\
UJ
ENVIRONMENTAL PROTECTION AGENCY
/ OFFICE OF WATER PROGRAMS
PESTICIDE USE ON THE NON-IRRIGATED CROPLANDS OF THE MIDWEST
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PESTICIDE STUDY SERIES - 4
DEVELOPMENT OF A CASE STUDY OF THE TOTAL
EFFECT OF PESTICIDES IN THE ENVIRONMENT,
NON-IRRIGATED CROPLANDS OF THE MID-WEST
This study is the result of
Contract No. 68-01-0117 awarded by the OWP,
as part of the Pesticides Study (Section 5(£)(2) P.L. 91-224)
to Ryckman, Edgerley, Tomlinson and Associates, Inc.
The EPA Project Officer was Charles n. Reese, Agronomist
ENVIRONMENTAL PROTECTION AGENCY
Office of Water Programs
Applied Technology Division
Rural Wastes Branch
TECHNICAL STUDY REPORT: TS-00-72-03
June 1972
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EPA Review Notice
This report has been reviewed by the Office of Water
Programs of the Environmental Protection Agency and
approved for publication. Approval does not signify
that the contents necessarily reflect the views and
policies of the Environmental Protection Agency, or
does mention of trade names or commercial products
constitute endorsement or recommendation for use.
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FOREWORD
Among all environmental pollutants, chemical pesti-
cides have aroused special concern. They are widely used
throughout the United States on croplands, rangelands,
forests, lawns, turf, in and around homes, for protection
of structures and stored products, and over entire areas
for mosquito control, insect eradication, imported fire-
ant control, and similar area-wide programs. Chemical
pesticides include insecticides, fungicides, nematicides,
herbicides, rodenticides, defoliants, desiccants, plant
growth regulators and similar biologically active com-
pounds. Depending on dosage many pesticides are toxic
to humans, animals and other non-target organisms.
Some environmental aspects of some specific pesti-
cides have been studied, but no overall quantitative
description and assessment of the pesticide pollution
problem has been made. In compliance with Section 5
(1)(2) of Public Law 91-224, however, the Water Quality
Office of the Environmental Protection Agency has or-
ganized and conducted a series of pesticide studies which
are intended to provide a comprehensive analysis of the
pesticide problem in the United States.
This particular case study conducted by Ryckman,
Edgerley, Tomlinson and Associates, Inc. (RETA) with
ii
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Dr. R. von Rumker as Sub-contractor and Project Consultant
is concerned with pesticide use on non-irrigated crop-
land, such as those in the midwestern United States. Pes-
ticides are used in this area extensively for weed and
insect control. In such lands, most of the area is sub-
ject to run-off and erosion which is seasonal. Generally,
the pesticides used in this region attach themselves to
organic matter and soil particles which, in turn, are
carried off into rivers and streams by erosion. Thus,
this region exhibits characteristic problems in pesti-
cide application techniques and run-off losses.
Using all available information, this study pro-
vides an in-depth evaluation of the impact on the natural
environment of pesticides used for control of specific
pests in the midwestern states of Illinois, Iowa, Kansas,
Minnesota, and Missouri.
ill
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TABLE OF CONTENTS
Page No.
Title Page .f
Foreword -}-1
Table of Contents ^Y
List of Tables V1*
List of Figures .x:}-
Participating Staff xiiz
Special Acknoxvledgements X1V
T J. A *-' XV
Introduction
STUDY - SUMMARY REPORT
APPENDIX B - INVENTORY OF PESTICIDE USES 1-B
Selection of Study Area 1-B
Description of the Five State Area 3-B
Pesticide Use in the Five State Area 5-B
Pest Problems in Relation to Pesticide
Use 16-B
Summary and Conclusions 21-B
Recommendations 23-B
Literature References 25-B
APPENDIX C - EFFECT OF APPLICATION TECHNIQUES 1-C
Introduction 1-C
Application Techniques 1-C
Reduction of Loss 5-C
Application Equipment 7-C
The Applicators 10-C
Recommended Treatment 14-C
Summary and Conclusions 21-C
Recommendations 23-C
Literature References 26-C
APPENDIX D - ROUTE OF PESTICIDES INTO WATER
ENVIRONMENT 1-D
Introduction 1-D
Soil Types 1-D
^-Transport Routes 5-D
Soil Transport 6-D
Quantity of Pesticides in the Environment 17-D
Other Transport Routes 18-D
Intensive Case Study Area 27-D
Methods of Disposal of Pesticide
Container and Excess Pesticides 36-D
IV
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Page No.
APPENDIX D (continued)
Monitoring Data 40-D
Summary and Conclusions 46-D
Recommendations 48-D
Literature References 51-D
APPENDIX E - IMPACT ON THE AQUATIC ENVIRONMENT 1-E
Introduction 1-E
The Aquatic Ecosystem 3-E
Evidence of Pesticide Accumulation 11-E
Pesticide Entry in Trophic Levels 25-E
Benthic Forms, Zooplankton and Fishes 27-E
Fishes . 37-E
vPesticide Degradation 43-E
Validation of Prediction of Harm 46-E
Differential Levels of Pesticide Stores 46-E
Terata 49-E
Behavioral Responses to Pesticides 52-E
Resistance to Pesticides 54-E
Testing with Living Organisms 59-E
Standard Test Water 60-E
Incidence of Injury 71-E
Farm Injury - Human 72-E
Illinois 77-E
Iowa 84-E
Kansas 86-E
Minnesota 86-E
Missouri 91-E
Farm Injury - Livestock 98-E
Iowa Community Pesticide Study 99-E
Aquatic Ecosystems 100-E
Summary and Conclusions 109-E
Recommendations 126-E
Literature References
129-E
APPENDIX F - DEGRADATION OF PESTICIDES IN
THE ENVIRONMENT 1-F
State of the Art 1-F
Aldrin 7-F
Atrazine 12-F
Summary and Conclusions 17-F
Recommendations 24-F
Literature References 26-F
APPENDIX G - ALTERNATIVES TO CHEMICAL CONTROL
OF WEEDS AND INSECTS 1-G
Weeds 1-G
Alternatives to Chemical Weed Control 3-G
Insects 6-G
v
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Page No,
APPENDIX G (continued)
Alternatives to Chemical Insect Control 8-G
Diseases 16-G
Summary and Conclusions 17-G
Recommendations 21-G
Literature References 22-G
APPENDIX H - REGULATIONS AND LAWS 1-H
Introduction 1-H
Federal Organization for Pesticide Control 2-H
State Control Programs 6-H
New Federal Legislation 20-H
Impact of the Pending Legislation 22-H
Testing and Registration of New Pesticides 39-H
State Laws 41-H
Illinois 41-H
Iowa 49-H
Kansas 56-H
Minnesota 68-H
Missouri 82-H
Effects of Laws on Environmental Quality 83-H
Identity of Favorable Types of Laws 112-H
Important Litigation 115-H
Summary and Conclusions 122-H
Recommendations 130-H
vi
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LIST OF TABLES
1
2
3
4
5
6
7
8
APPENDIX B
1-B
2-B
3-B
4-B
5-B
6-B
7-B
Title Page No.
Land Use and Major Field Crops 2
Grown in the 5-State Area
Estimated Quantities of Major 3
Pesticides Used in the 5-
State Area on Corn, Soybeans
and Small Grains
Pesticide Transport Routes 12
Pesticide Solubility 13
Selected Sediment Measurements
in the Five-State Study Area 13
Average Soil Pesticide Values 14
Disposal Methods 18
Comparison of Factors Affecting 36
the Degradation of Aldrin,
Dieldrin, and Atrazine
Land Use and Major Field Crops 4-B
Grown in the 5-State Area
Estimated Use of Herbicides and 6-B
Insecticides on Corn in the
5-State Area
Estimated Use of Herbicides and 7-B
Insecticides on Soybeans in
the 5-State Area
Estimated Use of Herbicides and 8-B
Insecticides on Small Grains
in the 5-State Area
Estimated Number of Acres Treated 9-B
By State, Type of Treatment,
Major Products, and Total
Quantities, 1971
Estimated Number of Acres Treated 10-B
By State, Major Products, and
Total Quantities, 1971
Estimated Number of Acres Treated 11-B
By State, Major Products and
Total Quantities, 1971
vii
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NO.
8-B
9-B
APPENDIX C
1-C
2-C
3-C
4-C
5-C
6-C
APPENDIX D
1-D
2-D
3-D
4-D
5-D
6-D
7-D
8-D
Title Page No.
Estimated Number of Acres Treated 12-B
By State, Type of Treatment,
Major Products, and Total
Quantities, 1971
Estimated Quantities of Major 13-B
Pesticides Used in the 5-
State Area on Corn, Soybeans
and Small Grains
Practices Utilized by Farmers to 6-C
Erosional Loses From Agricul-
tural Land
Incidence of Pesticide Drift as 8-C
Reported by County Agents
Problems Encountered with Cali- 9-C
bration of Equipment Used to
Apply Pesticides
Proportion of Farmers Who Apply 11-C
Their Own Pesticides
County Agricultural Agents Asses- 13-C
ment of Commercial Applicator
Ability and Training
Agricultural Agents Assessment 20-C
of Recommended Amount of
Pesticide Used and Residue
Calculations
Important Pesticide Transport 5-D
Routes
Water Solubility of Selected 6-D
Pesticides
Selected Sediment Measurements 8-D
in Five-State Study Area
Average Soil Pesticide Values 15-D
Methods of Disposal of Pesticide 38-D
Containers
Manufacturers Instructions on the 39-D
Pesticide Package as Assessed
by County Agricultural Agents
Typical Monitoring Data From 44-D
STORET System - Lower Missouri
River
Typical Monitoring Data From 45-D
STORET System - Mississippi
Mainstem - Most Recent Data
viii
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No. Title Page No.
APPENDIX E
1-E Levels of Dieldrin for Water,
Sediment and Periphyton,
Mississippi River - 1971 14-E
2-E Concentration of Dieldrin in
Periphyton, Mississippi
River, 13 May 1971 17-E
3-E DDT and Residues in Pacific
Coast Ecosystems 21-E
4-E DDT Residues in Carmans River
Estuary 22-E
5-E DDT Residues in Atlantic Marine
Fishes and Invertebrates,
Canadian Location. 24-E
6-E Biological Magnification of
14C-Labeled p,p'-DDT and
Aldrin by Freshwater
Invertebrates 28-E
7-E Estimated LC-50 Values of
Various Insecticides 35-E
8-E Comparative Toxicities of
Insecticides 36-E
9-E The Mean TL-50 and Coefficient
of Variability of p,p'-DDT
for fish and aquatic
invertebrates 38-E
10-E Dieldrin and DDT Residues in
Whole Fish 47-E
ll-E Affect of Age on DDT Residues 48-E
12-E Alterations in LC-50 in Natural
Fish Population Due to
Pesticide Resistance 55-E
13-E Alterations in Chromosome
Frequency in Fruit Fly,
California 57-E
14-E Comparison between Dieldrin
and DDT TLm for Four Species
of Salmonids 64-E
15-E Response of Farmers to Incidents
of Injury Resulting from
Farm Use of Pesticides 76-E
16-E Status of Reporting of Human
Injury Resulting from
Pesticide Use by States 78-E
17-E State Officials Contacted in
Five State Study Area 79-E
18-E Response of Outstate Medical
Doctors to Survey of Pesticide
Related Injury to Humans,
1970-71 93-E
ix
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NO.
Title
Page No,
APPENDIX E (continued)
19-E
20-E
21-E
22-E
APPENDIX F
1-F
APPENDIX G
1-G
2-G
Reported Poisoning Incidences
for the Five State Area 94-E
Illinois Poison Control Center Data 95-E
Location of Poisoning Incidences,
Five State Area 101-E
Fish Kills Due to Various Forms
of Pollution in Five Study
States (1961-1970) 104-E
Comparison of Factors Affecting 19-F
the Degradation of Aldrin,
Dieldrin and Atrazine
Summary of Major Weeds Affecting 2-G
Field Crops in the 5 State Area
Summary of Major Insects Affecting 7-G
Field Crops
APPENDIX H
1-H
2-H
3-H
Synopsis of Congressional Tally on
H.R. 10729, November 9, 1971
Consideration of "Federal Environ-
mental Pesticide Control Act
of 1971"
42-H
43-H
Litigation Involving Pesticides in 116-H
Illinois, Iowa, Kansas, Minne-
sota, and Missouri, 1956-1971
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LIST OF FIGURES
NO.
APPENDIX D
1-D
2-D
3-D
4-D
5-D
6-D
7-D
8-D
9-D
10-D
11-D
12-D
13-D
14-D
15-D
16-D
APPENDIX E
1-E
2-E
Title Page No,
Major Soils in Five State Study 3-D
Area
Concentrations of Aldrin/Dieldrin 9-D
Found in Iowa Soils
Concentrations of Chlordane/AtrazinelO-D
Atrazine Found in Iowa Soils
Concentrations of Aldrin/Dieldrin 11-D
Found in Missouri Soils
Concentrations of Chlordane/ 12-D
Atrazine Found in Missouri
Soils
Concentrations of Chlordane/ 13-D
Atrazine Found in Illinois
Soils
Concentrations of Aldrin/Dieldrin 14-D
Found in Illinois Soils
Time of Application of Pesticides 19-D
Measured Persistence of Pesticides 23-D
in River Water, Organochlorine
Compounds
Measured Persistence of Pesticides 24-D
in River Water, Organophos-
phous Compounds
Measured Persistence of Pesticides 25-D
in River Water, Carbamate
Compounds
Measured Persistence of Pesticides 26-D
in River Water, Comparison of
Types
Potential Sources of Pesticide 30-D
Residues in Iowa Waterways
Farm No. I 32-D
Farm No. II 33-D
STORET Data Point Locations 43-D
Comparison of Concentrations
of DDT and Dieldrin (HEOD)
in Two Different Fish
Concentration of Organochlorine
Compounds in Shags' Eggs at
Different Times. O, pp'-DDE;
0, HEOD
6-E
7-E
xi
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No. Title Page No.
APPENDIX E (continued)
3-E Fate of Chlorinated Hydrocarbons 9-E
in the Five State Study Area
4-E Map of Sample Locations, Water, 15-E
Sediment, Periphyton
5-E Location and Concentration of 19-E
DDT and Residues Along
California Coast and in Sand
Crab
6-E Kansas Pesticide Alert System - 87-E
Press Release
7-E Kansas Pesticide Alert System - 88-E
Memorandum
8-E Pesticide Alert Bulletin No. 1 89-E
xii
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PARTICIPATING STAFF
The following list includes key professional per-
sonnel whose efforts have contributed directly to the
study of the fate and effect of pesticides used on non-
irrigated croplands.
Project Principal
D. W. Ryckman, Sc.D., P. E., President
Project Manager
G. M. Barsom, Sc.D., Assistant Vice President
Project Coordinator
R. M. Matter, Ph.D., Associate
Sub-Contractor and Project Consultant
Rosmarie von Rumker, Sc.D.
Project Staff
D. P. Clement, Environmental Engineer
E. Edgerley, Jr., Ph.D., Senior Vice President
H. D. Tomlinson, Ph.D., P.E., Senior Vice President
F. K. Erickson, P.E., Director of Environmental Affairs
Donald B.' McDonald, Ph.D., Consultant
K. W. Axetell, Jr., P.E., Senior Associate
J. W. Irvin, Sc.D., Senior Associate
P. D. Kilburn, Ph.D., Consultant
O. C. Tirella, Director of Finance and Administration
C. J. Pace, Technical Writer
G. K. Lowder, Technical Writer
M. E. Wiese, Manager, Technical Services
M. R. Aron, Technical Writer
P. A. Braden, Senior Typist
xiii
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SPECIAL ACKNOWLEDGEMENTS
The report which follows is the product of six
months of intensive, in-depth research and analyses.
The scope of the study necessitated that the Contractor
call upon a large number of people and organizations
to provide information essential to a comprehensive
evaluation of the fate and effect of pesticides used
on non-irrigated croplands.
Gratitude is extended to the nearly 10,000 farmers,
county agents, university extension services, manu-
facturers, retailers, commercial applicators, doctors,
veterinarians, public officials and congressional leaders
who were contacted in the five study states of Illinois,
Iowa, Kansas, Minnesota and Missouri. While the names
of these contributors are too numerous to list individu-
ally, the assistance and cooperation of these citizens
was essential to the successful completion of this
project.
xiv
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INTRODUCTION
This study on the fate and effect of pesticides on
non-irrigated croplands undertaken by Ryckman, Edgerley,
Tomlinson and Associates, Inc. (RETA) had the following
objectives:
1. to analyze, describe and document quantita-
tively the use of pesticides on key mid-
western crops including corn, soybeans, and
wheat;
2. to evaluate in depth the direct and indirect
impact on the water environment resulting
from these pesticide uses;
3. to pinpoint areas of actual or potential
environmental damage;
4. to provide a basis for systematic correction of
such damage to the water environment;
5. to describe applicable local and state laws,
and evaluate their effectiveness in prevent-
ing environmental damage.
The report is organized to include a summary state-
ment as well as appendix material which provides docu-
mentation to support and verify the statements made in
the summary. The quantitative information encompassed in
Appendices B through H is outlined as follows.
xv
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Appendix B, Inventory of Pesticide Uses, includes
an inventory and description of pesticide uses in the
study area, including types and quantities of major pes-
ticides and the pests toward which they are directed,
and a discussion of the historical development of pesti-
cide use within the area.
Appendix C, Effect of_ Application Techniques, in-
cludes a discussion of techniques of pesticide applica-
tion for the major types of pesticides, with particular
emphasis on how these techniques tend to either
maximize or minimize run-off problems. Of particular
concern in this discussion are techniques which involve
the broadcasting of pesticides.
Appendix D, Route of Pesticides Into Water Environ-
ment, includes a discussion of the various means by which
pesticides move from their original point of application
into the aquatic environment. Analyses encompass a
discussion of soils and soil types and effects of ero-
sion and sedimentation in the area; the importance of
irrigation return flows, overload drainage, transport
through atmospheric processes, intentional dumping,
accidental spills, sediment transport and the disposal
of empty pesticide containers.
xvi
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Appendix E, Impact of Pesticide Pollution on the
Water Environment, provides quantitative documentation of
both short-term and long-term detrimental effects asso-
ciated with the use of one or more specific pesticides
used in the study area. Analysis includes the movement
of pesticides in the aquatic food chain, pesticide damage
to typical biota of the area, the interrelationship of
the pesticides discussed, and health hazards to human
beings.
Appendix F, Degradation of Pesticides in the Environ-
ment, includes analysis of the processes of degradation
of specific pesticides in relation to involved water
courses, and the toxicity of metabolites and other
break down products in term? of the biota of the study
area. The quantitative documentation of the persistence
of pesticides in the waterways is also included.
Appendix G, Alternatives to Chemical Control of_
Weeds and Insects, provides an identification and analysis
of feasible methods of pest control alternative to the
use of pesticides and suitable to the particular study
area. Where no alternative can be provided, an identi-
fication and analysis of those pesticide uses considered
essential is included.
Appendix H, Regulations and Laws, includes a dis^-
cussion of applicable local laws and regulations govern-
ing the use and sale of pesticides. Their effects on
xvii
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preventing environmental damage have been assessed and
an indication given of the types of laws and regulations
which could provide adequate environmental protection
in this particular geographical area. A discussion of
important past legal decisions concerning pesticides in
the study area is also included.
xvi 11
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SUMMARY
Corn, soybeans, wheat, oats and sorghum are major
ir.idwestern farm crops. Corn, soybeans and wheat account
for more than 50 percent of total farm use of herbicides
in the United States. In addition, corn alone accounts
for about 17 percent of total U- S. farm use of insecti-
cides. No major quantities of insecticides are*used on
soybeans or small grains in the midwestern states.
There are no distinct major uses of fungicides or other
pesticides on midwestern farm crops. We compared the
foregoing breakdown of pesticide uses by crops against
a breakdown of the acreage of these crops by states and
decided to focus this study geographically on the states
of Minnesota, Iowa, Illinois, Missouri and Kansas.
Table 1 summarizes for these five states the major
crops grown, total crop acreage and total land area.
The totals for each crop are compared to the U. S. total.
The five states comprise 9.7 percent of the total U. S.
land area, but 26 percent of the total U. S. crop acre-
age. There are about 88 million acres of farm crops
(including hay) grown in these five states. Corn, soy-
beans, small grains and sorghum combined account for
about 73 million acres, or 83 percent of total farm
crop acreage in the five states. Forty percent of the
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INVENTORY OF PESTICIDE USES
Corn, soybeans, wheat, oats and sorghum are major
midwestern farm crops. Corn, soybeans and wheat account
for more than 50 percent of total farm use of herbicides
in the United States. In addition, corn alone accounts
for about 17 percent of total U. S. farm use of insecti-
cides. No major quantities of insecticides are,used on
soybeans or small grains in the midwestern states.
There are no distinct major uses of fungicides or other
pesticides on midwestern farm crops. We compared the
foregoing breakdown of pesticide uses by crops against
a breakdown of the acreage of these crops by states and
decided to focus this study geographically on the states
of Minnesota, Iowa, Illinois, Missouri and Kansas.
Table 1 summarizes for these five states the major
crops grown, total crop acreage and total land area.
The totals for each crop are compared to the U. S. total.
The five states comprise 9.7 percent of the total U. S.
land area, but 26 percent of the total U. S. crop acre-
age. There are about 88 million acres of farm crops
(including hay) grown in these five states. Corn, soy-
beans, small grains and sorghum combined account for
about 73 million acres, or 83 percent of total farm
crop acreage in the five states. Forty percent of the
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LAND CSE AND MAJOR FIELD CROPS CROWN IN THE 5-STATE AREA
(In 000 Acrci)
State
Minnesota
Iowa
lUinoio
Missouri
Kansas
5 States
U.S.
5 States/
U.S.
5.28S
10.072
10,379
1,114
1,637
30,487
67,171
45*
3,129
5,369
6,665
3,557
1,005
19,945
43,332
46»
830
negl ,
993
1,059
9,001
11,943
47,000
251
3,354
1,817
612
312
250
6,345
24,312
26k
,negl.
negl .
negl .
298
4,277
4,575
17,292
261
3,231
2,496
1,260
3,008
2,384
12.379
63,234
20%
I '
1,671
negl,
303
negl .
494
2,464
77,65!)
n
Acreage
17,500
19,931
20,412
11,400
19,108
88,351
340,000
26%
Area
50,745
35,868
35,761
44,190
52,516
219,030
!, 266, 273
9.7
% of Total
Land Area
34
56
57
26
36
40
15
Notei Data in this tabulation originate from aevoral different sources
12E), and tome item* are not expressed numerically, ror those reason* BOD« column* do not bal*nce
arithmetically.
total land area in the five states is used for farm
crops, while the national average is only 15 percent.
Thus, this five state region is intensively
farmed. A high percentage of its total land area is
devoted to the growing of crops. Five field crops
dominate the scene.
Table 2 summarizes the estimated quantities of
major pesticides used in the five state area on corn/
soybeans and small grains in 1971. These data were
obtained by drawing on a considerable number of dif-
ferent sources of information. The states of Minne-
sota and Illinois collect and publish annually statis-
tical data on the numbers of acres treated with speci-
fic pesticides, but they do not report total quantities
of pesticides used. The states of Iowa, Missouri and
Kansas do not collect or publish similar state-wide
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TABLE &
ESTIMATED QUANTITIES OP MAJOR PESTICIDES USED IN THE 5-STATE AREA ON
CORN, SOYBEANS AND SMALL GRAINS
Herbicides .-
Insecticides:
Pesticide
atrazine
propachlor
amiben
alachlor
2,4-D - type
trifluralin
aldrin
Bux
heptachlor
phorate
toxaphene
carbaryl
diazinon
DDT
parathion
Crop
corn
corn
soybeans
soybeans 7,100)
corn 4,350)
corn 3,825)
small grains 3,200)
soybeans
corn
corn
corn
corn
corn
corn
corn
corn
corn
MM Ibs of
Active . Ingredient
30,000
18,700
13,600
11,450
7,025
3,970
11,000
2,800
2,660
2,364
2,000
1,200
662
200
80
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statistics. Pesticide use estimates for these states
were made by personal consultations with state exten-
sion personnel and other specialists in each state,
supplemented by the results of a field survey of pes-
ticide retailers, county agents and individual farmers.
State extension service recommendations for pesticide
use and manufacturers' label recommendations were also
consulted.
Of the approximately 30 million acres of corn
grown in the area, about 22 million acres (73 percent)
received herbicide treatments. Atrazine is the pre-
-------
dominant herbicide; we estimate that 30 million pounds
of this chemical were used in the region in 1971. Pro-
pachlor was the next most important product with almost
19 million pounds estimated use.
Of the almost 20 million acres of soybeans grown,
about 14 million acres (70.5 percent) received herbi-
cide treatments. In descending order of total quanti-
ties used, amiben, alachlor and trifluralin were the
soybean herbicides of choice.
Small grains accounted for only relatively small
quantities of herbicides used, primarily phenoxy (2,
4-D)-type products.
Control of corn insects is by far the most import-
ant insecticide use in this area. Approximately 16
million acres, that is 52 percent of all corn acres
in the five states, received insecticide treatments.
Aldrin was used in far greater quantities than any
other insecticide. Soybeans and small grains did not
receive insecticide treatments which would have to
be classified as "significant" within the context of
this survey.
The use of chlorinated hydrocarbon insecticides
in this area has declined, but is still rather sub-
stantial. Organic phosphate and carbamate insecti-
-------
cides are expected to increase in use.
The data presented in this report, once published,
will be the first detailed compilation of the esti-
mated quantities of major pesticides used in this re-
gion.
EFFECTS OF PESTICIDE APPLICATION TECHNIQUES
In this section is presented a discussion of tech-
niques of pesticide application for the major types of
pesticides, with particular emphasis being placed on
how these techniques tend to either maximize or mini-
mize runoff problems.
Pesticide Applicators, Individual v. Commercial
Pesticide contamination of the environment can be
minimized by better application techniques and by a
better understanding of the problems and dangers of
pesticides. The farmer may apply pesticides himself
or he may hire a commercial applicator to do the job
for him. Both groups could benefit'from instruction.
The contractor's survey indicates that about three-
fourths of the farmers apply their own herbicides, and
about half apply their own insecticides.
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The contractor asked county agents of their evalua-
tion of custom applicators. Agents responding in the
five-state study area gave some interesting responses:
(1) Slightly more insecticides than herbicides are
commercially applied; (2) "...I know he [the applicator]
has had training ... but he doesn't act like it;" (3) Most
agents have had training and are licensed but their staff
who do the work often lack sufficient training; (4) mini-
mum training and performance standards should be adopted
for custom applicators and farmers who apply their own
pesticides.
Pesticide Treatment Dosage Rates
Most county agents from Illinois, Iowa, Minnesota,
and Missouri feel that farmers do use the recommended
amounts of pesticides. Cost is the deciding factor.
Relatively more agents from Kansas feel recommendations
may not be followed. Pesticide residues may remain on
a field over a year, but few farmers take this fact in-
to consideration when calculating the amount of pesti-
cide to apply. For example, professional agricultura-
lists have estimated a 25 percent dieldrin residue from
year to year. The agents in Illinois, Iowa, Kansas and
Missouri point out that no one has given the farmer a
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method to make this evaluation. The farmer is not at
fault here; he simply lacks one of the tools to make his
operation more economical.
It is sufficient to add that any consideration of
existing residue levels and the addition of these levels
to any current crop years pesticide use anticipated
could amount to a considerably savings to the environ-
ment and especially the aquatic ecosystem.
The farmer applies or has applied pesticides as an
insurance policy on his crops. Whole crops are treated
when perhaps 10 percent of the acreage really needs the
benefits of the chemical. The manufacturers of pesti-
cides promote these operations with lavish advertising
and skilled salesmen in the area.
Farmers could learn to use less pesticide and to
apply them selectively but the present system of sales
and application equipment all team up to fight such an
approach.
Application Techniques
Most pesticides come in one or more of four forms:
(1) liquid, (2) wettable powder, (3) powder, (4) granu-
lar pellets. Liquids and wettable powders are mixed
with water or oil, then applied with a sprayer. Granular
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pellets are applied directly to the soil. Powdered pes-
ticide is mixed with the soil for direct application.
Pesticides are applied during one of three periods:
(1) before planting; (2) before the plant emerges; or
(3) after it has broken the ground. Application is usu-
ally made on an entire field of planting. Farmers have
the choice of: (1) "broadcasting" pesticide over the
entire field, or (2) "banding" it along narrow rows where
the crop is planted. Banding is a means of reducing the
amount of pesticide used. Typically, only seven inches
out of 30 inches are treated. Both the banded and the
broadcast materials may be left on the surface or incor-
porated into the top few inches of the soil. Incorpora-
tion provides a means of isolation from direct exposure
to the weather and thus helps minimize potential loss
and potential damage to the environment.
A group of farm journals (1) surveyed their readers
to find the methods of application which farmers prefer.
Seventy percent of the farmers broadcast herbicides on
corn. Although the survey showed that an average of
77 percent of the farmers band their corn insecticides,
in three of the five study states, the contractor's
survey indicated 90 percent of the farmers follow this
practice. These data substantiate the prevalance of
banding pesticides.
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Banding versus broadcasting does not per se affect
environmental contamination, rather the auxiliary mat-
ters of form the material takes, burial or exposure,
pressure, distance to ground, and temperature of a spray
effect the application efficiency and thus the amount
lost to the environment.
Spraying can be modified to release the spray at
or below ground level and thus reduce drift greatly.
Spraying on a cool day with low wind will help also.
The greatest reduction in application loss can come in
the form of granular application instead of liquid
application.
Applying the correct amount of pesticide to the
soil is important. Any amount greater than the minimum
required can only increase the possible damage to the
environment. The contractor asked 331 farmers in the
five-state study area how their application equipment
works in terms of calibration of rates.
Based upon these results, the contractor believes
closer inspection of the problems encountered with
calibration of equipment is warranted. Agents and
retailers indicated that this problem comes up every
crop season. The farmers themselves feel they have few
problems with calibration. However the number of farmers
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indicating occasional calibration problems suggests
that there is a continual minor problem with equipment.
Many of the farmers contacted had ingeniously modified
their equipment to implement application. It would appear
that manufacturers and agricultural engineers could con-
tribute by attempting to fit more uniform granular formu-
lations to better engineered application equipment.
Reduction of Pesticide Loss Following Application
There are several methods which a farmer can use to
reduce run-off from his land and the concurrent loss of
pesticides. One of the easiest ways is to apply granu-
lar pesticides and cover them as soon as they are applied.
Banding of pesticides reduces pesticide run-off by
reducing the area to which the material is applied, but
is difficult to do once the crop has emerged. Research
into ways of efficiently combining banding with culti-
vating could solve this problem.
By reducing run-off itself through minimum tillage,
and terracing of grass in natural waterways in the field
instead of cultivating the waterways, run-off carrying
pesticides can be reduced.
About 87 percent of the farmers contacted by the
contractor do try to reduce erosion by some means.
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However, their efforts are not coordinated nor maxi-
mized. The survey does indicate a knowledge and a
willingness to cooperate.
ROUTE OF PESTICIDES INTO THE WATER ENVIRONMENT
This section includes a discussion of the various
means by which pesticides get from their original point
of application into the aquatic environment. It in-
cludes an analysis of the relative importance of irri-
gation return flows, overland drainage, transport through
atmospheric processes, intentional dumping, and acciden-
tal spills. The transport of pesticides associated with
sediment transport and the disposal of "empty" pesticide
containers is also included. The thrust of this section
is toward laying the groundwork for control of pesticide
pollution through control of the above-mentioned processes
which are responsible for pesticides reaching the water
environment.
Mechanisms and Relative Importance of Pesticide Transport
Routes
Several pesticide transport routes are known to con-
tribute to the presence of pesticides in surface waters.
These routes are summarized and ranked below. A concerted
11
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program to develop effective counter-measures and an
enforceable implementation plan for control of pesticide
pollution through control of the above mentioned processes
must receive a top Federal priority.
TABLE 3
PESTICIDE TRANSPORT ROUTES
RANK*
ROUTE TO THE ENVIRONMENT
RELATIVE
SIGNIFICANCE
3
4
5
6
7
Overland Drainage
•Adsorption & movement
on sediment
•Solubility in water
Atmospheric Processes
•Evaporation during
application
• Evaporation from land
•Drift
Empty Container Disposal
Intentional Dumping
Accidental Spills
Movement in Groundwater
Irrigation Return Flows
Great, dominant
route
Moderate
Great
Moderate
Great (potentially)
Great (potentially)
Great (potentially)
Moderate
(potentially)
Low
Not applicable to
non-irrigated land
*in descending order of importance
Soil and Sediment Transport
The table below shows the water solubility of the
three most widely used pesticides in the study states.
12
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TABLE 4
PESTICIDE SOLUBILITY
Compound Solubility
Aldrin 11 ppb
Dieldrin 110 ppb
Atrazine 33 ppm
These low solubilities indicate that pesticides do not
travel as a water solution, but rather are carried in
suspension as an emulsion or more commonly adsorbed on
soil and sediment particles. The contractor's study has
confirmed that pesticide adsorption on sediment is the
main route of pesticides into the aquatic environment.
Therefore the amount of sediment carried in surface
waters is a critical route of pesticides to the aquatic
environment. The U.S. Geological Survey has reported
the sediment measurements (shown below) in the five-state
study area.
TABLE 5
SELECTED SEDIMENT MEASUREMENTS
IN FIVE-STATE STUDY AREA
' ~~~ Amount of Sedi-
Place River ment (tons/year)
, (6)
Mankato, Minnesota Minnesota 820,211
St. Louis, Missouri Mississippi 118,358,500
Red Oak, Iowa E. Nishnabotna 1,576,799
Chariton, Iowa Chariton River 56,209
Winfield, Kansas Walnut River 1,015,712
Arkansas Arkansas River 1,598,572
Wanego, Kansas Kansas River 1,104,402
13
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The total pesticide load in river sediment can then be
estimated by correlating these sediment loads with
average pesticide concentrations found in river sediment.
Measured sediment values for dieldrin in Iowa ranged
from 1.7 to 35 ppb, with an average of 11.1 ppb. If
this amount of dieldrin was in the sediment load pass-
ing St. Louis, the total annual dieldrin pesticide load
would be 260 pounds.
Many factors may influence the soil's capacity for
pesticides including organic content, pH, colloidal day,
catien exchange capacity, and moisture retention. Usu-
ally organic carbon correlated better with pesticide
levels than any other parameter.
The following table shows average values of aldrin,
dieldrin and atrazine found in Illinois, Missouri and
Iowa, as reported by the U.S. Department of Agriculture
(USDA).
TABLE 6
AVERAGE SOIL PESTICIDE VALUES
State
Illinois
Missouri
Iowa
Compound
Aldrin
Dieldrin
Aldrin
Dieldrin
Aldrin
Dieldrin
Atrazine
Value (ppm)
0.147
0.138
0.133
0.129
0.07
0.107
0.05
14
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Although it is difficult to measure pesticide residues
in soils and they are subject to extreme variability
over even small areas, these USDA figures are still
useful. When these figures are related to measured sedi-
ment carried in the Mississippi at st. Louis, resulting
calculations show that about 10 tons of dieldrin are
annually carried in the Mississippi at St. Louis. Better
measurements and a more comprehensive monitoring program
are needed before more accurate conclusions can be
drawn about the quantity of pesticides in the water envi-
ronment .
The contractor's survey determined that farmers
apply the largest portion of their yearly pesticide
dose when run-off is most likely to occur. The U.S.
Geological Survey (USGS) 30-year river discharge patterns
for three rivers in Iowa was correlated with pesticide
application in these areas. The data show peaks in the
same months farmers apply pesticides. Since high dis-
charge means large run-off from the fields with corres-
ponding high sediment transfer rates, from an environ-
mental standpoint, pesticide application comes at the
worst possible time of the year. This same phenomena
is true in each of the other study states.
15
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Atmospheric Transport Routes
Lloyd Harrold (2) in Ohio has measured loss from
drift of spray-applied dieldrin. He reported a 25 per-
cent loss in material application, although it was into
three inches of soil the day of application.
Generally, drift is a minor problem because of the
short distance involved. However this could be a po-
tentially serious local problem if a water body was
located within drift distance. Improved application
techniques could minimize drift.
Frost and Ware (3) measured drift produced in
aerial spraying as opposed to ground spraying and found
that the former produced four to five times as much
drift as the latter. On the ground one large nozzle pro-
duced less drift than three smaller units while covering
the same area.
Thus spraying from the ground using equipment with
a few large nozzles rather than several small ones
produces less drift.
Lloyd (2) , Caro and Taylor (4) of Ohio also mea-
sured evaporation of dieldrin from farm land and found
that two percent of the dieldrin evaporated during the
year of application. Spencer (5) confirmed these
findings for dieldrin and lindane.
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Pesticide Monitoring Data
Pesticide monitoring presently consists of haphazard,
disorganized data collection. The current program does
not detect pesticides at concentrations greater than a
few parts per trillion, levels which ten years ago were
undetectable by most techniques and levels which have not
been shown to be harmful to man.
A comprehensive data collection system sensitive
to the parameters influencing pesticide movement - run-
off and sediment and weather conditions - must be develop-
ed. The contractor proposes in the recommendations sec-
tion of this report a series of intensive study areas in
small watersheds supplemented by daily measurement of
pesticides from large municipal water treatment plants
on major rivers.
Methods of Disposal of Pesticide Containers and Excess
Pesticides
One of the biggest potential problems associated
with the use of pesticides is the disposal of their con-
tainers. The contractor's survey to determine disposal
methods utilized by farmers is shown below:
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TABLE 7
DISPOSAL METHODS
RANK* DISPOSAL METHOD COMMENT
1 Burn Containers burned with other
trash in open fire
2 Wash & Save Containers rinsed out and
stored or reused
-3 Throw in Trash Containers thrown for pick-
up with other solid waste
4 Bury Farmer buries containers on
his property
5 Discard Farmers throws containers in
ditch or field edge
*in order of frequency of use
All of these disposal practices are potentially dangerous
to the environment. Burning containers is recommended by
most manufacturers but reliable estimates suggest tempera-
tures obtained in open burning, practiced by farmers,
are insufficient to destroy the compound.
A large number of farmers still continue to wash old
containers and use them for general purpose farm pails,
despite specific warnings against such practices.
Disposal of containers in a town dump has similar
drawbacks to burying. Leakage of contaminants and sub-
sequent contamination of ground and surface waters is
a problem.
Burying the containers appears to be the least
18
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harmful of all disposal techniques, if care is taken to
assure that containers are buried where contamination of
ground or surface waters cannot result. However, there
is no procedure to insure effective burying practices.
At the present time there is no effective practical
method of empty pesticide container disposal.
To confirm the lack of practical container disposal
methods, farm agents in the five state area were asked
if they felt manufacturer's application instructions and
instructions for container disposal were understandable
and practical. Most agents felt the application instruc-
tions were understandable and practical to follow for
proper usage. In general, the farm agents felt container
disposal instructions were understandable, but felt
strongly that disposal instructions were impractical for
the average farmer to follow.
IMPACT ON THE AQUATIC ENVIRONMENT
Very little is known about the effects of various
pesticide compounds on the total aquatic environment.
Part of this general inability to properly assess
environmental damage comes from the lack of sufficient
knowledge of the intimate, subtle and extremely complex
functioning of aquatic ecosystems. Sufficient information
is presently at hand to indicate that environmental
19
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damage has occurred, is occurring, and despite what we
do now, will continue to occur for some period of time.
The contractor feels sufficient knowledge is at
hand now to set forth the following summary and
conclusions relating to impact on the aquatic environment,
Persistent pesticide compounds do not disappear
after application. They may remain for variable periods
of time, hopefully fulfilling the task that they were
designed for: the destruction of agricultural pests,
potential disease vectors, and other noxious pests
of all varieties. Concomitant with application and again
for varying periods of time and at differing rates,
these compounds co-distill, vaporize, adsorb on
inorganic and organic particles and are absorbed into
living material where they may be altered chemically,
exert an often unidentified influence over the
living tissue, be stored with no apparent harm, or
eliminated to the environment.
It has been shown that some kinds of pesticide
compounds have been found in almost every kind of
living material when looked for. The key word here
is when, for many of our informational gaps are the
result of simply not having had the time or the money
or the experience to measure all aspects of our global.
biota. It is significant that no ecosystem, terrestrial
20
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or aquatic, has been found free of these compounds no
matter whether it be simple or complex. It is also well
to remember that even the most "simple" ecosystem has,
upon closer inspection, been found to be extremely
complex. It can truthfully be said that we really do
not fully understand the complete biochemical or
molecular nature of even the most "simple" such system.
It is highly unlikely that we ever will.
Implicit in an appreciation of the trophic dynamic
structure of any ecosystem is the concept that, in
addition to energy, other compounds are transferred from
one trophic level to the next. One of the difficulties
in developing a full appreciation for pesticide involve-
ment in trophic structure is that any trophic level
can and does acquire additional qualities completely
independent of any other level. This is accomplished
most commonly by ingestion or absorption from the
surrounding environment.
Thus we find that the primary producer group of
photosynthasizing plants of the aquatic environment
have the ability to accumulate these compounds from the
water. The metabolism and the degree of degradation
accomplished by these plants is poorly understood at
this time. Although not all groups respond in the same
fashion, some exposures have resulted in a reduction of
21
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photosynthetic rate in both marine and fresh water
algae.
Zoo plankton have shown a variety of responses to
pesticide exposure. Species susceptibility within the
same taxonomic group varies from almost no effect to
complete intoxication and death at similar exposure
levels. Although some experiments have been conducted
and many more are either being conducted now or planned
for the future, our knowledge of the response of natural
populations of zoo planktons to environmental levels of
pesticides is quite inadequate. Long term chronic
exposure to sub-lethal "natural" levels as are ibeing
conducted by the Federal Fish Pesticide Laboratories and
independent investigators are vitally needed to identify
effects on longevity, productivity, and intrinsic rates of
natural increase. Such additional information is required
to properly assess the effects of environmental variables,
such as temperature, pH, water hardness, and other water
quality factors, and the synergistic effects of combinations
of other potentially harmful compounds. Prodigeous
quantities of these organics are consumed by higher
trophic levels. The combined production of zoo plankton
must be maintained to support sustained yield of higher
forms. A significant degree of biomagnification is
observed by virtue of the critical quantities consumed
22
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as well as from the environment.
Benthic organisms like some zoo planktons now occupy
different trophic levels depending upon their age and
life style. Vegetarian species are obviously primary
consumers, while omnivores or strictly carnivorous
species may be primary consumers as young or primary or
secondary consumers as adults.
The literature is clear that these forms can
accumulate pesticide loads far in excess of the levels
below them. Considerable species variation as well as
differences between genera and family can be seen relative
to the ability to "withstand" certain levels of pesticides.
At the present time, an insufficient number of different
organisms have been examined carefully enough to identify
the effects of long term sub—lethal exposure. Frequent
examples of virtually complete denudation of streams have
been observed following heavy applications of pesticides.
