.  Simazine and
        diuron have been used experimentally in extensive testing to
        control pH and reduce plant biomass responsible for oxygen depletion
        hazards in ponds used for fish production.   Increases, in pH and
        oxygen levels are highly desirable and appreciable toxicology and
        residue research is being conducted on these herbicides to support
        registration for their uses.

Emersed and Marginal Weeds.  Emersed weeds are common to shallow bodies of
water and shallow slow moving streams.  Because most are littoral species;
they are an important component of the habitat for  fish and other aquatic
animal life, and play an important role in the aquatic food chain.  Their
location makes them especially undesirable to lakeside homeowners, swimmers,
and other water users.

1.   Broadleaved Plants.

    a.  2,4-D.  It is commonly recommended as a general control for most
        marginal and emergent broadleaf vegetation.

    b.  Silvex.  It is used in the same manner as 2,4-D above.

2.   Grass and Grass-like Species.

    a.  Dalapon.  It is used for most grasses and grass-like species
        including cattails and bulrushes.

    b.  2,4-D.  It may be substituted for dalapon in the control of     •
        bulrushes and cattails.
                              i

    c.  MSMA and TCA.  Neither MSMA (monosodium methanearsenate) nor TCA
        (trichloroacetic acid) is registered for use in and around water.
        Both have been field tested extensively and both appear to have
        desirable uses for control of ditchbank grass weeds.

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                                                                           XI-1
                                   APPENDIX XI

                        SELECTED MINOR USE PESTICIDE NEEDS
                      BY U. S. DEPARTMENT OF INTERIOR (DOI)


A.  General Observations.

    Within the Department of Interior there are several specific pesticide
    needs which are classified as minor uses.  Examples can be found in each
    of three DOI agencies below.

    1.  Bureau of Reclamation.

        Bureau of Reclamation project facilities include about 304 storage
        reservoirs; 60,000 miles of canals, laterals and drains; and 16,000
        miles of transmission lines.  Chemicals are used to control algae
        and aquatic weeds in water distribution and drainage systems.  (Some
        of these needs have been documented in more detail in Appendix X).

    2.  Bureau of Sport Fisheries and Wildlife.

        A number of chemicals are used in fish and wildlife management programs
        for disease control in fish cultures, fish eradication, habitat
        improvement, population sampling, and stream and pond reclamation.
        A number of wildlife damage control toxicants are also used to aid
        in protecting crops and livestock; human health and safety; urban
        structures; and forest, range and wildlife resources.

    3.  Bonneville Power Administration

        The Bonneville Power Administration uses herbicides to control
        vegetation on powerline rights-of-way in the Pacific Northwest.  A
        presently non-registered formulation provides the best control.

B.  Specific Problems

    Documented below are some of the specific use problems that relate to
    the general observations above.

    1.  Avicides - for protection of fruits, small grains, and feedlots from
        bird damage, all minor uses.  One new repellent and one new toxicant
        have been registered by private companies during last 6 years.  All
        current registered compounds are due for review.

        a.  Methiocarb - a repellent that can be used to protect fruit,
            sprouting corn, rice from birds  - not registered.  The DOI has
            spent over $200,000 trying to convince the company that the
            material is effective and should be registered.

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                                                                      XI-2
    b.   Avitrol   a bird repellent  that  can be  used  to protect  field  corn,
        sunflowers, table corn from birds.  The company registered the
        material with DOI assistance ($400,000)  for  field  corn. Other
        registrations will probably require data obtained  by DOI.

2.   Rodenticides - are used to protect agricultural  crops,  forest products,
    urban areas from rodents   Industry  interest generally only with
    commensal rats and mice.

    a.   Zinc phosphide   an old compound.  The  registration of  new uses  is
        needed.  One residue tolerance has been secured through a joint
        registration effort by DOI  and the Hawaii Sugar Can Grower
        Association   cost $200,000.

    b.   Gophicide - specific for certain rodents.   It  is registered for
        use on pocket gophers without a  residue tolerance.  The owner
        of the Compound did not renew the registration when a residue
        tolerance was required - $200,000 cost  to Department.

3.   Predacides   needed for protecting livestock from  predators.  None
    are now available and any new materials will probably  have  to be
    developed and registered by the DOI  or other governmental agencies.

4.   Herbicides   are used in weed control on  croplands in  such  volume
    that industry considers them a  major use  and has assumed responsibility
    for registration.  However, those needed  in or near aquatic situations
    are considered minor uses and registration  has become  the responsibility
    of the user agency.   These needs have been  detailed above  in  Appendix X.
    (U. S. Corps of Engineers - Aquatic  Herbicide Uses).

