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
-------
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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11
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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(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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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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(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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(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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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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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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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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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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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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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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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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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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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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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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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
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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.
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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.
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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.
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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.
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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
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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
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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
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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
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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
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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.
-------
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.
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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
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a
i—i
x
t—I
X
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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.
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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
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X
X
*This was the situation under ARS prior to the most recent reorganization.
x
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