Repopulation of these diminished areas within a year are
given as evidence of no real harm. Repopulation by this
nominally very mobile group of crustaceans and essentially
aerial insects should not surprise anyone. We do not
know what effects chronic sub-lethal exposure has on rates
of feeding, food conversion, reproductive success or
growth and longevity. Basic experiments which have been
performed suggest that sub-lethal exposure for periods of
23
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up to one or two hundred days are harmful to zoo
planktons and benthic forms in terms of growth and
viability. Higher trophic levels are usually composed of
vertebrate organisms. The smaller members (minnows and
other forage fishes) usually have a relatively short life.
Thus, individually they may not accumulate a tremendous
body burden during their lifetime. Larger organisms
(predaceous and piscivorous fishes) live longer and
consumer many smaller organisms, thus accumulating much
higher burdens in their lifetimes. One of the things that
is so difficult to assess in the aquatic ecosystem is
relative lack of fitness. If organisms from any trophic
level have been weakened or debilitated in any way, they
are far more susceptable to capture, disease, or
parasitic infection. The possible effects of low level
chronic exposure resulting from potentially harmful
pesticides are more easily eaten and thus removed from
our scrutiny.
Larger aquatic vertebrates have generally been
studied longer and have more known about them than the
lower trophic levels. This fact, plus the fact that
they are usually economically more valuable to man, has
resulted in a considerable body of information on
pesticide effects to this group. Admitting that acute
exposure levels are necessary to establish guidelines
24
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for water quality and to protect the stocks of fishes
to some extent, we would nevertheless like to stress the
results-of chronic sub-lethal exposure.
It has been demonstrated that long term sub-lethal
exposure to some chlorinated hydrocarbon compounds does
produce terotogenic effects in a number of valuable
species of fishes. The extreme case is demonstrated by
the loss of entire broods of Atlantic salmon at the time
of hatching, following exposure of the parents. Numerous
examples harm warm water fishes, particularly pond
stocks of channel catfish, show increased levels of
malformed and dead young, resulting from exposed parental
stocks. Transovarian movement of many of these compounds
have been demonstrated for mammals, birds and fishes;
it is assumed to be a vertebrate phenomena varying only
in degree between class and species.
It appears that behavioral abnormalities can result
to fishes from exposure to chlorinated hydrocarbons.
Some of the experiments at very low sub-lethal levels are
only noticed when the most sophisticated electro-
physiological measurements are conducted. The fact that
many lay people do not understand what this kind of
technology means does not detract from the potential for
harm to these organisms. Likewise learning behavior
has been reported as lessened in chronically exposed
25
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fishes. No data is available for other aquatic life.
Endocrinological alteration, especially in pituitary
and adrenal function, have been noted. These effects may
have far reaching effects on the life of individuals
as well as the perpetuation of the species.
Hepatic microsomal enzyme induction has been
recorded for other vertebrates as well as for fishes.
The resulting disturbance of steroid metabolism is well
documented. Evidence has been presented which indicates
that variations in respiratory rate affect the uptake of
certain chlorinated hydrocarbons. We know nothing about
the pharmacodynamics of uptake or diffusion rates as
they relate to variations in water chemistry. Alterations
in protein metabolism have been demonstrated in fishes
and other vertebrates. This may be a reflection of the
hepatic microsomal enzyme response. It may be particularly
important in fishes as a vertebrate group since these
animals seem to be adapted specifically to the metabolism
and elimination of nitrogenous compounds.
Some of the most striking effects to fishes have
been the result of studies which showed no apparent
harm under regimens of chronic sub-lethal exposure.
When starved or when conditions exist that require the
animal to draw on body stores of fat or protein for energy,
the resulting concentration of stored material exerts
26
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its effect: reduced vitality, decreased muscular ability,
disturbed metabolism and death are observed.
Research in metabolism of cold blood organisms have
lagged behind mammalian and bird studies. Little is
known of how fast or to what extent body stores of fat
are mobilized by stressed aquatic organisms. Serious
question is raised as to the suitability of acute and
chronic exposure studies in aquatics as they have been
conducted. Certainly additional research is required
in this area.
Osmoregulation and osmoregulatory ability is more
of a problem with aquatic animals than terrestrial.
It is for this reason that alterations in kidney function
and disturbed osmoregulatory ability under conditions of
chronic exposure to chlorinated hydrocarbons pose such
a threat to this group.
The choice of experimental animals is often dictated
by availability as much as general suitability.
Although mechanisms do exist at the Federal level for
specifying the nature of information to be supplied the
manufacturer for registration of a compound, it is felt
that these criteria are in need of complete revision
and certainly must be expanded to include experiments
and measurements designed to better sense the impact on
the environment. In this connection it is particularly
27
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important that additional non-target species be included.
Those organisms which constitute the decomposer
group (bacteria/ fungi, and other microbes of soil and
water) have been demonstrated to exert a limited effect
on the degradation of persistent pesticides in natural
environments. Under laboratory conditions, groups have
been identified which will degrade to some extent;
often the degradation products are more toxic than the
parent compound. Our total information in this area,
particularly from natural environmental conditions, is
particularly meager.
The literature is clear in the picture it presents
of global contamination of our abiotic and biotic
ecosystems. All trophic levels carry body burdens —
whether the persistent compounds kill outright or
only reduce trophic level efficiency is still open to
question. In any event, it is clear that biomagnification
does occur between successive trophic levels, additional
bioaccumulation can and does occur at each trophic level.
The result is one of sufficient body burdens of these
compounds at the highest levels to cause death, debility,
reduced reproductive success, reduced mental alertness
and a generally disturbed physiology,all tending to
reduce the biological fitness of the animal to meet the
demands of the environment.
28
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Studies with laboratory mammals suggest the
possibility of harm to the human animal. It must be
stated that no adequate demonstration of clinical
manifestation of carcinogenicity, mutagenicity or
terotogenicity has been shown for humans, resulting
from chlorinated hydrocarbon exposures at low levels
commonly encountered in the environment.
Acute toxicity has been demonstrated with some
compounds at high levels and should not be surprising
in view of their poisonous nature.
There is mounting evidence of past careless use of
organo-phosphate compounds. Clearly industry and all
segments of agriculture and agribusiness must dedicate
themselves to better education of the users of these
chemicals. Additional research is urgently needed to
make use and particularly application safer for the
general user.
Farm Injury - Human
County agents, farmers and doctors in the five study
states were surveyed to determine the extent of possible
harm to farmer/applicators from the handling of pesticides.
About twenty-five per cent reported knowledge of particular
incidences of pesticide-exposure-related illness within
the past year. Twenty-five per cent of the doctors
responding indicated they had treated patients for
29
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pesticide-related symptoms. Of these, 65 per cent were
from organo-phosphate poisoning.
The greatest causes of illness were: (1) spray
drifting back on the operator; and (2) contact with
pesticide due to mechanical breakdown of the equipment.
Phorate and disulfoton fumes were most often singled out
as being responsible for operator illness. In all cases
reported by County agents, operator carelessness was
blamed as primarily responsible for the exposure to
pesticide. In many cases agents indicated they had
cautioned farmers to use protective clothing, but the
warning went unheeded. These results confirm earlier
reported findings that most accidential exposures are
the result of improper application or obvious disregard
of adequate safety measures. Containers and label
directions, although superficially adequate, do not
draw sufficient attention to the dangers or are not
practical for the farmer to follow. This situation,
compounded by the applicators' reluctance to utilize
safety clothing, plastic gloves, respirators, etc.
create a potentially hazardous medical situation.
The contractor contacted state health officers or
offices and/or state officers in charge of poison
control centers, state pesticide officers, vector
control authorities, state veterinarians, bureaus of
30
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hazardous substances and similar agencies in each of
the five states. Representatives of these agencies were
asked: (1) Are there pesticide-related illness not
being reported? (2) Are doctors reporting pesticide-
related illness to health agencies? and (3) What kinds
of damage to wildlife and livestock go unreported?
Illinois
There is a lack of machinery and enforcement for
reporting pesticide-related illness. No systematic
procedure exists for reporting this kind of injury,
however, the educational material and short courses
conducted through the University of Illinois,along with
an aggressive program of farmer education,appears to be
quite good.
Iowa
Dr- Keith Long of the Institute for Agricultural
Medicine conducted a postcard survey of farmers. Of
the 1100 replies, 900 reported treatment for pesticide
exposure of some kind. For the same time period, poison
control centers and hazardous substance centers in the
State of Iowa reported only 37 cases. These results
indicate the entire problem of injuries from pesticide
use is far greater in magnitude than previously
anticipated.
31
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Kansas
All contacts from state offices indicated there
were no records system other than the Poison Control
Center. Kansas has initiated the Kansas State Pesticide
Alert System to provide a workable early warning system
for those concerned with pesticide use.
Minnesota
A study of commercial/aerial applicators completed
in the summer of 1971 indicated that although these men
are not fully aware of the potential harm from the use
of insecticides, ground crewmen hired to assist
applicators have the greatest possibility of harm.
However, good insecticide sprayers, because of a lack
of rigorous enforcement from the State Department of
Agriculture, are subject to greater harm than aerial
sprayers.
Missouri
At present, Missouri has no mechanism for reporting
or recording incidences resulting from pesticide use.
In summary, the five study states have rather poor
systems for identifying the problems of health hazards
from pesticide use. It is significant that none of
the states has a standard reporting system for injury or
32
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illness related to pesticide exposure. The Kansas Alert
System appears to offer the pesticide user: (1) a closer
working relationship between various involved agencies;
(2) prediction of possible hazards to human health;
(3) valuable recommendations on pesticide application
rates; and (4) potential dollar savings to farmers and
decreased hazard to the environment.
Farm Injury - Livestock
Contacts with veterinarians and other state officials
by the contractor has indicated there is no adequate
system for reporting or caring for farm animals exposed
to pesticides. In many cases, field diagnosis is
inaccurate and after death of the animal, measurements
are usually not made. The general philosophy seems to
be that "a dead cow is a dead cow — who is going to
pay for an autopsy."
Damage to the Aquatic Ecosystems
Adequate reporting and recording of local incidences
of pesticide "damage" to the waterways does not exist
in the five state study area. Although dead fish and
invertebrates are observed, they are seldom reported.
This attitude is borne out by Federal reports of fish
kills which are filed only when the incident is
sufficiently great.
33
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County farm agents were surveyed to assess the
extent of possible pesticide damage to farm water supplies,
Not surprisingly, a very small number of incidences were
reported. State conservation officials contacted
declined to cite figures but all indicated that the
County Agent reports were far too low.
Reports to the EPA for the period of 1960-1970 do
not cite pesticides as a major contributor to fresh
water fish kills. Pesticides are responsible for less
than 10 per cent of the total losses (except in Minnesota,
where the total number of animals is rather small), while
feedlot and fertilizer damage may run up to 50 per cent
of the total. In Missouri, mining practices account for
up to 50 per cent of the total fish kill reported.
Despite improvements in the reporting system, it is
doubtful if it will be adequate to effectively monitor
pesticide damage to public waters.
DEGRADATION OF PESTICIDES IN THE ENVIRONMENT
In line with the increasing concern about pesti-
cides and their possible impact on the environment,
a number of recent conferences, panelrs and committees
have addressed themselves to this problem. A large
volume of literature on this subject has been exhaus-
34
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tively reviewed, abstracted and commented upon in the
recent past. It is the general consensus of these
comprehensive studies and reviews that present pesti-
cide use patterns do not adversely affect human health
directly, but that they cause adverse effects on cer-
tain species of wildlife, and further actual or po-
tential environmental harm whose nature and extent may
escape our present capabilities of detection and/or
foresight. Many scientists working in this area are
increasingly concerned about possible long-term low-
level environmental effects.
Based on their volume of use on midwestern farm
crops and on their physical, chemical and biological
properties, we selected the insecticide aldrin and the
herbicide atrazine for a more extensive review of in-
formation on their degradation in the environment.
Table 8 presents a summary and comparison, prob-
ably over-simplified, of the factors affecting the
degradation of aldrin, dieldrin (the principal meta-
bolite of aldrin) and atrazine. There are important dif-
ferences in the physical and chemical properties of
these compounds which in turn influence their persist-
ence, degradation and propensity for environmental
damage.
Among pathways of "disappearance" from the site
35
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TABLE 8
COMPARISON OF FACTORS AFFECTING THE DEGRADATION OF
ALDRIN, DIELDRIN AND ATRAZINE
Factor
Volatiliza-
tion
Metabolism
-major meta-j
bolite(s)
Leaching
Surface run-
off
-in water
-on. solids
Wind erosion
Hicrobial
degradation
-aerobic
-anaerobic
Non-biological
degradation
Av. Half-life
in soil
Vapor pressure
Lipid solu-
bility
Water solu-
bility
Stability to
hydrolysis
-alkaline
-acid
Aldrin
substantial
epoxidation
dieldrin
(15-30%)
No
negligible
may be sub-
stantial
possible
demonstrated
in the lab,
but not con-
firmed in the
field
Yes
1 year
6xlO~6ranHg
at 25°C
High
0.027 ppri
at 25°C
stable
stable with
dilute acids
Dieldrin
small except
when on sur-
face
not known in
detail
"photo-diel-
drin", diol-
compound
No
negligible
may be sub-
stantial
possible
demonstrated
in the lab,
but not con-
firmed in the
field
Yes
1 year
1.8x10" mmHg
at 25°C
High
0.186 ppm
25°C
stable
stable with
dilute acids
Atrazine
occurs,
probably
not sub-
stantial
not known
in detail
hydroxy-
atrazine
Yes
Yes; may
be sub-
stantial
Yes
possible
but prob-
ably minor
possible
but prob-
ably minor
substan-
tial
1 year
3.0xlO~7mmHg
at 20°C
Low
33 ppm
at 27°C
stable in
neutral
and slight-
ly alka-
line or
acid media
36
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of application, volatilization is one possible escape
route of aldrin. It has the highest vapor pressure of
the three chemicals in this comparison. Volatilization
of atrazine may occur, but it is not believed to be
substantial.
The exact pathways of metabolism and degradation
and the nature of the ultimate breakdown products are
essentially unknown for all three chemicals.
Leaching and surface run-off as a solute in water
are not likely in the case of aldrin and dieldrin,
but may be substantial in the case of atrazine because
of its relatively high water solubility. Adsorption on
solids and consequently, transport by soil erosion or
wind erosion are possible routes of escape for all
three products.
Microbial degradation has been demonstrated in the
laboratory, but not confirmed in the field for aldrin
and dieldrin. It is possible but probably minor in the
case of atrazine.
Non-biological degradation occurs with all three
products, probably to a substantial degree, especially
in the case of atrazine.
Both aldrin and atrazine have been in large-scale
commercial use for many years. Yet, disturbingly little
is known about their fate in the environment after appli-
37
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cation, or about their pathways of metabolism and de-
gradation under field conditions. Information on their
effects on non-target species consists largely of data
on the amounts of chemical lethal to various test or-
ganisms, in the majority of cases obtained under labo-
ratory conditions. There is very little information on
possible interactions between these pesticides and/or
their metabolites with other chemicals. Practically
nothing is known about possible effects of long-term
low-level residues of these pesticides and/or their
metabolites on the environment in general, or on aquatic
ecosystems in particular.
Thus, it is obvious that there are glaring gaps
in our knowledge of the environmental behavior of these
important pesticides. The type of research required"
to fill these gaps will be complex, and it will be suc-
cessful only if it is planned and performed by an inter-
disciplinary approach.
The emphasis must be on studies under actual field
conditions. Every effort should be made to encourage
interdisciplinary teams to engage in comprehensive re-
search on complete ecosystems. Work on isolated or-
ganisms in the laboratory, far removed from field reality,
with which the present literature is filled is of rela-
tively limited value unless its significance in regard
to field conditions can be clearly assessed.
38
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In this connection, it must be recognized that the
more comprehensive, interdisciplinary approach is not
liable to produce material suitable for quick publica-
tion of simple results. The publishing incentive sys-
tems in the academic world may require some adjustments
in this regard.
The examples of the triazine symposium (6) con-
ducted by the University of California at Riverside in
cooperation with the product's manufacturer, as well as
the symposium on "pesticides in the soil" conducted at
Michigan State University through Guyer's (7) initative
demonstrate how useful such work conferences can be in
pulling together all available data and expert opinions
on a complex problem. Prerequisites for success are
selection of a sufficiently narrow and well-defined
subject, good preparation and execution of the con-
ference, and timely publication of the proceedings,
preferably with a good index.
ALTERNATIVES TO CHEMICAL CONTROL OF
WEEDS AND INSECTS
Field crops in the five state area are affected by
a considerable company of weeds, predominantly annual
species. However, perennial weeds are slowly becoming
more prevalent since the annual weeds are so effectively
controlled by chemical herbicides.
39
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There are no specific non-chemical agents such
as "beneficial insects" available for control of any
of the weeds in this region, and no significant work
in this direction appears to be in progress. However,
it is noted that weed control at the farm level does
not rely exclusively on the use of chemicals, but has
always been carried out by the integrated use of many
farming practices such as crop rotation, tillage, selec-
tion of planting date, etc. This system was not aban-
doned when chemical herbicides arrived, but these pro-
ducts were included in it.
One of the elements important to good "integrated
control" practices is information on economic damage
thresholds. Considerable attention has been devoted
to this question by scientists in the area, and their
work has provided useful data on the relationships be-
tween weed infestations and yields of the major field
crops.
By far the most important insect problem in the
five states are corn rootworms and soil insects on
corn. Much effort has been focused on the search for
alternate methods of insect control in general, but
soil insects have not received much attention in this
regard thus far. To the best of our knowledge, there
are no realistic prospects that microbial, hormonal or
40
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other agents for selective control of soil insects will
be available in the foreseeable future.
All three economically important species of the
corn rootworm occur in the five state area. The northern
and western species are highly resistant to chlorinated
hydrocarbon insecticides and increasingly resistant to
some organic phosphate insecticides. Corn rootworms
are most damaging in "continuous corn", i.e., when corn
is grown without rotation with other crops. The de-
velopment of corn varieties more tolerant to the ef-
fects of corn rootworm feeding is the most promising
lead as an alternative to the use of chemicals. How-
ever , improved varieties with these desirable corn root-
worm resistance features are not yet available. Crop
rotation to break the insects' life cycle is a presently
available alternative, but it is not ecnoomically attrac-
tive to many corn growers.
In the past, the European corn borer caused major
damage to corn in the midwest. DDT was used extensively
to control it. Much success has been achieved in the
development of corn hybrids resistant to this insect.
The "soil insect complex" which includes white
grubs, wireworms, sod webworms, corn billbugs, cutworms
seed-corn maggots and seed-corn beetles is most damaging
to corn grown after sod, pasture, forage crops, etc.
Chlorinated hydrocarbon insecticides still are used
41
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heavily against this complex. There are no practical
leads to specific non-chemical methods or agents for
the control of these insects. At the same time, they
occur so erratically and infrequently that entomologists
experience great difficulty in conducting meaningful
performance trials against them. Many entomologists
agree that a large portion of the insecticides applied
for this purpose, probably as much as 90 percent, is
applied needlessly. Discontinuation of this practice
would eliminate a major source of environmental con-
tamination in this area.
Soybeans in the five states are not presently af-
fected by major insect pests requiring routine insecti-
cide treatment. However, entomologists anticipate that
the increasing intensification of soybean growing
practices will bring about greater insect problems on
this crop in the future. This situation where a major
crop is not yet subject to routine insecticide appli-
cations presents a unique challenge and opportunity
for the development of suitable "pest management"
systems from the outset. In this area, there is a
great need for practical, down-to-earth approaches,
including development of insect damage threshold data,
insect damage forecasting, improved weather forecast-
ing, and establishment of the organizational require-
ments and structures necessary for effective programs.
42
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Furthermore, in order to use chemical insecti-
cides to best advantage as one element in an inte-
grated system, information is needed on the spectrum
of selectivity and the degree of effectiveness of
potentially useful products at the low end of their
dosage range. The use of presently available in-
secticides at lower dosage rates is one reservoir
of selectivity which is still largely under-utilized,
if not completely untapped today.
APPLICABLE LAWS AND REGULATIONS
The contractor has endeavored to examine and pre-
sent in concise form, the status of federal and state
laws directly pertinent to the five-state study area.
By collecting and analyzing pertinent laws at the
state and federal level, and through a series of inter-
views with key people, a picture of good and bad has
been assembled; each will be presented with the con-
tractor's evaluation of areas of needed reform.
The federal regulation of pesticides operates
under the Federal Insecticide, Fungicide and Rodenti-
cide Act (FIFRA), enacted in 1947 and amended in 1959,
1961, and 1964. The act prohibits the interstate or
international shipment of economic poisons unless they
are: registered pursuant to provisions of Section 4
43
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of the act; are in unbroken immediate containers; and
are labeled according to the provisions of the act.
Should the Administrator find that an imminent
hazard to the public would exist, he may suspend the
registration of an economic poison immediately. Any
person who violates this law may be found guilty of a
misdemeanor and on conviction can be fined not more
than $1,000.00.
New Federal Legislation
During 1971, Congress has considered legislation
to amend or replace FIFRA. At least eight different
bills dealing with pesticides were introduced in the
House of Representatives. The primary one was H. R.
4152. In the Senate four bills have been under con-
sideration, two of which (S. 600 and S. 745) would -
like H. R. 4152 - replace the present FIFRA. The
other bills would either prohibit the sale of DDT or
prohibit the sale of aldrin, chlordane, DDD/TDE, diel-
drin, endrin, heptachlor, lindane, and toxaphene. The
fate of any legislation in the Congress is to be con-
sidered uncertain until enacted by both Houses and
sent to the President. H. R. 10729, the Committee
rewrite of H. R. 4152, was enacted by the House in the
first session of the 92nd Congress. There is strong
44
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expectation that Senate action in the 1972 session
will result in enactment of a new FIFRA very similar
to H. R. 10729.
H. R. 10729 incorporates many of the provisions
of the existing law (FIFRA), but goes well beyond it
in the federal regulation of intrastate as well as
interstate activities, including registration of
pesticides in intrastate commerce. It provides for
the classification of pesticides as to: (a) "general
use" or (b) "restricted use." The original versions
had a third category of "use by permit only." It also
provides for the certification of pesticide applicators.
It provides for aid and guidance to states in developing
training programs for pesticide applicators and for the
certification of individuals entitled to use restricted
pesticides.
The bill also substantially increases the enforce-
ment powers of the federal agency. There are provisions
for criminal misdemeanor and for civil penalties. These
include not only the registrant, wholesaler, dealer, re-
tailer, or other distributor, the commercial pesticide
applicator, but the farmer who "knowingly violates any
provision of the Act."
Impact of the Pending Federal Legislation
A sampling of views from Congressional offices in
45
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the five study states of Illinois, Iowa, Kansas, Minne-
sota, and Missouri showed: (1) the legislation was an
integral part of more effective pollution control, (2)
improved control of commercial and private applicators
to prevent overdoses and careless applications, (3)
more effective handling of pesticides, (4) reduction in
on-site storage of pesticides, and (5) more effective
control over retail sales subject to recall on order
of the Administrator.
There seemed to be a general concurrence from farm
communities on the need for legislation of this general
nature. The contractor's own survey and Congressional
office mail strongly express approval for passage of
the legislation. The greatest opposition came from
some retailers who were also applicators and some com-
mercial applicators - both saw impending legislations
as entirely too restrictive.
With respect to the potential impact of the federal
legislation on state programs, each Congressional office,
state Departments of Agriculture, farmers and county
agents surveyed indicated the role 'of all state Depart-
ments of Agriculture and Agricultural Extension Service
would have major responsibility.
Section 20, Research and Monitoring, and Section 23,
of H. R. 10729 State Cooperation and Training, are par-
46
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ticularly significant advances. The provisions which
specifically empower the Administrator to (1) foster
research in biologically integrated alternatives for
pest control, (2) formulate a national plan for moni-
toring, (3) expand public funds to encourage state pro-
grams in training of certified pesticide applicators,
are viewed by the contractor as necessary and desirable.
Testing and Registration of New Pesticides
Section 3. Registration of pesticides appears to
provide for sufficient information to allow the Adminis-
trator to make adequate judgments regarding new compounds,
The provisions which allow a full description of tests
performed, 3 (c)(1)(D), and the results thereof to the
Administrator as he desires and 3 (c)(1), wherein the
Administrator shall publish guidelines specifying the
kinds of information required in support of registration,
are regarded as particularly important. The further pro-
vision that the Administrator shall make public all
scientific information relating to the registration of
any particular compound is viewed as an absolute neces-
sity and long overdue (S 23(c)(2), p. 18, lines 4-9).
Illinois
The State of Illinois has sound laws on record
47
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wjiich are consistent with H. R. 10729. The provisions
of the existing law are rather weak in regard to li-
censing of employees of pesticide applicators but com-
pliance with the Administration bill should insure
training and safety precautions. When asked about this
issue, Congressman Finley's office indicated: (1)
response for this bill has been favorable, (2) the
bulk of the farmers and the organizations and farm
cooperatives recognize the need to work within a
regulatory framework in order to preclude more re-
strictive limitations on their use of agricultural chemi-
cals, (3) farm cooperatives are gearing up to assist
farmers through education to qualify under proposed
registration systems.
Iowa
The Pesticide Act of Iowa is a combined registra-
tion (use) and applications law. Licensing provisions
and enforcement need to be strengthened in Iowa. Finan-
cial responsibility for violation is more stringent in
Iowa than in Illinois. The institution of a chemical
technology review board in Iowa will allow the Secretary
of Agricluture to promulgate additional laws and regu-
lations .
48
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Kansas
Stringent financial responsibility makes the Kansas
Pesticide Use Law. Kansas is the only study state re-
quired to issue regulations regarding storage and safe
disposal of pesticides and used containers. Although
viewed as something of an intrusion on the state's own
pesticide law, all the Congressmen interviewed from
Kansas indicated support of H. R. 10729.
Minnesota
Minnesota's Spraying and Dusting Law was the first
law in the five-state study area to employ restricted
use pesticide classification. DDT and its metabolites
and the cyclodiences were severely restricted as of
July, 1970.
Congressman Bergland did not feel that the farmers
of Minnesota have been at any disadvantage to farmers
from other states because of the restrictions on the use
of certain pesticides. He stated that the contacts he
has had with farmers and farm organizations have at no
time indicated such a disadvantage. The general tenor
of comments from his home district during the period when
the legislation was under consideration was favorable
to passage. The only comments he has received since he
49
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voted for the bill have been from individuals who ex-
pressed the view that legislation along the line of H. R.
10729 has been long overdue.
In total view, Minnesota already has more stringent
control than most states and compares favorably with
the Administration bill. No difficulty is seen in
field implementation of that legislation.
It should be admitted that Minnesota does not have
the same degree of agricultural involvement, as say,
Iowa or Illinois, as far as corn and soybeans are con-
cerned.
Missouri
Missouri has the weakest pesticide control law in
the five-state study area. Two bills introduced in 1971
were fought strenuously by dealers and manufacturers.
Public hearings were held and testimony received. Manu-
facturers and Applicators reported they could live with
the House committee substitute for 315 and 571. Biolo-
gists and environmentalists were also satisfied. However,
when brought to a vote, the bill failed to pass and both
sides appeared to be surprised. At a special session
(November 18, 1971), it was decided that proponents of
the bill(s) would wait and see what happened to the
Administration bill in the Senate (H. R. 10729).
50
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Identity of Favorable Types of Laws
The contractor's survey of farmers, county agents,
Congressional offices, pesticide applicators and re-
tailers support the Administration bill (H. R. 10729).
Although some states presently have laws which appear
to control use and application, it is seen that suffi-
cient control is not observed in practice at all times.
Hopefully the provisions of the bill which would streng-.
then or reinforce federal aid to educational programs
designed to improve methods of application and human
safety would have their impact in increased environmental
protection as well.
Some of the verbiage of the existing state laws is
rather loose in the interpretation of how to dispose of
containers and unused pesticide. Hopefully this major
source of environmental contamination will be solved by
more useful state laws in the future. As indicated in
another section of this report, many farmers have ex-
pressed an earnest desire to dispose of their material
in a suitable way but do not know of a practical solu-
tion. Aid in this matter should come from all states
as soon as possible.
Assistance to farmers by way of increasing their
ability to implement soil erosional control techniques
51
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would have the multiple advantage of increasing crop
yield, keeping soil loss to a minimum, and most im-
portantly, keeping pesticides used on the land where
they are normally effective. An obvious benefit would
occur to farmers since annual application of certain
compounds could be adjusted downward to take advantage
of residue.
The strengthening of applicator laws is viewed as
another very desirable feature of some laws. However,
responsible operators who perform valuable services
should not suffer from over-regulation.
RECOMMENDATIONS
Inventory of Pesticide Uses
1. The contractor recommends that information on
the quantities of pesticides (active ingredients) used
in this region should be collected and published
annually. This could be done by extending the systems
already initiated in the states of Minnesota and Illi-
nois so as to include quantitative data on pesticides
used, and by the establishment of similar procedures
in the other states.
2. As a further source of input into the already
existing and the suggested additional state systems, a
52
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statutory requirement to report quarterly or annually
the quantities of pesticide active ingredients sold to
growers, might be imposed on pesticide marketers in
the area.
Effects of Pesticide Application Techniques
3. The contractor would like to see a massive
research effort to establish safe, effective, economi-
cal, practical solutions to the problem of empty pes-
ticide container disposal. In the interim labels should
be easily understandable so that directions can be
followed under actual field conditions.
4. To help minimize contact with the toxic chemi-
cals, plastic disposal gloves and a respirator mask,
if needed, should be attached to the outside of every
pesticide container holding chemicals for farm use.
The user would be inclined to use safety equipment, if
it were there when he picked up the package.
5. Studies of effective agricultural techniques
for reducing environmental damage such as minimum
tillage, grass waterways, and banding of chemicals
should be made and results publicized along with an
effective implementation plan.
Mechanisms of pesticide entry into the aquatic
environment, the potential harm of the practices such
as fall plowing should be publicized and alternative
53
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countermeasures developed.
6. The manufacturers of pesticides have a well
established system for promoting their products to the
farmers. Through sales promotion the farmer is encou-
raged to use more, not less pesticide. This pressure
the manufacturers place on farmers, on retailers, and
to some extent through county agents prevents a change
in use patterns from developing.
The contractor feels very strongly that a pest
management program should be used, for both herbi-
cides and insecticides to combine all agricultural
practices, including selected use of pesticides on
diagnosed problems such as corn rootworm in one field
when it occurs, rather than a blanket application of
aldrin to an entire crop at planting time. A systems
approach to the pest problem could bring about a major
reduction in pesticide usage without significant loss
in crop yield or expense to the farmer.
The approach needed is active education of farmers
to this idea, and rapid, usable advice from the state
agricultural departments.
Route of Pesticides into the Water Environment
From this investigation it is clear that water con-
tamination by pesticides will be minimized when farm
field erosion is reduced. Practices such as contour
54
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plowing and minimum tillage help slow erosion, but fall
plowing and plowing to the edge of a field may produce
large amounts of sediment. Several practices can reduce
sediment transport of pesticides:
7. Elimination of fall plowing, which exposes
broken soil to winter storms and spring run-off.
8. Leaving a barrier strip around field edges
for sediment basins to catch sediment from fields.
An area plowed but left unharrowed and unplanted would
slow run-off and allow a portion of the sediment to
settle.
9. Construction of large sedimentation basins
to catch run-off from several fields, with provisions
to remove sediment after each storm and return it to
fields or land-banked areas for deporit.
10. Investigation of the plowing scheme; ridge
plowing described by Ritter which reduced erosion and
pesticide losses by a factor of seven times.
11. An extensively monitored typical basin of
about 100 square miles will provide better understanding
of the route of pesticides to water and their potential
harm. Meteorological data, continuous flow and tur-
bidity measurements, and sedimentation rates could be
compiled with pesticide inventories and soil pesticide
measurements.
55
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If a 10 to 20 basin system could be implemented,
one could more effectively evaluate the effect of
pesticides in the water environment.
Impact of Pesticides Qn the Aquatic Environment
The contractor recommends that additional effort
be expended to achieve the following:
12. Understanding of the mechanisms by which
pesticide compounds are adsorbed by photosynthesizing
plants is achieved.
13. Virtually a total lack of information on the
cellular responses of green plants and diatoms to pes-
ticides exists. This includes information on binding
sites, specific affinities for membrane surfaces, mode
of action.
14. Community structure, natural succession,
growth, viability and reproduction as well as the res-
ponse of photosynthetic rate to pesticide exposure for
a much larger variety of aquatic plants at levels
currently found in the environment as well as experi-
mental levels is necessary.
15. There appears to be a great need for basic
experimental designs which would identify not only
biomagnification but long term effects which would follow
reproductive success for several generations.
56
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16. Effects of long term sub-lethal exposure
on growth, reproduction and viability of a much wider
variety of benthic organisms.
17. Identification of cellular routes of entry
of pesticides with benthic forms.
18. Elaboration of metabolic degradation pathways
of pesticide compounds in benthic animals.
19. information of effects of chronic sub-lethal
exposure to major food items of top trophic levels.
These include larger crustaceans, small fish, minnows,
frogs, toads, salamanders, etc.
20. Much additional information on all aspects of
physiology of fish exposed to chronic sub-lethal expo-
sures of pesticides.
21. New and expanded criteria for scientific
information required of registration. These criterial
should be more pertinent to impact on chronic exposure
to larger varieties of non-target species.
22. Expand studies on effect of soil and water
microorganisms which may degrade persistant compounds
and which may themselves be effected in such a way as
to not perform their ecological function as we now
know it.
23. Much additional information required on rates
of excretion and particularly differential turn-over
57
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rates between different animal groups.
24. Model ecosystems probably have lower values
in predicting the fate of certain compounds. Such
modeling should be continued with trophic dynamic
considerations and attempts at balance equations.
25. Although models have their place, there is
no substitute for field studies. These should be
expanded to include more in-depth studies of specific
watershed and basins and a much wider variety of aquatic
ecosystems.
26. Fxpanded programs to identify the potential
for harm to humans from both chlorinated hydrocar-
bonds and organo-phosphates. State support should be
solicited.
27. Expanded educational efforts on use and
application as well as health hazards involved.
28. Industrial support is needed to develop safer
compounds; this may include new technology aimed at
safer handling practices and formulations.
29. Agricultural engineering might provide new
and innovative methodology for application of pesti-
cides.
Degradation of Pesticides in the Environment
30. We recommend that a massive, interdiscipli-
nary research effort be mounted to clarify the environ-
58
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mental behavior of major pesticides which are expected
to continue in use for the foreseeable future. Infor-
mation needed includes their fate in the environment
after application; routes of metabolism, degradation
and disappearance; nature of the ultimate breakdown
products; effects of long-term exposure of ecosystems
to low-level residues; and interactions with other
chemicals in the environment. It will be necessary to
establish an order or priority among products to be
thoroughly investigated in this fashion.
31. We recommend that the responsibility to
establish such a priority system and to plan, spear-
head and oversee the research program itself be
assigned to a specific office or committee within the
EPA.
32. We further recommend that actual performance
of the research work required should not be limited to
tax-supported agencies, but that all possible research
capabilities should be mobilized including those of
industry, independent and non-profit research organiza-
tions, etc. By and large, industrial and independent
research organizations have more experience and have had
more success in the management and performance of truly
inderdisciplinary research than government or university
laboratories. This type of experience is greatly needed
59
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in this extremely complex area of environmental research,
Alternatives to Chemical Control of Weeds and Insects
33. The contractor recommends that a concerted
effort be undertaken to reduce or eliminate the pro-
phylactic use of insecticides, especially chlorinated
hydrocarbons, for the control of the "soil insect
complex" on corn. Growers should be strongly encouraged
to leave entire fields or portions thereof untreated
and/or to use insecticides at reduced rates, to es-
tablish to what extent, if any, prophylactic insec-
ticide treatments are needed for this purpose. As an
alternative or additive measure, establishment of an
insurance system similar to hail insurance, coupled
with a ban on the prophylactic use of chlorinated hydro-
carbon insecticides, should be investigated.
34. The contractor further recommends that the
development of a practical, realistic "pest manage-
ment" system for soybeans receive all necessary research
administrative and organizational attention. The
present state of affairs where this important crop is
not yet subject to routine insecticide treatments offers
a unique opportunity to develop all aspects of a sound
insect management system for the bottom-up, unincum-
bered by pre-existing pesticide use patterns, vested
interests, etc.
60
-------
Applicable Laws and Regulations
35. The contractor, throughout surveys and inter-
views, found general support for the Administration
Bill (H. R. 10729).
36. Licensing provisions of H. R. 10729 appear
adequate provided sufficient valid support of claims is
presented. This would include updated standards, es-
pecially in the area of chronic sub-lethal exposure.
Rising costs dictate that new products should not be
unduly restricted where no imminent harm to humans or,
more important, to the total ecosystem is presented.
37. Compounds which are known to rapidly hydro-
lyze or otherwise decompose in the environment should
be given considerably more latitude than compounds
which are specifically identified as persistent.
38. The contractor believes that there are some
applications of some persistent pesticides which may
be tolerated on a prescriptions dispensing basis for
structural pest users and other uses which show none,
or very little likelihood of environmental contamination.
In any event, the amounts used should be rigidly con-
trolled and even these uses should be phased out as
soon as compounds with more desirable characteristics
are found. We should strive to achieve integrated methods
and control which would specifically identify the need
61
-------
for use of these compounds only when needed and in the
amounts needed.
39. It is clear that some kind of licensing is
required of pesticide applicators. Federal and state
sponsorship of training requisites to licensing is
encouraged as is a rigid enforcement program.
40. Catalytic thermal decomposition of unused
pesticides and empty pesticide containers is not
possible by the average farm user. Clearly, state or
Federal implementation is required to dispose of unused
or surplus pesticides. Manufacturers directions are
not practical. Dumping or burning as presently prac-
ticed are clearly inadequate. The single biggest
complaint from farmers was that no one has provided
sufficient information for safe disposal.
41. The likelihood of increased human exposure is
enhanced with increased pesticide use. Statewide
implementation plans, such as those in Kansas and Iowa,
which alert medical doctors to the possibility of harm,
is a helpful measure and should be encouraged. Pre-
scribed safety methods, including the wearing of plastic
garments and gloves or respirators, appear to be largely
ignored. The contractor thus recommends that additional
steps be taken by manufacturers to product formulations
which are more dust-free, covered with a protective
62
-------
coating which could dissolve when wetted, or such other
plans which would reduce the likelihood of human
exposure.
42. It is recommended that considerably more
effort be expended in the area of controlled degradation
and self-destruct methodology.
43. Standardization of leak-proof, safe container
is absolutely essential. The manufacturer who packages
in a desirable container and then tells the farmer to
destroy it is obviously unaware of the inherent
thrift of most farmers. Self-punching boxes and cans
which do not require additional handling by the
operator have been suggested. The payment of demurrage
or a premium on returned containers is also a possible
solution.
44. Additional research is badly needed in methods
of adequate disposal of used pesticide containers.
45. It is recommended that stronger effluent
requirements be instituted and enforced against pesti-
cide manufacturers and formulators.
46. The contractor recommends integrated research
programs as well as a streamlined registration proce-
dure. This will enhance cooperation between scientists
and generally insure that adequate information is gathered
openly to assure maximum environmental protection with
due regard to the interests of pesticide companies.
63
-------
TABLE
FACTORS WHICH LIMIT FARMERS USE OF PESTICIDES
Factor
Cost
Availability
Ease of application
Dangerous to use
Fear of environmental
damage
Other, unspecified
(little need, "carry-
over", etc.)
Total Contacts
Illinois
69%
—
19
21
21
10
52
Iowa
66%
6
22
32
34
11
98
Kansas
35%
9
11
51
35
16
57
Minnesota
60%
5
12
17
27
13
60
Missouri
64%
3
20
22
40
17
55
Total
72%
5
18
29
30
14
NOTE: Percentages do not add to 100% since many farmers made multiple entries.
All figures rounded off to nearest whole number.
-------
TABLE
OPINIONS OF AGENTS AND FARMERS AS TO WHETHER
PESTICIDES ARE REQUIRED TO INSURE GOOD CROP YIELD
Source
Agents Response
Yes
No
2
Farmers Response
Yes
No
CO
•H
o
c
-H
rH
j_j
H
91%
9
80
20
(0
o
H
97%
3
81
19
w
(0
CO
c
(0
88%
12
78
22
.p
o
W
C
c
•H
a
81%
19
68
32
•H
V4
^
0
to
CO
-H
g
100%
—
89
11
Totals from 176 county agents uniformly distributed
over five study states.
2
Totals from 331 independent farmers uniformly dis-
tributed over five study states.
-------
TABLE
EXTENT OF USE OF ALTERNATE METHODS OF INSECT AND
WEED CONTROL IN FIVE STUDY STATES ASKED OF AGENTS
Specific Method Used
Yes
No
Methods
Cultivation
Biological* (includes
Parasites and
Bacteriological)
Rotation
CO
•H
o
c
•H
rH
rH
H
21
15
G
p
G
(0
&
0
H
23
12
G
F
G
w
«J
to
a
(d
«
30
7
?
F
G
(0
-p
0
to
0)
c
c
•H
s
21
16
G
P
G
-H
M
d
0
en
CO
-H
a
15
7
G
G-VP
G
G = Good success where used
F = Fair success where used
P = Poor result where used
VP = very Poor
? = Questionable results . ,
. diffucult to assess
*Responses noted are from very few isolated agents comments
-------
TABLE
COUNTY AGENTS RESPONSE TO OBJECTIVE EVIDENCE BY
MANUFACTURERS FROM TEST OR YIELD PLOTS
Objective Evidence
Yes
No
Company
Geigy
Monsanto
Stauffer
Blanco
Shell
Niagra
Cyanamide
Kaiser
Arco
Lily
POW
1
State
in
ID
•rH
O
c
•H
r-l
rH
H
22
23
82
5
2
1
2
1
1
P
*a*
«— -
(0
o
H
14
18
8
5
1
1
2
1
~
^
W
(0
W
c
n)
17
19
8
1
^
*""^'
4J
0
(0
-------
IS ANYONE IN YOUR AREA TRYING
AN ALTERNATE METHOD OF CONTROL?
REPLIES OF THE FARM AGENTS
ILLINOIS
-We have one organic farmer
-Alternating corn and soybeans.
-A hammer and a block of wood are slow.
-Yes, with total failure.
-"Old fashioned" farmers use cultivation instead.
-Has been work done by University of Illinois on alfalfa
weevil control-parasite.
-It doesn't work.
-Rotation of crops and other management practices have
long been used as an alternative to chemicals. Pesti-
cides fill the gap when others fail.
IOWA
-For insect control, yes, not in weed control so much.
-A few organic farmers. Some rotate to control corn
rootworms.
-Bacillus Thuringiensis for corn bore control.
-Alternating corn and soybeans to control corn rootworm.
-Some still depend only on cultivation.
-Some do but yields generally show it.
KANSAS
-Only rotation where possible.
-There have been attempts to control greenbugs in grain
sorghum with lady beetles - effect is too little, too
slow and unpredictable.