    Registration of these minor uses has, where possible,  been  assumed
    by the DOI, and active cooperation of industry and other federal
    agencies (such as U. S. Corps of Engineers) is required.  For  example,
    government agencies have spent  about $300,000 toward registration of
    2,4-D for use in irrigation ditches, ponds, lakes  and  navigation  systems
    Although residue tolerences have been established  for  certain uses  in
    irrigation ditches,  further work is  needed  to obtain a label  for
    registration for other uses.

5.   Algaecides   are used to maintain algae free irrigation systems and
    erradicate bluegreen algae that are  toxic to fish  and  wildlife.   These
    materials are also used to reduce algal blooms that result  in  taste
    and odor problems, clog screens and  water conveyance  structures,  and
    cause problems with noxious growths  in ponds, lakes, marshes,  flowages,
    streams and raceways involving  fish  that  are propagated and managed.
    Again, the problem was detailed above in  Appendix  X.

6.   Disinfectants, fungicides, parasiticides  and disease  control  agents
    are needed for fish propagation and  require registration when used  in
    water or soil treatment and in  the  sanitization of facilities.   Thus,

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                                                                       XI-3
    the present uses of malachite green, formaline— acriflavine,
    potassium permanganate,  copper sulfate, Dvlox^ Baytex®,  di-n-butyl
    tin-oxide, dibutyl tin dilaurate, RoccalCE), Hyamine 1622 (and other
    Hyamines), methylene blue,  furpyrinol, wescodine (for Betadine)  and
    even salt and acetic acid (vinegar) for these purpose are without
    full registration status.  Many of these will also require  dual
    registration as both a drug (with FDA) and a pesticide according to
    specific uses claims or intention of the applicator.

7.   Piscicides - are major tools for restoration of fish populations used
    by fishery management biologists.  The lampricide "TFM" used  to
    control the parasitic sea lampray in the Great Lakes is a piscicide.
    The Great Lakes Fishery Commission in cooperation with the  Canadian
    government, States, Provinces and the Bureau of Sport Fisheries  and
    Wildlife have conducted a $600,000 registration oriented research
    program for obtaining clearance and registration of TFM and the
    synergist "Bayer 73."  The DOI has also conducted cooperative studies
    with industry on formulations of antimycine A, rotenone, squaxin and
    certain salicylanilides that are needed for selective removal of
    undesirable fishes, renovation of fish populations, and for collecting
    or harvesting target species in management operations.

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                             ARS FACILITIES DEVOTED PRIMARILY TO PESTICIDE RESEARCH'
Beltsville, Md.
College Station,
   Texas

Duran, Oklahoma

Fargo, N.D.


Gainesville, Florida

Kerrville, Texas


Morris, Minnesota

Savannah, Georgia


Stoneville, Miss.

Tifton, Ga.

Yakima, Washington
PSRD - Crops Protection Research Br.
ERD - Insect Physiology Pioneering Lab
ERD - Pesticide Chemicals Branch
ERD - Pesticide Chemicals Branch
ERD - Pesticide Chemicals Branch
ERD - Pesticide Chemicals Branch
SWCRD - Northeast Branch

VSRD - Vet. Tox and Entomology Lab.
SWCRD - Southern Plains

PSRD - Crops Protection Research Br.
ASRD - Swine Research Branch

ERD - Pesticide Chemicals Branch

ERD - Insects Affecting Man § Animals


SWCRD - Northcentral Branch

MQRD - Stored-Product Insects Research
          Branch

PSRD - Crops Protection Research Branch

ERD - Pesticide Chemicals Branch

ERD - Pesticide Chemicals Branch
Pesticide Behavior in Soils
Hormonal insecticides
Aerosols
Analytical Methods
Insecticides-efficacy
Insecticides-residues
Pesticides fate in soil and water

Veterinary and insect toxicology
Pesticides fate in soil and water

Pesticides metabolism in plants
Pesticide metabolism in farm animals

Insecticides-efficacy

Veterinary toxicology § Insecticides-
   residues

Pesticides fate in soil and water

Insecticides-efficacy and residues


Weed Control

Insecticides-residues

Insecticides-residues
T)
T3
Cfl

O
l—i
X

X
 *This was the  situation under  ARS  prior  to  the  most  recent  reorganization.
                                                                                                                       x

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