-Biological control is stressed where practiced by the
extension service. It is not practiced in most cases,
however.
-Yes, but not doing well with them.
-------
-We (extension service) encourage farmers to allow natural
control whenever possible. An example would be control
of aphid or greenbugs by predators.
-Rotation.
-Only through extension channels.
-Of course, cultivation is still used for weed control,
but as a supplement to chemicals. Also, disease and
insect resistant varieties are used.
MINNESOTA
-Yes, several are using a Wonderlife product, which failed
miserably in our area this year on Weevil Control. Those
using have only half a crop.
-The ones with no control have suffered extensive losses.
-Majority of farmers are using crop rotation and cultural
methods.
-A few organic enthusiasts.
-We have a few organic people who have ideas of control,
but on this amount of acreage it proves nothing.
-We have a few "Organic" farmers that are moving in, but
they soon get over that idea.
-Cultivation and rotation are the only alternate practices.
-Some have and failed.
-No, no practical alternatives except crop rotation.
-Flame cultivation
-Some have gone to cultivating again, but I don't think
that they had as much success as they had hoped for.
MISSOURI
-Practically all farmers practice some type of rotation,
but not on all fields. This actually helps some insects.
-No alternate methods of control are being used except
for crop rotation.
-Few farmers use rotation; they use it unknowningly.
-On some of the smaller farms they are cultivating crops
as a means of weed control, but this is an old method and
farmers using it simply have not progressed.
-------
-Rotation of crops is not used as much as previously,
but it still is used for insect and disease control
when pesticides don't work.
-Ladybugs have taken care of aphid problems on milo.
-Yes, but failing miserably.
-Cultivation for weeds.
-What alternate method is there? Rotation, yes.
-Yes, farmers always have. Demand for better products
and cost price squeeze necessitate its use.
-Yes, most farmers are using pesticides on a "have to"
basis as much as possible.
-------
ARE PESTICIDES REQUIRED TO INSURE A GOOD CROP YIELD?
REPLIES OF THE FARM AGENTS
ILLINOIS
-Not all the time.
-No, but they are beginning to worry about corn borer.
-Yes, against the corn root worms.
-They are forced to due to pure economics.
-They know it!
IOWA
-The majority do on specific crops when specific pro-
blems are present.
-Yes, they must.
-Yes, for corn rootworm control especially.
-Many do but not all.
KANSAS
-Without pesticides 60% of our farmers would cease
operations - no profit.
-More progressive farmers do.
-No, you can still get a good yield without using
pesticides.
-Not necessarily, they use it as a last resource.
-Most do; thus, tending to spray before needed at times,
-In many years, yes, especially in our corn fields.
-Most use crop insecticides as a last resort.
MINNESOTA
-Mo, pesticides cost money, therefore, are used to
counteract a problem.
-------
-Especially corn rootworm control.
-In our area it is not totally necessary.
-Certain pesticides use is generally considered
necessary.
-Only a portion feel so.
-Herbidides, yes, and potato insecticides.
-Only on second year corn is it a must situation.
-Absolutely, they can't do the job without.
MISSOURI
-Yes, during certain times when weather favors pests,
-Insecticides are too costly to use unless severe
epidemic of bugs is expected.
-Pesticides are a "tool of production."
-------
APPENDIX B
INVENTORY OF PESTICIDE USES
Selection of Study Area
The use of pesticides on important midwestern farm
crops in relation to total U. S. agricultural pesticide
use is as follows (1):
Herbicides;
Corn 46 million pounds of active ingre-
dient or 41 percent of total U. S.
farm use
Soybeans 10.4 million pounds of active ingre-
dient or 9 percent of total U. S.
farm use
Wheat 8.2 million pounds of active ingre-
dient or 7 percent of total U. S.
farm use
Thus, the above three crops account for more than
50 percent of total farm use of herbicides in the
U. S.
Insecticides;
Corn 23.6 million pounds of active ingre-
dient or 17 percent of total U. S.
farm use
1-B
-------
Soybeans 3.2 million pounds of active ingre-
dient or 2 percent of total U. S.
farm use
Use of insecticides on soybeans is small, and even
smaller amounts of insecticides are used on wheat
and other small grains. Corn receives by far the
largest amounts of insecticides among the midwestern
field crops.
Fungicides:
There is no distinct major use of fungicides on
midwestern farm crops. Total U. S. use of fungi-
cides (exclusive of sulfur) in 1966 amounted to
approximately 31 million pounds, used on a variety
of different crops in all parts of the country.
Heaviest uses are on fruit and vegetable crops.
Other Pesticides;
There are no distinct major uses of other pesti-
cides on midwestern farm crops
The foregoing analysis of pesticide uses on major
midwestern field crops led us to focus this study on the
use of herbicides on corn, soybeans and wheat, and on the
use of insecticides on corn.
The leading corn producing states are Illinois,
Iowa, Indiana and Minnesota (2). The leading soybean
producing states are Illinois, Iowa, Arkansas and Missouri.
2-B
-------
The leading wheat producing state is Kansas. This
geographical distribution pattern of corn, soybeans
and wheat prompted us to select the states of Minne-
sota, Iowa, Illinois, Missouri and Kansas for an in-
tensive study of the problems outlined in the intro-
duction.
Description of the Five State Area
Geographically, the five state area extends from
87.5° (Eastern border of Illinois) to 102° (Western
border of Kansas) western longitude, and from 36°
(Missouri bootheel) to 49° (Northern border of Minne-
sota) northern latitude. Naturally, such a consider-
able spread encompasses considerable variation in cli-
matic, soil and other environmental conditions. These
in turn account for some important differences in
general agricultural practices and, more specifically,
in pest problems and pesticide use patterns. On the
other hand, some growing practices and pesticide use
patterns are remarkably similar for a given crop over
the entire five state area.
Table L-B summarizes for the five states the major
crops grown, total crop acreage, and total land area
(2, 3, 4, 5, 6, 7, 8). The total acreage of each crop
is compared to the U. S. total. The five states
3-B
-------
TABLE 1-B
LAND USE AND MAJOR FIELD CROPS GROWN IN THE 5-STATE AREA
(In 000 Acres)
State
Minnesota
Iowa
Illinois
Missouri
Kansas
5 States
U.S.
5 States/
U.S.
Major Crops Grown
Corn
5,285
10,072
10,379
3,114
1,637
30,487
67,171
45%
Soybeans
3,129
5,389
6,865
3,557
1,005
19,945
43,332
46%
Wheat
830
negl.
993
1,059
9,061
11,943
47,000
25%
Oats
3,354
1,817
612
312
250
6,345
24,312
26%
Sorghum
negl.
negl.
negl.
298
4,277
4,575
17,292
26%
Hay
3,231
2,496
1,260
3,008
2,384
12,379
63,234
20%
All Other
Crops
1,671
negl .
303
negl.
494
2,464
77,659
3%
Total Crop
Acreage
17,500
19,931
20,412
11,400
19>108
88,351
340,000
26%
Total Land
Area
50,745
35,868
35,761
44,190
52,516
219,080
2*266,273
9.7
Crop Acreage
% of Total
Land Area
34
56
57
26
36
40
15
CD
Note: Data in this tabulation originate from several different sources (including 2, 3, 4, 5, 6, 7, 8),
and some items are not expressed numerically. For these reasons some columns do not balance
arithmetically.
-------
account for 45 percent of the total U. S. corn acre-
age, 46 percent of soybeans, 25 percent of wheat, 26
percent of oats and sorghum, respectively, and 20 per-
cent of hay. The five states comprise only 9.7 percent
of the total U. S. land area, but 26 percent of total
U. S. crop acreage. Of the total land area in the five
states (220 million acres), 40 percent or 88 million
acres were planted to field crops. The ratio of total
crop acreage to total land area varies from 26 percent
for Missouri to 56 to 57 percent for Iowa and Illinois,
respectively. In the U. S. as a whole, total crop acre-
age represents only 15 percent of total land area. Thus,
the five state area selected for this study is one of
the more intensely farmed land areas of the U. S.
Pesticide Use in the Five State Area
Tables 2-B, 3-B; and 4-B summarize the estimated uses of
herbicides and insecticides in the five state area on
corn, soybeans and small grains, respectively.
Tables 5-B through 8-B summarizes the estimated total
number of acres treated by state, type of treatment,
major individual pesticide products, and approximate
total quantities used for corn herbicides (Table 5-B)
soybean herbicides (Table 6-B), small grain herbicides
(Table 7-B) and corn insecticides (Table 8-*). Table 9-B
5-B
-------
TABLE 2-B
ESTIMATED USE OF HERBICIDES AND INSECTICIDES ON CORN IN THE 5-STATE AREA
State
Minnesota
Iowa
Illinois
Missouri
Kansas
5 States
Total
Acres
Grown
(000)
5,285
10,072
10,379
3,114
1,637
30,487
Herbicide Treatments
Area Treated
Acres.
(000)
4,144
6,000
8,324
2,500
1,230
22,198
% of
Acres
Grown
78
60
80
80
75
73
Pre-Emergence
Acres,
(000)z
2,814
4,500
7,000
1,750
1,050
17,114
%'of '
Treated
Acres
68
75
67
70
85
77
Post-Emergence
Acres,
(000)
2,762
4,500
2,800
1,000
300
11.362
% of
Treated
Acres
67
75
27
40
25
51
Insecticide Treatments
Area Treated Yre-Emergence
Acres,
(000)
1,112
6,500
5,702
2,020
650
15,984
% of
Acres
Grown
. 21
65
55
65
40
52
Acres,
(000)
1,067
6,500
5,800
2,000
575
15,942
% of
Treated
Acres
96
100
100+
100
88
100
Post-Emergence
Acres,
(000)^
77
2,000
286
200
350
2,913
% of
Treated
Acres
7
31
5
10
54
18
(fl
to
Net acres (acres treated one or more times).
Gross acres (acres treated more than once counted for each treatment).
-------
TABLE 3-B
ESTIMATED USE OF HERBICIDES AND INSECTICIDES ON SOYBEANS IN THE 5-STATE AREA
State
Minnesota
Iowa
Illinois
Missouri
Kansas
5 States
Total Acres
Grown (000)
3,129
5,389
6,865
3,557
1,005
19,945
Herbicide Treatments
Area Treated
Acres
(000)
1,932
4,000
4,900
2,700
550
14,082
% of
acres
grown
62
75
71
75
55
70.5
Insecticide Treatments
Area Treated
Acres
(000)
less tt
75
130
negligi
less th
250
% of
acres
grown
tan 1%
1.4
2
ble
tan 1%
1.25
Remarks
Up from
42,000
acres
treated
in 1969
I
ro
-------
TABLE 4-B
ESTIMATED USE OF HERBICIDES AND INSECTICIDES ON SMALL GRAINS1 IN THE 5-STATE AREA
State
Minnesota
Iowa
Illinois
Missouri
Kansas
.5 States
Total Acres
Grown (000)
4,866
1,817
1,645
1,371
9,311
19,010
Herbicide Treatments
Area Treated
Acres
(000)
2,732
550
45
550
4,650
8,527
% of
acres
grown
56
30
27
40
50
45
Insecticide Treatments
Area
Acres
(000)
less t
Treated
% of
acres
grown
nan 1%
negligible
less than 1%
negligible
900
950
10%
5%
00
"Small grains" = primarily oats in Minnesota and Iowa; primarily wheat in Missouri
and Kansas; about 2/3 wheat and 1/3 oats in Illinois.
-------
TABLE 5-B
CORN HERBICIDES
ESTIMATED NUMBER OF ACRES TREATED, BY STATE, TYPE OF TREATMENT,
MAJOR PRODUCTS, AND TOTAL QUANTITIES, 1971
State
Minnesota
Iowa
Illinois
Missouri
Kansas
Type of
Treatment
pre-em.
post-em.
pre-em.
post-em.
pre-em.
post-em.
pre-em.
post-em.
pre-em.
post-em.
Total acres (000)
Treated
Avg. rate, Ibs. active/acre
Total herbicide quantities,
000 Ibs. a.i.
Major Products, Acres (000) Treated
(U
Qi
I
oi
C
• H
N
id
M
4J
id
863
2,300
2,240
—
1,000
800
\ 7,2(^3__
117
4J
11)
(U
c
•H
N
id
4J
10
1,374
2,250
—
728
300
120
4j772
375 '
2.4
28,800
1,200
30,000
QJ
i
N
id
-p
10
^1
o
rH
A
O
10
o
Q.
307
__
605
—
—
912
3/1.3
2,700
(propa-
chlor)
1,200
(atra-
zine)
^i
o
rH
O
id
Oi
o
M
Q,
1,432
700
2,067
—
260
—
4,459
3.6
16,000
2,700
18,700
i.
o
•H
A
O
10
i-H
10
144
900
285
—
260
150
1,739
2.5
4,350
01
•n
Ou
1
0>
a.
4J
i
a
i
*3"
(S
—
__
550
—
—
—
550
1.5
v_§25_J
4J
III
O
0,
1
01
^1
4J
1
Q
1
^l1
(N
1,269
2,250
—
1,753
600
120
5,992
0.5
-J, 000.
3,825
in
-P
u
•a
o
)H
a
M
(I)
J-)
o
rH
10
si
1) [ 1)
o c
CJ
•H —
*d K
•H 01
O H
•H O
J3 10
H
O> O
A o
o
rH
id
4,144
6,000
8 , 324
2,500
1,230
>2,198
1C
to
acres (acres treated one or more times)
2Gross acres (acres treated more than once counted for each treatment).
-------
TABLE 6-B
SOYBEAN HERBICIDES
ESTIMATED NUMBER OF ACRES TREATED, BY STATE,
MAJOR PRODUCTS, AND TOTAL QUANTITIES, 1971
State
Minnesota
Iowa
Illinois
Missouri
Kansas
Total acres
(000) Treated
Avg. rate,
Ibs. act./
acre
Total herbi-
cide quanti-
ties, 000
Ibs. active
ingredient
Major Products,
Acres (000) Treated
JH
O
rH
X!
U
i — 1
(0
330
800
446
1,100
170
2,846
2.5
7,100
c
H W
XI 0
n e s
o d'tj
ceo
•rl M
e to a
1,846
W
0)
•rH 0)
U SH
•H O
£! fd
i-i
0) ^-,
x: o
o
rH 0
(0
1,932
4,000
4,900
2,700
550
14,082
10-B
-------
TABLE 7-B
SMALL GRAIN HERBICIDES
ESTIMATED NUMBER OF ACRES TREATED, BY STATE,
MAJOR PRODUCTS AND TOTAL QUANTITIES, 1971
State
Minnesota
Iowa
Illinois
Missouri
Kansas
Total acres (000)
Treated
Avg. rate, Ibs.
Active/ Ac re
Total herbicide
quantities, 000 Ibs..
active ingredient
Major Products
Acres (000) Treated
0)
a
>.
.p
i
>i
X
o
d
0)
.c
a
2,729
545
45
545
4,250
8,114
0.4
3,200
w
0)
TJ
•H
O
•H
X3
H
0)
X!
M
-------
TABLE 8-B
CORN INSECTICIDES
ESTIMATED NUMBER OP ACRES TREATED, BY STATE, TYPE OF TREATMENT,
MAJOR PRODUCTS, AND TOTAL QUANTITIES, 1971
State
Minnesota
Iowa
Illinois
Missouri
Kansas
Type of
Treatment
pre-em.
post-em.
pre-em.
post-em.
pre-em.
post- em.
pre-em.
pre-em.
post-em.
Total acres (000)
Treated
Avg. rate.lbs active/
acre
Total insecticide
quantities, 000 Ibs.
active ingredient
•)
c
•H
•o
iH
248
2,700
2,600
1,300
negl.
6,848
1.6
11,000
X
3
n
390
1,750
841
140
190
3,311
0.85
2,800
Major Products, Acres (000) Treated
B
.y
10
c
o
c
•H
N
id
•rl
•0
18
gl.
350
56
424,
662
1.0
662
E
I
a)
H
o<
o
•P
id
o
a.
167
875
853
140
ibile -
200
.2,235
27
E
ai
10 U
C 0
•H id
,
g o
Q) O
I O
-p ^
to
o
a
1— 1
,-^
id
77
2,000
286
200
350
2,913
^-i
in
•o —
•H CO
u a>
•H H
•P 0
o id
(U
(0 0
C o
•H 0
^-*
rH
1-1
id
1,112
6,500
5,702
2,020
650
15,984
to
U
acres (acres treated once or more times).
2Gross acres (acres treated more than once counted for each treatment)
-------
TABLE
ESTIMATED QUANTITIES OF MAJOR PESTICIDES USED IN THE 5-STATE AREA ON
CORN, SOYBEANS AND SMALL GRAINS
1971
Herbicides:
Insecticides:
Pesticide
atrazine
propachlor
amiben
alachlor
2,4-D - type
trifluralin
aldrin
Bux
heptachlor
phorate
toxaphene
carbaryl
diazinon
DDT
parathion
Crop
corn
corn
soybeans
soybeans 7,100)
corn 4,350)
corn 3,825)
small grains 3,200J
soybeans
corn
corn
corn
corn
corn
corn
corn
corn
corn
MM Ibs of
Active Ingredient
30,000
18,700
13,600
11,450
7,025
3,970
11,000
2,800
2,660
2,364
2,000
1,200
662
200
80
-------
summarizes the estimated total quantities of the major
herbicides and insecticides used in the five state area.
Until recently, reliable information on the quanti-
ties of specific pesticides used by crops or by states
was practically unavailable to the public. Several com-
mercial market survey organizations specialize in col-
lecting this type of data and offer it for sale. In
addition, most, if not all of the major pesticide manu-
facturers have their own market intelligence organiza-
tions and systems. Thus, each of these groups have their
own estimates of the total volume and distribution pat-
terns of pesticides, but this information is closely
guarded and generally not accessible to scientists,
regulatory officials and policy makers in the public
domain.
In response to the increasing concern about possible
environmental damage from the use of pesticides, several
states have initiated procedures to collect pesticide
use data within the last few years. Among these, Cali-
fornia probably has the best and most advanced system.
In our five state area, Minnesota and Illinois, which
belong to the five Great Lakes States, began in 1969 to
gather information along these lines. The governors
of the states of Illinois, Indiana, Michigan, Minnesota
and Wisconsin met in April of 1969 to review the pesti-
14-B
-------
cide situation in regard to possible environmental pol-
lution. Following this conference, the governors in-
structed the agricultural statisticians in their re-
spective states to collect and publish annually statis-
tical data on the use of pesticides on farms. The
second annual survey was made in 1970. The data from
this survey were used for the states of Minnesota and
Illinois (9, 10) in compiling Tables 2-B through 9-B.
While these state publications certainly represent
a great improvement over the previous condition of a
complete lack of pesticide use data, they still leave
many questions unanswered. For instance, the states re-
port pesticide use only in terms of numbers of acres
treated, but not in terms of quantities of specific
pesticides applied. There are tables on rates of appli-
cation, but it is not clear whether these refer to
active ingredients or to formulation, and the rates
given are sometimes considerably at variance with those
recommended by the manufacturers and the state exten-
sion services (11, 12, 13, 14). As a result, we still
had to use considerable extrapolating and guessing in
compiling the inventory of pesticide uses, even for the
states of Minnesota and Illinois.
The states of Iowa, Missouri and Kansas do not col-
lect or publish similar statistics on the use of pesti-
15-B
-------
cides. Pesticide use estimates for these states were
made by way of personal consultation with the state
extension entomologists and weed control specialists
in each state, supplemented by the results of the
field survey of pesticide retailers, county agents and
individual farmers. State Extension Service use recom-
mendations for pesticides (15, 16, 17, 18, 19, 20, 21),
the "1971 Weed Control Manual" (22) and manufacturers'
label recommendations were also consulted.
It must be emphasized that in spite of a great
amount of effort spent in preparing these pesticide use
estimates for the five states, these are probably not
as accurate as would be desirable. It must also be
emphasized that Tables 2-3 through 9-B are composed of
elements of different origin and different reliability.
However, we believe that our findings and recommenda-
tions, insofar as they refer to these data, are still
valid because they are based on scope of magnitude-
type considerations for which great accuracy is desir-
able but not essential.
Pest Problems in Relation to Pesticide Use
A more detailed discussion of weed, insect and
disease problems on major crops in the five states is
included in Appendix G, "Alternatives to Chemical Con-
16-B
-------
Tirol", because it is essential to a meaningful treat-
ment of that topic. The following more general comments
are pertinent in the context of this section.
By and. large, weed problems on corn, soybeans and
wnear, and the percentage of acres treated in each
state vary within only relatively narrow ranges. Of
the approximately 30 million acres of corn grown in
the five state area (Tables 2-B, 5-B)» 73 percent or about
22 million acres received herbicide treatments. The
ratio of acres treated to total acres of corn grown
varied from a low of 60 percent in Iowa to a high of
80 percent in Illinois and Missouri. Seventy-seven
percent of all acres treated with herbicides received
pre-emergence treatments, 51 percent received post-
emergence treatments. A considerable number of acres
received more than one treatment. Therefore, the per-
centage totals exceed 100, and the sum of "gross
acres" treated pre-emergence and post-emergence, re-
spectively, exceeds the number of total "net acres"
treated.
Of the almost 20 million acres of soybeans grown
in the five states (Tables 3-B, 6-B), 70.5 percent or about
14 million acres received herbicide treatments. The
ratio of acres treated to total acres of soybeans grown
varied from a low of 55 percent for Kansas to a high of
17-B
-------
75 percent for Iowa and Missouri. Almost all soybean
herbicides are applied pre-emergence; therefore, no
separation between pre- and post-emergence herbicide
treatments has been made for this crop.
Of approximately 19 million acres of small grains
grown in the five states (Tables 4-B, 7-B) , 45 percent or
about 8.5 million acres received herbicide treatments.
Ratio of acres treated to total acres of small grains
grown varied from a low of 30 percent for Iowa to a
high of 56 percent for Minnesota, with the exception
of a reported figure of only 2.7 percent (45,000 acres
out of 1.6 million) of total acreage treated for the
state of Illinois (10). This low figure for Illinois
is so completely out of line with the figures for the
other four states that we question its validity and
tend to believe that in reality, a higher percentage of
Illinois small grain acres receive herbicide applica-
tions, more nearly in line with the situation in the
other four states. Almost all small grain herbicides
in this area are applied post-emergence. Therefore, no
separation between pre- and post-emergence treatments
has been made in Table 4-B.
Insect problems and acreage treated for insect
control vary more widely within the five state area.
Approximately one-half of all corn acres in the five
states (Tables 2-B, 8-B) received insecticide treatments.
18-B
-------
The ratio of acres treated to total acres of corn crown
varied from 21 percent in Minnesota to 65 percent in
Iowa and Missouri. Some corn acres were treated with
insecticides more than once. As in the case of herbi-
cide treatments on corn, this is the reason why the per-
centage of treated acres exceed 100, and why the com-
bined "gross acres" for pre- and post-emergence insecti-
cide treatments exceed the numbers of "net acres" treated
About 2 million acres of corn in Iowa received
post-emergence insecticide treatments, primarily against
corn borers and cutworms. Insecticides used for this
purpose include an estimated 100 to 200,000 pounds of
DDT. By contrast, Illinois reported only 286,000 acres
of corn treated with post-emergence insecticides, and
the products used did not include chlorinated hydro-
carbons. These apparent differences are surprising,
but in assessing them, it must be remembered that the
Illinois data come from the official state statistics
(10), whereas the collection of the Iowa data had to
rely heavily on personal interviews and field contacts.
We are inclined to believe that in Illinois, perhaps
some corn acres treated with post-emergence insecti-
cides escaped the official survey, but emphasize that
this is just a suggestion, not backed up by hard facts.
The use of insecticides on soybeans (Table 3-B) is
19-B
-------
rather small; only 1.25 percent (250,000 acres) of the
approximately 20 million acres grown received insecti-
cide treatments. Slightly more than one-half of these,
or 130,000 acres, were in the state of Illinois. It
is important to note that this represents a large in-
crease (more than 200 percent) in comparison to the
42,000 acres treated for insect control in Illinois in
1969. Many entomologists predict a large increase in
the use of chemical insecticides on soybeans in the years
to come.
Of the approximately 19 million acres of small
grains grown, 950,000 or about 5 percent received in-
secticide treatments (Table 4-B). Almost all of this
treated acreage is located within the state of Kansas.
Table 9 summarizes the total quantities of 6
major herbicides and 9 major insecticides which com-
prise the great majority, probably well above 90 per-
cent of all agricultural pesticides used in the five
states. Before these estimates were finalized, they
were checked for plausibility against the most recent
national pesticide statistics (23, 24) and also against
the only breakdown of agricultural pesticide uses
thus far published by the U. S. Department of Agri-
culture (1), although the latter is now five years old.
Atrazine is used in far greater quantities than
20-B
-------
any other pesticide. The use of propachlor is declin-
ing, a development reportedly encouraged by its manu-
facturer who pushes another product, alachlor, instead.
The use volumes of amiben, trifluralin and the phenoxy-
type herbicides appear to be fairly level.
Among the insecticides, aldrin still dominates the
scene. A substantial decline in its volume has been
predicted for years, but seems to materialize only very
slowly, despite increasing corn rootworm resistance and
regulatory restrictions. Other chlorinated hydrocarbon
insecticides which were used in substantial quantities
include heptachlor and toxaphene, and even some DDT.
Use of organic phosphate and carbamate insecti-
cides is expected to increase.
Summary and Conclusions
The five midwestern states selected for this study
comprise only 15 percent of the total U. S. land area,
but 40 percent of the total U. S. crop acreage (Table 1-B)
There are about 88 million acres of farm crops (includ-
ing hay) grown in these five states. Corn, soybeans,
small grains and sorghum combined account for about
73 million acres, or 83 percent of total farm crop
acreage in the five states. The balance consists of
hay (12 million acres) and some minor crops. Thus,
21-B
-------
this region is intensively farmed. A high percentage
of its total land area is devoted to the growing of
crops. Five field crops dominate the scene.
There are no publicly available sources of informa-
tion on the quantities of pesticides used in these states.
Minnesota and Illinois collect and publich annually infor-
mation on the number of acres of different crops treated
with specific pesticides, but do not include in their
statistics information on the total quantities of pesti-
cides used. The other three states do not collect or
publish any state-wide pesticide use data at all. Our
estimates of the amounts of major herbicides and insecti-
cides used, broken down by states, crops and type of
treatment, are summarized in Tables 5-B to 9-B. There are
no major fungicide uses in this area .
To the best of our knowledge, such quantitative
data on the pesticides used on major farm crops in this
region have not heretofore been available. However,
this type of information is needed by scientists, regu-
latory officials, legislators and others for an intel-
ligent and continuous assessment of the actual and poten-
tial impact of pesticides on the environment in the re-
gion; for pinpointing problems requiring research, regu-
latory or other actions; for the establishment of priori-
ties in research and in monitorng programs; and for many
22-B
-------
other purposes. The present situation where this infor-
mation is available only to a small group of commercial
interests on a privileged basis seems to be rather incon-
gruous with the public "need to know". We discussed
this problem with many of the major basic manufacturers
of pesticides. A great majority of them agreed that
publication of pesticide use data would not harm
their interests if it were a requirement imposed and
enforced equitably on all manufacturers. The fact that
the California system (25), which reports pesticide
uses by individual products, and by quantities, ap-
pears to be universally welcomed and used by all public
and private groups concerned with pesticides confirms
this view.
Recommendations
We recommend that information on the quantities of
pesticides (active ingredients) used in this region
should be collected and published annually. This could
be done by extending the systems already initiated in
the states of Minnesota and Illinois so as to include
quantitative data on pesticides used, and by the estab-
lishment of similar procedures in the other states. Al-
ternatively, or as a further source of input into the
already existing and the suggested additional state sys-
23-B
-------
terns, a statutory requirement to report quarterly or
annually the quantities of pesticide active ingredients
sold to growers, might be imposed on pesticide marketers
in the area.
24-B
-------
LITERATURE REFERENCES
1 "Quantities of Pesticides Used by Farmers in 1966,"
Agriclutural Economic Report No. 175, Economic
Research Service, U. S. Department of Agriculture,
Washington, D. C., 1970.
2 Agricultural Statistics 1970, U. S. Department of
Agriculture, Washington, D. C., 1970.
3 Minnesota Agricultural Statistics 1971, Minnesota
Department of Agriculture and State-Federal Crop
and Livestock Reporting Service, March 1971.
4 Iowa Annual Farm Census 1969, Bulletin No. 92-AE,
Iowa Department of Agriculture and U. S. Depart-
ment of Agriculture, Des Moines, Iowa, 1970.
5 Iowa Book of Agriculture 1968-1969, Iowa State
Department of Agriculture, Des Moines, 1970.
6 Illinois Agricultural Statistics/Annual Summary
1971, Illinois Cooperative Crop Reporting Service,
Illinois Department of Agriculture and U. S. De-
partment of Agriculture, Bulletin 71-1, 1971.
7 Missouri Farm Facts 1971, Missouri Crop and Live-
stock Reporting Service, Columbia,Missouri, 1971.
8 Farm Facts 1970/1971, Kansas Crop and Livestock
Information for 1970 and Preliminary Estimates
for 1971, Kansas State Board of Agriculture,
Topeka, 1971.
9 General Farm Use of Pesticides 1970, Minnesota and
Four Other Great Lakes States, Minnesota Depart-
ment of Agriculture and State-Federal Crop and
Livestock Reporting Service, 1971.
10 Illinois Agricultural Statistics/Pesticide Use by
Illinois Farmers, 1970, Illinois Cooperative Crop
Reporting Service, Illinois Department of Agricul-
ture and U. S. Department of Agriculture, Bulletin
71-3, 1971.
11 "Cultural and Chemical Weed Control in Field Crops
1971", Extension Folder 212-Revised, Agricultural
Extension Service, University of Minnesota, 1971.
25-B
-------
12 "Insecticides and Their Uses in Minnesota 1971",
Extension Bulletin 263 - Revised, Agricultural
Extension Service, University of Minnesota, 1971.
13 1971 Suggested Insecticide Guides/Insect Control
for Field Crops, University of Illinois at Urbana-
Champaign, College of Agriculture, Cooperative
Extension Service, In Cooperation with Illinois
Natural History Survey, Circular 899, Urbana,
Illinois, 1970.
14 1971 Weed Control Guide, from Illinois Agronomy
Handbook for 1971, Cooperative Extension Service,
University of Illinois at Urbana-Champaign, 1971,
pp. 1-12.
15 Weed Control Series, Iowa State University of Sci-
ence and Technology, Cooperative Extension Service,
Ames, Iowa, Pm-371 (Rev.), Feb., 1969.
16 Summary of Iowa Pest Control Recommendations for
1971, Cooperative Extension Service, Iowa State
University, Ames, 1C-328 (Rev.), 1971.
17 Anderson, L. E., 0. H. Fletchall, R. D. Wilson,
"1971 Recommendations for Weed Control in Corn",
Science and Technology Guide, University of Mis-
souri-Columbia Extension Division, 1971.
18 , "1971 Chemical Weed Control Recommenda-
tions for Soybeans", Science and Technology Guide,
University of Missouri-Columbia Extension Division,
1971.
19 Nilson, E. B., 0. B. Russ, J. L. Condray, and K. C.
Feltner, "Chemical Weed Control in Field Crops,
1971", Bulletin 540, Agricultural Experiment Sta-
tion, Kansas State University, Manhattan and
Agricultural Research Service, USDA, 1971.
20 1971 Kansas Field Crop Insect Control Recommenda-
tions, Cooperative Extension Service, Kansas State
University, Manhattan, 1971.
21 1970 Activities of the Division of Entomology,
Kansas State Board of Agriculture, Topeka, Kansas,
1971.
26-B
-------
22 "1971 Weed Control Manual", Farm Technology, Vol. 27,
No. 3, 1971, pp. 17-99.
23 The Pesticide Review 1970, U. S. Department of
Agriculture, Agricultural Stabilization and Con-
servation Service, Washington, D. C., 1971.
24 United States Production and Sales of Pesticides
and Related Products, 1970, Preliminary, United
States Tariff Commission, Washington, D. C.,
September 1971.
25 Pesticide Use Reports (published quarterly), De-
partment of Agriculture, Sacramento, California.
27-B
-------
APPENDIX C
EFFECT OF APPLICATION TECHNIQUES
Introduction
This section attempts to show how varying pesti-
cide application techniques and agricultural practices
maximize or minimize pesticide entry into the aquatic
environment.
The actual means of application are discussed, as
are ways of improving application in order to minimize
pesticide entry. The influence of manufacturers' recom-
mendations on use patterns is discussed.
Many farmers feel that herbicides are essential to
their successful farming, while insecticides are some-
what optional. The contractor discovered this fact
while contacting farmers, and it was confirmed by the
estimated use figures of pesticides in the study area.
The contractor estimates a 1971 use of 84,745,000 pounds
active of herbicides and 22,966,000 pounds active of
insecticides. This shows the much greater dependence
the farmer put on the herbicides to insure a profitable
operation.
Application Techniques
The contractor estimates that 219,000,000 acres
1-C
-------
are cultivated in the five state study area (Table 1).
Of this amount, 30,487,000 acres are in corn, and
19,945,000 acres are in soybeans. Seventy percent of
this area was treated with pesticides in 1971 (Tables
2, 3) .
Modern pesticides are generally organic chemicals,
quite powerful when undiluted, in their "technical"
form. The amount of the chemical used for each acre
is quite small. In order to facilitate application,
and allow the chemical to be spread uniformly, it is
diluted. Imagine the difficulty one would encounter
in spreading 1 pound of salt uniformly over 1 acre of
land. The task could be done more easily if the salt
were thoroughly mixed with 1000 pounds of sand and then
spread over the acre. If the mixing operation is pro-
perly done a uniform salt/sand mixture would be created
and the spreader should produce an even layer. Most
of the applied material would be sand, but 1 pound of
salt would have been spread evenly as well. Alterna-
tively, the salt could be dissolved in water and sprayed
on the area to be treated. This is analogous to the
job of applying pesticides to a field.
Most pesticides come in one or more of four forms,
liquid, wettable powder, powder, and granular pellets.
Liquids and wettable powders are mixed with water or
2-C
-------
oil, then applied with a sprayer. Granular pellets
are applied directly to the soil. Powdered pesticide
is mixed with soil for direct application, although
at the present time this is a relatively small proportion
of the total amount of pesticides used.
Pesticides are applied during one of three periods,
before planting, before the plant emerges, or after it
has broken the ground. Application is usually made on
entire field of planting. Farmers have the choice of
"broadcasting" pesticide over the entire field or "band-
ing" it along narrow rows where the crop is planted.
Banding is becoming more popular as the cost of some
pesticides increase. Both the banded and the broadcast
materials may be left on the surface or incorporated
into the top few inches of the soil. Incorporation pro-
vides a means of isolation from direct exposure to the
weather and thus helps minimize potential loss and po-
tential damage to the environment.
A group of farm journals (1) surveyed their readers to
find the methods of application which farmers prefer.
Seventy percent of the farmers broadcast herbicides on
corn. Although the survey showed that an average of
77 percent of the farmers band their corn insecticides,
in three of the five states 90 percent of the farmers
follow this practice.
3-C
-------
In three states, 60 percent of the farmers band
herbicides on soybeans, while only 40 percent do so
in the other two states. Insecticides are seldom used
on soybeans, for there are few insect pests which prey
on this plant. This picture will probably change in
the future.
The contractor's survey found that in Iowa insecti-
cides are applied as granular materials. About 85 per-
cent of the farmers who use insecticides band them on
corn, while 73 percent broadcast. Often farmers
apply pesticides both ways to different fields.
Farmers are divided on the necessity of applying
insecticides to corn. Published surveys (1) of farmers
in the five state study area show that 42 percent use
insecticides on corn, ranging from 21 percent in Minne-
sota to 56 percent in Illinois. Eighty-nine percent of
the insecticides are usually applied in a band, with a
range of 76 percent to 97 percent. These materials are
usually applied at planting time, thus many are applied
to the entire crop as insurance and not later as needed
to control a specific pest.
The state extension service entomologists try to
predict the times when a particular insect pest will
invade the crops, but this is not always reliable.
The exact form of application is not known, so the
4-C
-------
pollution potential from drift of these materials is
not available.
Reduction of Loss
There are several methods which a farmer can use to
reduce run-off from his land and the concurrent loss of
pesticides. One of the easiest ways is to apply granu-
lar pesticides and cover them as soon as they are ap-
plied since there are problems inherent in spraying.
Harrold (2) has found that it can result in a 25 percent
loss of dieldrin through evaporation and drift in the
application process alone. By reducing run-off itself
through minimum tillage, and terrace of grass in natural
waterways in the field instead of cultivating the water-
ways, run-off carrying pesticides can be reduced.
Table 1-C shows the methods that farmers use to reduce
erosional losses from their lands. Local conditions
will determine which method is most used and combina-
tion of methods will obviously provide the maximum
benefit to the total farming operation.
About 87 percent of the farmers contacted by the
contractor do try to reduce erosion by some means.
However, their efforts are not coordinated nor maxi-
mized. The survey does indicate a knowledge and willing-
ness to cooperate.
5-C
-------
TABLE 1-C
PRACTICES UTILIZED BY FARMERS TO REDUCE
EROSIONAL LOSES FROM AGRICULTURAL LAND
Do you use any means to
reduce erosion?
No1
Yes2
Means used
1 . Contour plow
2. Minimum tillage
3. Other includes
grass waterways,
strip cropping,
terraces, stubble/
mulch
0}
•H
o
•H
,—{
H
11%
89
24
50
43
tf
o
H
16%
84
47
42
45
to
(0
to
c
K
1%
99
66
34
43
•P
o
CO
0)
c
c
•H
s
33%
67
21
47
47
•H
V-l
3
O
to
(0
•H
s
6%
94
53
50
42
No response is based on total contacts for each state
2
Yes response is based on total contacts who answered
yes for each state.
Figures do not add to 100% since many made multiple
entries.
6-C
-------
Drift and evaporation are two ways applied pesti-
cides can enter the non-target environment which can
be controlled to some extent. In the chapter on Route
to the Water Environment, Spencer's (3) arguments about
evaporation, Harrold's (2), Frost and Ware's (4) and
Caro and Taylor's (5) measurements of evaporation and
drift are cited. If the moisture in the field is pro-
per, the evaporation can be minimized. Drift is a prob-
lem locally, but as Frost and Ware (4) shows the pheno-
mena doesn't occur very far and unless a local target
exists, doesn't cause a problem.
Table 2-C shows the number of reports of drift in-
cidents in 1970 and 1971 by the county agents.
Banding of pesticides, reduces pesticide run-off by
reducing the area to which the material is applied, but
is difficult to do once the crop has emerged. Research
into ways of efficiently combining banding with culti-
vating could solve this problem.
Application Equipment
Applying the correct amount of pesticide is im-
portant. Any amount greater than the minimum required
only acts to damage the environment. To this end, we
asked farmers how their application equipment works
in terms of calibration of rates. The results are in
Table 3-C.
7-C
-------
TABLE 2-C
INCIDENCE OF PESTICIDE DRIFT AS REPORTED BY COUNTY AGENTS
Approximate
Incidences
1970
1971
Estimate of trend
en
•rH
o
e
•H
rH
rH
H
232
to
239+
401
to
414+
incr .
(0
>
0
H
221
to
241+
256
to
278+
incr.
CO
rt
CO
C
rt
W
318
to
319+
240
to
241+
deer.
(0
4->
o
10
0)
£
c
•H
s
141
to
152+
124
to
136+
deer.
•H
H
3
O
en
en
•H
S
36
to
36+
56
to
56+
incr.
8-C
-------
TABLE 3-C
PROBLEMS ENCOUNTERED WITH CALIBRATION,OF
EQUIPMENT USED TO APPLY PESTICIDES
Extent of Problem
1 . None
2- Few
3 . Some
4 . Many
(0
•H
o
a
•H
rH
rH
H
45%
22
27
6
to
£
O
H
29%
39
20
2
en
(0
CO
a
to
«
35%
43
13
—
(0
-P
o
01
-------
The contractor believes inspection of the problems
encountered with calibration of equipment is warranted.
Agents and retailers indicated that this problem comes
up every crop season. The farmers themselves feel they
have few problems with calibration. However the number
of farmers responding "few" or "some" to this question
suggests that there is a continual minor problem with
equipment. Many of the farmers contacted had ingenu-
ously modified their equipment to implement application.
It would appear that manufacturers and agricultural
engineers could contribute by attempting to fit more
uniform granular formulations to better engineered
application equipment.
The Applicators
Pesticide contamination of the environment can be
minimized by better application techniques and by a
better understanding of the problems and dangers of
pesticides. The farmer may apply pesticides himself
or he may hire a commercial applicator to do the job
for him. Both groups could benefit from instruction.
A high percentage of farmers apply their own herbi-
cides (Table 4-C). A smaller percentage apply their
own insecticides. Application by commercial or pro-
fessional firms is an alternative. We asked county
10-C
-------
TABLE 4-C
PROPORTION OF FARMERS WHO APPLY
THEIR OWN PESTICIDES
1. Apply Insecticides
Yes
No
2. Apply Herbicides
Yes
No
CO
•H
O
c
•H
rH
rH
H
61%
39
90
10
fO
[5
O
H
70%
30
78
22
w
rt
w
c
ti
49%
51
67
33
*
0
CQ
0)
c
c
•H
g
39%
61
89
11
•rH
S-l
J3
O
CO
W
•H
g
58%
42
70
30
11-C
-------
agents for their opinion of custom applicators. Table
5-C shows the response.
Agents contacted by the contractor gave some in-
teresting responses on the subject of commercial appli-
cation of pesticides. There appears to be a wide vari-
ation in the agents understanding and knowledge of the
people who apply these products on farms. If their
estimates are correct, a variation of 10 percent to 80
percent commercial application exists between counties
of any given state. The agents report (Table 5-$ that
slightly more insecticides than herbicides are commer-
cially applied. This is uniform over the region and
probably reflects the farmers knowledge of the hazards
in handling these compounds.
Agents from Illinois and Minnesota are aware of the
prevailing state law licensing applicators and said so.
Agents from Kansas apparently aren't sure whether or
not licensing is required. At least two agents from
Iowa think that a license is not required, (it is) and
one from Missouri thinks it is (it is not). See Ap-
pendix G.
Whether or not the commercial applicator has been
adequately trained or is qualified requires a subjective
j udgment. As one agent commented ". . .1 know he (the
applicator) has had training. . . but he doesn't act
12-C
-------
TABLE 5-C
COUNTY AGRICULTURAL AGENTS ASSESSMENT OF COMMERCIAL
APPLICATOR ABILITY AND TRAINING
1 . Approximate percent-
age of farmers who hire
someone to apply:
Insecticides
Herbicides
2 . Have they had train-
ing?
Yes
No
3. Is license required?
Yes
No
4. Are they qualified
in your opinion?
Yes
No
CO
-H
o
•H
r-H
iH
H
40%
25%
41
4
45
__
37
5
(0
Jj
O
H
30%
30%
25
5
41
2
32
13
w
(0
CO
d
W
70%
50%
30
9
21
15
25
14
4-1
O
W
0)
d
d
•H
S3
60%
50%
38
5
45
—
36
9
•H
J-l
^
O
CO
in
•H
S
50%
30%
13
9
1
18
10
11
13-C
-------
like it." The agents believe that most of the applica-
tors have had some training.
Qualifications of the applicator were viewed as at
least adequate by agents from Illinois and Minnesota,
as might be expected for they have good laws. Many
felt that a much larger number are not qualified in
Kansas, Missouri, and Iowa.
The agents were unanimous in feeling that appli-
cators should attain a certain level of knowledge be-
fore being allowed to apply pesticides.
Comments from some of the agents are included on
the following pages. No attempt was made by the con-
tractor to evaluate these comments.
Recommended Treatment
Most county agents from Illinois, Iowa, Minnesota
and Missouri feel that farmers do use the recommended
amounts of pesticides. Cost is the deciding factor.
Relatively more agents from Kansas feel recommendations
may not be followed (Table ,&-C) . Pesticide residues
may remain on a field over a year, but few farmers
take this fact into consideration when calculating the
amount of pesticide to apply. The agehts from Illinois,
Iowa, Kansas, and Missouri point out that no one has
given the farmer a method to make this evaluation. The
14-C
-------
MISSOURI
Definitely, especially with parathion.
Some are trained by dealers, but not well enough.
Most just add lines of products and learn application
by trial and error.
Yes, should have to pass a test
Not sure about how this should be done.
We have formulators who will mix anything! If results
are poor, applicator is blamed. I answer all negative.
Some are trained and are qualified, others are not.
We need laws that require training and periodic certi-
fication and laws with sharp teeth.
Most commercial applicators are well qualified - have
only a very few of them. Yes, a certain level of know-
ledge about pesticide dangers and methods of safe appli-
cation should be required.
Aerial applicators, especially should be trained in the
use of all chemicals that they may be applying. Each
year considerable 2,4-D damage is done to certain crops
by careless aerial applicators.
Most of our commercial applicators are well trained. I
feel they should be required to take test and achieve a
certain level of knowledge.
A practical training program and examination should be
considered.
The commercial applicators know what they are doing.
I would like to see a license for the application of
pesticides.
Many are experienced in the use of certain chemicals,
doing a good job. Some regulation is necessary but pre-
cuations should be taken to guard users cost. We can
legislate starvation.
- Herbicides and insecticides are broadcast. Most of the
work is done by the farmer in the normal years. How-
ever, in wet years, field work may lag and the farmers
may take more advantage of aerial application.
15-C
-------
ILLINOIS
- Yes, but they often have personnel that are not quali-
fied for custom work.
- Most custom operators are good. There are a few who do
not follow label instructions.
- The state requires custom applicators to pass exams.
- Operator should be current on information available.
- The law is quite difficult to police.
- To obtain a license, one must demonstrate a certain level
of knowledge.
- Too much damage from airplane spraying.
- Some operators are qualified, some are not. License is
issued to firm, not individual.
- Although they may be licensed in 1971, will they keep
up with all changes in 72?
- Depends upon training given person who actually does the
work.
- Some could use more practical instruction or ways of pre-
cautions.
- Knowledge of the pesticide and rates, effectiveness, etc.
- Supervisors are knowledgable, but some hired personnel
of commercial applicators are not adequately trained.
- Yes, particularly as to proper chemical use, safe use of
chemicals, and calibration procedures.
- Licensing is increasingly important.
- Each year some errors are made in amounts and location,
but this is a minimum. An applicator soon learns the
technique of application if he doesn't already know at
the beginning of the season.
16-C
-------
IOWA
- The person doing the application should have the license.
- Both Manager and employees should be required to pass
very difficult tests.
- There needs to be a strong deal training program each
year.
- Iowa should have better means of registration, licensing,
regulation.
- Level of knowledge should be required. (3 agents made
this reply).
- Should have proper knowledge pertaining to chemicals
used.
- Practical experience is important, some required know-
ledge is required for license.
- A lot of commercial appliers pass the test and still
aren't as well informed as they might be. However, no
knowledge is required for anyone putting on their own
pesticide.
- A big difference in knowledge of applicators, most are
qualified, some are questionable.
- A test could be the screening tool.
- The manager has to pass a s^ate test, the applicator
himself may not be adequately trained.
- They are sometimes caught between making a sale and
recommending what they know is best.
- They should know their equipment, and keep it in top
operating condition.
- Permits are used instead of license, manager, only,
operator not required, is trained by manager.
- Yes, in area of plants so treated for food and safety as
regards harm to people.
- The license makes them keep up to date.
17-C
-------
KANSAS
Several schools are offering courses in pesticide usage
which every commercial applicator should be required
to take.
All commercial applicators should have training in the
use of pesticides.
In some cases training should be required.
A person should know how to read and follow directions.
Some applicators tend to use poor judgment, applying
2,4-D with 70 mph wind velocity.
Attitude towards proper use is important. Competition
and poor attitude help them bend the rules. Most
dealers, though, are reasonably ethical.
Yes, especailly in determining selection of mixture of
chemicals.
Applicators don't have enough knowledge to be using
these chemicals.
Commercial applicators should be licensed and bonded,
farmers should be exempt.
Should have education and pass a definite exam.
Should receive university extension or N.S.D.A. in-
structions, with required attendance for 1 to 2 days.
Kansas is ahead of many other states.
Most are qualified in rural areas. Urban operators
are not really qualified.
Should know safety precautions, the amounts to mix,
damage that can be done.
- State legislation passed will require licensing of appli-
cators.
In most cases applicators are adequate.
18-C
-------
MINNESOTA
Some are well trained and well qualified, others are not,
Would be helpful - very few people in our county are
interested in being licensed.
- Not all are well qualified/well trained, but all think
they are experts in application, chemicals, and related
information.
Commercial applicators must have good working knowledge,
perhaps farmers too should be required to show they have
knowledge to handle materials safely.
Minnesota State Department of Agriculture requires
test to be passed before issuance of licnese. Sprayer
equipment must also be licensed if used commercially.
Knowledge should be required. Some are competent,
other not - hired help by retailers often not competent.
Absolutely, they should be knowledgable as to all as-
pects of health, safety, and environmental effects.
Those with experience and willingness to obtain infor-
mation are well qualified.
Yes, I believe a certain level is require to lessen
error which in turn cause problems in our public rela-
tions.
Yes, definitely. In Minnesota applicators need to take
a test.
The owner of the license is, some operators are not.
Yes, should have a good understanding.
Examination by state agricultural department is ade-
quate .
Actual operator does not need a license - only owner
of contractor of equipment.
Yes, it all helps, and they are learning more each year.
19-C
-------
TABLE 6-C
AGRICULTURAL AGENTS ASSESSMENT OF RECOMMENDED AMOUNT
OF PESTICIDE USED AND RESIDUE CALCULATIONS
1. Feel that farm-
er uses recommend-
ed amount of pesti-
cide
Yes
No
2. Take residue in-
to consideration
when calculating
amount to use in
current crop year
Yes
No
10
•H
o
c
•H
iH
rH
H
43
7
16
32
<«
&
o
H
41
3
16
30
CO
fO
m
C
rd
«
29
13
14
26
(0
-P
0
CO
Q)
C
C
•H
s
38
8
22
20
•H
M
3
O
CO
CQ
•H
a
28
8
9
11
20-C
-------
fanner is not at fault here; he simply lacks one of the
tools to make his operation more economical.
Professional agriculturalists have estimated that
much of the soil in Illinois is carrying dieldrin resi-
dues of up to 25 percent of that applied (as aldrin)
from year to year. Taking this into consideration could
amount to a substantial saving.
Many of the farmers from Minnesota appear to take
residues into account. The organic matter content of
the soil is higher and tends to predispose higher resi-
due levels. The farmers are made more aware of it.
It is sufficient to add that any consideration of
existing residue levels and the addition of these levels
to any current crop years pesticide use anticipated
could amount to a considerable savings to the environ-
ment and especially the aquatic ecosystem.
Summary and Conclusions
Pesticides are available to farmers as liquids,
wettable powder to mix with water, granular pellets,
and powder to be mixed into fertilizers. These ma-
terials are either broadcast over an entire field or
applied in rows or bands parallel to and centered on
the rows of crop. Banding is a means of reducing the
amount of pesticide needed. Typically only 7 inches
out of 30 inches are treated.
21-C
-------
An educational effort is called for, supported by
proper unbiased research into usable techniques for
identifying pest trouble areas, informing farmers of
potential trouble and how to implement effective counter-
measures. Remote sensing techniques may be useful.
With such a plan a scheme of total crop and pest manage-
ment can result in efficient operations and reduced
chemical cost.
A massive education program is also needed to in-
form pesticide users, applicators and those who may
come into contact of the dangers and hazards of pesti-
cides and to insure safe container disposal. Inten-
sive campaigns may be needed to convince the farmer
to properly dispose of his empty bags, cans, and other
containers and to protect himself while working with
the chemicals. Also needed is a systematic
collection and disposal system for used pesticide con-
tainers. Instructions need to take into consideration
field conditions and the potential difference in edu-
cation between writer and user. All directions should
be field tested just as new products for the home
kitchen are test marketed. The development of a pest
management system concept of pesticidie use for crop
protection without significant yield loss is discussed
in the following recommendations section.
22-C
-------
Recommendations
The contractor would like to recommend a massive
research effort to establish safe, effective, econo-
mical, practical solutions to the problem of empty
pesticide container disposal. In the interim labels
should be easily understandable so that directions
can be followed under actual field conditions.
To help minimize contact with the toxic chemicals,
plastic disposal gloves and a respirator mask, if
needed, should be attached to the outside of every
pesticide container holding chemicals for farm use.
The user would be inclined to use safety equipment
if it were there when he picked up the package.
Studies of effective agricultural techniques for
reducing environmental damage such as minimum tillage,
grass waterways, and banding of chemicals should be
made and results publicized along with an effective
implementation plan.
Mechanisms of pesticide entry into the aquatic en-
vironment, the potential harm of the practices such as
fall plowing should be publicized and alternative
counter-measures developed.
There are now few insect pests which bother soy-
beans. The probability is that they will increase.
The contractor feels that this would be a good area to
23-C
-------
institute a total management scheme.
The manufacturers of pesticides have a well es-
tablished system for promoting their products to the
farmers. The contractor queried pesticide retailers
throughout the study area to see if availability of
compounds is a problem. The answer most frequently
given was "seldom", somewhat fewer saying "occasionally."
The manufacturers have set up a distribution to get
the materials to the farmer when he wants them. They
also advertise heavily in the farm journals, often with
full color, double page spreads. The farmer is en-
couraged to use more, not less, material. The con-
tractor's survey of county agricultural agents found
that agents feel the farmers do not take pesticide
residue into account when calculating the required
amount of material for the current year. In Minne-
sota, where higher organic content soils tend to hold
more pesticide, the agents were evenly split about con-
sideration of soil pesticide residue. Economic feasi-
bility was considered to be the major limiting factor.
In the corn producing area, the use of insecticides
is well established. Pesticides tend to be used as
insurance of a good crop, rather than as a specific
remedy to a problem when it arises. The pressure the
manufacturers place on farmers, on retailers, and to
24-C
-------
some extent through county agents prevents a change
in use patterns from developing.
The contractor feels very strongly that a pest
management program should be used, for both herbi-
cides and insecticides to combine all agricultural
practices, including selected use of pesticides on
diagnosed problems such as corn rootworm in one
field when it occurs, rather than a blanket application
of aldrin to an entire crop at planting time. Soy-
beans would be a good place to develop such a scheme.
Insecticides are not used on soybeans, but might be
needed if conditions change. The approach needed is
active education of farmers to this idea, and rapid,
usable advice from the state agricultural departments.
This might be done through use of county agents, radio,
television and newspapers to describe each problem and
recommended solutions.
A systems approach to the pest problem could
bring about a major reduction in pesticide usage without
significant loss in crop yield or expense to the
farmer.
25-C
-------
LITERATURE REFERENCES
Agricultural Chemicals Survey Report, Iowa, 1970,
Research Department, Wallaces Farmer, Des Moines,
Iowa; Agricultural Chemicals Survey Report,
Indiana and Illinois, 1970, Research Department,
Prairie Farmer, Des Moines, Iowa; Agricultural
Chemical Survey Report, Minnesota, South Dakota,
and North Dakota, 1970, The Farmer, St. Paul,
Minnesota; Agricultural Chemicals Survey Report,
Missouri, 1970, Missouri Ruralist, Cleveland,
Ohio; and Agricultural Chemicals Survey Report,
Kansas, 1970, Kansas Farmer, Cleveland, Ohio.
Harrold, L. L., Research on Agricultural Pollution
in Ohio, 1971.
Spencer, W. F., "Distribution of Pesticides
Between Soil, Water, and Air", Pesticides in the
Soil, Michigan State University, 1970.
Frost, K. R., and G. W. Ware, "Pesticide Drift
from Aerial and Ground Applications", Agricultural
Engineering, 5_1, 460 (1970) .
Caro, J. H., and A. W. Taylor, "Pathways of Loss
of Dieldrin from Soils Under Field Conditions",
Agricultural and Food Chemistry, 19, 379 (1971).
26-C
-------
APPENDIX D
ROUTE OF PESTICIDES INTO WATER ENVIRONMENT
Introduction
This chapter details how pesticides enter the water
system from a point of application or from some other
point source. Since many insecticides and some herbi-
cides are insoluble in water they are not dissolved at
the site of contamination; instead they are physically
transported to permanent bodies of water by one of
several mechanisms. The most important of these mech-
anisms is adsorption into soil particles which are later
carried into water during run-off. Evaporation, drift
of spray and residue from empty containers also may be
important factors. The problem of container disposal
is developed and the chapter is highlighted by a study
of pesticides in one of the states, Iowa. The effective-
ness and limitations of monitoring data systems also are
discussed.
Soil Types
Soil is "a function of various environmental factors
rather than a product of the interaction of these fac-
tors." (1)
1-D
-------
Five factors operate in this function: (1) parent
material whose characteristics, texture, structure, and
chemical and mineral composition, affect the soils it
forms; (2) soil biota, vegetative cover and organisms
within the soil; (3) climate, including variations in
temperature and amount and kind of percipitation; (4)
topography, especially as it affects internal and ex-
ternal drainage and variations in climate; and (5)
time period in which pedologic processes have been
operating. These factors all interact with one another;
soil cannot be viewed as an end product of an operation
but rather as a dynamic process. Each factor is inter-
related to and interdependent. Variation in one factor
affects the others.
In the five state region there are seven types of
soils as shown in Figure 1-D, Alfisols, Entisols, His-
tosols, Inciptisols, Mollisols, Spodosols and Utisols.
Mollisols are predominant in the study area. The
surface layer is dark, with more than one percent
organic matter, and at least ten inches in thickness.
This layer and the B horizon have a base saturation of
more than 50 percent, with calcium the predominant base.
There is wide variation in characteristics which affect
erodability (such as texture and permeability).
The surface layer of Alfisols, the second most
2-D
-------
LEGEND:
u£'?l Alf isols
Entisols
[""""iHistosols
Inceptisols
\iMollisols
FIGURE 1-D
MAJOR SOILS IN FIVE STATE STUDY AREA
3-D
-------
important group, may be light in color or dark and less
than 10 inches thick. This layer has less than one
percent organic matter, with a recognizable B horizon of
clay accumulation and base saturation of more than 35
percent at a depth of 50 inches below the top of the
B horizon.
Utisols are found mainly in the state of Missouri.
They are low in bases and have subsurface horizons of
clay accumulation.
Entisols are more important in Kansas. They lack
distinctive horizons, and thus are either recently de-
posited soils, sandy soils which lack sufficient materi-
als which could weather into horizons, or soils en
steep slopes where erosion has limited development.
Most Inceptisols in the study are are found in
Minnesota. They differ from Entisols in that their
horizons are weakly developed. They may not neces-
sarily be older, since their horizons can develop
rapidly.
Histosols also occur mainly in Minnesota. They
are organic soils, peats and mucks. Unless artificially
drained, they are wet.
Spodosols are the third group found mostly in Minne-
sota. They have a subsurface horizon of an accumulation
of organic matter in addition to compounds of iron and
aluminum.
4-D
-------
Transport Routes
Several pesticide transport routes are known or
theorized to contribute to the presence of pesticides
in water. These routes are summarized and ranked in
Table 1-D.
TABLE 1-D
IMPORTANT PESTICIDE TRANSPORT ROUTES
(descending order of importance)
Route Importance
1. Adsorption + movement on
sediment Greatest
2. Application loss spray
operations Great
3. Drift Potentially Great
4. Empty Container Disposal Potentially Great
5. Evaporation from land Moderate
6. Solubility in water Low - Med for some
herbicides
7. Accidental Spills Low - Potentially
8. Deliberate Very Great
Many pesticides used by farmers are extremely in-
soluble in water; however some pesticides, including
herbicide derivatives have appreciable solubility and
direct solution may be a significant transport route.
Table 2-D shows the water solubility for three
important materials in the study area.
5-D
-------
TABLE 2-D
WATER SOLUBILITY OF SELECTED PESTICIDES (2) (3) (4)
Compound Solubility
Aldrin 11 ppb
Dieldrin 110 ppb
Atrazine 33 ppm
Soil Transport
The low solubilities indicated above ensure pesti-
cides cannot travel as a water solution, but must be
carried in suspension. This suspension may be chemical,
as in the emulsion used to apply the material, or., more
commonly, adsorped on soil particles carried by water in
the normal process of erosion.
Erosion is a geologic process occurring on all
land masses at all times. The force of gravity which
causes erosion is continually acts to level the earth's
land masses. Of the three erosion agents - water, wind,
and glaciers - water is currently the most important in
the study area.
The level of sediment a given amount of water can
carry is determined by the total amount of water and by
the water's route. Rainfall routes to a stream may be
divided into two categories, run-off and soil absorption.
6-D
-------
This study is concerned primarily with run-off.
The rate of precipitation and the moisture content
of the soil determine how much water will be absorbed.
The rest will run off. The energy of run-off - the
factor which determines the amount of sediment the water
can transport - is determined by slope gradient. The
steeper the hill, the greater the energy. Swith and
Wechmeier have developed a formula for predicting ero-
sion (5). Sediment transport is the most important
method of introducing pesticides into the water environ-
ment. Depending on flow conditions, this sediment may
be carried to a river or deposited on the bottom of a
waterway.
Sediments are measured infrequently due to the
tedious methodologies required to accurately determine
the range of materials present. Table 3-D shows several
locations where these measurements were made within the
study area.
The St. Louis figure indicates a loss of about 600
pounds/acre annually for the entire Mississippi watershed
above St. Louis. Since about 36 percent of the land is
cultivated, the loss is approximately 1700 pounds/acre.
*
A farmers' survey completed by the contractor showed
that few respondents (21 percent in the five-state region)
could estimate soil loss from their farms. The average
7-D
-------
TABLE 3-D
SELECTED SEDIMENT MEASUREMENTS
IN FIVE-STATE STUDY AREA
Amount of Sedi-
Place River ment (tons/year)
(6)
Mankato, Minnesota Minnesota 820,211
St. Louis, Missouri Mississippi 118,358,500
Red Oak, Iowa E. Nishnabotna 1,576,799
Chariton, Iowa Chariton River 56,209
Winfield, Kansas Walnut River 1,015,712
Arkansas Arkansas River 1,598,572
Wanego, Kansas Kansas River 1,104,402
loss reported was 0.56 inch/acre. This estimate of the
unknown is too high when considered with the time needed
to produce new soil, and is not corroborated by the sedi-
ment loss estimate derived from Table 3--D.
Another unknown is the level of pesticides expected
in the soil. Taylor (7) has reported the difficulty of
measuring pesticide residues in soils due to extreme
variability over even small areas. He found fold vari-
ation in measured pesticide concentrations of a 36
square meter plot. Table 4-D shows average values from
Aldrin, dieldrin and atrazine found in three of the
study states by the United States Department of Agri-
culture (8). Distribution of these values is shown
in Figures 2-D through 7-D .
8-D
-------
3/-3 40/12
/I 1.5/6 N6.5/8 1/4
6.3\6.3 69/17
/2 1/21 9/10.5 13/13 2'Y8
1/4
4/2
2.5/4 20/33 V .
/I 2/6 .5/6 2.5/20
FIGURE 2-D
CONCENTRATIONS OP ALDRIN/DIELDRIN FOUND
IN IOWA SOILS (in parts per million)
-------
FIGURE 3-D
CONCENTRATIONS OF CHLORDANE/ATRAZINE FOUND
IN IOWA SOILS (in parts per million)
-------
FIGURE 4-D
CONCENTRATIONS OF ALDRIN/DIELDRIN FOUND
IN MISSOURI SOILS (in parts per million)
-------
FIGURE 5-D
CONCENTRATIONS OF CHLORDANE/ATRAZINE FOUND
IN MISSOURI SOILS (in parts per million)
-------
FIGURE 6-D
CONCENTRATIONS OF CHLORDANE/ATRAZINE FOUND
IN ILLINOIS SOILS (in parts per million)
13-D
-------
/4 27/36 714
15/34.5 .3/3.3
28/80
78.7/22.7 ^ 15/7.5
75/124 //g
3/5.5 ' 4.3/11.3
/4.5 22.3/14.8
20.3/14.3 3.5/5
67/19 -2.5/5
72/15.5 19.5/11.5
5/21 15/6
FIGURE 7-D
CONCENTRATIONS OF ALDRIN/DIELDRIN FOUND
IN_ItiIMOIfiISOII»S- (in- parts-per • miiilon)
14-D
-------
TABLE 4-D
AVERAGE SOIL PESTICIDE VALUES
State Compound Value (ppm)
Illinois Aldrin 0.147
Dieldrin 0.138
Missouri Aldrin 0.133
Dieldrin 0.129
Iowa Aldrin 0.07
Dieldrin 0.107
Atrazine 0.05
When these figures are related to measured sediment car-
ried in the Mississippi at St. Louis, resulting calcula-
tions show that about 14 tons of dieldrin are annually
carried in the Mississippi at St. Louis. However, mea-
sured sediment values for dieldrin in Iowa (9) range
from 1.7 to 35 ppb, with an average of 11.1 ppb. If
this amount of dieldrin was in sediment at St. Louis,
the total carried annually would be only 260 pounds
as compared to 14 tons calculated above.
Better measurements are needed before more accu-
rate conclusions can be drawn about the quantity of
pesticides in the water environment. There are no
15-D
-------
obvious effects to man from this level of material as
shown in the impact chapter of this report. It has been
shown (9) that factory workers producing these materials
are exposed to greater levels of these compounds without
harmful effects (10).
Certain features of a soil make it prone to erosion.
Martin, et al. (11) report that high organic matter and
finer particles of soil tend to be eroded first and
fastest. The less dense organic material is in higher
concentrations at the surface and tends to be subject to
heavier erosion. Organic matter in the soil traps pesti-
cides tightly; thus erosion mechanisms and pesticide
chemistry combine for a greater potential impact on the
environment. Measurements were taken of 950 pounds per
acre of organics lost in one year, and 668 pounds after
erosion had progressed.
Some Minnesota soils have a 3 percent or more
organic content. This soil holds greater amounts of
pesticides thus reducing the amount required for appli-
cation after the first year.
Many factors may influence the soil's capacity for
pesticides including organic content, pH, colloidal day,
catien exchange capacity, and moisture retention. Usually
organic carbon correlated better with pesticide levels
than any other parameter. However in some soils with
16-D
-------
some pesticides the parameters may be insensitive to the
capacity (12) .
Total erosion has been estimated at 4 billion tons,
or 4 million acres 6 inches deep of good topsoil (13).
Oschwald (14) reports a total carnage of $25 million a year
due to sediment in the Upper Mississippi alone, with
almost $6 million lost in reservoir capacity and river
dredging operations. Thus erosional soil loss is a major
problem without consideration of the soil as a pesticide
carrier. The Soil Conservation Service of the Department
of Agriculture has created the "universal Soil Loss Equa-
tion" to help a farmer estimate and control this loss.
About 35 parameters are evaluated and fed into an equa-
tion to predict soil loss in tons per acre per year.
However, the equation cannot be used to estimate sedi-
ment entering a watershed since it was developed as a
measurement of land loss, not watershed gain. The con-
tractor did not contact any farmer mentioning applica-
tion of this equation to his land.
Quantity of Pesticides in the Environment
A fraction of the pesticide applied to an agricul-
tural field under specific circumstances may be moved
into the water environment. The pesticide travels pre-
dominantly with sediments in which it is adsorbed (15)
(16) (17) . Direct contamination of water by free pesti-
17-D
-------
cide is seldom a problem since as a group, pesticides
are essentially water insoluble organic compounds.
Transport of pesticides is further detailed in the
"Soil Transport" section of this report.
Other Transport Routes
The contractor's surveys found that farmers apply
the largest portion of their yearly pesticide dose when
run-off is most likely to occur. Figure 8-D shows a clear
peak in May, as indicating the time of year pesticides
are applied. The retailers surveyed show a slight tail
on the sales for post-emergence use, but this is rela-
tively insignificant in the total use pattern. However,
the 30-year discharge patterns for three rivers in Iowa,
which the United States Geological Survey (6) terms repre-
sentative of river flows in that state, show peaks (bars
on graph, Figure 8-D for May of each year), the same
month farmers apply pesticides. Since high discharge
means large run-off from the fields with corresponding
high sediment transfer rates, from an environmental stand-
point, pesticide application comes at the worst possible
time of the year. This same phenomena is true in each
of the other study states.
Minor transport routes to the water include wind-
carried drift from application directly to the water,
18-D
-------
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— — Insecticide - Farmer
19-D
TIME OF APPLICATION
OF PESTICIDES
-------
and evaporation of active material and subsequent preci-
pitation with rain. Generally, drift is a minor problem
because of the short distances involved. However this
could be a serious local problem if a water body was
located within drift distance.
Lloyd Harrold (15) in Ohio has measured loss from
drift of spray-applied dieldrin. He reported a 25 per-
cent loss in material application, although it was
into 3 inches of soil the day of application.
Although there is no proof this material reached water,
it did leave the field of application and a large por-
tion did evaporate.
After evaporation, pesticide vapor may attach to
dust particles or collide with falling water particles
and enter the water. Pooler (18) has measured atmos-
pheric pesticide concentration and found that "direct
continental scale spreading from a source can be fairly
rapid, but global scale spreading should be much slower."
Frost and Ware (19) measured drift produced in
aerial spraying as opposed to ground spraying and found
that the former produced four to five times as much
drift as the latter. On the ground one large nozzle
produced less drift than three smaller units while cover-
ing the same area.
Thus, spraying from the ground using equipment with
20-D
-------
a few large nozzles rather than several small ones pro-
duces less drift.
Lloyd (15) , Caro and Taylor (16) of Ohio also mea-
sured evaporation of dieldrin from farm land and found
that 2 percent of the dieldrin evaporated during the
year of application. Spencer (18) confirmed these find-
ings for dieldrin and lindane, and theorized the eva-
poration in terms of competition between water in the
soil and pesticides for available adsorption sites with-
in the soil. When the soil is very dry, pesticides
adhere to soil particles and remain in one place. But
when the soil becomes slightly wet, water displaces
lindane or dieldrin, and pesticide vapor pressure and
volatility increase with resulting loss from soil into
the atmosphere. This theory could be significant in
terms of the total loss of pesticides from soil.
Table 1-D (see "Transport Routes," this chapter)
shows that atrazine has a solubility of 33 ppm, which is
significantly greater than that of chlorinated hydro-
carbon insecticides. The result is that some atrazine
may be leached from the soil by water and carried as a
water solution. Ritter (20) at Iowa found that:
Generally pesticide concentration [was]
higher in sediment than water but greater
losses [were] associated with the water
phase than the sediment because of the
greater volume of water.
21-D
-------
A storm producing 1.15 inches of rain one week
after an atrazine application resulted in a 15 percent
loss of applied material on contour plowed land, and 2.2
percent loss on ridge plowed land. As suggested by
Ritter, ridge plowing of corn could reduce pesticide
loss considerably. Atrazine is not extremely toxic to
fish and its effect on the aquatic environment is mini-
mal.
After insecticides are applied to the soil, they
must last long enough to be transported to the water
to cause a problem. If rapid break down of compounds
occurs and the broken down compounds are not toxic
there is no problem to the environment.
Figures 9-Df 10-D-, H-D/ ]2-D (21) shows the persis-
tence of several selected pesticides. At least one of
these, telodrin,is no longer manufactured because of
its high degree of toxicity. However it also degrades
quickly and completely, not merely reverting to another
more persistent form as do aldrin/dieldrin and hepta-
chlor/heptachlor epoxide.
Within eight weeks some compounds degrade com-
pletely while others do not deteriorate at all. Based
on the persistence factor, the most desirable choice
of pesticide from an environmental viewpoint is the
material which degrades rapidly and is non-toxic.
22-D
-------
100
0 -
4 5
Time, Weeks
FIGURE 9-D
RETA
1025
23-D
MEASURED PERSISTENCE
OF PESTICIDES IN
RIVER WATER
ORGANOCHLORINE
COMPOUNDS
-------
100
90
80
70
c
°c
'6
I 60
50
O
O
o
;| 40
O
30
20
10
0 -
Dimethoafe
Malathion
345
Time, Weeks
8
FIGURE 10-D
RETA
4
1025
24-D
MEASURED PERSISTENCE
OF PESTICIDES IN
RIVER WATER
ORGANOPHOSPHORUS
COMPOUNDS
-------
0 -
345
Time, Weeks
RETA
1025
FIGURE 11-D
25-D
MEASURED PERSISTENCE
OF PESTICIDES IN
RIVER WATER
CARBAMATE COMPOUNDS
-------
100
90
80
70
o>
c
'£
'6
I 60
•o
o
«• 50
o
U
30
20
10
345
Time, Weeks
RETA
1025
FIGURE 12-D
26-D
MEASURED PERSISTENCE
OF PESTICIDES IN
RIVER WATER
COMPARISON OF TYPES
-------
Future registration of materials should take these
factors into consideration, and promote compounds such
as carbanates, which meet these criteria.
Intensive Case Study Area
Information on pesticides in water soils and re-
lated ecosystems was gathered through professional con-
tacts. Primary contacts were Dr. Robert Morris of the
State Hygenic Lab, Dr. Donald McDonald, Associate Pro-
fessor of Environmental Engineering and of Preventive
Medicine and Environmental Health, Dr. Keith Long,
Chief of Environmental Toxicology Section, Institute of
Agricultural Medicine and Dr. David Mick, Community
Pesticide Studies, Institute of Agricultural Medicine
of the University of Iowa, Iowa City.
Dr. McDonald found that pesticides free in water in
the Iowa City area generally were in the low parts per
trillion (ppt) range, the bottom silts in the parts
per billion, and periphyton up to 12 parts per million
(22). Aldrin was found in amounts up to 28 ppb in muds
during July. DDT was found most frequently in mud, with
positive results in 13 out of 19 samples tested. Highest
concentrations of pesticides usually occurred in July,
August, September, and October following application
in May and June as shown in the application section
27-D
-------
Figure 8-D). There were no pesticides found in water in
November and only trace amounts in January-March.
Cherryholmes (23) made an extensive study of Clear
Creek, a tributary entering the Iowa River just below
Coralville Reservoir. He found pesticide levels cor-
related with turbidity, indicating that adsorption is
the major transport mechanism. Samples were taken during
and after precipitation periods to test the effects of
heavy run-off on water quality. Although levels were
low (3-37 ppt in water), they were detected only at
times of high run-off (2140 CFS) and high turbidity
(600 JTU). In contrast, at a flow of 132 CFS, which is
still above average, and a turbidity of about 15 JTU,
no pesticides were measured.
Metha (24) reported the Iowa River below the
Coralville Reservoir had less pesticides than those
portions in or above the reservoir during the high
pesticide level period of July through September. This
may have been due to settling out of sediment in the
still water behind the dam. Metha found heptachlor and
its metabolites only twice in his study, although it
is used widely in Iowa; in a survey by the contractor the
estimated 1971 use in the state was 480,000 pounds
active.
Appleby (25) studied Iowa sources of dieldrin and
28-D
-------
found increases below such point sources as pesticide
formulation plants, aldrin-fertilizer blending plants,
home bases of aerial applications of aldrin, and wool
mothproofing operations with dieldrin. The results of
his study are shown in Figure 13-7). He reports an
increase in dieldrin in catfish below each of these
point sources.
Available data is not sufficient to point to any
one source, such as the wool mills at Amana, as the
main dieldrin source in Coralville Reservoir. There are
many other sources, such as small watersheds, which
could contribute to the reservoir; also, the stilling
effect of the impoundment and consequential settling
out of sediment allow fish and other aquatic forms to
be exposed to greater amounts of material.
In the southwest part of the state on the Nishna-
botna River, formulation plants do seem to lead to a
marked increase in fish levels from 400 ppb above the
plants to 1600 below. This same trend is apparent be-
low Des Moines in Red Rock Lake. This situation could
warrant a ban on eating catfish in certain regions of
the state since these levels exceed the FDA recommended
limits. (25)
McDonald also measured pesticides in fish in the
Cedar River (26), and Mississippi River (27), water
29-D
-------
POTENTIAL SOURCES OF PESTICIDE RESIDUES IN IOWA WATERWAYS
o
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|N- pu /^S>iy Vfj — ^..^f.;, Ut^_.-k^iJJ-i ,p^.JT^ft^L. J^^J^Vl£-B«(^^^
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JT (;-""• Jj "^^i^V"i'':"'\"''iy^»^ll|wiii||i'1i^i||'p!^ws'^a|l'f "'I'1" ^f"^v"^;'Sc/1^~^''
^W^^u-s?" l'^p--/^W»Q)tt™^wa»^''^TCM^
-------
and fish. Dieldrin is found most often with concen-
trations of about 3.5 parts per trillion maximum in
the water, and fish samples containing about 20 parts
per billion with a record peak of 400 ppb.
In 1967, Morris (17) studied two farms shown in
Figures 14-D and 15-D. Background readings were 0.01
ppb or less. The fields marked were treated with 2
pounds of active ingredient per acre before treatment
and planting. After a heavy rain (4 inches in 12
hours) about 1 month later numerous water and sediment
samples were taken. Figures shown indicate the amount
of pesticide found in run-off. Much of the aldrin
applied had been converted to dieldrin by that time;
it was assumed that since the diazinon was not detect-
ed, it had degraded. Sediments in the water were
analyzed and found to contain up to 170 ppb dieldrin.
Morris found that
From the amount of solids and the con-
centration of aldrin and dieldrin on
the solids it can be seen that the
total amount of insecticides carried
by these solids is about equal to the
amount carried by the water.
Even though the concentration of
pesticides is much greater in the
solids than in the water, the
weight of the water is so much
greater than that of the solids that
the total amounts of pesticides car-
ried by the solids and by water were
about equal in samples described in
31-D
-------
11
FAPM No. I
Pesticides in Water
_Part8 Per Billion
Faro I
Dieldrln
Alelrin
Inches of
Jfctlafall
Drain I
Drain II
Creek A
Rapid Creek
Xova River
0.10
0.20
0.19
0.11
0.01
* None detected
FMH...I
0.02 9:30AH 3
0.06 9:30AM 3
0.06 10:OOAM 3
0.04 6:45AM 2.5
* 10:30AM 3.5
Pesticides in Solids
Parts Per Billion
Pielurin
Drain I
Drain II
Creek A
Rapid Creek
lova River
143
170
150
63
28
97
120
131
29
15
0.22
0.19
0.24
0.16
0.05
32-D
-------
12
FARM Ho. E
Pesticides in VaCer
Parts Per Billion
Dieldrin Aldrln Dlrjrlron Time
Inches of
Enltifnll
Praln III
Creek B
Creek C
* None detected
*
0.08
0.13
*
0.01
0.06
*
*
*
12 noon
12 noon
12 noon
Pesticides in Solids
Parts Per Billion
Farm it
Drain III
Creek B
Creek C
OxeWrir.
*
142
18
Aldrln1 '
^
137
2
Dinilnon
*
*
7. Solids
0.28
0.10
0.27
33-D
-------
this report. Possibly some of the
insecticides in the water were car-
ried, by soil particles which were
small enough that they did not set-
tle out in 24 hours.
The data in this report make it
clear that pesticide concentration
in surface water due to agricultural
run-off is much higher in the small
streams which are directly fed by
the run-off water.
A significant portion of the pesti-
cides are adsorbed on solid soil
particles which will settle out on
the bottom of the streams and
rivers. There the pesticide may
be partially desorbed and taken
into the water slowly over a long
period of time. It will also be
slowly degraded to less toxic pro-
ducts over a period of time (17).
The fate of these materials is questionable.
McDonald, Cherryholmes and Metha found only parts per
trillion in the Iowa River. In the Mississippi River
dieldrin was found in the parts per billion range in
1964, 1965, and 1966 but was not detected in 1967 near
the time of Morris' 1967 measurements.
Metha (24) traced some pesticides through algae
measurements and found 7800 ppb aldrin, and in one
sample 79,000 ppb of chlordane; although dieldrin shows
up in water and fish samples, he does not report diel-
drin in any of his algae work. Sediment accumulates in
the bottom as the water slows down, where algae and
bottom feeders pick up the materials. Rough fish and
34-D
-------
catfish feed on bottom feeders and the biomagnifica-
tion chain begins.
These pesticide studies in Iowa have had several
effects. One outcome was a law enacted in 1971 limit-
ing soil erosional losses to prevent transport of soil
to the waterways. The law encourages better farming
practices to prevent soil loss.
There has also been a suggestion that catfish from
certain parts of the state not be eaten (25). Per-
haps the most striking effect of these studies is the
incomplete pesticide picture developed. The work to
date has been useful in defining the problem. However,
a comprehensive study is needed to examine all factors
and routes involved in pesticide operations to deter-
mine the significance of pesticides rather than merely
their concentrations. Morris (17) (28) concluded that
Coralville Reservoir and the Mississippi in Iowa would
be good starting places for such a study. He has
called pesticide levels in fish a "dismal situation"
in Iowa and concludes
Soil erosion must be reduced with all
dispatch and immediate toxicants
[dieldrin, aldrin] is indicated. . .
(in order that) we may still have
a sport fishery potentialin Iowa (17).
35-D
-------
Methods of Disposal of Pesticide Container and Excess
Pesticides
One of the biggest potential problems associated
with the use of pesticides is the disposal of their con-
tainers. At present there is no efficient disposal
method. The recommended procedure is to bury them in
an area where the pesticides are not likely to leach
to ground or surface waters.
Farmers were surveyed to determine disposal me-
thods utilized. Of those responding, 62 percent buried
them, and 16 percent disposed of them in the town dump.
Twenty percent reported washing containers, presumably
for reuse.
All of these disposal practices are potentially
dangerous to the environment. Burning containers is
recommended by manufacturers, but often the incinera-
tion temperature is not high enough to accomplish suffi-
cient degradation. The ash residue may be washed into
a stream or pond during spring or summer rainfall.
Burying the containers appears to be the least harmful
of all disposal techniques, if care is taken to assure
that containers are buried where contamination of
ground or surface waters cannot result.
Disposal of containers in a town dump has similar
drawbacks to burying. Leakage of contaminants other
36-D
-------
than pesticides to groundwater is often a problem in
landfills. Pesticides disposed of in landfills where
leakage occurs can be predicted to contaminate ground-
water although this has not been proved. Reuse of con-
tainers has obvious harmful effects and farmers are
warned against such use by the manufacturers.
Disregard or ignorance by the farmers surveyed of
possible environmental damage through container dis-
posal is evident from Table 5-D.
Farm agents in the five state area were asked if
they felt manufacturer's instructions for container dis-
posal were understandable and practical (Table 6-D) .
Most agents responding felt the application instructions
were understandable and practical to follow for proper
usage. However with regard to applicator's safety the
agents agreed the instructions were understandable but
were almost evenly divided as to whether instructions
were practical to follow. When queried about container
disposal instructions, they were divided as to whether
the instructions were understandable, but felt strongly
that disposal instructions were impractical.
Container disposal continues to be a major environ-
mental problem. Although burning is specifically indi-
cated by most manufacturers, reliable estimates suggest
temperatures obtained in open burning are insufficient
37-D
-------
TABLE 5-D
METHODS OF DISPOSAL OF PESTICIDE CONTAINERS
Method Used
1. Throw in trash
for pick-up
2 . Burn
3. Wash and store
4 . Wash and use as
container
5 . Dump in ditch
or field edge
6 . Bury
7 . Other
w
•H
o
-H
.H
H
H
14%
65
40
10
8
12
24
£
o
H
20%
70
8
3
8
5
21
CO
rfl
CO
c
(«
«
22%
51
9
11
13
11
29
fd
-P
O
CO
-------
TABLE 6-D
MANUFACTURERS INSTRUCTIONS ON THE PESTICIDE PACKAGE
AS ASSESSED BY COUNTY AGRICULTURAL AGENTS
State and Problem
Illinois (45) l
Proper Usage
Safety to Man
Container Disposal
Iowa (47)
Proper Usage
Safety to Man
Container Disposal
Kansas (41)
Proper Usage
Safety to Man
Container Disposal
Minnesota (44)
Proper Usage
Safety to Man
Container Disposal
Missouri (37)
Proper Usage
Safety to Man
Container Disposal
Are the instruc-
tions clear
enough for every-
one to understand
YES
77%
87
56
79
76
47
79
82
57
71
77
45
70
62
35
NO
23%
13
44
21
24
53
21
18
43
29
23
55
30
38
65
Are the instruc-
practical to
follow?
YES
51%
49
43
79
53
35
75
68
36
71
66
37
59
54
25
NO
49%
51
57
21
47
65
25
32
64
29
34
63
41
46
75
Number in parentheses indicates the number of farm agents
contacted in each state.
39-D
-------
facturers it is little used by farmers. The reasons
most often given are that it is difficult to imple-
ment.
A large number of farmers still continue to uti-
lize old containers for general purpose farm pails
despite specific warnings against such practices.
There seems to be no economical way to detoxify
many of these materials and avoid eventual environ-
mental contamination. Incineration at temperatures in
excess of 1625°F should be sufficient to oxidize the
compounds at municipal incineration units. A portable
incineration unit might be obtained through a pesti-
cide tax to collect containers and dispose of the
material property. Sufficient information is avail-
able on the success of portable (29) or fixed
incinerators (30) to warrant further research in this
area, including a thorough study of the transportation
and materials handling aspects of the problem.
Monitoring Data
Measurement of pesticide levels in water or sedi-
ment or the speed with which these materials move down
a watershed is difficult due to a lack of data. Sample
analysis is costly, and there are not many places where
measurements are made throughout a watershed. Many mea-
40-D
-------
surements are made on a three or six month schedule; no
additional effort is made to measure pesticides during
peak flow conditions which coincide with periods of maxi-
mum pesticide concentration. Some measuring periods
skip the June sample, which Figure 8-D (see Chapter 3)
shows as the most likely time to encounter pesticides.
Bills currently before Congress (HR56, S681), would
set up a National Environmental Data Bank to allow
better access to collected information. Despite oppo-
sition to the bill by the Council on Environmental
Quality and Environmental Protection Agency, its spon-
sors feel current operations do not allow for efficient
retrieval of information.
Congressmann John D. Dingel (D-Mich.),
author of HR 56, said he was appalled
at the amount of money spent on re-
search that is poorly organized and
stored, and which is difficult to
retrieve.
He said there already is a vast
amount of useful information stored
in federal files "in essentially un-
retrieval form" and noted that the
amount of this material will in-
crease within a few years. A system
to reduce the amount of information
that would have to be reproduced
and distributed would reduce the
administrative burden on the Govern-
ment and result in substantial sav-
ings, he contended. (31)
Most analytical data is stored in STORET, a data
retrieval system containing all Federal analytical
41-D
-------
work as well as some state and private information.
However non-federal inputs to STORET are voluntary and
often not made due to lack of money or personnel.
STORET does contain some data on water measure-
ment from the stations shown on Figure 16-D, but major
drawbacks to the collection system negates the value
of these data. Table 7-D shows all STORET data (32)
on pesticides for selected stations along the main-
stream of the Mississippi, Missouri, and Kansas Rivers.
Sampling dates used do not facilitate the tracing of
pesticides downstream nor the location of pesticide
sources. It is possible to infer that the Kansas River
contributed herbicides to the Missouri River since
herbicides were detected in the Missouri below the
mouth of the Kansas in 1969 and 1970, but not above the
mouth in 1970 or 1971, and they were detected at Topeka,
Kansas in 1969 and 1970. But because no measurements
were made above the Kansas for the same period it is not
possible to certify that the herbicide source is the
Kansas River.
There are almost no values reported for sediment
which might help answer questions about pesticides
carried by this transport method.
Pesticide monitoring is vital to increase know-
ledge about this source of potential danger to man.
42-D
-------
MINNESOTA
FIGURE 16-D
STORET DATA POINT LOCATIONS-
•Reported in Table 7-D
A Not Reported in Table 7-D
43-D
-------
Table 7-D
TYPICAL MONITORING DATA FROM STORE! SYSTEM
LOWER MISSOURI RIVER
Pesticide Compound
Sampling Location
I Date
Omaha, Nebr.
3/9/71
Nebraska City, Nebr.
j^ 9/17/70
.^ 2/11/71
i 3/16/71
0 4/8/71
St. Joseph, Mo.
3/9/71
Miami, Mo.
10/21/69
3/10/70
5/20/70
Herman, Mo.
10/28/69
2/5/70
5/26/70
8/18/70
12/28/70
3/16/71
St. Louis, Mo.
3/12/71
Kansas River at
Topeka, Kansas
12/11/69
3/17/70
6/12/70
Aldrin
ug/1
O.OOOE
O.OOOE
O.OOOE
O.OOOE
O.OOOE
O.OOOE
O.OOOE
O.OOOE
O.OOOE
0.030E
O.OOOE
O.OOOE
0.010E
O.OOOE
O.OOOE
O.OOOE
O.OOOE
O.OOOE
O.OOOE
O.OOOE
BHC
ug/1
O.OOOE
O.OOOE
O.OOOE
O.OOOE
O.OOOE
O.OOOE
O.OOOE
O.OOOE
O.OOOE
O.OOOE
O.OOOE
O.OOOE
O.OOOE
..
O.OOOE
O.OOOE
O.OOOE
O.OOOE
O.OOOE
O.OOOE
Chloro-
dane
ug/1
O.OOOE
O.OOOE
__
O.OOOE
O.OOOE
O.OOOE
—
— -
__
O.OOOE
—
— —
O.OOOE
O.OOOE
O.OOOE
O.OOOE
O.OOOE
—
—
0.020E
DDD
ug/1
O.OOOE
0.010E
O.OOOE
O.OOOE
O.OOOE
O.OOOE
O.OOOE.
O.OOOE
O.OOOE
O.OOOE
O.OOOE
O.OOOE
O.OOOE
O.OOOE
O.OOOE
O.OOOE
O.OOOE
O.OOOE
O.OOOE
0.010E
DDE
ug/1
O.OOOE
O.OOOE
O.OOOE
O.OOOE
O.OOOE
O.OOOE
O.OOOE
O.OOOE
O.OOOE
O.OOOE
O.OOOE
O.OOOE
O.OOOE
O.OOOE
O.OOOE
O.OOOE
O.OOOE
O.OOOE
O.OOOE
O.OOOE
DDT Dieldrin
O.OOOE
0.010E
O.OOOE
0.010E
O.OOOE
O.OOOE
0.010E
O.OOOE
O.OOOE
0.020E
O.OOOE
O.OOOE
0.010E
O.OOOE
0.010E
O.OOOE
O.OOOE
O.OOOE
O.OOOE
0.020E
O.OOOE
O.OOOE
O.OOOE
0.010E
O.OOOE
O.OOOE
0.010E
0.010E
0.010E
O.OSOE
O.OOOE
O.OOOE
0.020E
O.OOOE
O.OOOE
O.OOOE
O.OOOE
O.OOOE
O.OOOE
0.010E
Endrin
O.OOOE
O.OOOE
O.OOOE
O.OOOE
O.OOOE
O.OOOE
O.OOOE
O.OOOE
O.OOOE
O.OOOE
O.OOOE
O.OOOE
O.OOOE
O.OOOE
O.OOOE
O.OOOE
O.OOOE
O.OOOE
O.OOOE
O.OOOE
HCHLR
O.OOOE
O.OOOE
O.OOOE
O.OOOE
O.OOOE
O.OOOE
O.OOOE
O.OOOE
O.OOOE
O.OOOE
O.OOOE
O.OOOE
O.OOOE
O.OOOE
O.OOOE
O.OOOE
O.OOOE
O.OOOE
O.OOOE
O.OOOE
HCHLR- Para-
EP Malathion thion Diazinon
uq/1 ug/1 ug/1 ug/1
O.OOOE
O.OOOE
O.OOOE
O.OOOE
O.OOOE
O.OOOE
O.OOOE
O.OOOE
O.OOOE
O.OOOE
O.OOOE
O.OOOE
O.OOOE
O.OOOE
O.OOOE
O.OOOE
O.OOOE
O.OOOE
O.OOOE
O.OOOE
O.OOOE
__
O.OOOE
O.OOOE
O.OOOE
O.OOOE
—
__
~~
—
—
_~
—
_—
__
O.OOOE
O.OOOE
—
--
—
O.OOOE
_„
O.OOOE
O.OOOE
O.OOOE
O.OOOE
—
__
__
—
—
_._
—
__
__
O.OOOE
O.OOOE
—
—
—
O.OOOE
__
O.OOOE
O.OOOE
O.OOOE
O.OOOE
—
__
__
~
—
__
—
__
..
O.OOOE
O.OOOE
—
.-
—
M-Para-
thion
ug/1
O.OOOE
— -
O.OOOE
O.OOOE
O.OOOE
O.OOOE
—
--
-—
-—
—
-—
—
— -
— —
0 . OOOE
O.OOOE
—
—
— "•
2,4-D 2,4,5-T
O.OOOE
O.OOOE
O.OOOE
O.OOOE
O.OOOE
0.070E
0.060E
0.110E
0.110E
O.OSOE
0.020E
0.190E
0.040E
O.OOOE
O.OOOE
0.060E
0.060E
O.OOOE
O.OOOE
0.580E
O.OOOE
O.OOOE
O.OOOE
O.OOOE
O.OOOE
O.OOOE
0.010E
O.OOOE
O.OOOE
O.OSOE
0.060E
0.030E
0.040E
O.OOOE
O.OOOE
0.090E
0.040E
0.020E
0.010E
0.150E
Silvex
O.OOOE
O.OOOE
O.OOOE
O.OOOE
O.OOOE
O.OOOE
0.010E
0.020E
0.020E
0.100E
0.030E
0.040E
0.010E
O.OOOE
0.370E
0.020E
0.010E
0.010E
O.OOOE
O.OOOE
-------
Table 8-D
TYPICAL MONITORING DATA FROM STORET SYSTEM
MISSISSIPPI MAINSTEH - MOST RECENT DATA
Pesticide Compound
01
1
O
Sampling Location
t Date
Below St. Paul
11/3-11/10/64
9/22/65
9/13/66
9/29/67
Dubuque , Iowa
9/23/64
9/22/65
9/12/66
10/2/67
Burlington, Iowa
9/23/64
9/22/65
9/13/66
9/29/67
East St. Louis, 111.
9/23/64
9/22/65
9/13/66
9/29/67
Cape Girardeau, Ko.
9/23/64
9/22/65
9/13/66
9/29/67
Aldrin
ug/1
0.000
0.000
0.000
0.000
O.OOON
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
BHC
ug/1
0.000
0.000
0.012
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
Chloro-
dane
ug/1
--
•--
0.000
—
— -
--
0.000
~
--
—
0.000
—
— —
— -
0.000
~
—•
"»
0.000
—
ODD
ug/1
o.ooo
0.000
0.600
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
DDE
ug/i
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
O.OOON
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
DDT Dieldrin
ug/1
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
O.OOON
0.000
0.000
0.000
0.000
O.OOON
0.000
0.000
0.000
0.000
0.000
0.000
Ug/1
O.OOON
O.OOON
0.000
0.000
0.000
0.024
0.002
0.000
0.004
0.009
0.007
0.000
O.OOON
o.oos
O.OOON
0.000
0.008
0.000
0.009
0.000
Endrin
ug/1
0.000
0.000
0.000
0.000
0.000
0.000
0.003
0.000
0.004
0.000
0.000
0.000
O.OOON
0.000
0.000
0.000
0.000
0.000
0.000
0.000
HCRLR
ug/1
0.000
0.000
0.000
0.000
0.000
0.048
0.000
0.000
0.000
O.OOON
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
HCHLR- Para-
EP Malathion thion Diazinon
ug/1 ug/1 ug/1 ug/1
0.000
0.000
0.004
0.000
0.000
0.067
0.000
0.000
0.000
O.OOON
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.002
0.000
M-Para-
thion
ug/1
2,4-D 2,4,5-T Silvex
U9/1 ug/1
E - Composite lab sample
N - Presumptive evidence of material
-------
However, haphazard monitoring such as now exists is
not the key. Nor will a program such as that proposed
by Feltz, et al. in the Pesticide Monitoring Journal,
(33) - quarterly water measurement and semi-annual sedi-
ment measurements at 161 U. S. stations - provide the
necessary answers. The contractor feels that this would
be a fruitless effort. A series of intense studies,
supplemented by daily data from water intakes of large
cities on major waterways would be of vital importance.
This program is detailed in the recommendations section
of this chapter.
Summary and Conclusion
Pesticides may enter the water environment through
many routes from its point of application. A primary
transport mechanism is adsorption onto soil particles
which, during erosion are subsequently moved in water
as sediment. Due to the low solubility of most pesti-
cides in water they do not dissolve to any great extent.
Some materials, especially derivatives of some herbi-
cides, are slightly soluble, and the resulting solution
can become a significant transport mechanism. The total
quantity of herbicides moved by water has been shown to
be equal to the amount moved on sediment because of the
greater amount of water in relation to the amount of
46-D
-------
sediment involved in transport.
Drift from spray application was limited in signi-
ficance due to relatively short distances the drifting
material travels before it settles to the ground. The
distances are usually no more than 1/2 mile downwind,
and no further than the edge of the field under upwind
application. Drift does become a problem when a body of
open water lies near the application field.
Loss to the atmosphere through drift and mist can
be significant and has been measured at 25 percent of
the amount applied. Evaporation may amount to 2 to 3
percent of the amount of pesticides applied, with moisture
content of the soil greatly influencing the size of this
contribution.
Since pesticides are easily adsorbed into the soil,
they usually do not penetrate to ground water unless a
fissure or crack exists allowing surface water to flow
directly into ground water.
A great potential for pollution does exist when
empty pesticide containers are not properly disposed.
However, thus far no effective means of disposal has been
developed.
Agricultural practices can reduce erosion losses
to a minimum, and could be a most effective means of
preventing pesticides from entering the aquatic environ-
ment.
47-D
-------
Pesticide monitoring presently consists of haphazard,
disorganized data collection. The current program does
not detect pesticides at concentrations greater than a
few parts per trillion, levels which 10 years ago were
undectable by most techniques and levels which have not
been shown to be harmful to man.
A comprehensive data collection system sensitive
to the parameters influencing pesticide movement - run-
off and sediment and weather conditions - must be develop-
ed. The contractor proposes in the recommendations
section of this report a series of intensive study areas
in small watersheds supplemented by daily measurement
of pesticides from large municipal water treatment
plants on major rivers.
Recommendations
From this investigation it is clear that water con-
tamination by pesticides will be minimized when farm
field erosion is reduced. Practices such as contour
plowing and minimum tillage help slow erosion, but fall
plowing and plowing to the edge of a field may produce
large amounts of sediment. Several practices can reduce
sediment transport of pesticides:
1. Elimination of fall plowing, which exposes
broken soil to winter storms and spring run-off.
48-D
-------
2. Leaving a barrier strip around field edges
for sediment basins to catch sediment from
fields. An area plowed but left unharrowed
and unplanted would slow down run-off and
allow at least a portion of the sediment
to settle.
3. Construction of large sedimentation basins
to catch run-off from several fields, with
provisions to mechanically remove sediment
after each storm and retruck it to fields or
land-banked areas for deposit. This system
would "recycle" soil and prevent loss from
the area, with resultant savings to the farmer
and to those who must keep navigation channels
open and water impoundments functions.
4. Investigation of the plowing scheme, ridge
plowing described by Ritter (20) which re-
duced erosion and pesticide losses by a
factor of 7 times. (5) A series of exten-
sively monitored typical basins would provide
better understanding of the route of pesti-
cides to water and their potential harm.
Weekly water and sediment monitoring of a
small basin of about 100 square miles will
provide background data to be supplemented
49-D
-------
by more frequent samples during periods of
high water flow or rainfall. Meteorological
data, continuous flow and turbidity measure-
ments, and sedimentation rates could be com-
piled to study the effects of different farm-
ing practices. Pesticides inventories and soil
pesticide measurements could also be estab-
lished.
If a 10 to 20 basin system could be implemented,
one could more effectively evaluate the effect of
pesticides in the water than would be possible in the
larger network on a time basis proposed by Feltz.
50-D
-------
LITERATURE REFERENCE
1 Fehrenbacher, J. P., G. 0. Walker, and H. L. Wascher,
Soils of Illinois, University of Illinois Agricultural
Experiment Station Bulletin 725, 1967.
2 Shell Chemical Company, Technical Data Bulletin,
Summary of Basic Data for Technical Aldrin, 1968.
3 Shell Chemical Company, Technical Data Bulletin.,
Summary of Basic Data for Technical Deldrin, 1971.
4 Geigy Agricultural Chemicals, Aatrey Herbicide Tech-
nical Bulletin, CIBA-Geigy Corporation, 1971.
5 Smith, D. D. and L. H. Wischmeier, "Rainfall Erosion",
Advances in Agronomy, 14, 109 (1956).
6 U. S. Geological Survey, Water Resources Data for:
Iowa, Minnesota, Missouri, Kansas, U.S.G.S., 1970.
7 Taylor, A. W., "The Measurement of Pesticide Per-
sistence in Soils," 162nd ACS Meeting, Washington,
D. C., 9/71.
8 U.S.D.A., National Soils Monitoring Program, Labora-
tory Analysis Report - Soil 0-6", for Illinois, Iowa,
Missouri, Fiscal Year 1969.
9 Morris, R. L., L. G. Johnson, Pesticide Levels in Fish
and Bottom Silts from Iowa Streams, Report #71-10,
State Hygienic Laboratory, University of Iowa,
Iowa City, Iowa, 1970.
10 Jager, K. W. , Aldrin, Dieldrin, Endrin and Telodrin,
Elsevier Publishing Company, Amsterdam, New York, 1970.
11 Martin, W. P., W. E. Fenster and L. D. Hanson,
Fertilizer Management for Pollution Control in
Agricultural Practices and Water Quality,ed.
Willrich, T. L., and G. E. Smith, Iowa State
University Press, Ames, Iowa, 1970.
12 Adams, R. S., Jr., and L. Paulina, "Soil Properties
Influencing Sorption and Desorption of Lindame",
Soil Science Society of America Proceedings, 35, 78
(1971).
51-D
-------
13 Martin, W. P. and R. S. Adams, "Soil Pollutants and
Their Effects in Agriculture", 19th Annual Meeting
of Agricultural Research Institute, National Academy
of Sciences, 1970.
14 Oschwald, W. R., "Erosion and Sedimentation as Causes
of Pollution", Illinois Research, 12, 12 (1970.
15 Harrold, L. L., Research on Agricultural Pollution
in Ohio, USDA Agricultural Research Service, Soil
and Water Conservation Research Division, Coshocton,
Ohio, 1971.
16 Caro, J. H. and A. W. Taylor, "Pathways of Loss of
Dieldrin from Soils Under Field Conditions",
Agricultural and Food Chemistry, 192, 379 (1971).
17 Morris, R. L, L. G. Johnson, and W. Patton, Some
Aspects of Pesticides in the Iowa Environment,
Report 70-10, Iowa State Hygienic Laboratory,
University of Iowa, Iowa City, Iowa, 1969.
18 Spencer, W. F., "Distribution of Pesticides between
Soil, Water, and Air," Pesticides in the Soil,
Michigan State University, East Lansing, Michigan,
1970.
19 Frost, K. R. and G. W. Ware, "Pesticide Drift from
Aerial and Ground Applications," Agricultural
Engineering, 51, 460 (1970.
20 Ritter, F. R., Environmental Factors Affecting the
Movement of Atrazine, Propachlor, and Diazinon in
Ida Silt Loam, Ph.D. Dissertation, Iowa State Uni-
versity, Ames, Iowa, 1971.
21 Eichelberger, J.W. and J. J. Lichtenberg,"Persistence
of Pesticides in River Water," Environmental Science
and Technology, 5_, 541 (1971) .
22 McDonald, D. B., Personal Communication, 1971.
23 Cherryholmes, K. L., The Effects of Agricultural
Land Runoff on the Limnology of Clear Creek,
Master's Thesis, University of Iowa, Iowa City,
Iowa, 1970.
52-D
-------
24 Metha, S. C., Limnological Factors Affecting
Pesticide Residues in the Iowa River and Coral-
ville Reservoir, University of Iowa, M. S. Thesis,
Iowa City, Iowa, 1969.
25 Appleby, W. G., Sources of Dieldrin Residues in
Iowa Fish and Waterways, Shell Chemical Company,
1971.
26 McDonald, D. B., DAEC Cedar River Water Quality Study
Quarterly Report, Summer 1971.
27 McDonald, D. B., Personal Correspondence, 1971.
28 Morris, R. L. and L. G. Johnson, Pesticide Levels
in Fish and Bottom Streams from Iowa Streams,
Report 71-10,Iowa State Hygienic Laboratory,
University of Iowa, Iowa City, Iowa, 1970.
29 Danielson, J. A., Air Pollution Engineering Manual,
U.S. Public Health Service NCAPC, Cincinnati, Ohio,
1967.
30 Shuman, S. L., Jr., B. J. Stojanovic, and M. V.
Kennedy, "Engineering Aspects of the Disposal of
Unused Pesticides, Pesticide Wastes, and Pesticide
Containers," J. Environmental Quality 1, 68 (1971).
31 BNA Current Events, £, 887 (1971).
32 EPA, Storet Data (Pesticides for 5 states in study
area), 1971.
33 Feltz, H. R., W. T. Sayers, and H. P. Nicholson,
"National Monitoring Program for the Assessment of
Pesticide Residues in Water," Pesticides Monitoring
Journal, 5, 54 (1971).
53-D
-------
APPENDIX E
IMPACT ON THE AQUATIC ENVIRONMENT
Introduction
The dilemna of pesticides is that they do so much
good and yet threaten so much harm. ( 1 ) The relative
good and harm have been the subjects of considerable
numbers of review papers in the literature, governmental
hearings, public outcry, popular press, mountains of
scientific papers and a phenomenal quantity of good sub-
stantial scientific investigation as well as notorious
misinformation, distorted truths, and gaping voids in
our total understanding of the use and fate of these com-
pounds .
The entire problem, especially that of the aquatic
environment/ was summed up quite well by Johnson ( 2 )
who, quoting SurberX1948) states that "studies of the
effects of pesticides on fish, on their food, and on
various forms of wildlife are proceeding along operational
lines. From an ecological standpoint, this seems an ideal
method of approach, as all implications of the operations
may be viewed in their entirety." Unfortunately (states
Johnson), progress in the last eighteen years (now 23
years) seems to indicate that "operational lines" have
not been as effective as was hoped.
1-E
-------
Scandinavian researchers tried to alert the world
population to the potential danger of high residue levels
of DDT and its metabolites and dieldrin in food supplies
in the early fifties - warnings that went largely unheeded.
National recognition of the real potential for harm came
to the United States in 1962 with the prediction of SILENT
SPRING by Carson ( 3 ). While both deservedly applauded
and denied by different segments of societyrthe book did,
nevertheless, have a profound impact on public thinking.
An alert and aroused public could see the results
of overt misuse (overuse) of compounds which'following
massive applications,left untold numbers of dead and dying
fish and wildlife species across the lands and waters of
the country. This same public was and still is, unfortu-
nately, quite naive about parts per thousand, million or
trillion or nannogram or picogram quantities. It is pre-
cisely these small, persistent and ever accumulating
quantities to which we must address ourselves.
This task assignment will not be presented as a
complete literature review — such a review would con-
stitute a needless restatement of the problem already
covered by many thoroughly competent scientists around
the globe. It does, however, seek to identify and dis-
cuss those areas, which in our opinion, deserve thought-
ful consideration and in which major research emphasis
2-E
-------
should probably be directed in the next several decades.
There is a definite scarcity of hard data in the
literature for biological responses to aldrin, dieldrin
or atrazine. While a copious literature exists for DDT
and related products the story which we have pieced
together for dieldrin is the result of isolated frag-
ments and similarly related environments and their flora
and fauna. Much of this section then, is largely inter-
pretive with many of the conclusions resulting from infer-
ence.
We are somewhat blessed by the Iowa Community Pest-
icide and related State Hygienic Laboratory activities
in Iowa and the Federal Fish-Pesticide Research Laboratory
in Columbia, Missouri. The inclusion of data from other
(often remote) sources is deemed justified when it demon-
strates a particular point.
The Aquatic Ecosystem
A thorough understanding of trophic structure and
trophic level dynamics is still wanting. An appreciation
of the complexity of trying to understand the effects of
a foreign chemical when applied to any natural, living
system when we are really only at the threshold of under-
standing of the system itself should be obvious.
One primary requirement for all of us seems to be
that we stop looking at our own often petty, vested
3-E
-------
interests and begin to view the global implications of
our acts. The agricultural use of pesticides to insure
a continued high yield of high quality food and fiber is
not at issue and is viewed by most rational men as necessary
to a vibrant productive agriculture. What is at issue is
the kinds of products used, the quantities applied and
an implementation of practices which will insure minimum
damage to our fragile environment.
Although some studies have been conducted on basic
physiological responses of fishes and pesticides* such
studies are largely lacking from invertebrate animals.
The oyster and some few other commercially valuable
species are exceptions. That these other animals are
vital links in the chain of concentration of pesticides
residue has been amply demonstrated. The point which
should be made, perhaps, is that basic physiology —
especially as it relates to growth and population dynamics*
may be the most important feature. The good health of any
food chain or trophic structure rests on the good health
and perpetuation of any individual trophic level. Thus,
we believe that more fundamental experiments should be
instituted to determine the long range effects of sub-
lethal exposure on basic invertebrate groups, especially
as such exposure relates to intrinsic rates of natural
4-E
-------
increase. Unfortunately we know relatively little about
the basic physiology of these organisms, let alone their
population dynamics.
Fundamental to our discussion and directly relevant
to the different organo-chloride compounds is the question
of whether other compounds (i.e. cyclo-dienes) follow the
picture of distribution observed in the much more widely
examined family of DDT and it's residues. Such data is
presented by Robinson et al ( 4 ) and dramatically shows
the intimacy of the relationship between dieldrin (HEOD)
and pp'DDE in two fishes (Figure 1-E ).
Of equal impact, we think, is the seasonal picture
demonstrated; a winter low and a summer high. This source
variation is reflected in the 1965 data for concentrations
of these two compounds in the egg of the shag, Phalacrocorax
aristotelis, which showed a considerable increase in concen-
trations as the egg laying season progressed, (Figure 2-E).
Thus, the increasing quantities in their food (the fish)
reflected in the increasing quantities in eggs. Data for
1964 showad a decrease, which could easily reflect data of
the kind seen for fish for the year 1966. (Figure I-E)/
especially during the period when egg material is being
metabolized.
5-E
-------
Figure 1-E
COMPARISON OF CONCENTRATIONS OF DDT AND
DIELDRIN (HEOD) IN TWO DIFFERENT FISH
0-03r
0-05
0-04
0-03
0-02
0-01
Feb. Apr. June Aug. Oct. Dec. Feb. Apr. June Aug. Ort.
1965 1066
Date of catch
Concentrations of («> j>p'-DDE, and (O) HEOD in cod causht
at different times in the area around the Fa
Feb. Apr. June Aug. Oct. Dec. Feb. Apr. June Aus. Oct
1065 1066
Date of catch
Concentrations of (©) pp'-DDE. and (O) HEOD in sand efU
caught at different times in the area around the Fame Islands.
Several additional points are made which deserve
our attention. The suggestion is made that the concen-
tration of pesticide in birds is in equilibrium between
intake and excretion (and metabolism) of insecticide
residues. Thus, if the rate of metabolism and excretion
is greater in certain vertebrates than in invertebrates
or food of the next trophic level, no concentration or
6-E
-------
Figure 2-E
CONCENTRATION OF ORGANOCHLORINE COMPOUNDS IN SHAGS'
EGGS LAID AT DIFFERENT TIMES. 0,pp'-DDE; 0, HEOD.
_ JO
\i.ril May June April May Jnw April May June
10!U ]»'J"> 1950
J>,ii<' of eca l:iyi»-.;
hiological amplification would be seen. One assumes that
the reverse is true in some,but not all, food chains,
since many examples are seen which indicate a progressive
accumulation and concentration up the food chain or
trophic level.
Clearly much additional research is necessary to
identify the fate of parent compounds and residues at
each trophic level. This is particularly true as it
relates to the rate of turnover of the compounds.
A step in the right direction is seen in the recent
work of Metcalf and co-workers ( 5 ). The model
eco-system they propose could be very useful in relatively
rapid screening tests of large numbers of compounds as well
as identifying the fate and chemical nature of metabolites-.
We feel that the worth of such an approach could be improved
7-E
-------
tremendously if all levels were investigated (i.e.) bac-
teria, fungus, protozoans, etc.)
We have taken the liberty of modifying the presen-
tation of Harrison, et al ( 6 ), Figure3-E and present-
ing in graphic form the fate of DDT compounds and other
chlorinated hydrocarbons. This figure helps bring the
study area into focus. It should be remembered that each
of the compartments; atmosphere, surface and substrate,
each contribute to the larger global environment. Con-
tributions to the substrate component streams are seen as
contributing to the larger streams (Missouri, Illinois,
Mississippi), thence to the delta and estuarine areas, the
Gulf, Caribbean Sea and finally, the high seas. Such a
sophisticated modeling of a natural system is absolutely
essential to future calculations of the fate of compounds
added to and persistent in the environment. This study
points up the low solubility in water, high solubility in
lakes and high stability of the organo-chlorides in living
tissue, features which allow magnification of these compounds
from lower to higher trophic levels within an ecosystem.
Studies of this kind are also valuable in that they
show us, mathematically, features about age distribution,
8-E
-------
Figure 3-E
FATE OF CHLORINATED HYDROCARBONS IN THE FIVE STATE STUDY AREA
INPUTS
STORAGE
OUTPUTS
ATMOSPHERIC
DDT & Cyclodienes
Gaseous
AS: Particulate
Precipitation
ATMOSPHERIC
I
DDT
DDE I Gaseous
EpoxidesJ Particulate
Parents
IN:
SURFACE
Living organisms
Dead tissue
\ MINNESOTA
SURFACE
DDT & Cyclodienes
And Products
IN: Food
Commercial
Living Organis
SURFACE
DDT, DDE, DDD
Epoxides & Parents
IN: Living Organisms
Food
IN: Soil
Deep water bodies
Deep organic
sediment
DDT, Cyclodienes
And Products
IN: Lakes and
Lake Biota
Streams and
Stream Biota
DDT, DDE, Eppxides
And Parent Compounds
IN: Lakes and Lake
Biota
Streams and
Stream Biota
9-E
-------
generation time and other demographic features of popu-
lation structure and how these relate to systems equili-
brium. Thus, their estimates (for Lake Michigan ecosystems)
for the time necessary to reach equalibrium after the
introduction of organo-chlorides, depends upon the life
spans in the trophic structure and the various age distri-
butions. Their estimates lie between four times the average
life span of the longest-lived species and the sum of all
of the life spans for all trophic levels. It is easily
possible, they conclude, that ecosystems with such long
lived constituents as eagles, ospreys, and gulls (and whales,
seals, walrus, etc. etc.) have not felt the full impact of
the original use of DDT in the late 1940's. Of even more
sobering consequence is the prediction that the concentration
of DDT and other organo-chlorides once present in obliter-
ated populations would then be concentrated into the remain-
ing species. How far this could be carried is doubtful to
say. It does become apparent, however, that the consequences
of present additions of these compounds on the worldwide
environment will not become apparent for many years.
Eberhardt and co-workers ( 7 ) point out that, although
much has been written about modeling, we possess insufficient
knowledge of the kinetics of pesticides in ecosystems to
10-E
-------
complete these models. Utilizing radiolabeled compounds,
these workers have identified slow and fast compartments;
fast compartments representing transient conditions when
the concentration of pesticide in the water was relatively
high and slow compartments, such as long term retention as
might be accumulated through the food chain. The contractor
feels that the concept has important ramifications since so
many of the acute or chronic studies completed in the past
have failed to identify the rates and routes by which
pesticides were accumulated or retained. Although not
stated ( 7 ) it would appear to us that any gilled animal
or any vertebrate with a moist skin (like frogs) could
possess both a fast and slow compartment, neither of which
are very well documented for the mass of animals which
have been studied so far.
What Kinds of Evidence are there that Pesticides do
Accumulate and Concentrate?
The only study which might demonstrate a natural bio-
accumulation in the five state study area is some of the work
of the Iowa Community Pesticide Study. Unfortunately, much
of this data collection is fragmentary and the residue analys<
devoted to something other than a complete ecological analysi
Although more thorough ecosystem analysis is contemplated,
at present the experiments either have not been completed
11-E
-------
or previously gathered data has not been analyzed.
Studies of several of the rivers and reservoirs in
Iowa suggest that agricultural runoff is considerable and
that residues, particularly of dieldrin,are close to, or
exceed, the FDA action guideline of 300 ppb. Samplings of
water, muds, fish and fish eggs have been conducted and
analyzed for organo-chlorine residues. A number of
points are in order.
The reports of the State Hygienic Laboratory ( 8 ) are
regarded as rather naive in their presentation. Often
species names are omitted, dates of couple collections
are not presented and age and/or size is often omitted.
It is clear, however, that many species of fishes from
instate water are carrying heavy body burdens of DDT and
its metabolites as well as dieldrin and other organo-
chlorides. Bottom dwelling feeding species in general
carry higher residues than carnivorous species. An
interesting point is that the eggs of the bullhead (no
species given) are much lower than other species. We
interpret this to suggest that transovarian movement of
pesticides is much less marked in this bottom feeding
species than in other insectivorous or piscivorous
12-E
-------
fishes. Unfortunately no data for channel catfish eggs
is presented — this may be a characteristic of the family.
The identification of foods eaten and the relative
contribution of these foods to the total body load of pesti-
cides is regarded by us as highly desirable and a serious
shortcoming of these studies at present. ( 9, 10)
Graduate studies sponsored by the project tend to
support other studies and do present seasonal data. An
increase in residue from water to mud to algae to fish is
also indicated. Dieldrin was the most frequently occuring
pesticide found in fish flesh as well as the most highly
concentrated residue.
Some interesting recent data collected by Me Donald
( 11) is presented to demonstrate rather dramatically, we
think, the extreme variability and consequently the difficulty
encountered in trying to make meaningful interpretations
of water, muds or biological samples. Tables l-E,2-E,and 8-E
Figure 4~E . The data for dieldrin at stations 1-4
appear to/ reflect the river hydronamics; main channel valves
lower (tr) than near shore valves (3.0, 1.5) or running
slough (2.0) This may mean then sediments which carried
a heavy load of absorbed residue and were deposited in
13-E
-------
TABLE 1-E
LEVELS OF DIELDRIN FOR WATER, SEDIMENT
AND PERIPHYTON, MISSISSIPPI RIVER - 1971*
Station
1
2
3
4
5
6
9
Water pptr
3.0 (4 Aug)
1.5
2.0
tr (8 Sept)
1.6 (4 Aug)
1.2
(3.6, 22 Sept)
.6 (4 Aug)
LOCATION
Sediment ppb
tr
.053, 7.2 Aldrin
0.23
(ca 1.0, 18 Aug)
tr
Periphyton ppb
.20 (4 Aug)
.09
(1.0, 18 Aug)
.24 (4 Aug)
(2.8, 18 Aug)
.10 (4 Aug)
(1.0, 18 Aug)
w
* See Location Map, Figure
-------
O W A
CLINTON COUNTY
Figure 4-E
MAP OF SAMPLE LOCATIONS, WATER,
SEDIMENT, PERIPHYTON
-------
these locations, now are in some kind of equilibrium with
the water there.
It is also dramatically shown that rainfall and sub-
sequent discharge from the land resulted in transitory
three fold increase in water (1.2 to 3.6 pptr.) on or about
the 10th to 18th of August. Such a rise in water is re-
flected in a ten fold increase in periphyton levels .10
to 1.0 ppb. This example serves, we feel, to emphasize
the necessity for mobile non-time based monitoring as is
currently practiced or anticipated. It is vitally impor-
tant that measurements be made when biological events are
occurring, not by the calendar.
This data on periphyton residue valves from different
water areas presents to us a very interesting picture of
the potential for accumulation with reduced water flow
table.
The most significant ecological feature of this and
the water and sediment data, is the fact that these shallow
areas (1,2,5,6) or reduced flow areas (closed slough, back-
water) which carry the highest residues, are the areas
which warm the fastest (and as a result, speed biological
processes) and are consequently used as nursery grounds
for young invertebrates and fishes alike. Since most
younger animals are considerably less tolerant of pesti-
16-E
-------
TABLE 2 - E
CONCENTRATION OF DIELDRIN IN PERIPHYTON, MISSISSIPPI RIVER
13 May 1971
tfater Condition
Dieldrin
ppb.
Approx. Concentration
over water at 20 ppb.
Running Slough
Side Channel (up)
Closed Slough
>ide Channel (down)
Jackwater
2.4
2.0
3.8
1.4
12.1
1000X
6000X
17-E
-------
cides than adults of the same species, the combination is
particularly devastating. Thus, the juxtaposition of
young organisms, high residues, and speeded metabolism,
is viewed as potentially very damaging to aquatic food
chains at all levels.
The subject of the contamination of ecological cycles
has been covered extensively by numerous excellent test
treatments and review articles ( 12, 13, 14, 15, 16 and 17).
Several examples will serve to demonstrate that additions
of these compounds made in inland waters do find their way
downstream to bays, estuaries and the seas. Thus, exami-
nation of body levels of DDT in the sand crabs Emerita analoga
from nineteen California beaches apparently shows that addi-
tions of DDT at one point along the coast give the observed
results ( 18). Sediments near the outfall are estimated
to contain over 100 metric tons of total DDT as a
potential reservoir for inclusion into marine food chains.
It is interesting that interpretation of possible point
sources of contamination leads this author to conclude
that historically additions of DDT could be attributed to
a significant degree to industrial waste discharge in ad-
dition to extensive agricultural usage (Figure 5-E ) . Al-
though not directly comparable, the accumulation of DDT
18-E
-------
Figure 5 - E
LOCATION AND COIJCEIJTRATION OF DDT AND
RESIDUES ALONG CALIFORNIA COAST AND IN SAND CRAB
10,000
Plot of mean concentrations in parts her billion (ppb) (wet weight) of tDDT in
Emerita analoga at various locations along the California coast. (Open circles) Samples
collected in November 1970; (solid circles) samples collected in February 1971. The
curve is a freehand interpolation between points.
Mean concentrations (X) and standard error (S.E.) in parts per billion (wet
weight) of DDT, DDD, and DDE in Emerita analoga for given latitudes along the California
coast. N, animals colie:ted in November 1970; F, animals collected in February 1971.
Sta-
tion
1 N
2 N
3 N
4 N
5 N
6 N
7 N
8 N
9 N
10 N
11 N
12 N
12 F
13 N
13 F
14 N
14 F
15 N
15 F
16 F
17 F
18 F
19 F
Latitude
37°48'
37°46'
37°38'
37°30'
37°13'
37°00'
36°50'
35°42'
35°10'
34-28'
34-16'
34-02'
34C02'
33°53'
33°53'
33°42'
33°42'
33°42'
33842'
33-34'
33°22'
32°48'
31°50'
No.
8
8
8
7
8
8
8
8
8
8
7
7
7
6
8
7
8
8
7
7
8
7
6
DDT
X
69.
74.
35.
11.
7.0
26.
24.
4.2
14.
14.
36.
20.
23.
580.
340.
150.
78.
88.
48.
45.
18.
13.
26.
•4-
-*-
^
It
-*-
-+-
Ct
i:
±:
±
-+-
it
-»-
-H
-t-
:£
it
;+-
H-
it
-»-
-f-
H_
±
S.E.
13.
8.
3.
1.
1.2
3.
2.
0.5
2.
1.
3.
2.
4.
90.
30.
20.
11.
4.
8.
8.
4.
2.
3.
No.
7
6
8
7
3
8
7
8
8
7
7
7
8
5
8
7
8
7
7
7
8
8
6
DDE
X ±
69.*
51. ±
37. ±
24. ±
43. ±
70. ±
52.*
60. ±
100. *
122. ±
84. ±
210. ±
460. ±
680. ±
1590. ±
4900. ±
6900. ±
2200. ±
4200. ±
470. ±
190. ±
71. ±
6S. ±
DDD
S.E.
13.
7.
5.
1.
10.
5.
7.
7.
8.
8.
5.
12.
50.
100.
60.
480.
900.
200.
400.
50.
20.
12.
5.
No.
7
7
7
7
8
8
7
7
8
8
7
7
S
5
8
6
8
8
7
7
8
8
6
X
19.
17.
11.
4.7
2.9
16.
9.8
3.8
11.
17.
14.
21.
30.
210.
410.
590.
270.
240.
160.
56.
25.
9.1
12.
± S.E.
± 4.
± 1.
± 1.
± 0.2
± 0.6
± 2.
± 1.1
± 0.6
± 1.
± 3.
± 1.
± 3.
± 9.
±40.
± 30.
±80.
±60.
±20.
±40.
± 7.
± 6.
± 2.6
± 1.
19-E
-------
and its degradation products has been demonstrated in the
Pacific Coast ecosystem ( 19 ) Table 3-E . Notice that the
concentration in vertebrates (ppm) is considerably greater
than in invertebrates (ppb). East Coast estuaries are simi-
larly affected; the Carmans River estuary and vicinity
provide a broad overview of the problem ( 20) Table 4-E.
These authors remind us that for many species, the subtle
effects of long term exposure may be so acute that some
of the species in the area have already been depleted to
the point where study is difficult or impossible. A plea
is made for examination of the entire ecosystem, partic-
ularly the carnivores or other top concentrating members
rather than water levels in which quantities of pesticides
are often vanishingly small or "non-detectable". Non-
detectable to our chemical technology but not, obviously,
to organisms living in the water.
Long term field studies by scientists from this area
suggest that populations of many fish-eating birds have
seriously declined over the past twenty years, even though
the physical characteristics of the marsh area have remained
essentially unchanged during this period.
Fishes and invertebrates from more northern waters do
not show such high values as these examples ( 21 ) . The ad-
ditions from near inshore regions of pesticides are not as
great, however, as more southern waters, and the one ex-
20-E
-------
Table 3 -E
DDT AND RESIDUES IN PACIFIC COAST ECOSYSTEMS
DDT RESIDUES IS
Samples
Mytilvs californianw (common mussel)*
Thau cmary'iiata (short-spired purple
snail) t
Pisiisffr whraceus (common starfish),
eiyht animals*
Mile/la iiolijmeru* (Pacific (joose barnacle)
forty aniii'.r.lsj
Crassus>.rea.yi']nis (giant Pacific oyster),
five animals?
Stronyylocentrotui purpuratut (purple
urchin)1'
I'ulifia Miniata (sea bat starfish), ten
animals'!
Lfiligf) opalesecns (squill), thirteen
amnuils**
Stichoptu taliformtus (sea cucumber),
three animals**
Puy-ttia iirtMtur.ta (kelp crab), six
animuls 11
Ttttii emarainata (short-spired purpln
snail), Monterev§§
Jlntilv* cnlifniiiin/iiii (common mussel),
Monterey: !i
3I/ili!>is califoniiamH Ensenada, Baja
Jl!riiii>*ciilifnri,i«im*, Farallon Tvlands*'* 34 0 84 0
* Point Sar\ J'filro, San Matco C'o., May ^fi. IflCB. pooled sample of twenty
animals, slu'lls ivmoved befyri' analysis; -f Point San Pedro, !>an Mateo Co..
May -Jij, 19(i(i pooled sample ol riahty auiinitl-i, shells removed before
auMvsis; 11'oir.t S:u\ IVilro, May 20. "l9(i(V, $ Tuuial-s Buy, ^lariu Co..
September l~> \Wa- II I'oint Arena. Mrii'locinn ('"., September 16, lOCii.
ennncl^ of ei«l(t animals; r »|ruit-re>, March 6. I'.iBO; *• Monterey, June 10.
IMS: tt Mont'-ivy, March 12. li'flfi; ; : Moulvrcy, March (i. mild: §5 April
11 \'.«'. |mi»lcd
«ampl.Miffirti-eiianim,ils; ••• April ft. HUMS. piic.J.-il s-impleof i-\even animals.
M.UUXE INVERTEBRATES
Total
l)D'i'
residues
(parts
per
billion)
19
!)4
20
I, 27
29
5
7S
28
93
42
103
84
31
Pcrcentasp of residue as
f,f'-OJ)'C DDK DDD
26 28
33 29
15 24
7 50
42 24
100 0
19 55
3D 32
43 25
10 62
28 45
32 3S
21 53
26
2.0
32
22
17
0
14
14
25
10
15
W
0
11DT REMDCKS (p.p'-Dm, ff.)»'-I>l)T, p,p'-DHE. p.p'-DDD,
Hf SEA r.IRDS RESlriESI IS CA11FOKSU
Sample
Total
DDT
residues
(p.p.m.)
5-1
Percentage of residue as
ji.p'-VDT DDK DDD
Ptyclioramphut aleuticus (Cassin's 5-1 0-4 95
ttuklct), nine adults*
Ptyrhnramphut eieutieui, one adult 15-4 0-1 96
found dead*
/VycAonniipAiitafeutfeiNi.ln-o adults t 1-0 3-8 87
PlyrfiorampliutatevticuiAhne
adults*
Breast muscle 2-0 11 81
Braiu 0-7 82 64
Liver j-0 fl-7 79
Subcutaneous fat 56 1-5 92
Plycharamphut aitxticm, fourteen 10-8 0-8 96
eggs*
Lams oecidtntalit (Western gull),
two adults*
Breast muscle 9-2 0-1 89
Brain 1-8 2-2 83
Subcutaneous fat 211 0-4 94
LOTUS occideiitalii, nine eggs, oue-egg 6-5 2-9 8"
clutches*
Plialacrocorax pelayicu* (pelagic
cormorant), one adult t
.Breast muscle 0-8 1-3 83
ml Liver 0-7 0-0 84
Phalanororax ptnicilMvt (Brandt's
cormorant), five adults§
Breast muscle 4-4 0-0 91
liver 3-3 0-0 85
Brain (three birds) J-2 0-0 92
Pdtcanut oecidentalis (brown
pelican) t
Breast muscle 84-4 1-4 91
Cnaaalgc (common murre)t 7-3 0-3 93
• Varallon Islands. April and May 1966; t Monterey Bay, November and
December 1906. Although these species breed in California, the Individual
birds may have come from elsewhere; * Toroalcs Bay, M»riu Co., Starch 4.
1966; § Tomalcs Bay, December 31, 1965.
Concentrations are expressed fn parts per million, wet wsicht. Unlets
otlicnvise indicat«d the whole bird was analysed. Concc-ntrations In cgss
are based on the entire contents of the «M. The proportion* of DOT (p.p*-
MJT), DDE (p,p'-DDB) and DDD (;>.p'-DDD) are expressed as a percentage
of the total. o.p'-DDT and j»j>'-DDMU constitute the balance.
1-1
1-0
I'O
5-9
3-9
1-5
1-0
6-9
4-4
3-1
7-3
11-9
10-9
6-2
9-2
5-2
4-8
4-0
21-E
-------
Table 4 ~E
DDT RESIDUES IN CARMANS RIVER ESTUARY
DDT residues (DDT+DDE + DDD) (/) in samples from Carmans River estuary
and vicinity, Long Island, N.Y., in parts per million wet weight of the whole organism, with
the proportions of DDT, DDE, and DDD expressed as a percentage of the total. Letters
in parentheses designate replicate samples.
Sample
Water*
Plankton, mostly zooplankton
Cladophora gracilis
Shrimpf
Opsamts tau, oyster toadfish (immature) f
'Mcnidia menidia, Atlantic sflversidet
Crickets?
Nassaritts obsoletus, mud snailt
Gasterosteus aculeatus, threespine sticklebackt
Anguilla rostrata, American eel ( immature) t
Flying insects, mostly Dipterat
Spartina patens, shoots
Merctnaria merccnaria, hard clamt
Cypriiiodon variegatits, sheepshead minnowf
Aitay ntbripds, black duck
Funduhis hetvrocliius, miimmichogt
Paraliclilhyf flentains, summer floundert
Esox iiiger, chain pickerel
Larus argentutus, herring gull, brain (d)
Strons)lura marina, Atlantic needlefish
Spartina patens, roots
Sterna hirundo, common tern (a)
Sterna hirundo, common tern (b)
Butorides virescens, green heron (a) (immature, found dead)
Larus argentatus, herring gull (immature) (a)
Butorides virescens, green heron (b)
Larus argentatus, herring gull, brain§ (e)
Sterna albi/rons. leabt tern (a)
Sterna liirundo, common tern (c)
Larus argentatus, herring gull (immature) (b)
Larus argcntatns, herring gull (immature) (c)
Sterna alhlfrons, least tern (b)
Sterna liiritntlo, common tern (five abandoned eggs)
Larus argentatus. herring gull (d)
Larus argentatus, herring gulll (c)
Paitdion lialiatttis, osprey (one abandoned cgg)||
Lams argentatus, herring gull (f)
Mrryus serrator, red-breaslcc! merganser (I964)t
Plialacrocorax attriius, double-crested cormorant (immature)
Larus dclawarcnsis, ring-billed gull (immature)
DDT
resi-
dues
(ppm)
0.00005
.040
.083
.16
.17
as
.23
.26
.26
.28
.30
.33
.42
.94
1.07
1.24
1.28
1.33
1.48
2.07
2.80
3.15
3.42
3.51
3.52
3.57
4.56
4.75
5.17
5.43
5.53
6.40
7.13
7.53
9.60
13.8
18.5
22.8
26.4
75.5
Percent of residue as
DDT
25
56
16
None
17
62
18
24
29
16
58
71
12
43
58
28
34
24
21
31
17
21
20
18
8
22
14
17
IS
25
17
23
19
22
15
30
28
12
15
DDE
75
28
58
100
48
19
39
51
43
44
26
17
20
46
18
44
26
61
28
57
67
58
57
73
70
67
71
55
71
62
6S
50
70
71
64
56
65
75
71
DDD
Trace
16
26
Trace
35
19
43
25
28
40
16
12
68
11
24
28
40
15
51
12
16
21
23
9
22
11
15
28
11
13
15
27
n
7
21
14
7
13
14
22-E
-------
tremely high value (for the list) is from the mackerel (54
ppm), a normally migratory, warmer water fish, which probably
accumulated its higher residues while at the south central
and southern coast of the United States. Table 5 - E.
One unfortunate consequence of studies such as these
is this: Data collected in 1967-68 was not published until
1971. Once a rather comprehensive study is finished,
other workers are reluctant to enter the area for a num-
ber of years. Thus, even though individual species may
be examined, the impact on the total environment may not
be resurveyed for some time. Our monitoring program should
probably include some of the more sensitive species from
coastal and estuarine environments, as well as periodic
status reports, utilizing all available information, on
the total health of the ecosystem.
23-E
-------
Table 5- E
DDT RESIDUES IN ATLANTIC MARINE FISHES
AND INVERTEBRATES. CANADIAN LOCATION
DDT residues measured in Atl.intic marine fishes and shellfishes collected in October 1967. Averages of
four or five samples from different individuals are given, followed by the range in parentheses. All values have been
toundcd to two decimal places. A dash (-) indicates less than 0.01 ppm. Average size of individuals is given in centi-
meters, with carapace length for lobsters.
Species
Mussel, edible
Mytilus edulis L.
Mussel, edible
Mussel, edible
Scallop, giant
Placopecten magellanicus
(Gmelin)
Scallop, giant
Clam, soft-shelled
Mya atenaria L.
Clam, soft-shelled
Clam, soft-shelled
Oysters, eastern
Crassostrea virginica
Gmelin
Oysters, eastern
Quahaugs, Venus
merceitaria L.
Lobster, American
Homarus americania
Milne-Edwards
Lobster, American
Mackerel, Atlantic
Scomber scombrus L.
Salmon, Atlantic
Salmo solar L.
Salmon, Atlantic
Cod, Atlantic
Cadia morhua L.
Cod, Atlantic
Hake, white
Vrophycis lenuis
(Mitchill)
Hake, white
Smelt, American
Osmcrus mordax
(Mitchill)
Smelt, American
Flounder, winter
fseiidopteuronectcs
americania (Walbaurn)
Flounder, winter
Tomcod, Atlantic
Microgadus lomcod
(Walbaum)
Location*
M
E
St.A
R
StA
M
E
St.A
M
E
M
R
R
M
M
M
R
R
R
R
M
E
R
R
M
Size
(cm)
7.6
6.7
4.4
8.0
10.7
6.3
6.7
5.5
7.8
13.9
6.1
8.5
8.5
41.8
59
59
58
58
64
64
16.5
19.4
28
28
24.5
ppm
Organ
Whole
Whole
Whole
Whole
Whole
Whole
Whole
Whole
Whole
Whole
Whole
Muscle
Eggs
Whole
Muscle
Viscera
Muscle
Viscera
Muscle
Viscera
Whole
Whole
Muscle
Viscera
Whole
DDT
-
0.01
(-.0.05)
0.04
(-.0.10)
0.01
(-.0.07)
_
_
-
_
_
0.04
(-.0.21)
0.01
(-0-02)
0.04
(-.0.09)
0.38
(0.28,0.48)
0.02
(-.0.04)
0.08
(0.04,0.19)
0.01
(-0.04)
0.40
(0.09,0.68)
0.01
(-.0.03)
0.19
(0.08,0.36) ^
-
0.06
(-O.J6)
-
_
-
DDD
-
_
_
—
_
-
_
—
_
—
.
0.01
(-,0.02)
0.01
(-,0.04)
0.08
(0.04,0.13)
0.01
(-.0.03)
0.06
(-.0.19)
_
0.10
(0.02,0.17)
-
0.10
(0.04,0.16)
0.01
(-.0.03)
_
_
-
DDE
0.05
(0.03,0.11)
0.06
(-.0.13)
0.05
(0.03,0.10)
0.02
(0.01,0.01)
0.03
(0.01,0.03)
0.01
(-,0-04)
0.05
(-.0.14)
-
0.01
(-0.03)
0.02
(0.01,0.02)
0.01
(0.01,0.02)
0.03
(0.02,0.04)
0.31
(0.07,0.94)
0.09
(0.05,0.16)
0.03
(0.02,0.04)
0.16
(0.08,0.27)
0.04
(0.02,0.05)
0.24
(0.14,0.34)
0.03
(0.01,0.05)
0.13
(0.05,0.24)
0.01
(-.0.04)
0.05
(0.02,0.09)
001
(-.0.03)
0.01
(-.0.02)
-
ZDDT
0.05
(0.03,0.11)
0.08
(-.0.17)
0.09
(0.06,0.15)
0.03
(0.01.0.09)
0.03
(0.01,0.03)
0.01
(-,0.04)
0.05
(-.0.14)
—
0.01
(-.0.03)
0.02
(0.01,0.02)
0.05
(0.01,0.23)
0.04
(0.02.0.08)
0.36
(0.07,0.94)
0.54
(0.45,077)
0.05
(0.02,0.10)
0.29
(0.15,0.65)
0.05
(0.02,0.08)
0.75
(0.36,1.16)
0.04
(0.01,008)
0.43
(0.17,0.76)
0.03
(-0.06)
0.10
(0.02.0.19)
0.01
(-.0.03)
0.01
(-.0.02)
-
•M, Miramichi; E, EllcrsUe; St.A., St. Andrews; R, Richibucto.
24-E
-------
How Do Pesticides Enter Succeeding Trophic Levels?
Algae and other photosynthesizing plants as well
as fungi and bacteria probably acquire pesticides by ab-
sorption across limiting membranes. The relative insolu=
bility in water and the high solubility in lipids creat-
ing an apparently "active" accumulation. Whether active
transport or passive diffusion is involved is still open
to question. In any event, many algal forms are observed
to concentrate pesticides to quantities far in excess
of that of surrounding water. Data from the five state
study area suggests concentrations over one thousand
times water ( 11 ). Controlled laboratory studies have
demonstrated concentrating abilities of 120-270 times the
medium in seven days for 2 species of Blue-green algae,
1 Desmid, l filamentous species. (22 ), while studies
with natural populations have demonstrated that benthic
algal species can concentrate at least forty times the
water concentration. (23 ). Observations in Scottish
streams following the dumping of sheep dip have indicated
that diatoms of the aufwuchs can concentrate dieldrin
to over 1200 times that of water in less than one day.
( 24 ). Several species of aerobic fIQC forming bacteria
were observed to absorb aldrin from solutions and con-
centrate 625 times the media in 20 minutes. ( 25 )
25-E
-------
Thus Protozoan species, especially those which feed
on bacteria, can ingest considerable quantities of pesti-
cide in very short periods. Diffusion through or across
the general body surface as well as pinocytotic activity
are other active routes of uptake.
Low concentrations of DDT (10 mg/70 ml) apparently
do not inhibit growth of Euglena ( 26 ), but caution is
emphasized here, since it was found that the suspending
medium, ethanol, was responsible for growth anomalies ob-
served. The suggestion is made the PCB in the medium was
not taken up to any extent and that DDT was selectively
absorbed, probably by some physiological control mechanism.
With this organism, all of the initially added DDT was pres-
ent after 5 days of growth and no degradation products were
observed.
Chlorella and Euglena were observed to sorb and ab-
sorb 60 to 80 per cent of the quantity of lindane present
in aqueous solutions ( 27 ). Concentration in the food chain
at this level is specifically indicated but hydrolysis and
microbiological degradation is not ruled out.
Much additional research at this fundamental level of
uptake, accumulation and metabolism of aquatic food chains
is badly needed.
26-E
-------
Benthic forms, Zooplankton and Fishes
The primary route is probably through ingested food
although entry through gills and, in general, the body surface,
cannot be ignored. Most aquatic invertebrates respire by
means of gills or some other thin membrane. Considering
the rapid heart rate in most and high fat content of
many it appears that rapid uptake and storage is possible
by this route. Table g-E taken totally from Johnson
et al ( 28) is included since it is one of the few papers
utilizing concentrations in pptr range. (The level found
in many natural waters.) It can be seen that direct uptake
occurred rapidly in the absence of food.
As-
tounding magnification occurred in only three days. The
authors stress the impact of such magnification on succeed-
ing trophic levels; (1) rapid accumulation during periods
of limited pollution exposure (2) ability to concentrate
even at extremely low ambient levels, (3) source of bio-
logical magnification of degradation products. Thus, the
conversion of aldrin to dieldrin was 25% accomplished in
three days and the degradation of DDT to DDE was 85%
accomplished in the May fly nymph in three days. Additional
metabolites were recovered from other organisms.
27-E
-------
Table 6-E
BIOLOGICAL MAGNIFICATION OF 14C-LABELED p,p'-DDT AND ALDRIN
BY FRESHWATER INVERTEBRATES
Pesticide residue (mean value ± SE')
Stage of Water
Pesticide Organism development No./sample (ng/liter)
tO
00
1
W
DDT Cladocera
Daphnia magna
Amphipoda
Gammarus fasciatus
Decapoda
Orconectes nais
Palaemonetes
kadiakensis
Ephemeroptera
Hexagenia bilineata
Siphlonurus sp.
Odonata
Ischnura verticalis
Libellula sp.
Diptera
Chironomus sp.
Culex pipiens
Aldrin Cladocera
Daphnia magna
Ephemeroptera
Hexagenia bilineata
Diptera
Chironomus sp.
Mature
adult
Mature
adult
Mature
adult
Mature
adult
Nymph
Nymph
Naiad
Naiad
Larvae
Larvae
Mature
adult
Nymph
Larvae
60
1
1
1
1
10
1
1
10
10
60
1
10
80.3±13.7
81.3±13.0
80.3±13.7
100.0±0.07
52.1 ±10.0
47.0±5.1
101.3±5.8
79.3±4.3
46.3±3.5
104.6±8.8
16.7±0.37
21.3±2.4
21.3±2.4
Total body (ng/mg)
1 day
2.04±0.04
0.38 ±0.04
0.071"
0.152±0.01
0.49±0.04
0.48b
0.36±0.07
LOb
0.29±0.04
0.26±0.01
2 days
5.55±0.31
0.99±0.15
0.171
0.375±0.02
0.87 ±0.02
0.94
0.375±0.02
0.072 ±0.005
1.13±0.20
13.9±0.78
1.7
0.44±0.04
0.35±0.04
3 days
9.17±0.17
1.68 ±0.15
0.233
0.503±0.06
1.68 ±0.06
1.08
2.2±0.21
2.4
0.66±0.08
0.48±0.06
• Biological magnification
factor
Iday
25400
4600
880
1500
9400
10200
7800
58000
13800
12300
2 days
69100
12100
2100
3700
16700
20000
3500
910
24500
133600
100000
20900
16600
3 days
114100
20600
2900
5000
32600
22900
47800
141000
31400
22800
"Data represent the mean value of at least triplicate samples.
bData represent the mean value of duplicate samples.
-------
Several additional points are worthy of mention. Cladocera
subjected to less than one-fourth the concentration of aldrin
as DDT showed a fwo-fold biological magnification in one day
for a rate of accumulation over eight times as fast as DDT.
Similarly, Chironomus sp. and Hexagenia concentrated aldrin
about four times faster than DDT in one day. The total bio-
logical magnification for Hexagenia bilineata was approxi-
mately equal for aldrin and DDT over the three-day period,
but was only one-half the total magnification for aldrin in
three days. This later fact may reflect the suspicion
that equilibrium storage capacity was being reached, or
that once a compound has entered the body, a differential
storage is possible. It should be noted that dipterous lar-
vae and Cladocera are two of the primary foods of young fish
in addition to being the two greatest concentrations ob-
served.
A great deal of confusion seems to exist as to which
is the correct or dominant route of pesticides into the bod-
ies of fish. There would appear to be no reason to debate
any of the data presented by various authors. Although tech-
niques vary, all appear to be reasonably consistent with
physiological principles. Thus the gill is suggested as
the site of inward diffusion of pesticides (dieldrin) where
it dissolves in the lipid portion of lipoprotein, in which
29-E
-------
form it is transported to and incorporated into the lipids
of various tissues ( 29). Concentrations of 169-515 ppb
in bath water resulted in plasma perfusate concentrations
of 64-220 ppb. This results in a constant inward diffusion
gradient; continued transport and storage; thus, perpet-
uates the gradient»(30 ). Radioisotope techniques were
utilized to show that brook trout accumulated almost ten
times as much DDT from their food as from the water directly
( 31). Using comparative figures, pptr in water and ppm
in food, they suggest that at their calculated rates, it
would take the fish 12 years to accumulate 1 ppm total resi-
dues when exposed to a constant 3 pptr in water. Since
yearling salmonids from lakes often contain 1-2 ppm in
their first year of life, it is offered that the food chain
is the major source of DDT concentration in fish.
30-E
-------
Primary Production; Any energy-yielding or energy-
requiring system must leave the source of that energy iden-
tified. Photosynthesis and carbon fixation are fundamental
to the support of succeeding trophic levels. An understand-
ing of the effects of pesticides on this basic biochemical
and life support system is therefore essential. Natural
bodies of water are quite diverse, as are the forms of
vegetative life they support. Oceanic water masses and
impounded or semi-impounded waters accomplish carbon fixa-
tion, primarily through the action of free floating phyto-
plankton green plants which, by definition, have very poor
or no means of self-mobility. Rivers and other flowing
waters, because of the movement of the water mass, support
relatively few freely floating plant forms. Forms attached
to the substrata, diatoms, coccoid and filamentous algae,
accomplish a part of the photosynthetic task in these waters,
More recently it has been shown that often as much as
75% of the total energy-yielding food base in streams does
not arise in the stream itself, but comes from the watershed
in the form of bits of fragmented plant material. This
allochthanous material could bring to the stream accumulated
quantities of pesticide materials, along with loads of
silt and running water, each contributing its share.
Each of these sources, including that portion of
31-E
-------
airborne pesticides brought in by rainfall directly (pre-
viously co-distilled from the global environment) assure
that pesticide compounds find their way into the water en-
vironment. Now, do these compounds actually exert a harm-
ful effect on the total global photosynthetic picture, or,
depending upon local conditions, a sufficient effect on
photosynthesis in general to merit our concern?
DDT, when applied to laboratory cultures of coastal
and oceanic phytoplankton species was sufficient to re-
duce photosynthesis in all at concentrations less than
LO ppb ( 32). It is emphasized that although such a level
is high for the open ocean, it would be of the same order
of magnitude as other authors have found for natural waters
under certain circumstances (133 ppb in Florida salt marsh
for 1 week following DDT spraying; 22 ppb in some Califor-
nia coastal waters; and 14-20 ppb added directly to Clear
Lake, California). Levels far in excess of 10 ppb have
been recorded at outfall sources in freshwater streams and
lakes. The ecological importance of such physiological
stress as is imposed by DDT. is that species composition
may be altered, allowing species which may normally be sup-
pressed by others to "explode" and dominate the community
for varying periods of time, thus, the normal ecological
32-E
-------
succession is disturbed and community structure upset. The
influence of varying toxic susceptibility is indicated in
other studies ( 33) which show that some forms from differ-
ent oceanic environments show dramatically different res-
ponses to DDT, dieldrin and endrin in culture. One species
was inhibited by all of these pesticides at concentrations
above 1 ppb with cell division markedly reduced at 0.1 pph,
while another species was completely insensitive to these
ranges. This extreme difference serves to further emphasize
the dramatic influence on succession and dominance of algal
populations referred to above.
Very few studies have been conducted on algal species
native to the five-state study area. Work already referred
to on natural communities of periphyton ( 11 ) is valid for
an assessment of total accumulation of pesticides. It does
not, however, identify the response of native periphyton
communities to these pesticides. One such study which does
utilize an ubiquitous, naturally occuring fresh water algal
species indicates that DDT, dieldrin and toxaphene all de-
creased cell numbers at all levels of treatment in culture.
In addition, total biomass and the rate of carbon assimila-
tion were reduced. (33 a) .
33-E
-------
Static bioassays with three species of stoneflies ( 34 )
indicated that endrin and dieldrin were the most toxic
organo-chlorides used out of thirty-eight different commonly
used pesticide compounds. Differences between species is
indicated as well as differences between sizes of the same
species; the smaller (younger) individuals being more
susceptible than larger (older). Carbonates and organo-
phosphates were generally less toxic to stonefly naiads. It
might also be mentioned that the symptoms of intoxication,
increasing irritability, loss of equilibrium, tremors,
convulsions, are precisely those features which would tend
to expose these organisms to capture, ingestion and incorpor-
ation into the food chain. (Table ?E)
DDT and ODD were the most toxic compounds to cladocerans.
(Table 8E) ( 35 ) .
Differences in toxicity between species is observed
as well as differences between potency of certain insecticides,
Mention has already been made to the fantastic
biomagnification possible in certain members of the food
chain* (Table6E).
Good,comprehensive studies of a wide variety of
aquatic insect larvae under similar laboratory conditions or
identical natural conditions are lacking. We do find
isolated examples which are useful.
34-E
-------
Table 7-E
Estimated LCia values of various insecticides (technical grade)
for naiads of three species of stoneflies, tested at 15.5C
Ptemnarcyi californica
Insecticides
24 hr
48 hr
96 hr
Endrin
Dieldrin
Heptnchlor
Toxaphene
Faratbinn
Carbaryl
Malathion
DDT
Dursban
Trichlorofon
4.0(3.0-4.9)
6.0 (4.0-9.0)
8.0(2.3-15)
18 (12-27)
28 (19-42)
30 (22-40)
35 (23-43)
41 (27-62)
SO (38-65)
320 (200-512)
0.96(0.53-1.7)
1.3
5.6
7.0
11
13
20
19
18
180
(0.76-2.2)
(2.9-11)
(5.0-9.8)
(8.0-15)
(10-16)
(15-27)
(14-27)
(12-26)
(128-252)
0.25(0.20-0.31)
0.5
1.1
2.3
5.4
4.8
10
7.0
10
35
(0.35-0.71)
(0.85-1.4)
(1.3-4.0)
(4.7-6.2)
(3.0-7.7)
(7.0-13)
(4.9-9.9)
(7.0-13)
(22-55)
* Figures in parentheses are confidence limits of the LCM lor p =0
24 hr
PteroiutTcella badia
I-CK,, iiig/liter
48 hr
96 hr
2.8(2.3-3.4)
3.0(2.2-4.2)
6.0 (4.3-8.0)
9.2(6.8-12)
8.0(6.3-10)
5.0(3.6-7.0)
10 (6.7-15)
12 (8.8-16)
4.2(3.0-6.0)
50 (39-64)
1.7(1.2-3.4)
1 5(1.3-2.0)
4.0(3.3-4.8)
5.6(4.0-7.8)
5 6 (4.0-7.8)
3.6(2.9-4.8)
60(4.1-8.7)
9.0(7.0-11)
1.8(1.2-2.6)
22 (16-29)
0.54 (0.40-0.72)
0.5 (0.37-0.67)
0.9 (0.60-1.3)
3.0 (2.0-4.4)
4.2 (3.4-5.2)
1.7 (1.4-2.4)
1.1 (0.78-1.5)
1.9 (1.3-2.7)
0.38 (0.30-0.49)
11 (8-16)
.05.
24 hr
3.2(2.2-4.6)
4.5(3.1-6.5)
9.0(6.2-13)
6.0(4.6-7.9)
8.8(6.5-12)
12 (9-16)
13 (9.6-17)
16 (12-20)
8.2(4.9-14)
110 (76-159)
Claaisenia sabtiloitt
"•CM, »g/]iter*
48 hr
0.84(0.64-1.1)
2.3 (1.8-2.9)
6.4 (4.9-8.4)
3.2 (2.2-4.6)
3.5 (2.3-5.2)
6.8 (5.1-8.9)
6.0 (4.1-8.7)
6.4 (4.9-8.3)
1.8 (1.2-2.2)
70 (52-94)
96 hr
0.76(0.62-0.93)
0.58(0.40-0.84)
2.8 (2.1-3.7)
1.3 (1.0-1.6)
1.5 (1.0-2.2)
5.6 (3.9-8.1)
2.8 (1.8-4.3)
3.5 (2.9-4.2)
0.57 (0.39-0.83)
22 (16-29)
35-E
-------
Rather sophisticated measurements of respiration and
glucose metabolism in stoneflies showed that exposure
to DDT at 380 ppb was sufficient to elicit a change in
oxygen consumption (raised) and alter glucose metabolism
so that in treated organisms, 69 per cent of the glucose
was catabolized via the pentose shunt as opposed to 83
per cent catabolized by this pathway in controls. Such
subtle alterations of metabolic paths in food chain
organisms could have far reaching consequences on total
energy budgets for the ecosystem. Very few studies of this
kind have been conducted and many more obviously are
required. (36)
Table 8-E
COMPARATIVE TOXICITIES OF INSECTICIDES REPORTED
IN THE LITERATURE AND BY THE FISH-PESTICIDE
RESEARCH LABORATORY FOR FOUR SPECIES OF DAPHNIDS.
EC5Q IMMOBILIZATION VALUES ARE IN MICROGRAMS/LITER.
Toxicant
Daphnia magna1 Daphnia magna* Daphnia pulcx* Daphnia carinata' Simocephalus serrulatus3
50-hour ECX 24-hour ECM 48-hour EC^, 64-hour EC-. 48-hour EC...
DDT
Methoxychlor
TDE (ODD)
Alrlrin
Heptachlor
Dicldrin
Endrin
Lindane
6SF
1.4
3.6
_
29.2
57.7
330.0
352.0
—
68 F
4.4
3.7
4.6
30.0
52.0
740.0
900.0
1,100.0
60 F
0.36
0.78
3.2
28.0
42.0
250.0
20.0
460.0
78 F
2.2"
_
4.0s
20.0
250.0s
50.0
60 F
2.5
5.0
4.5
23.0
47.0
240.0
26.0
520.0
70 F
2.8
5.6
5.2
32.0
80.0
1900
450
880.0
» Values reported by Boyd (unpublished).
'Values reported by Kawar (\uipublished).
"Values determined in this study.
•Values reported by Matida and Kawasaki (1958).
B Values indicate 32-hour figures.
36-E
-------
Fishes
A large number of publications have presented data
on acute and chronic toxicity to fish and other aquatic
organisms, of a wide variety of pesticide compounds.
Unfortunately, very few of these have utlized aldrin or
dieldrin of the insecticides or atrazine of the herbicides,
The body of published information on DDT alone would fill
volumes. Due to the paucity of information on aldrin,
we have decided to review selected papers dealing with
DDT where they demonstrate a particularly valuable point
and other cyclodienes, as their mode of action might be
expected to reflect the action of aldrin/dieldrin. It
has been suggested by several authors recently that
considerably more effort could and should be directed at
studies utilizing organo-phosphates and carbonates since
it is hoped by many that these less persistent
compounds will eventually replace the more persistent
organo-chlorides.
In a study of relative pesticide susceptibility
to some common fishes, Macek and McAllister ( 37) found
considerable differences not only between classes of
pesticide compounds but between the various families of
fishes. It was possible to establish a range of species
susceptibility — a hierarchy of response. It was not
37-E
-------
possible to relate chemical structure absolutely with
the observed response but it was suggested that such
hierarchial rankings could be used to predict responses to
fish populations. The idea is not new (V. E. Shelford
arrived at similar conclusions in 1917 when investigating
phenolic wastes). The point is that such an evaluation
does appear to have merit, but is rarely applied by
workers. It was pointed out, and should be emphasized,
that safe levels based on assays with one group might be
extremely hazardous for another.
Analysis of inherent biological variability as
reflected in variability in genetic constitution and
physiological condition of the test species is identified
as being responsible for the wide differences observed
to the same toxicant (38 ). (Table 9-E)
Table 9-E
-The mean TLu> and coefficient of variability of p,p'-DDT for fish and aquatic invertebrates.
The 96-hour values are given for fish and the 48-hour values are given for invertebrates
Species
Rainbow trout
Salmo gairdneri
Fathead minnow
Pimephales promelas
Channel catfish
Ictalurus punctatvs
Bluegill
Lepomis macrochiru*
Largemouth bass
Micropterus salmoides
Daphnia
Daphnia magna
Seed shrimp
CyprUiopfis cidua
Sowbug
Asellus brcticaudus
Glass shrimp
Palaemonetei kadiakensis
Damselfly
Ischnura tertiealii
Scud
Gammaria fasciatus
Number
of tests
15
14
10
18
13
11
10
9
11
9
17
Temperature
(C)
12.5
18.5
18.5
18.5
18.5
21.1
21.1
15.5
15.5
15.5
15.5
24 hours
9 C (^7)1
24.6 (47)
25.8 (34)
14.7 (35)
3.9 (28)
_
„
7.8 (19)
6.9 (20)
60.0 (22)
10.4 (31)
48 or 96 hours
7.2 (30)1
19.9 (39)
17.4 (17)
9.5 (37)
1.8 (28)
4.0 (15)
54.0 (15)
4.7 (15)
4.2 (17)
22.5 (35)
3.6 (30)
1 Coefficient of variability.
38-E
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The importance of this feature of testing as it
relates to the significance of acute exposures can
hardly be overemphasized. The fathead minnow showed
the greatest variation in susceptibility. It is
unfortunate that data for the goldfish is not included
since this species is routinely used in such studies and
for registration applications.
Various metabolic effects have been noted in fishes.
Thus, treating immature rainbow trout with 1.0 mg dieldrin/
kg. BW (140 days) and subjecting to forced swimming for
24 hours. Total serum amino acids in control and DDT
treated fish were decreased. Significantly, dieldrin
exposed fish did not decrease. It was concluded that
amino acids were preferentially utilized by dieldrin treated
fish while fat and carbohydrate was preferentially used
by DDT and control groups for an energy source during
the first week of forced swimming.
RBT subjected to loading with DDT and dieldrin and
then forced to swim showed that stressed dieldrin treated
fish lost 32 per cent more weight during two weeks of
stress than similarly treated controls or DDT loaded
fish. The loss of weight of these two latter groups was
60 per cent more than fasted groups of fish, however.
39-E
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Measurements of losses of mesenteric fats during the
forced swimming showed that DDT was not appreciably
metabolized until the depot fat was about depleted, then
rapid mobilization and brain and liver inflammation,
followed by death. Little fat was mobilized by stressed
dieldrin treated fish during forced swimming(previously
described) ( 39) and elimination followed predicted
elimination half-life. Thus, a basic difference in the
metabolic response of fish is noted between these two
compounds. Rodgers and Stalling (40).
The importance of diet control in toxicological
studies was pointed out by Mayer (41 ) in studies which
showed that DDT and dieldrin acted synergistically when
fed in combination to rainbow trout. More DDT was stored
in the brain of fishes on low methionine diet than in
those on high methionine diet.
A similar feature has been noted in rats and
dogs and may be a general vertebrate response to combin-
ations of these two chemicals.
Macek et al (29 ) present interesting data to
indicate that dieldrin and DDT both increase lipogenesis
in the rainbow trout (RBT). Furthermore, the effect
of both of these organo-chlorides was additive and most
significantly, it took several months of exposure to
40-E
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cause this effect. Feeding combinations of DDT and
dieldrin resulted in the trout retaining relatively
more of the total load of DDT than of dieldrin. Thus,
98 per cent of the DDT was retained after 56 days and
50 per cent of the dieldrin was eliminated in less than
14 days. It is suggested that the fish have a greater
capacity to metabolize and/or excrete dieldrin than DDT.
Data on responses of fishes to atrazine are absent.
Simazine, a substituted triazine, has been utilized
and, as most other herbicides, found to be far less
toxic than insecticide compounds.
Concentrations of simazine g 0.1, 0.3, 1.0 and
3.0 mg/e (ppm) resulted in residues of 0.0, 0.1, 0.3,
and 0.5 ug/gm (ppm) in bluegill reared in these treated
ponds. Dead and decaying vegetation lend an immediate
and temporary enriching effect but this was ultimately
offset by a decrease in net primary production. Although
it was not commented upon, gross shifts in CO_/HC03
ratios resulting from the treatment could have dramatic
effects on feeding and food utilization by the fish. (43)
Features of the environment which alter respiratory
rates such as the above might augment the harmful effects
of pesticides.
41-E
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We are cautioned that experiments with one year
(age or size) class might yield spurious results when
metabolism (respiration) rates are compared to uptake
of pesticides. The slope of log oxygen-log weight
relationship is considerably less than one in most
species tested. Thus, because of their higher respiratory
rate and hence higher respiratory volumes, smaller
fishes accumulated greater concentration of compounds
like pesticides for their weight. Since respiration
generally follows the Q,Q rule, fishes from warmer waters
may be expected to accumulate higher levels of residues
from water than fish from colder waters assuming equal
ambient concentrations ( 44 ).
Measurements of respiration in fishes exposed to
pesticides are largely lacking. One such study yielded
rather variable results and fluctuations in respiratory
rate in goldfish chemically subjected to sub-lethal
concentrations of dieldrin ( 45).
Although variations in respiratory rate may provide
rather sensitive parameters, it is felt that metabolic
studies incorporating labelled compounds are far better
indicators of meaningful metabolic events.
42-E
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Once Inside the Body of an Aquatic Organism, How are
Pesticides Degraded or Metabolized?
The liver is the site of active metabolic alteration
of a great variety of chemical compounds.
Atlantic salmon degraded DDT to DDE and TDE within
nine hours when immersed in solutions of the parent
compound ( 46) .
Decrease in the total quantity of organo-chlorine
in ovarian tissue of the winter flounder was observed as
the spawning season progressed. The total of DDT, DDE,
heptachlor, heptachlor epoxide and dieldrin was sequential
concentrated from October 30 (0.21 ppm) to March 29
(1.29 ppm). Although less than one-half of that value
was reported by Burdick ( 47) to cause fry death, these
authors felt that the high larvae mortality observed in
this species at final yolk sac absorption time could be
the result of synergistic response or species tolerance
differences ( 47a).
The effects of intestinal microflora have been
demonstrated to degrade certain pesticides (46 ) . This
general phenomenon, although minor, is nevertheless a
known route to decay. DDT has a strong inhibitory effect
2
on adenosine triphosphatese (Ma+, K+, Mg +) at 5 ppm.
43-E
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Noneverted intestinal sac of seawater-adapted eels
showed impairment of fluid absorption when bathed in DDT
solutions. This impairment was seen to have an
enzymatic basis. The DDT at 5 ppm producing a 43 per cent
2
inhibition of adenosine triphosphatase (Na+, K+, Mg +)
activity in mucosal homogenates (48 ) .
Osmoregulatory impairment in teleosts is thought to
be involved with sodium transport and an ATP mixed system.
Organo-chlorines have shown such inhibition when
investigated. Lindane,endrin, chlordane and DDT inhibition
of one or more ATP-ases from gill, muscle, brain,
intestinal mucosae, and liver have been shown for a
variety of freshwater and marine fish ( 49,49a) .
In addition to inhibition of ATP-ase systems,
organo-chloride insecticides has been observed to alter
other enzymatic systems. Thus, dieldrin was lethal
to the sailfin mollie within 72 hours at concentrations
of 12 ppb and caused a significant increase in serum
glutamic oxalacetic trans:amlnase levels (50) .
The liver, in addition to or as a result of, its
being the site of most active in vivo degradation of
pesticides, is also the site of greatest enzyme
induction. As previously stated, the effect of enhanced
microsomal induction of enzymes may be the most serious
44-E
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single biochemical event. The effect on disturbed
steroid metabolism and the consequences observed in
raptorial and fisheating birds is well documented.
Young coho salmon were observed to sucumb to DDT
in diets in direct proportion to their size. Younger
fish consumed a proportionately greater amount of food
for their body weight and thereby received the highest
dose (51 ). This feature is common to all young
animals which are in an active phase of growth.
Dieldrin was demonstrated to reduce growth rate in
160 and 230 day experiments with guppies continually
exposed to 1.0 and 2.5 ppb. While lower levels seemed
to increase the intrinsic rate of increase, at higher
levels (2.5 ppb) the intrinsic rate of increase was
reduced by a combination of lower total reproduction,
increase in number of aborted broods and delay in age
of first reproduction. Post natal survival was not
expected at concentrations up to 2.5 ppb (52 ).
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Do Natural Populations of Fishes Contain Sufficient
Pesticide Levels to Validate the Prediction of
Potential Harm?
Spraying with DDT for flying insects around summer
homes on Sebago Lake apparently resulted in abnormally
high tissue levels of DDT and DDE in landlocked salmon
(53 ). Tissue levels, especially gonads, showed a
steady increase in fishes from three successive years,
spraying by year class. Thus, age class III 1.2 ppm,
age class IV 8.0 ppm and age class V, 8.8 ppm for tissues.
Amount stored in gonadal tissue showed that females
stored considerably more in this tissue than males.
The differences as in most tissue examined in aquatic
animals, was related to fat content* It should
be noticed that species differences are particularly
evident; five year lake whitefish and two year old
brook trout showing the same DDT levels. The longer
animals are exposed, the greater residues are
accumulated, metabolism notwithstanding.
Do Different Fishes Accumulate and Store Different
Levels of Pesticides?
A survey of pesticide residue in Great Lakes fishes
(53), Sebago Lake, Maine, fishes ( 54) (Tables 10-E and 11-E)
suggest very strongly that varying amounts of pesticides
46-E
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TABLE 10-E
DIELDRIN AND DDT RESIDUES IN WHOLE FISH
Species (fi)
Smelt 4
Suckers 40
White Fish 18
Minnows 1
Alewives 4
Bullheads 2
Carp 4
Pike 5
Chubs 4
Yellow Perch 4
RBT 18
Brown Trout 8
Brook Trout 8
Lake Trout 5
Co ho 3
Chinook 1
Total Pesticide ppm
Dieldrin
.187
.072
.229
.001
.121
.153
.315
.097
.225
.054
.075
.259
.031
.146
.209
1.47
Total DDT (DDE & ODD)
6.16
2.43
2.8
.57
2.05
1.46
2.83
2.91
6.53
1.59
2.46
3.16
1.74
3.84
10.3
2.14
47-E
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TABLE 11-E
AFFECT OF AGE ON DDT RESIDUES
Species
Lake White Fish
Brook Trout
8MB
Chubs (live)
(dead)
Common Shinner
Smelt
Number
11
2
5
3
4
10
6
200
Age Class
V
II
IV
V
VI
I
I
DDT ppm
6.2
6.2
2.0
3.7
4.0
0.28
1.0
.60 (same
site as Chubs
.32 (1 mile
away)
.70
48-E
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are accumulated and stored. Differences between species
may certainly reflect differences in feeding habits
but does not preclude the fact that inherent differences
in the basic physiology of the animal is involved. A
general increase in tissue levels is indicated as fishes
increase in age (see 8MB and salmon). It should also be
noted that no direct relationship appears to exist
between the storage of dieldrin and/or DDT although all
animals are theoretically exposed to the same concentra-
tions. Although not documented by anyone, it would
appear that such differences could accrue largely from
the levels of residues in food chain organisms. Differences
in retention rates is not ruled out.
Terata
Brood stock of the channel catfish proved to be
already highly contaminated with organo-chlorine
residues. Diets of 0.0, 0.3 and 2.0 jig/g B.W. of
endrin for one month prior to spawning produced a large
incidence of deformity in fry of the following types:
Tail-less 44 + 9%
Spinal curvature 8+3%
Large mandible 9 + 2%
49-E
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It was impossible to correlate the terata with any
one residue due to the prior contaminations of the
breeders. That this result was due to the treatment and
high residues is borne out by the fact that brood stock
from the same source and maintained on pesticide-free
regimes for 2 years, exhibited fewer than 3% deformed
progeny. ( 55 )
It is seen that fishes such as those catfish
examined by Morris and co-workers (56 ) from Iowa and which
carried a body burden of organo-chlorine pesticides
(dieldrin = 500-1000 ppb)of the same order of magnitude
or higher, are or were quite capable of suffering some
degree of reproductive failure. These small fry are
generally too small to be noticed; the potential for
harm would only be seen in the strength or weakness of
year classes years later (like 1975-1976+).
Lake trout fry sustained a heavy mortality at
hatching when egg fat content reached 2.95 ppm or
above (47 ). Fry of the Sebago salmon had 76 ppm DDT in
fat, 24 PPM DDT one week after yolk sac absorption.
On a wet weight basis, this was 0.76 ppm; no mortality
was observed ( 53 ).
Gonad development was reduced and a lowered
gonadosomatic index was evident in goldfish chronically
50-E
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exposed to endrin, through feeding at levels .43 ppm
and .143 ppm in food. These figures are not inconsistent
with levels observed in natural food organisms ( 57 ).
Similar injury to sac fry of the cutthroat trout
was noticed and reported as early as 1963 ( 58 ). More
recently, studies have demonstrated this in brook trout eggs.
The release of DDT by metabolized phospholipids is
probably of greater importance than the utilization of
triglyceride oil droplets as previously thought ( 59 ).
These studies indicate that the greatest phospholipid
mobilization occurred at 65-70 days, the period of final
yolk sac absorption and greatest fry mortality.
Submersing carp eggs in various insecticides
resulted in 50-100 per cent mortality above 5 ppm; none
caused significant mortality below 1 ppm, leading the
researchers to conclude that carp embryos are less
susceptible to pesticides in the water than are adults.
Whether or not uptake and accumulation reached levels
known detrimental to trout and salmon was not determined.
Chlordane was found to be responsible for slightly
increased viability and apparently stimulated develop-
ment time. Additional data is desperately needed to
determine whether chemicals like chlordane can stimulate
microsomal enzyme induction and thereby effect develop-
mental rates in fishes ( 60 ).
51-E
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Do aquatic organisms exhibit behavioral changes in res-
ponse to certain pesticides?
The obvious results of acute toxicity are well docu-
mented. Subtle, difficult-to-identify changes in beha-
vior associated with sublethal, chronic exposure to
pesticides is not as well documented. The chlorinated
hydrocarbons including the cyclodienes are known to
effect both central and peripheral nervous tissues in
mammals and birds. From the animals' point of view and
for his continued success as a member of the larger popu-
lation. Behavioral alterations which reduce alertness,
increase restlessness, reduce visual acuity or otherwise
are responsible for exposing the animal to capture or
debilitating injury all have a damaging effect on the
long term success of the species.
Brook trout, exposed to DDT at sub-lethal concentra-
tions of 100-300 ppb increased the duration of response
to a simple mechanical disturbance. The response is
greatly potentiated by cold. The greatly increased
instability in sensory nerve fiber firing in the cold
suggests that DDT (and perhaps other compounds as well)
may be more lethal in colder temperatures. A constant
barrage of uncoordinating bursts may easily reduce the
animal's vigilance.(61). Twenty parts per billion of
DDT for 24 hours was sufficient to seriously reduce the
ability of brook trout to respond to training.
52-E
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It is also pointed out that such a disturbance may
be devastating to the sensitivity of temperature
selective mechanisms in cold water tissues.
In a subsequent paper (62), under different experi-
eental conditions, it was determined that DDT did not
appear to affect learning per se, but that the effect of
sub-lethal concentrations under cettain learning condi-
tions significantly alter the ability to perform cer-
tain tasks. The possibility that sublethal amounts of
DDT could alter a fish's natural repertoire of CR's
produced in response to a given conditioning regime is
suggested (62 A).
53-E
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Have aquatic organisms developed resistance to pesticides?
The development of some degree of resistance to
insecticides by vertebrates has been erroneously
heralded as a significantly desirable feature by many.
The claim that such resistance signals the development
of an ability of "cope" with the compounds in question
overlooks and tends to overshadow the biological and
ecological significance of such data. The inescapable
fact is that any such resistance implies a genetic
change in the target species. Any compound capable of
affecting one such change in the genome can conceivably
be responsible for many more unidentified changes which
might spell doom for the species.
Another undesirable feature of such resistance is
that resistant species can develop massive body burdens
of persistent compounds which, when incorporated into
the food chain, could easily prove fatal to susceptible
organisms higher in the food chain. Examples of such
resistance are presented in Table 12.
It is interesting to note that in these and related
studies the greater resistance is seen to aldrin,
dieldrin, endrin and related pesticides, much lesser
resistance is seen with DDT. It is suggested that a com-
bination of heavy use of DDT, its stability, and the
absence of DDT resistance to any extent emphasizes the
danger of DDT (53) .
54-E
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TABLE 12-E
ALTERATIONS IN LC5Q IN NATURAL FISH POPULATION
DUE TO PESTICIDE RESISTANCE
Species
Golden Shiner
Bluegill
Green Sunfish
Mosquito Fish
Black Bullhead
Previously
Exposed
48 hr. LC50
900 ppb
900
1,250
500
55
No Prior
Exposure
48 hr. LC50
25 ppb
25
33
16
2.5
Utilizing mitochondrial preparations from both
resistant and susceptable strains of the mosquito fish
(54) it has been possible to identify enzyme alteration
and suggest that vertebrate resistance is a membrane
phenomenon involving either a physical alteration of the
membrane, a functional modification, or both. Using a
succinic dehydrogenase-mitochondrial membrane as the
model it is indicated that the action of certain organo-
chlorides may be a general action involving disruption of
cellular function in all organs and tissues of an animal
rather than a direct and unique central nervous system
involvement.
We have very little data at present to indicate how
stable the resistance patterns may be in natural popula-
tions .
55-E
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We would like to mention a recent paper which, although
not dealing with the aquatic ecosystem,per se, does make
a very valuable point. Chromosomal changes in natural
populations of the fruit fly Drosophila pdeudobscura
have been correlated to DDR applications and residue
patterns in distribution area. One type of change was
occurring progressively with time over a great area and
could not be correlated to any particular meteorological
event or activity in May other than DDT spray applica-
tions. Without laboring the point, what was found was
an increase in percentage of one type of chromosome and
a decrease in others. Specific landmak alteraations are
directly correlated with DDT applications and aerial
drift into specific areas from these applications. ( 65 )
Increase in ST and PP chromosomes and decrease in AR and
CH are quite pronounced (Table 13 )(b). The important
point is this. It required over 24 years of research
effort with an animal which has many generations per
year by teams of internationally renouned geneticists to
identify this change in natural populations. It should
not be surprising that we have difficulty identifying
genetically based population changes in animals such as
native fish which have generation times of three to
eight years or more.
In any event the resistance to pesticies observed
should be sufficient to warn us of biochemical changes
56-E
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Table 13-E
ALTERATIONS IN CHROMOSOME FREQUENCY IN
FRUIT FLY, CALIFORNIA
Extracts -from Tables in Publications by Dobzhansky on
Changes in Population Percentages of ST, AR. CH. and PP Chromosomes
Month and year
(a) April 1939
May 1939
June 1939,
July 1939
Aug. 1939
Sept. Oct. 1939
April 1940
May 1940
June 1940
July 1940
Aug. 1940
Sept 1940
May 1941
June 1941
July 1941
Sept. 1941
April 1942
May 1942
June 1942
July 1942
April 1945
April 1946
June 1946
Year
(6) 1945
1946
1947
1950
1951
1954
1957
1959
1961
1962
ST
35.7
30.9
30.0
20.3
29.2
27.3
45.3
39.9
64.3
53.6
ST
32.5
32.6
24.8
28.6
29.5
26.0
30.6
26.8
31.9
34.5
37.6
41.2
29.0
38.3
35.4
38.2
45.1
45.1
28.2
26.0
41.0
52.0
48.0
AR
35.7
36.6
39.4
49.8
43.2
36.4
33.2
35.6
14.0
27.1
AR
30.0
28.5
30.8
29.3
30.5
35.7
22.8
22.1
20.7
24.8
26.4
17.6
29.4
17.6
27.2
25.0
17.6
14.7
15.4
18.0
22.2
15.5
15.0
CH
17.2
17.1
20.2
17.4
11.2
12.6
3.8
10.7
3.4
2.2
CH
32J
36.2
41.2
37.3
37.6
35.1
42.7
47.1
43.4
37.4
31.5
32.4
37.9
39.3
33.5
32.4
29.4
33.3
46.4
52.0
29.2
23.7
32.5
PP
—
0.3
0.7
2.8
4.6
11.7
9.8
4.4
6.3
8.7
(a) Populations at Keen Camp, western face of San Jacinto
Mountains. PP chromosomes not yet present here (from ref. 17).
(ft) Pooled yearly data on gene arrangements at Mather, 1945-1962
(from ref. 24).
57-E
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which certainly could foretell if genetic changes
occurring in natural populations. At present there
appears to be no laboratory experiments which verify
the alarming field data presented for resistant popula-
tions of fish stocks.
Many of the naturally occurring aquatic Dipterous
larvae would be obvious choices to test for genetic
changes. Unfortunately, we do not have the background
data required to identify a suitable baseline value and
this kind of experimentation appears to be largely
untried.
58-E
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Standards for Testing With Living Organisms
It appears to the contractor that one of the areas
which is badly in need of remedial help is that of stan-
dards. What constitutes adequate standards for tests of
acute or chronic toxicity, which organisms are truly
adequate, which kinds of tests and measurements will be
made, and, most important who will decide what these
criteria shall be? Sadly the words of Cope { 66 ) come
back to sharpen our focus. "On the other hand, the
reporting of toxicity data in a complete manner has
lagged behind, and today's literature is little improved
over yesterday's with regard to completeness and suscept-
ability to interpretation. He cites (and we take
the liberty of adding to the list) three types of infor-
mation required:
(1) The fish themselves (or any other organism)
(2) Methods used in experiment (or other
valuable data from field measurements.
(3) The environment
We have been unable to detect that strict adherence
to these requirements is followed today, despite the
restatement of such aims by numerous workers in the field,
( 67, 68 ,69 ,70 , 71 ) . The problem seems far from
solution since it appears that differences of opinion and
59-E
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interpretation exist today in what constitutes "safe"
levels of pesticides or any other pollutant see especially
Sprague ( 71). The establishment of safe or "no-effect"
levels seem remote indeed when we note that the FDA action
guideline G 300 ppbDieldrin in fish flesh for human con-
sumption is a quantity sufficient to cause considerable
damage to other members of the aquatic ecosystem in chronic
exposure tests. Such a number, empirically derived from
experimental data has real value, however, and probably
deserves serious consideration by all workers. The
difficulty of arriving at suitable numbers is made doubly
difficult by considering the multiplicity of environmental
parameters involved.
It has been suggested (68 ) that where mounting evi-
dence demonstrates that a pesticide is an undesirable or
suspected con.taminantof the aquatic environment its use
would be halted until proven safe, particularly in those
chemicals which accumulate in succeeding trophic levels or
to which resistance has developed (See earlier).
Water itself Appears to Cause Considerable Trouble. What
Water shall be Used?
The use of a standard test water for acute and chronic
bioassays would appear to be an absolute minimal requirement
60-E
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when investigating the responses of aquatic organism to
pesticide compounds. Too often this has not been done,
more often than not laboratory tap water or natural water
is used (unspecified chemistry). The practice of specify-
ing the basic water chemistry has been followed by the
Fish Pesticide Laboratories and other responsible research
institutions. It should likewise be included that temper-
ature and photoperiod should always be included. It would
seem desirable (although not always possible perhaps) to
establish such as acute and chronic bioassays would be con-
ducted so that various research efforts would be more
strictly comparable.
It should also be noted that the drinking water
supplied to laboratory mammals varies quite considerably
around the country. It has been shown that variations
in carbonate content can yield strikingly different
results in kidney enzyme activities. Since alteration
and protein metabolism and elimination of pesticide
metabolites are problems these animals might face in acute
or chronic studies this consideration, if implemented,
should yield more consistent results. In any event the
inclusion of a series of field conducted experiments
utilizing natural water supplies would appear to be very
61-E
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desirable as a complement and comparison to laboratory
studies so long as the water quality is stated.
The entire problem is summed up very well by Walker
( 68 ) for herbicides:
We need to:
(1) Better relate acute toxicity data to
chronic effects or hazards posed by
field use;
(2) Define the significance of residues
to the actual hazard posed;
(3) Determine effects of multiple exposures
and use patterns of several pesticides
and how they will affect toxicity, effi-
cacy and residues.
(4) Recognize and evaluate complications
of water quality, physical conditions,
kinetics of absorption=desorption, and
biological variables on toxicity, effi-
cacy and residues
(5) Develop adequate information on the mode
of action, absorption, distribution,
chemical metabolism, accumulation and
excretion of each herbicide
(6) Know the effects on the behavior and
ecology of non-target organisms.
(7) Develop methods of formulating and
applying herbicides to minimize
hazards to non-target organisms.
(8) Find methods for speeding residue
loss, degradation in water, soil,
fauna, and flora and for the disposal
of herbicide containers.
62-E
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(9) Establish guidelines to interpret
this information and translate it
into label recommendations and
precautions in use patterns; and
(10) Be more concerned with all uses of
water and its depreciation in terms
of future needs.
These comments would appear to be equally valid if
we included insecticides (or other pesticides) as well.
It can be seen that there are serious deficiencies in
our knowledge of everyone of the aforementioned areas.
There would seem to be some hope for the future,
however, the Chemicals in Fisheries Committee of the
American Fish-ries Society is preparing a desk reference
for all biologists, administrators, and students on the
"Use of Chemicals and Methods for Evaluation in Fish
Culture and Fisheries Management. Hopefully this long
overdue effort will point the way to more critical
evaluation and thoughtful experimentation in the field
of pesticide research.
The fact that acute toxicity data can be misleading
is clearly demonstrated by Post (72 ), Table 14-E.
63-E
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TABLE 14-E
COMPARISON BETWEEN DIELDRIN AND DDT TL
FOR FOUR SPECIES OF SALMONIDS
'M
Toxicant
Species
Fish Body Weight
Endrin
DDT
Brook Trout
Brook Trout
Cutthroat Trout
Cutthroat Trout
Rainbow Trout
Coho Salmon
Brook Trout
Brock Trout
Cutthroat Trout
Cutthroat Trout
Rainbow Trout
Coho Salmon
Coho Salmon
1.15
2.04
0.37
1.30
1.24
1.50
1.15*
2.13
0.33
1.25
0.41
0.50
1.65
0.355
0.59
0.113
0.192
0.405
0.77
7.4
11.9
0.85
1.37
1.72
11.3
18.5
It is seen that considerable difference in 96 hour TL
exist between the four species Cutthroat and Rainbow Trout
are often common co-habitants of much of our western waters,
yet they differ by a factor of three in their response to
endrin. Differences between these species and the Brook
Trout are even more pronounced for DDT. This serves to
point up the questionable practice of specifying a certain
fish (i.e., the bluegill) as the sole or preferred warm
water fish for such studies. How pronounced the differ-.
ences become in chronic sub-lethal exposures is unknown
at present.
64-E
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It must be clearly stated that no overt harm to humans
has been demonstrated resulting from exposure to normal
levels of DDT or cyclodienes. On the other.hand, many
deaths are recorded annually from organo-phosphate pesti-
cide use, especially in areas of high exposure or fre-
quest use. At least two obvious problems are involved
here: (1) Do DDT and the cyclodienes cause identifiable
harm to persons either occupationally exposed or by vir-
tue of heavy residential use of the pesticides; and
(2) Other than fatal or near-fatal exposures to organo-
phosphates, can identifiable harm to persons be demon-
strated by virtue of chronic or sublethal exposures to
these pesticides?
Volumes of data are available from a variety of
sources. It is not anticipated that the controversy
over the carcinogenicity or mutagenic capabilities of
these compounds will be resolved for some long time.
Several features do emerge, though, and they seem to be
common to the organochlorines as a group. Thus, the
strong suggestion that at least some of the responses may
be general tissue responses and as a result, might be
common to all vertebrates.
A considerable number of studies have dealt with
long term occupational exposure or chronic ingestion
of varying amounts of DDT in humans. These studies for
the most part have failed to disclose significant tissue,
physiological or biochemical (especially blodd parameters)
65-E
-------
alteration (73, 74, 75, 76 , 77, 78, 79 , 80, 81).
Persons occupationally exposed do, as might be expected,
carry much heavier body burdens than the general public.
Amounts of DDT and DDE in whole blood samples have been
shown to be transient and related to the recency and
the extent of the exposure (75).
It has been suggested by these workers that of
T
the metabolites, DDE would provide the more adequate and
meaningful measure of exposure for a prolonged time.
This is borne out in later studies which demonstrated
that the initial dechlorination of DDT is of critical
important to its metabolic fate. Conversion to pp-DDD
allows further degradation to pp-DDA, a water soluble
and readily eliminated metabolite. Dehydrochlorination,
on the other hand, results in the formation of the stable
metabolite pp-DDE, which is avidly retained in adipose
tissue ( 82). One of the results of such studies appears
to be that the conversion of DDT to DDE is extremely
limited in subjects who have either inhaled or ingested
DDT. The rapid conversion to ODD is shown, however.
It is suggested that tissue storage levels of pp-DDE
in the generation population probably originate from
pre-formed dietary pp-DDE rather than the in vitro
degradation of pp-DDT. It is suggested that the loss of
pp-DDE from adipose storage may take many years in man
since loss from storage in man is much slower than for
monkey, dog or cat.
66-E
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Lindane, the o isomer of benzene hexachloride, has
been shown to be readily absorbed through skin, respira-
tory tract and gastro-intestinal tract; once absorbed
it is rapidly eliminated in urine and feces unlike the
6-isomer which does store in depot fat. Studies con-
ducted on persons exposed from periods of weeks to
years failed to disclose clinical symptomology or phy-
sical evidence of disease clearly attributable to this
exposure.
Other workers have failed to detect pathological
differences between control and exposed populations (80 ) ,
although the suggestion is offered, that when considered
in total the differences do indicate a physiological
response to pesticide exposure. It is argued by many
that present exposure levels in the county indicate a
high degree of safety of DDT for the general population.
Rates of ingestion 555 to 1250 times the general popula-
tion rate failed to elicit demonstrations of clinical
injury (83 )• It should be indicated at this point that
most of the chronic exposure studies in question with
humans have been performed on men. Prison inmates, male
students, medical students, formulators, tank men,
sprayers, etc. Thus, the criteria of effect or no effect
may present a biased view. Evidence has been accumula-
ting that age, race and sex do dramatically effect the
prevalence of DDE in blood, and fatty tissue. Especially
67-E
-------
important here are studies sufficiently sophisticated to
consistently identify demographic differences of DDE
( or any other metabolite) in blood which are due to
person, place, and time, and which suggest subtle varia-
tions in DDT exposure within the general population ( 80) .
Results from community Pesticide Studies in South
Florida ( 81, 84) and Iowa ( 85 , 86 ) and others ( 87 )
suggest that differences observed are due to factors
associated with socioeconomic conditions (housing, sani-
tation) . Thus, high levels of DDE in blood relate well
to the economically disadvantaged (southern rural N.egro,
ghetto Negro) or close proximity to available sources
(above and both northern and southern farmers). The
more disadvantaged persons utilize the less expensive
pesticides (containing DDT). (81). Although no signi-
ficant morbidity excess was found in pesticide workers
when compared to the general population, blood bio-
chemistries did reveal subtle differences between exposed
and the controls. It is of significance that rural
Negro children had levels that approached those of
heavily exposed industrial workers ( 87).
Farming habits as they related to high and low
pesticide use was observed to produce significant correl-
ations between certain chlorinated hydrocarbon exposure
and blood biochemistries. No evidence of organic disease
68-E
-------
was isolated from clinical examinations of high and low
use groups < 88 ). The subtlety of exposure and the
variety of routes has been presented ( 89 , 90) .
In addition to the demonstrated estrogenicity of
in op-DDT in rats ( 91 ), DDT has been shown to cause
significant changes in neonatal mineral metabolism
( 92 ), .and DDE may be correlated to prematurity in
populations of humans chronically exposed ( 93 ).
Transplacental passage of insecticides has been
clearly demonstrated for other animal groups as well
as humans.
Interesting studies with dogs have recently been
presented. Reproductive failure was noted in all
females receiving daily doses of DDT or Dieldrin for
varying periods of time ( 94 ). Significantly, many of
the dogs contained body burdens less than those obser-
ved in occupationally exposed humans. Results of
these experiments also indicated a direct synergism
between DDT and dieldrin as seen in trout, and
suggests very strongly that this response (dieldrin
slowing the retention of DDT and its metabolites) may
be another general vertebrate tissue response.
Insufficient evidence is present at this time to
suggest that DDT or other organo-chloride compounds, at
the levels currently encountered, pose an immediate
health hazard to humans of the general population.
69-E
-------
Certain ethnic groups and the occupationally chronically
exposed farmer or formulator may be carrying body bur-
dens not consistant with the interests of best health.
Although it is not possible to show convincing
direct clinical indications of harm to humans from organo-
chloridescompounds, this is not the case with organo-
phosphate pesticides. The contractor does feel, however,
that sufficient propensity for harm is indicated from
studies on other vertebrates from the long term exposure
to sub-lethal levels of organo-chlorides. A sufficient
number of general tissue and organ responses have been
indicated from studies with other vertebrates to suggest
the likelihood of such responses in man with continued
exposure to certain compounds. Even if man escapes the
physiological damage observed in other vertebrates, the
environment has not escaped, and will continue to suffer.
The next section deals specifically with the con-
tractor's effortsto determine the propensity for harm
to agricultural uses of pesticides presently, as well
as that of the future. The results of agricultural
use (reported as incidences) both to man and his environ-
ment are indicated.
70-E
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Incidence of Injury
The contractor has elected to treat all incidents
in this subsection because of the thread of continuity
common to most, if not all/ cases. This has been and
continues to be the carelessness, ignorance, and, to a
large measure, the truculent attitude widely held that
one is trying to reduce a truly remarkable agricultural
effort by unequivocally baning all pesticide use.
The purpose of this section is to indicate that a
potential for harm does exist to livestock, to the en-
vironment, and to fish and wildlife resources as well
as to man's own health and safety.
It should be realized that agencies which maintain
and analyze statistics, and disseminate safety informa-
tion do so solely to protect the public health. However
methods of reporting, retrieval, recording and collec-
tion vary in effectiveness and efficiency. Also per-
sonnel in charge of these agencies are not always able
or willing to disclose what facts they might have. Thus
in the five state study area - an area of relatively
intense use of pesticide products - one finds fragmented
information on the extent of real or potential harm
Some bright spots do exist and these will be
commented upon in the following text.
71-E
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Farm Injury - Human
County agents and farmers were surveyed to deter-
mine the extent of possible harm to farmer/applicators
from the use and application of pesticides. When county
agents were questioned, twenty-five to thirty (25-30 per-
cent) reported knowing or hearing of particular inci-
dents of exposure within the past year. Others indi-
cated no knowledge of incidents within their county.
The agents were located throughout the state and can
be considered representative of a state. Figures for
agents responding are shown below:
111. Iowa Kan. Minn. Mo.
Incidences
of human ,
injury 6/46 13/47 15/42 12/45 16/37
Positive responses/ number of farm agent contacts.
The greatest cause of illness was spray drifting
back on the operator, with numerous examples of mech-
anical break down of the equipment, and contact result-
ing from that break down. Estimates of man hours lost
from an incident varied from 4 hours (an afternoon) to
as many as three weeks. The average cost time in the
field per exposure was about three (3) days. Phorate
and disulfoton fumes were most often singled out as
72-E
-------
being responsible for operator complaint of illness.
According to the agents, in all cases, including
mechanical failure, operator carelessness was blamed
as primarily responsible for the injury. In many cases
agents indicated they had cautioned farmers to use pro-
tective clothing, but the warning went unheeded. In
the responses received, there seemed to be an overrid-
ing lack of sympathy for farmers who did not follow manu-
facturers or container directions, wear protective
clothing, wash off after exposure, etc. For obvious
reasons a clear case of misuse of a compound was severely
criticized by the agents.
The nature of incidences is generally supported
by farmer assessment of use problems. Container dis-
posal and applicator safety are regarded as the least
important problems facing a farm user.
Farm agents are aware of this problem, as shown
in their responses:
did not wear protective clothing
carelessness
did not follow directions
precautions not followed
operator did not follow recommendations
guilty of improper storage and use
improperly sprayed during high winds
73-E
-------
faulty information
faulty storage
farmer did not follow advise
commercial firm may be licensed but the
operator was careless
no protective clothing - no mask
farmers fail to realize these are hazardous
chemicals
some of the farmers in my county have very
poor reading skills
dealers are sometimes careless in sales
some of the applicators are irresponsible
County agents do feel pesticide use is essential
to maintaining high crop yield. However a great num-
ber of them also appreciate the necessity for continued
and improved educational programs. Many suggest the
necessity of improved regulatory laws but, do not want
to see these laws become overly restrictive.
Relative importance of reported pesticide "inci-
dences" is an extremely sensitive area. The respon-
sibile agent and the farmer both feel the problem is
distorted out of proportion to the magnitude of damage
observed. Both are extremely defensive about use of
pesticides, and alternatively call attention to the
often careless or irresponsible utilization by urban
dwellers. They see ". . .a few dead stunted bluegill"
as the result of careless use - as potentially distorted
74-E
-------
ammunition to be used by ... the environmental ex-
tremist. The point is not without foundation.
With regard to development of a total picture of
use and misuse, little comment is made about pesticide
or residue which leaves the land and enters public water-
ways (methods of transport are detailed in "Route of
Pesticides into the Water Environment").
Also, it should be pointed out that most accidental
exposures are the result of improper application or
obvious disregard of adequate safety measures. Containers
and label directions, although superficially adequate,
do not draw sufficient attention to the dangers. This
situation, compounded by the applicators reluctance to
utilize safety clothing, plastic gloves, respirators,
etc. create a potentially hazardous medical situation.
Farmers in the five state area responded with
similar figures of incidence. However, it was also
implied that farmers do not report everything to the
agents. Based on the data gathered, the two most com-
mon illnesses observed, their responses are shown in
Table 15-E.
Major questions raised during the contractor's
data gathering attempts included: (1) Are there in-
juries which are not being reported? (2) Are there
simply no injuries resulting from pesticide use?
75-E
-------
TABLE 15-E
RESPONSE OF FARMERS TO INCIDENTS OF INJURY
RESULTING FROM FARM USE OF PESTICIDES
Illinois Iowa Kansas Minnesota
Total Replies
No. Use
Pesticides
Total People
111
Do Not Use
Pesticides
Break Down of
Headaches
Dizziness
Sick to
Stomach
Other
Left Ques-
tion Blank
But Use
Pesticides
52
49
14
(28.
2
98
92
17
5%) (20.3%)
57
46
11
(23.9%)
60
46
11
(23.9%)
Missouri
64
55
11
(20%)
1
Illness Reported
10
3
5
3
2
13
5
8
4
26
6
2
7
1
6
6
3
6
1
3
4
1
5
1
5
(3) Are there injuries to farmers which are reported to
doctors but not to state or local health agencies? (4)
What other kinds of damage to wildlife or livestock does
occur and go unreported in the five state study area?
The contractor contacted state health officers
or offices and/or state officers inAcharge of poison
control centers, state pesticide officers, vector con-
trol authorities, state veterinarians, bureaus of
76-E
-------
hazardous substances, and similar agencies in each of
the five states to determine answers to the above ques-
tions.
Table 16E indicates response by the states to the
contractor's pesticide poisoning reporting queries.
It is significant that none of the states has a
standardized system for recording or noting of injury
to farmers. In most cases accidental poisonings are
recorded by poison control centers predominantly for
children from age 0 to age 12. (This situation is de-
tailed later in the chapter). Table 17E identifies
state officials contacted.
Illinois
Dr. H. Petty indicated he was somewhat vexed by
the lack of enforcement of the memorandum of under-
standing to which Illinois is a signatory. "We have
the agreement but with no teeth in the law." He sug-
gested one of the reaons for the lack of machinery for
reporting pesticide-related illnesses might be due to
legal responsibility and the confidential nature of
patient/doctor relationships.
He further suggested there has been some purpose-
ful confusion in terminology fostered by extremists,
i.e., malathion (low toxicity) and parathion (high
77-E
-------
Table 16-E
STATUS OF REPORTING OF HUMAN INJURY RESULTING FROM PESTICIDE USE BY STATES
>J
00
1
W
Agency of System
Illinois
1000
Iowa
2000
Kansas
3000
Minnesota
4000
Missouri
5000
St&te Heal€h
Department
NO1
No
No
Commercial
applicators
information
letters
sent 1971
No
Poison Control
Center
Yes, feel have
good cooperation
May be poor
Felt they do
good job
No
No
Alert
System
No
No
Yes,
Roden-
ticide
1971
No
No
Other (Specify
Memorandum of Understanding.
See comments.
Institute of Agricultural Medi-
cine Survey. Memorandum of
Understanding .
Memorandum of Understanding
Memorandum of Understanding
"Inquired of Kansas, 1970"
Anticipated
?
M.D. alert and request
for cooperation.
Full implementation
for crop year 1972
All states require death occuring within the state be documented as to cause of death. In many cases these
are lumped under poison.
All states have poison control centers but accurate records of cases treated is not required by states. Any
reporting is voluntary.
-------
TABLE 17-E
ILLINOIS
TITLE
NAME
DATE OF
CONTACT
State Entomolo- Mr. Harvey Dominite 11/4/71
gist, State
Health Dept.
Bureau of
Hazardous
Substances
Environmental
Health Office
Chief of
Bureau
Dr. Suess
217-525-7747
11/4/71
Mr. Verdin Randolph 11/3/71
217-525-6555
Mr. Stratton, Asst.
Dir., Bur. of
Personal Planning
Health
Mr. Rodney Anderson
217-525-3817
\D
w
Weed Pesti- Mr. Hogancamp
cide Specialist
Dir. of Diease
Control
Ms. Mary M. Henry
Adm. Assistant.
217-525-7747
State Exten- Dr. H. (Pete) Petty 11/5/71
sion Specialist 217-333-6652
in Entomology
COMMENTS
No figures to indicate any reporting of
agricultural workers hours, lost, sick-
ness, nausea, etc. from this office.
Not in this office.
Only through PCC.
Analytical only. As aid to economic poisons
Act, Dept. of Agriculture Interagency
Committee on Pesticides.
No source information for adult exposure
at this time.
Tried to identify the problem but with
little success.
"Under custom applicator law an incident
may go completely undetected." No
machinery for recording illness of this
type in Illinois. See additional comments
in text following.
-------
ILLINOIS
(Continued)
TITLE
National Safety
Council,
Chicago, 111.
NAME
Mr. Sidney Smith
Assistant Dir.
Statistics Div.
DATE OF
CONTACT
11/4/71
COMMENTS
No standard reporting system for pesti-
cides or other non-fatal accidents.
oo
o
I
w
-------
00
IOWA
TITLE
NAME
Dept. of Health Dr. Schoff, M.D.
Commissioner
General Health
Services
Coordinator/
PCC
DATE OF
CONTACT
11/3/71
Dr. John Goodrich, 11/3/71
Director
515-281-5443
Mr. Paul Ogilvie 11/3/71
515-281-5445
Institute of Dr. Keith Long,M.D. 11/3/71
Agr. Medicine,
Univ. of Iowa
COMMENTS
Nothing from this office. No plans at
present to require this reporting.
Only mechanism is through poison control
centers and on a strictly voluntary
basis. This is not among the things
required by law to be reported (of
V.D., etc.). Suspects that PCC may be
quite lax in reporting.
May be faulty due to lack of reporting.
Trying to improve.
See text comments.
i
w
-------
00
to
W
MINNESOTA
TITLE
State Pesticide
Office
Health Dept.
State of Minn.
Health Dept.
Environmental
Health Section
Environmental
Health Section
NAME
Mr. Tarmann
DATE OF
CONTACT
11/4/71
Mr. Russell Frazier
Dir. of 11/3/61
Analytical Ser.
Mr. Parrell Anderson
612-378-1150 Ext. 325
Mr. Raschka
612-378-1150
11/2/71
COMMENTS
-No- manually handled through PCC
Routinely runs samples from water and
wildlife from the state. . . or
if specifically requested
to do so.
No state machinery for such reporting.
PCC in Minnesota primary function is
to information to regional
centers do fair to poor job of re- '
porting (0-12 yrs.).
Industrial injuries reported through
Commerce Dept. Farmers and farm
workers not covered by this or work-
men's compensation in Minnesota.
M.D.'s do not report occupational injury.
Will undoubtedly be reported when and if
state becomes of Federal
Occupational Safety and Health Act.
-------
00
CO
w
MISSOURI
TITLE
St. Louis County
Medical Examiner
Mo. Div. of
Public Health
Epidemiologist
NAME
DATE OF
CONTACT
Dr. Geo. Gantner
(Ch. Dept. of
Pathology, St.
Louis Univ.
School of Medicine
Dr. Wm. F. Raithel
11/5/71
Dr. H. Denny Donnell
314-635-4111
COMMENTS
No machinery established in State of
Missouri
Suspects are most often ignored.
and Drug function primarily
Food
A new function - probably will get to it
in the future. Presently have a hard
enough time getting people to report
syphilis and gonorrhea without something
as unimportant as pesticides.
-------
toxicity). He was finding it difficult to get orchar-
dists to believe ethyl parathion was a poison and be-
lieved it probably was carelessly used by many. Dr. Petty
has cholinesterase assays run before, during and after
his demonstrations and has never suffered cholinesterase
depression.
It should be pointed out that Illinois officials
were courteous and as helpful as possible. (This was
also true for the other four states covered). The
fact remains however, that no system exists for re-
porting this kind of injury.
It also should be pointed out that while we are
attempting to make no comparison between state pro-
grams, the educational material and short courses con-
ducted through the University of Illinois along with
an agressive program of farmer education in pesticide
in the State of Illinois appear to be quite good. The
dedication of men such as Dr. Petty is undoubtedly
responsible for some of Illinois' success in keeping
injury to a minimum (see Table 17-E).
Iowa
Dr. Keith Long has been in charge of Institute
for Agricultural Medicine for 6 years. He suspected
84-E
-------
that reporting by other agencies is or might be faulty.
As a result last year he instituted a post card survey
receiving 1100 replies, 900 of which reported treatment
for pesticide exposure of some kind. At the same time
state poison control centers and hazardous substance
cehters reported only 37 cases. A more complete pro-
gram of action is planned for crop year 1972. Although
Dr. Long is aware that his efforts are not as well
organized as Kansas alert system, he has solicited
help in obtaining reports from rural medical doctors
in the state.
In summary he feels the entire problem of in-
juries from pesticide use is of far greater magnitude
than previously believed.
Particular reference and attention should be
directed to these excellent studies. It appears that
little will be accomplished at the state level until
or unless a strong interdisciplinary program is es-
tablished and funded. Of the five states only Iowa
has such on-going studies and the results of this
contriving program help to focus on the potential
magnitude of the problem.
85-E
-------
Kansas
All contacts from state offices indicated there
was no records system, although it is felt the Poison
Control Center does a very good reporting job. Un-
like most other states, Kansas Poison Control Centers
do report people over the age of 12 years. All con-
tacts referred us to Mr. Roger Oxius, coordinator of
the new Kansas State Pesticide Alert System. Mr. Ozius
reviewed the mechanism of the memorandum of understand-
ing (ethyl parathion) and indicated that although the
state was a signatory he felt the system was too cum-
bersome and much too late. What was needed was to
keep ahead of potential injury. Plans were initiated
too late for the agricultural crop year 1971; conse-
quently, the first alert was for rodenticide use in
fall of 1971 (see Figures 6-E, 7-E, an*1 8-E) . Full imple-
mentation of the plan for the crop year 1972 is anti-
cipated. The plan appears to provide a workable early
warning system for those concerned with pesticide use.
Minnesota
Mr. Roschka noted a little-publicized study com-
pleted summer 1971, on commercial/aerial applicator-
86-E
-------
KANSAS STATE DEPARTMENT OF HEALTH
Edwin D. Lyman, M.D., M.P.H.
Director of Health
SPECIAL TO KANSAS DAILIES, AP,
UPI, RADIO and TV Stations
For Immediate Release
Mailed October 13, 1971
FIGURE 6-E
KANSAS PESTICIDE ALERT SYSTEM
The State Health Department's Pesticide Program and the State Board of Agriculture's
Entomology Division are beginning a Pesticide Alert System. Purpose is to alert public
health and medical personnel of the possible use of a potentially hazardous pesticide in their
area. This will permit immediate medical treatment in cases of overexposure to the pesticides,
some of which are so new that little may be known about them.
The Entomology Division monitors fields in Kansas and predicts types and areas of
insect infestations, and the pesticides most likely to be used. Now these predictions will
be sent to the State Department of Health. Staff will notify public health officials and
physicians in the area about the probable pesticides, their ingredients, and suggested
treatment in case of over exposure.
State Health Department officials remind the public that all pesticides should be
used with care, following instructions on the label.
The Pesticide Alert Bulletin mailed October 8 lists rodenticides for rats and
mice seeking warmth as Winter approaches. The list and treatment chart have been mailed
to local health departments, hospital emergency rooms, and poison control centers.
87-E
-------
KANSAS STATE DEPARTMENT OF HEALTH
FIGURE 7-E
MEMORANDUM
To: Local Health Departments, Poison Control Centers and Hospital Emergency Room
Supervisors
From: Virginia Lockhart, Director of Health Education, Kansas State Department of Health
Subject: Current Information Regarding Emergency Medical Treatment for Acute Pesticide
Poisoning
Attached is current information regarding emergency treatment for cases of acute
pesticide poisoning. We are sending this information to you as part of our state-
wide "Pesticide Alert System". This system is a cooperative activity of this
agency, the Entomology Division, State Board of Agriculture and the local health
departments.
The Entomology Division through its regular surveillance of fields in the state is
able to predict insect build-up, the period of time the insects will be a problem
and what pesticides will be used to combat them. This information will be provided
on a regular basis to this office. We will promptly notify local health departments
in the counties under the alert who in turn will notify physicians and hospitals in
their county. In this way the information of possible danger from misuse of pesticides
will be promptly available to medical personnel in the affected counties.
We suggest that the attached chart be placed in the emergency rooms of hospitals
and posted on the walls of the poison control centers.
Please let us know if you have questions or encounter problems.
VPLrnp
88-E
-------
FIGURE 8-E
PESTICIDE ALERT BULLETIN No, 1
With Winter approaching, members of the rodent family, especially rats
and mice, will be seeking warmer climes. In doing so ihey will be entering
buildings, and a resultant increase in the use of rodenticides should be
expected.
The Kansas State Department of Agriculture has notified us that the following
chemicals are recommended for use against pests and will soon be used to
effect their control:
Rodenticide LD5Q (mg/kg)
Fumarin 25
Rival 50
Warfarin 186
RoZol
Diphacin 5
1080 5
Valdan
ANTU 6.5
Red Squill 150
Zinc Phosphide 40
Strychnine 1-30
Please refer to the enclosed treatment chart in case of poisoning by one of these
materials.
Roger Ozias
Pesticide Program
Kansas State Department of Health
10-8-71
89-E
-------
use patterns. The results of that study, although some-
what limited in scope, are nevertheless, very interest-
ing. It would appear that aerial applicators in Minne-
sota are aware of potential harm from the use of phos-
phate insecticides although they seldom realize how
dnagerous (only 40 percent over more respirators). The
group in which the greatest possibility for harm exists
appears to be ground crewmen hired to assist applicators.
These people, usually of college age, are of limited
experience and probably quite naive about the potential
for harm. Unless specifically required to take pesti-
cide measurements, they probably would not. The study
concludes by presenting information to suggest that ground
insecticide sprayers, because of a lack of rigerous re-
quirements by the State Department of Agriculture, may
well constitute the groups possibly subject to greater
harm from phosphate insecticides than aerial sprayers.
For the first time in Minnesota a somewhat effec-
tive liason has been established between a state agency
(Department of Health) and the prospective target (com-
mercial aerial and ground applicators). Plans for the
crop year 1972 include an intensive educational and
informative effort.
90-E
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Missouri
At present, Missouri has no mechanism for reporting
or recording incidences resulting from pesticide use,
primarily because it simply has not been regarded as
sufficiently important.
In summary the states in the study area appear to
have rather poor means of identifying the problem of
health hazards from pesticide use if it in fact does
exist. The Kansas Alert System appears to be a step in
the right direction; for the best effect pre-season esti-
mates of possible insect infestation must be as accurate
as possible. There is a nulti-pronged result involved
here: a closer working arrangement; prediction of pos-
sible hazards to human health; valuable recommendations
on pesticide application rates, if forecasts are valid;
and, consequently, tremendous potential dollar savings
to farmers and decreased hazard to the environment.
Armed with information from the state officials,
the Iowa Institute of Agricultural Medicine and a
Minnesota customer applicator survey, many of the ques-
tions previously posed still remairied unandwered. The
contractor then initiated a survey of 1600 outstate
medical doctors to better characterize the nature of
potential harm to farmers and farm workers. The results
91-E
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are tabulated in Table 18-E .Twenty-five percent of the
doctors responding indicated they had treated patients
for pesticide-related symptons. Of these, 65 percent
were from organo-phosphate poisoning. When one considers
that respondent were rural doctors only, that farmers
could and probably do seek medical help in larger cities,
and that farmers are not apt to seek any medical help
for milder symptons, the numbers are regarded as signi-
ficantly lower than the real total. Replies recorded
were slightly less than 20 percent of the number of
contacts. Assuming a random response, these figures
are probably five times lower than the real totals.
As part of the contractor's information gathering
efforts, all states were requested to supply data from
their respective poison control centers or State Bureaus
of Vital Statistics. Not all states replied and as
noted earlier, none had identical or correlative re-
porting methods. A break down of poisonings by cause
is beyond the scope of this project but it is noted
here that along with an increase in the total number of
poisoning, incidences for pesticides and rodenticides
as a SLS group appear to be increasing, as shown in
Table19-E. The general increase in poisoning incidences
observed in Kansas is a primary reason for the develop-
ment of the Alert System.
92-E
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TABLE 18-E
RESPONSE OF OUTSTATE MEDICAL DOCTORS TO SURVEY OF PESTICIDE
RELATED INJURY TO HUMANS, 1970-1971
State
Illinois
Iowa
Kansas
Minnesota
Missouri
TOTAL
Response (1)
Yes
21
13
11
22
16
83
No
69 (90)
39 (52)
30 (41)
56 (78)
45 (61)
239(322)
Incidences (2)
Organo-
Phosphate
(14) 53
( 8) 19
(11) 29
( 9) 61
( 8) 46
(50)208
Chlorinated
Hydrocarbon
—
--
—
4
1
5
Mercury
17
1
--
6
22
46
Arsenic
24
1
1
9
16
51
Unspecified
or Other
2
3
—
7
3
15
VD
u>
W
Number in parentheses indicates total responses from each state.
2
Under organo-phosphate; the number in parathensis indicates number of doctors
reporting incidences. The number following indicates number of patients seen or
treated for this cause of injury. Thus, (14) 53 means that 14 doctors treated
53 patients for organo-phosphate poisoning.
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TABLE 19-E
REPORTED POISONING INCIDENCES FOR THE
FIVE STATE STUDY AREA
Pesticide/
Year Total (Poisonings) Rodenticide
1968
1969
1970
1971
*Data
Projections
when summer
1671
2101
2345
1658*
61
75
131
73
Frequency
Index
365
357
560
(440)
about 800
projected
for first two quarters only (i.e., 1/2 year).
for 1971 surpass 1970 by Frequency Index
applications of pesticides are included.
Data from the State of Illinois shows some change
in the total number of incidents, especially for the
year 1971. This may reflect increased activity, aware-
ness, safety programs - but the role of these factors
cannot be verified.
As might be expected, there are significant in-
creases in incidences in the summer months of June, July,
and August, although the number reported for each month
remain consistent for the period of examination (1966-
1970). Surprisingly, incidents from certain formula-
tions, i.e., moth balls, cakes, etc., do not show
94-E
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TABLE 20-E
ILLINOIS POISON CONTROL CENTER DATA
Downstate - Excludes Cook County, Chicago
1970
1969
1968
Insect.
141
180
181
Rod.
175
178
163
Herb.
16
12
20
F. Moth.
66
72
1 73
Other
7
4
5
1967-1966 - No break down
NOTE: Most of insecticides are roach, ant, fly
bait spray. Many (most) of incidences seem inordinately
high - really only a report - no symptons, no after
effect - child found with box, contents, on surface of
skin - no way of telling how much if any was ingested.
dramatic seasonal distributions as might be expected.
Analysis of monthly records show that these types of
poison are available at all times of the year but for
differing circumstances; for example, in fall and winter,
children encounter the preparations when playing indoors
on the floor, in closets, in, under, around, and behind
furniture, etc. These incidents occur until late in
the spring when parents begin to store woolens. The
preparations are then encountered when parents care-
lessly leave them unattended. Later, in late summer
or early fall, as woolens are removed from storage and
shaken out, the preparations can fall, unnoticed, from
clothing and roll under furniture or next to baseboards.
95-E
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Here the child encounters and ingests them. Thus, through-
out the year, these formulations account for a fairly
consistent monthly percentage of the total.
The same pattern is observed for mouse and rat
baits. As rodents enter homes in the fall and early
winter, more of these "baits" are purchased and laid
out where they are subsequently discovered by children.
Spring house cleaning and late spring and summer airing
of homes apparently uncovers once-carefully placed
baits, many apparently on the way to disposal when they
are ingested by playing children.
Roach baits of different formulations are rather
uniformly ingested, on a monthly basis, perhaps a re-
flection of the ubiguitous nature of the pests in its
almost daily association with man.
The months of June, July and August universally
show an increased level of incidents due to agricultural
type pesticides. Analysis of these records show a
marked increase in the contact of children with prepara-
tions used against flying insects, garden and lawn
pests, and, particularly, preparations designed for use
against ants. The number of incidents rather clearly
reflects increased exposure at this time of the year.
Only a few cases were reported in which the product
in question caused harm when used as directed. Ant,
96-E
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roach, and mouse preparations are obviously not placed
sufficiently far from agile fingers of curious children.
Nationally known insecticides and herbicides are
conspicuously absent from incident lists, which may be
a reflection of more or less adequate precautions for
the purchaser. (See labeling and packing directions
elsewhere). The most disturbing exception is when
contents are transferred from original containers to
temporary packages - such as soft drink bottles - for
use by other people, a flagrant violation of the pack-
ing directions for which the manufacturer or formulator
cannot be held responsible. The most tragic accidents
reported have been to children ingesting the contents
of such bottles.
The annual report of the Iowa Community Pesticide
Study (FDA-70-17) should also be consulted for referrals.
Some cases of documented pesticide exposure and resulting
illness show an intimate relationship between the two.
It should be noted it is extremely difficult to
document and medically distinguish true pesticide poison-
ing from other human illnesses. However, lack of proper
caution is indicated in a great number of cases.
A large part of the medical effort in these studies
is being directed at possible subtle behavioral changes
(nervousness, agitation, disorientation, etc.) which
97-E
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could possibly be the result of chronic low level ex-
posure to pesticides.
The existing mechanisms for reporting injuries from
accidental exposure to agricultural pesticides in the
five study states and the attitudes maintained by the
respective states is, at worst, reprehensible, and at
best, subject to close scrutiny (see summary chart,
Table 1^~E)•
While pesticide exposure may be difficult to sepa-
rate from other common ailments, only one of the study
states has a adequate program to identify and quantify
the extent of possible harm resulting from use or mis-
use of pesticide formulations. The survey of farm
agents strongly suggested that phorate was responsible
for rather severe headaches and nausea when the dust
drifted back onto the applicator. Careless application
of ethyl parathion by some orchardists resulted in
severe nausea. Yet neither of these obvious examples
are reported through channels to state medical authori-
ties. Nor does the National Safety Council (headquartered
in Chicago, Illinois) keep nation-wide statistics on
illness of injuries or fatalities involving pesticides.
Farm Injury - Livestock
Contacts with veterinarians and other state offi
98-E
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cials by the contractors has indicated that there is
no adequate system for reporting or caring for farm
animals so injured. In many cases in-field diagnosis
of organo-phosphate poisoning to livestock is faulty
or called for after death so that valid measurements
cannot be made. The general philosophy seems to be
that 'a dead cow is a dead cow! Besides who is going
to pay for the analyses of blood, tissue or gut con-
tents after it's dead!
Although local attempts may be made to identify
and characterize injury these items do not have to be
specifically reported by law and hence, usually are
not.
The Iowa Community Pesticide Study
Through a system of alerting local practicing
veterinarians is solicited such support and as a re-
sults, cases are referred. This system of local re-
ferrals, clinical diagnosis, and treatment and care-
fully executed physiological and neuro-physiological
investigations presents some thought provoking and
sobering data. In Iowa alone, hundreds of farm
animals have suffered some kind of debilitation
(usually death) as the result of contact with pesti-
cide compounds. Additional hundreds have suffered
99-E
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loss of production, reproductive failure or death from
a variety of other agricultural chemicals.
It should be pointed out that a large number of
the cases were and probably continue to be the result
of gross misuse and carelessness in the use of these
compounds.
Aquatic Ecosystems
Adequate reporting and recording of local inci-
dences of pesticide "damage" to the waterways has not
been conducted by any of the five study states. Based
on interviews with county and farm service agents, the
problem appears to be extremely minor. However this
attitide reflects the general feeling that pesticides
are vital to maintain and improve crop yields.
In all cases, reported incidences to farm water,
stock water, creeks, and ponds represent one percent
of the total water involved in the farm. Although dead
fish and invertebrates are observed they are seldom
reported (see causes of problems). This attitude is
borne out by federal reports of fish kills due to
pollution of all types which afe filed, only when
the incident is sufficiently gret or is seen.
Farm ponds tend to be located where grass covers
most of the watershed and intensive agriculture is
100-E
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not practiced. The potential for unreported damage to
creeks and smaller flowing bodies of water is thus
poorly documented. In most documented cases, care-
lessness and/or unexpected heavy rainfall during
application periods are responsible.
County farm agents were surveyed to assess the
extent of possible pesticide damage to farm water
supplies, especially the aquatic ecosystem. Not sur-
prisingly, a very small number of incidents were
reported, as shown in Table 21-E.
TABLE 21-E
LOCATION OF POISONING INCIDENCES, FIVE-STATE AREA
Poison
Incident Illinois Iowa Kansas Minnesota*Missouri
Farm pond 34 6 18 13 18
State Water 14 7 2 6 4
Creek or Stream 31 10 5 2 14
Other-Includes
well poisoning
by back sip-
honing, etc. 1020 4
Approximate
Number of Ponds
in Survey Area
Approximately
1/4 to 1/2
acres 19,714 12,470 42,026 8,140 69,462
*Minnesota figures mean little here in that of
the area and agents surveyed in excess of 200,000
acres is natural water.
101-E
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Considering the total number of ponds involved in
the area these figures appear to be quite low. However,
natural reluctance by the land owner to admit careless-
ness is involved. Also, it appears some farm agents
carefully avoid knowledge of the problem due to damag-
ing press coverage pesticides have thus far received.
One authority who wished to remain anonymous indicated
that agents in one state were specifically instructed
not to report pesticide incidents.
State conservation officials were also contacted
and although they declined to cite figures, all of
them indicated that the figures received from county
agents were far too low - by at least a factor of 10.
Estimates of state officials were based on complaints
to local conservation agents, which are not tabulated
or recorded by state agencies.
Reports to Federal Water Pollution Control Associa-
tion and Environmental Protection Agency for the period
1960-1970 do not cite pesticides as a major contributor
to fresh water fish kills. Despite inprovements in the
reporting system, it is questionable if it will be ade-
quate to effectively monitor potential damage to public
water.
To more adequate assess the extent of damage the
contractor requested each state to provide the field
102-E
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notes for a typical annual report (1970) . Illinois de-
clined, indicating a majority of the cases were still
in litigation and the public exposure might bias the
court or endanger the litigants. Examination of the
reports received did give a better insight into the
field reporting of incidences. However they also
failed to implicate pesticides to any greater extent
thhan the federal reports.
Headlines such as INSECTICIDES KILL 500,000 FISH
IN X CREEK. . . appear to contradict the reports cited
above. However, when one investigates it is found that
this figure represents 400,000 small forage fish, 95,500
rough fish and fewer than 5,500 valuable game fish. Thus
the impact of a headline such as this is far out of
proportion to the real dollar value of the fish invol-
ved.
The point which most often is overlooked is that
the product, in question if properly transported and
used in the manner intended might not directly result
in death or a reduction in the aquatic population.
Table 22E shows 1969-1970 fish kill data for the
five state study area.
103-E
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TABLE 22-E
FISH KILLS DUE TO VARIOUS FORMS OF POLLUTION IN
FIVE STUDY STATES (1969-1970)
Pesticides
Operations Code (11)
t-j
0
.1^.
il •
I
w
Illinois
1969
1970
Iowa
1969 (1)
1970 (2)
Kansas
1969
1970 (3)
Minnesota
1969 (4)
1970 (5)
Missouri
1969 (6)
1970
8.0+%
—
-
Some
3.0+
50.0
66.0
74.0
1.0
1.0
Fertilizer
& Feedlot
(12 & 13)
43.0%
32.0
-
Some
24.0
45.0
0
0
50.0
1.0
Food
Processing
(22)
35.0%
7.0+
-
—
0
1.0
3.3
Heavy
14.0
22.0
% from
Mining Other Causes
(21)
6.0% (84)%
26.0 (65)
-
—
50.0 (75)
(96)
(30)
(05)
1.0 (65)
30.0 (53)
All values approximate from Federal Report of the number reported.
Numbers in parentheses refer to numbered comments (1-6).
-------
The basic inadequacies of the reporting system
become apparent when the following factors are examined.
1. The report of no losses from pesticides,
feedlots, fertilizer and/or food processing
industries for Iowa in 1969.
2. An undetermined number of fish died from
pesticides and feedlot wastes. Since no
numbers are indicated the values that
we reported bias the sample. The losses
were indicated to be of 1 and 2 severity.
3. Pesticiees were suspected in the death of
over 60,000 fish from Marion Reservoir,
this was later confirmed by Dr. Klassen,
Kansas State University. The kill was
reported as due to undetermined causes (90).
An additional 40,000 fishes were killed prob-
ably as a result of pesticides used in a
sewer plant to kill larvae. This was re-
ported as a sewer plant incident. Thus,
50 percent of the 1970 total kill was at-
tributable to pesticides but not reported
in 1969.
4. Sixty-six percent of a total state kill was
attributable to pesticides in 1969.
5. The 1970 report lists no numbers for the
105-E
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Zumbro River kill but state officials indi-
cate that it was an extremely heavy kill -
food processing was the cause. The Roseau
River kill was also due to pesticides and
was, in the opinion of the reporting officer,
probably twice as extensive than reported.
6. Officials from Missouri indicate that the
reported figures are probably far too low for
pesticide incidences.
As a general comment, far too many causes are
calssified as "other" to properly assess damage from
any category. This is not a result of any state
directly trying to minimize the damage from a specific
cause. In most cases responsible state officials
were not notified of the kill(s) until days had passed.
Fished were often found after suspected material (s)
diluted to a point where analysis was impossible or im-
practical .
The real losses reported from the four listed
causes, fertilizer, feedlots, food processing, and
mining (12, 13, 21, 22) account for the major causes of
fish kills in Missouri, Kansas, Illinois, and Iowa for
1969 and 1970. An inescapable fact is that losses
from pesticides are rather insignificant when compared
to the losses due to sloppy agricultural practices, feed-
106-E
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lots and industrial causes.
It is the feeling of the contractor that reports
of losses of fish in farm ponds is so poorly documented
and represents such an insignificant quantity that it
will not be reported here. In terms of total pesti-
cide incidents, Minnesota represents a very badly biased
sample.
Farm agents appear to be aware of the desirability
of reducing erosion losses to keep pesticides where
applied as well as a generally sound agricultural prac-
tice. However most are also aware that this is not
financially practical at present.
It is difficult to impress agents with the signi-
ficance of pesticide damage to the aquatic ecosystem
when he is aware of the effects of fertilizer and feed-
lot damage and the other listed causes. Pesticides,
are responsible for less than 10 percent of the total
losses (except in Minnesota, where the total number
of animals is rather small), while feedlot and fertili-
zer damage may run up to 50 percent of the total. In
Missouri mining practices account for up to 50 percent
of the total fish kill reported.
Most agents (80-90 percent responding) believe
pesticides could be made safe (or safer) for land and
water if manufacturers directions were carefully fol-
107-E
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lowed. All pointed out that a certain level of care-
lessness could be expected, no matter what the directions
said. Gross misuse was cited as the major cause of in-
dentified or potential harm. The general feeling was
that most farmers honestly tried to follow directions
and that for the most part, directions were adequate.
Interestingly, agents from all states felt that more
meaningful information could and should be provided
by state departments of agriculture for local condi-
tions and needs.
Many agents felt that industry and urban and
suburban homeowners were responsible for a far greater
share of the total problem than independent farmers.
108-E
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Summary and Conclusions
Very little is known about the effects of various
pesticide compounds on the total aquatic environment.
Part of this general inability to properly assess
environmental damage comes from the lack of sufficient
knowledge of the intimate, subtle and extremely complex
functioning of aquatic ecosystems. Sufficient information
is presently at hand to indicate that environmental
damage has occurred, is occurring, and despite what we
do now, will continue to occur for some period of time.
The contractor feels sufficient knowledge is at
hand now to set forth the following summary and
conclusions relating to impact on the aquatic environment.
Persistent pesticide compounds do not disappear
after application. They may remain for variable periods
of time, hopefully fulfilling the task that they were
designed for: the destruction of agricultural pests,
potential disease vectors, and other noxious pests
of all varieties. Concomitant with application and again
for varying periods of time and at differing rates,
these compounds co-distill, vaporize, adsorb on
inorganic and organic particles and are absorbed into
living material where they may be altered chemically,
exert an often unidentified influence over the
109-E
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living tissue, be stored with no apparent harm, or
eliminated to the environment.
It has been shown that some kinds of pesticide
compounds have been found in almost every kind of
living material when looked for. The key word here
is when, for many of our informational gaps are the
result of simply not having had the time or the money
or the experience to measure all aspects of our global
biota. It is significant that no ecosystem, terrestrial
or aquatic, has been found free of these compounds no
matter whether it be simple or complex. It is also well
to remember that even the most "simple" ecosystem has,
upon closer inspection, been found to be extremely
complex. It can truthfully be said that we really do
not fully understand the complete biochemical or
molecular nature of even the most "simple" such system.
It is highly unlikely that we ever will.
Implicit in an appreciation of the trophic dynamic
structure of any ecosystem is the concept that, in
addition to energy, other compounds are transferred from
one trophic level to the next. One of the difficulties
in developing a full appreciation for pesticide, involve-
ment in trophic structure is that any trophic level
110-E
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can and does acquire additional qualities completely
independent of any other level. This is accomplished
most commonly by ingestion or absorption from the
surrounding environment.
Thus we find that the primary producer group of
photosynthasizing plants of the aquatic environment
have the ability to accumulate these compounds from the
water. The metabolism and the degree of degradation
accomplished by these plants is poorly understood at
this time. Although not all groups respond in the same
fashion, some exposures have resulted in a reduction of
photosynthetic rate in both marine and fresh water
algae.
Zoo plankton have shown a variety of responses to
pesticide exposure. Species susceptibility within the
same taxonomic group varies from almost no effect to
complete intoxication and death at similar exposure
levels. Although some experiments have been conducted
and many more are either being conducted now or planned
for the future, our knowledge of the response of natural
populations of zoo planktons to environmental levels of
pesticides is quite inadequate. Long term chronic
exposure to sub-lethal "natural" levels as are >being
conducted by the Federal Fish Pesticide Laboratories and
111-E
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independent investigators are vitally needed to identify
effects on longevity, productivity, and intrinsic rates of
natural increase. Such additional information is required
to properly assess the effects of environmental variables,
such as temperature, pH, water hardness, and other water
quality factors, and the synergistic effects of combinations
of other potentially harmful compounds. Prodigeous
quantities of these organics are consumed by higher
trophic levels. The combined production of zoo plankton
must be maintained to support sustained yield of higher
forms. A significant degree of biomagnification is
observed by virtue of the critical quantities consumed
as well as from the environment.
Benthic organisms like some zoo planktons now occupy
different trophic levels depending upon their age and
life style. Vegetarian species are obviously primary
consumers, while omnivores or strictly carnivorous
species may be primary consumers as young or primary or
secondary consumers as adults.
The literature is clear that these forms can
accumulate pesticide loads far in excess of the levels
below them. Considerable species variation as well as
differences between genera and family can be seen relative
to the ability to "withstand" certain levels of pesticides.
112-E
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At the present time, an insufficient number of different
organisms have been examined carefully enough to identify
the effects of long term sub-lethal exposure. Frequent
examples of virtually complete denudation of streams have
been observed following heavy applications of pesticides.
Repopulation of these diminished areas within a year are
given as evidence of no real harm. Repopulation by this
nominally very mobile group of crustaceans and essentially
aerial insects should not surprise anyone. We do not
know what effects chronic sub-lethal exposure has on rates
of feeding, food conversion, reproductive success or
growth and longevity. Basic experiments which have been
performed suggest that sub-lethal exposure for periods of
up to one or two hundred days are harmful to zoo
planktons and benthic forms in terms of growth and
viability. Higher trophic levels are usually composed of
vertebrate organisms. The smaller members (minnows and
other forage fishes) usually have a relatively short life.
Thus, individually they may not accumulate a tremendous
body burden during their lifetime. Larger organisms
(predaceous and piscivorous fishes) live longer and
consumer many smaller organisms, thus accumulating much
higher burdens in their lifetimes. One of the things that
113-E
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is so difficult to assess in the aquatic ecosystem is
relative lack of fitness. If organisms from any trophic
level have been weakened or debilitated in any way, they
are far more susceptable to capture, disease, or
parasitic infection. The possible effects of low level
chronic exposure resulting from potentially harmful
pesticides are more easily eaten and thus removed from
our scrutiny.
Larger aquatic vertebrates have generally been
studied longer and have more known about them than the
lower trophic levels. This fact, plus the fact that
they are usually economically more valuable to man, has
resulted in a considerable body of information on
pesticide effects to this group. Admitting that acute
exposure levels are necessary to establish guidelines
for water quality and to protect the stocks of fishes
to some extent, we would nevertheless like to stress the
results of chronic sub-lethal exposure.
It has been demonstrated that long term sub-lethal
exposure to some chlorinated hydrocarbon compounds does
produce terotogenic effects in a number of valuable
species of fishes. The extreme case is demonstrated by
the loss of entire broods of Atlantic salmon at the time
114-E
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of hatching, following exposure of the parents. Numerous
examples harm warm water fishes, particularly pond
stocks of channel catfish, show increased levels of
malformed and dead young, resulting from exposed parental
stocks. Transovarian movement of many of these compounds
have been demonstrated for mammals, birds and fishes;
it is assumed to be a vertebrate phenomena varying only
in degree between class and species.
It appears that behavioral abnormalities can result
to fishes from exposure to chlorinated hydrocarbons.
Some of the experiments at very low sub-lethal levels are
only noticed when the most sophisticated electro-
physiological measurements are conducted. The fact that
many lay people do not understand what this kind of
technology means does not detract from the potential for
harm to these organisms. Likewise learning behavior
has been reported as lessened in chronically exposed
fishes. No data is available for other aquatic life.
Endocrinological alteration, especially in pituitary
and adrenal function, have been noted. These effects may
have far reaching effects on the life of individuals
as well as the perpetuation of the species.
Hepatic microsomal enzyme induction has been
recorded for other vertebrates as well as for fishes.
115-E
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The resulting disturbance of steroid metabolism is well
documented. Evidence has been presented which indicates
that variations in respiratory rate affect the uptake of
certain chlorinated hydrocarbons. We know nothing about
the pharmacodynamics of uptake or diffusion rates as
they relate to variations in water chemistry. Alterations
in protein metabolism have been demonstrated in fishes
and other vertebrates. This may be a reflection of the
hepatic microsomal enzyme response. It may be particularly
important in fishes as a vertebrate group since these
animals seem to be adapted specifically to the metabolism
and elimination of nitrogenous compounds.
Some of the most striking effects to fishes have
been the result of studies which showed no apparent
harm under regimens of chronic sub-lethal exposure.
When starved or when conditions exist that require the
animal to draw on body stores of fat or protein for energy,
the resulting concentration of stored material exerts
its effect: reduced vitality, decreased muscular ability,
disturbed metabolism and death are observed.
Research in metabolism of cold blood organisms have
lagged behind mammalian and bird studies. Little is
known of how fast or to what extent body stores of fat
are mobilized by stressed aquatic organisms. Serious
116-E
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question is raised as to the suitability of acute and
chronic exposure studies in aquatics as they have been
conducted. Certainly additional research is required
in this area.
Osmoregulation and osmoregulatory ability is more
of a problem with aquatic animals than terrestrial.
It is for this reason that alterations in kidney function
and disturbed osmoregulatory ability under conditions of
chronic exposure to chlorinated hydrocarbons pose such
a threat to this group.
The choice of experimental animals is often dictated
by availability as much as general suitability.
Although mechanisms do exist at the Federal level for
specifying the nature of information to be supplied the
manufacturer for registration of a compound, it is felt
that these criteria are in need of complete revision
and certainly must be expanded to include experiments
and measurements designed to better sense the impact on
the environment. In this connection it is particularly
important that additional non-target species be included.
Those organisms which constitute the decomposer
group (bacteria, fungi, and other microbes of soil and
water) have been demonstrated to exert a limited effect
on the degradation of persistent pesticides in natural
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environments. Under laboratory conditions, groups have
been identified which will degrade to some extent;
often the degradation products are more toxic than the
parent compound. Our total information in this area,
particularly from natural environmental conditions, is
particularly meager.
The literature is clear in the picture it presents
of global contamination of our abiotic and biotic
ecosystems. All trophic levels carry body burdens —
whether the persistent compounds kill outright or
only reduce trophic level efficiency is still open to
question. In any event, it is clear that biomagnification
does occur between successive trophic levels, additional
bioaccumulation can and does occur at each trophic level.
The result is one of sufficient body burdens of these
compounds at the highest levels to cause death, debility,
reduced reproductive success, reduced mental alertness
and a generally disturbed physiology,all tending to
reduce the biological fitness of the animal to meet the
demands of the environment.
Studies with laboratory mammals suggest the
possibility of harm to the human animal. It must be
stated that no adequate demonstration of clinical
manifestation of carcinogenicity, mutagenicity or
terotogenicity has been shown for humans, resulting
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from chlorinated hydrocarbon exposures at low levels
commonly encountered in the environment.
Acute toxicity has been demonstrated with some
compounds at high levels and should not be surprising
in view of their poisonous nature.
There is mounting evidence of past careless use of
organo-phosphate compounds. Clearly industry and all
segments of agriculture and agribusiness must dedicate
themselves to better education of the users of these
chemicals. Additional research is urgently needed to
make use and particularly application safer for the
general user.
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Farm Injury - Human
County agents, farmers and doctors in the five study
states were surveyed to determine the extent of possible
harm to farmer/applicators from the handling of pesticides.
About twenty-five per cent reported knowledge of particular
incidences of pesticide-exposure-related illness within
the past year. Twenty-five per cent of the doctors
responding indicated they had treated patients for
pesticide-related symptoms. Of these, 65 per cent were
from organo-phosphate poisoning.
The greatest causes of illness were: (1) spray
drifting back on the operator; and (2) contact with
pesticide due to mechanical breakdown of the equipment.
Phorate and disulfoton fumes were most often singled out
as being responsible for operator illness. In all cases
reported by County agents, operator carelessness was
blamed as primarily responsible for the exposure to
pesticide. In many cases agents indicated they had
cautioned farmers to use protective clothing, but the
warning went unheeded. These results confirm earlier
reported findings that most accidential exposures are
the result of improper application or obvious disregard
of adequate safety measures. Containers and label
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directions, although superficially adequate, do not
draw sufficient attention to the dangers or are not
practical for the farmer to follow. This situation,
compounded by the applicators' reluctance to utilize
safety clothing, plastic gloves, respirators, etc.
create a potentially hazardous medical situation.
The contractor contacted state health officers or
offices and/or state officers in charge of poison
control centers, state pesticide officers, vector
control authorities, state veterinarians, bureaus of
hazardous substances and similar agencies in each of
the five states. Representatives of these agencies were
asked: (1) Are there pesticide-related illness not
being reported? (2) Are doctors reporting pesticide-
related illness to health agencies? and (3) What kinds
of damage to wildlife and livestock go unreported?
Illinois
There is a lack of machinery and enforcement for
reporting pesticide-related illness. No systematic
procedure exists for reporting this kind of injury,
however, the educational material and short courses
conducted through the University of Illinois,along with
an aggressive program of farmer education,appears to be
quite good.
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Iowa
Dr- Keith Long of the Institute for Agricultural
Medicine conducted a postcard survey of farmers. Of
the 1100 replies, 900 reported treatment for pesticide
exposure of some kind. For the same time period, poison
control centers and hazardous substance centers in the
State of Iowa reported only 37 cases. These results
indicate the entire problem of injuries from pesticide
use is far greater in magnitude than previously
anticipated.
Kansas
All contacts from state offices indicated there
were no records system other than the Poison Control
Center. Kansas has initiated the Kansas State Pesticide
Alert System to provide a workable early warning system
for those concerned with pesticide use.
Minnesota
A study of commercial/aerial applicators completed
in the summer of 1971 indicated that although these men
are not fully aware of the potential harm from the use
of insecticides, ground crewmen hired to assist
applicators have the greatest possibility of harm.
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However, good insecticide sprayers, because of a lack
of rigorous enforcement from the State Department of
Agriculture, are subject to greater harm than aerial
sprayers.
Missouri
At present, Missouri has no mechanism for reporting
or recording incidences resulting from pesticide use.
In summary, the five study states have rather poor
systems for identifying the problems of health hazards
from pesticide use. It is significant that none of
the states has a standard reporting system for injury or
illness related to pesticide exposure. The Kansas Alert
System appears to offer the pesticide user: (1) a closer
working relationship between various involved agencies;
(2) prediction of possible hazards to human health;
(3) valuable recommendations on pesticide application
rates; and (4) potential dollar savings to farmers and
decreased hazard to the environment.
Farm Injury - Livestock
•%
Contacts with veterinarians and other state officials
by the contractor has indicated there is no adequate
system for reporting or caring for farm animals exposed
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to pesticides. In many cases, field diagnosis is
inaccurate and after death of the animal, measurements
are usually not made. The general philosophy seems to
be that "a dead cow is a dead cow — who is going to
pay for an autopsy."
Damage to the Aquatic Ecosystems
Adequate reporting and recording of local incidences
of pesticide "damage" to the waterways does not exist
in the five state study area. Although dead fish and
invertebrates are observed, they are seldom reported.
This attitude is borne out by Federal reports of fish
kills which are filed only when the incident is
sufficiently great.
County farm agents were surveyed to assess the
extent of possible pesticide damage to farm water supplies,
Not surprisingly, a very small number of incidences were
reported. State conservation officials contacted
declined to cite figures but all indicated that the
County Agent reports were far too low.
Reports to the EPA for the period of 1960-1970 do
not cite pesticides as a major contributor to fresh
water fish kills. Pesticides are responsible for less
than 10 per cent of the total losses (except in Minnesota,
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where the total number of animals is rather small), while
feedlot and fertilizer damage may run up to 50 per cent
of the total. In Missouri, mining practices account for
up to 50 per cent of the total fish kill reported.
Despite improvements in the reporting system, it is
doubtful if it will be adequate to effectively monitor
pesticide damage to public waters.
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Recommendations
The contractor recommends that additional effort
be expended to achieve the following:
1. Understanding of the mechanisms by which
pesticide compounds are adsorbed by photosynthesizing
plants is achieved.
2. Virtually a total lack of information on the
cellular responses of green plants and diatoms to pes-
ticides exists. This includes information on binding
sites, specific affinities for membrane surfaces, mode
of action.
3. Community structure, natural succession,
growth, viability and reproduction as well as the res-
ponse of photosynthetic rate to pesticide exposure for
a much larger variety of aquatic plants at levels
currently found in the environment as well as experi-
mental levels is necessary.
4. There appears to be a great need for basic
experimental designs which would identify not only
biomagnification but long term effects which would follow
reproductive success for several generations.
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5. Effects of long term sub-lethal exposure
on growth, reproduction and viability of a much wider
variety of benthic organisms.
6. Identification of cellular routes of entry
of pesticides with benthic forms.
7. Elaboration of metabolic degradation pathways
of pesticide compounds in benthic animals.
8. Information of effects of chronic sub-lethal
exposure to major food items of top trophic levels.
These include larger crustaceans, small fish, minnows,
frogs, toads, salamanders, etc.
9. Much additional information on all aspects of
physiology of fish exposed to chronic sub-lethal expo-
sures of pesticides.
10. New and expanded criteria for scientific
information required of registration. These criterial
should be more pertinent to impact on chronic exposure
to larger varieties of non-target species.
11. Expand studies on effect of soil and water
microorganisms which may degrade persistant compounds
and which may themselves be effected in such a way as
to not perform their ecological function as we now
know it.
12. Much additional information required on rates
of excretion and particularly differential turn-over
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rates between different animal groups.
13. Model ecosystems probably have lower values
in predicting the fate of certain compounds. Such
modeling should be continued with trophic dynamic
considerations and attempts at balance equations.
14. Although models have their place, there is
no substitute for field studies. These should be
expanded to include more in-depth studies of specific
watershed and basins and a much wider variety of aquatic
ecosystems.
15. Expanded programs to identify the potential
for harm to humans from both chlorinated hydrocar-
bonds and organo-phosphates. State support should be
solicited.
16. Expanded educational efforts on use and
application as well as health hazards involved.
Industrial support is needed to develop safer
compounds; this may include new technology aimed at
safer handling practices and formulations.
17. Agricultural engineering might provide new
and innovative methodology for application of pesti-
cides.
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36 Thompson, A.R. Stonefly metabolism and the Effects
of DDT , Ph.D. Dissertation, University of Utah, 1971
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48 Janicki, R.H. and W.B. Kinter. "DDT: Disrupted
Osmoregulatory Events in the Intestine of the
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sic Rate of Increase of the Guppy^Ph.D. Disser-
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of DDT in Landbodied Salmon at Sebago Lake, Maine".
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ment of Natural Resources. Mngt. Rpt. No. 34, 1970,
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of Fish from Iowa Water.The State Hygienic Labora-
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60 Mazone, C.R. and B.C. Blaylock. "Toxicity of Insec-
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70 Sprague, J. B. "Measurement of Pollutant Toxicity
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APPENDIX F
DEGRADATION OF PESTICIDES IN THE ENVIRONMENT
State of the Art
In line with the increasing general concern about
pesticides, there have been a considerable number of
expert committees, panels and conferences which have
dealth with all aspects of pesticides, including their
fate in the environment after application. Thus, the
available information on this topic has been exhaus-
tively reviewed, abstracted and commented upon in the
recent past by many of our foremost experts in the
field.
Publications emanating from these activities in-
clude the "Report of the President's Science Advisory
Committee - Use of Pesticides," May 15, 1963; "Sci-
entific Aspects of Pest Control," National Academy of
Sciences - National Research Council, 1966 (1); "Re-
port of Committee on Persistent Pesticides," Division
of Biology and Agriculture, National Research Council,
1969 (2); "Cleaning our Environment - The Chemical Basis
for Action," American Chemical Society, 1969 (3), and,
the most comprehensive state of the art summary yet,
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the "Report of the Secretary's Commission on Pesti-
cides and their Relationship to Environmental Health,"
U. S. Department of Health, Education and Welfare,
December 1969 (4), more popularly known as the "Mrak
Report," after its chairman.
The first and second annual reports of the Council
on Environmental Quality to the U. S. Congress (5, 6)
also deal with the problems of pesticides.
In addition, many recent meetings of scientific
societies have featured symposia, workshops and paper
reading sessions dealing with pesticides in the envi-
ronment, including the American Chemical Society, the
Entomological Society of America, different Engineering
Societies, and probably many or all of the other learned
societies whose scope of interest includes pesticides.
It appears to be the consensus of all of these
comprehensive and learned studies and evaluations that
- present levels of pesticide residues in
man's food and environment do not adversely
affect human health;
- present methods of regulating pesticides
provide effective products and generally
have held the amounts of residues in man
and his food supply at low levels;
- present pesticide use levels cause environ-
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mental contamination, adverse effects on
certain species of wildlife, and further
actual or potential environmental harm whose
nature and extent may escape our present
capabilities of detection and/or foresight.
The uncertainty about long-term environmental ef-
fects, especially of chlorinated hydrocarbons in the
marine environment, is strongly emphasized by the Panel
on Monitoring Persistent Pesticides in the Marine En-
vironment of the Committee on Oceanography of the National
Academy of Sciences in a very recent report (7).
This national concern has been paralleled by similar
activities in the midwestern states. For example, Iowa
State University held a conference on "The Role of Agri-
culture in Clean Water" at Ames, Iowa in November, 1969.
Willrich and Smith have summarized, edited and published
the proceedings of this conference in a 414-page book
entitled "Agricultural Practices and Water Quality" (8).
An international symposium on "Pesticides in the
Soil: Ecology, Degradation and Movement" was held in
February, 1970 at Michigan State University, East Lansing
(9).
In both of these publications, each author's con-
tribution is followed by an extensive listing of litera-
ture references which in turn include all other appli-
3-F
-------
cable review articles and original research reports.
A review of these copious sources of information
leads to the conclusion that in effect, very little is
known about the fate of pesticides in the environment
under actual field conditions. Many investigators have
studied individual factors or subsystems under labora-
tory or greenhouse conditions but, as Kaufman (10, 11)
comments:
Unfortunately, the mechanisms observed
in model systems are not always the same
as those observed in soils. The ulti-
mate question the microbiologists or
biochemists must face, therefore, is
whether or not the degradative mecha-
nisms observed in vitro are applicable
or even relevant to in vivo systems.
Biggar (12), in discussing pesticide movement in
soil water, shares this view, stating:
There is considerable literature on
field and laboratory investigations
on the behavior of a wide range of
pesticide compounds for a large num-
ber of soils and climatic conditions.
Such investigations have provided
rough guidelines for the use of these
chemicals while knowledge is lacking
on the many variables that determine
their behavior; Many of these inves-
tigations were on leaching and move-
ment. Quite often, leaching studies
are used as a means of assessing the
adsorptive properties of soil's with
ranges in texture representing ranges
in adsorptive capacity. Generally,
very little is known or reported on
the important water relations or
physical properties, or on factors
which are quantitative measures of
4-F
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the transport process. Likewise, no
direct measurements are reported of
soil adsorptive capacity. . . . In-
complete studies of transport that do
not include variables of flow do not
explain transport or predict transport
or adsorption. . . . The movement
and distribution of a pesticide under
limited conditions cannot be pro-
jected to a wide range of conditions
without quantitative understanding of
the factors that contribute to and
affect transport. Implicit in this
last statement is the necessity for
models that will assist in the design
of experiments and in extension or
prediction of results from observa-
tions made.
In those instances where actual field conditions
N
have been investigated, so-called "soil persistence
studies" are the most common type of test reported.
However, such studies usually measure the "persistence"
or "disappearance" of chemicals by analytical methods
sensitive only to the parent compound. As Lichtenstein
(13) points out, "disappearance" has in most cases been
equated simply with the inability to detect the origi-
nally applied compound where it had been applied. This
often does not account for the metabolism of the parent
compound into other chemicals which could also be bio-
logically active. "When we speak of disappearance or
loss through volatilization, the parent compound or its
metabolites really have not disappeared, except that they
have been transported somewhere else."
5-F
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For the present study, we selected two specific
pesticides for more detailed investigation of avail-
able data on their fate in the environment, based on
the following rationale:
(1) aldrin; We estimate that more than 10 mil-
lion pounds of aldrin active ingredient have
been used on corn annually in the five state
area in recent years (Appendix B, Table 9-B).
This use may decline in the future due to
development of resistance in some of the in-
sects on which aldrin is used and because of
regulatory restrictions and recommendations
against its use in some of the states. In
spite of these factors, the use of aldrin on
corn in the midwest is still surprisingly
high. At the same time, aldrin is known to
metabolize into dieldrin, a highly persistent
and lipophilic chemical which has a strong
tendency to accumulate and "biomagnify" in
the environment.
(2) atrazine; We estimate that approximately 30
million pounds of atrazine per year are used
on corn in the five state area. Atrazine is
not as persistent as the aldrin/dieldrin com-
plex and does not appear to "biomagnify".
6-F
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However, its residues following a full-rate
application often persist in the soil long
enough to be phytotoxic to crops other than
corn grown on treated land the following sea-
son. Thus, atrazine must be considered a
moderately persistent chemical. It is of
concern for this reason, combined with the
large volume in which it is used in the five
states.
Aldrin
Aldrin and its main metabolite, dieldrin, which is
also an insecticide in its own right, belPng to a group
of highly chlorinated cyclic hydrocarbons produced by
the Diels-Alder diene reaction. Their discovery in the
late 1940's is attributed to Julius Hyman (14). Shell
Chemical Company is the only manufacturer of both insec-
ticides in the U. S. at present. Both aldrin and diel-
drin have been in large scale commercial use for many
years. A huge volume of scientific literature deals
with these chemicals.
In the five state area, by far the most important
use of aldrin is for the control of soil insects on corn.
For this purpose, the product is applied directly to the
soil by way of granular formulations or, to a much smaller
7-F
-------
extent, as a spray or impregnated on fertilizer.
The extensive literature on the fate of aldrin can
basically be summarized in one sentence: "The mech-
anisms by which aldrin and dieldrin are lost from soils
are not known for certain" (15) . Data indicate that
volatilization may be one of the important routes of
"disappearance" of aldrin (9, 15, 16, 17, 18, 19). A
substantial pathway of aldrin metabolism is its epoxi-
dation to dieldrin (9, 15, 20). Leaching and surface
run-off in water as a solute have not been shown to occur
with aldrin and are unlikely because of its low water
solubility (9, 16, 19). However, aldrin is strongly
adsorbed on soil particles and may therefore be trans-
ported away from sites of application by soil erosion
or wind erosion (9, 15, 16). It has also been shown,
although only in the laboratory, that aldrin can be
degraded by microbes under aerobic as well as anaero-
bic conditions (9, 15, 21, 22). Its conversion to
dieldrin can also occur non-biologically (9).
Dieldrin is the major known metabolite of aldrin
(9, 15, 20). Its vapor pressure is much lower than that
of aldrin, and volatilization would therefore occur to
a lesser extent as compared to aldrin, except when diel-
drin residues are directly exposed on the soil surface
(18, 23, 24, 25). Dieldrin can be isomerized, physi-
8-F
-------
cally as well as biologically, to "photo-dieldrin", an
isomer more toxic than the parent compound to many
biological organisms. Dieldrin may also be converted
to more polar degradation products. One of these is the
diol formed by hydrolysis of the epoxide group; the others
are unidentified (9, 15, 26).
As with aldrin, leaching and surface run-off of dieldrin
as a solute in water do not occur to any appreciable extent,
but adsorption on soil particles and disappearance from
site of application by soil erosion or wind erosion may
be substantial (9, 15, 16). Dieldrin is much more re-
sistant to microbial degradation than aldrin as demon-
strated in laboratory studies. Some soil organisms have
been reported to be capable of degrading dieldrin, but
it is not known to what extent this may occur in the
field (9, 22). The "average half-life" of dieldrin has
been reported to be 3-4 years, as opposed to approxi-
mately 6 months for aldrin under similar experimental
conditions (15).
Thus, dieldrin is considerably more stable than
aldrin and therefore reason for greater concern from an
environmental standpoint. It is not surprising that
along with DDT, dieldrin residues are most ubiquitous
in all elements of the environment, especially water-
ways (27, 28, 29, 30, 31). The aldrin-dieldrin pair
9-F
-------
is the only pesticide group whose residues in food, as
determined by comprehensive monitoring studies, were so
high that the dietary intake exceeded the allowable
standards established by the World Health Organization.
This occurred in the mid-sixties. Food residues of the
aldrin-dieldrin group have since declined somewhat and
have remained below the WHO acceptable level up to the
present (6, 32, 33).
The midwestern states, especially Iowa and Illinois,
have used large quantities of aldrin on their extensive
corn acreage for many years. Consequently, dieldrin re-
sidues have been found in these states in soils, water-
ways, crops, poultry, beef, pork, milk and fish. Attempts
have been made to track down the origin of dieldrin re-
sidues found in certain beef or dairy herds, but this
has generally proved to be unexpectedly difficult. One
source of dieldrin residues in animals and animal pro-
ducts seems to be direct contamination of feed with
pesticide granules (34) . A second important source is
feed and forage grown on land previously treated with
aldrin. Animal husbandmen, especially dairymen, are
being advised not to feed any items grown on land which
has received aldrin treatments within the last two years.
However, in the light of the heavy use of aldrin in
these states, this recommendation is not realistic in
many instances.
10-F
-------
Concerning the presence of aldrin and dieldrin re-
sidues in Iowa waters, sediment, and fish (31), there is
a debate on whether these originate primarily from run-
off from agricultural lands, or from direct contamination
of waterways by industrial operations such as pesticide
manufacturing and formulating activities, pesticide
drum refurbishing, or moth proofing. This debate was
unresolved at the time of writing of this report.
Extensive data on the human toxicity of aldrin and
dieldrin, including toxicological studies of long-term
occupational exposure have recently been summarized and
published by Jager (35). Pimentel's very recent, excel-
lent compilation of "Ecological Effects of Pesticides on
Non-Target Species" (36) includes sections on aldrin and
dieldrin. For both chemicals, a considerable body of
data is available on quantities or concentrations which
were lethal to different organisms, mostly under labora-
tory conditions. Practically no information is available
on the effects of long-term low-level exposure on species
other than laboratory mammals.
Very recent findings suggest that dieldrin at die-
tary feeding levels as low as 0.5 mg/kg. of body weight
may affect the learning behavior of sheep (37, 38, 39, 40,
41). The electroencephalograms of the experimental
animals also showed deviations from the norm (39, 42).
11-F
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Thus, we know disturbingly little about the fate of
aldrin and dieldrin in the environment after application,
about their pathways of metabolism and degradation, and
about their effects on non-target species, especially
from long-term low-level exposure such as is likely to
occur under actual field conditions. The observations
by Van Gelder and colleagues cited in the preceding
paragraph are one indication that much more research work
in this area is needed.
Atrazine
Atrazine herbicide belongs to a family of s-tria-
zines developed in the laboratories of J. R. Geigy, S.A.,
Basle, Switzerland in the mid-50 ' s.. it is one of the
world's major chemical pesticides. We estimate that
about 80 to 100 million pounds of atrazine active in-
gredient are produced annually in the United States alone.
By far the most important use of atrazine is for the con-
trol of weeds in corn. As indicated in Appendix B of
this report, we estimate that about 30 million pounds of
atrazine per year are used for this purpose in the five
state area. Atrazine is marketed primarily as an 80 per-
cent wettable powder formulation trade-named "Aatrex".
•^
It is applied as a suspension in water either pre- or
post-emergence, by itself or in combination with other
12-F
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herbicides. Recommended rates of application range from
2 to 4 pounds of active ingredient per acre, depending
on soil conditions, soil organic content, etc.
Recognizing the increasingly difficult problem for
many scientists to keep abreast of the rapidly growing
volume of literature on important pesticides, the
Geigy Company and the University of California co-
sponsored an international symposium to bring together
all available information on s-triazine-soil inter-
actions. Over 150 scientists attended this symposium
at Riverside, California in Feburary of 1969. Sixteen
papers were presented covering every aspect of s-tria-
zine-soil interactions. These papers include very com-
prehensive coverage of the scientific literature on this
subject up to 1968 and were published together as Volume
32 of "Residues Reviews", edited by F. A. Gunther (43).
This volume is made doubly useful by a comprehensive
subject index.
A review of this summary of the state of the art
leads to a discomforting conclusion: While there is a
large number of papers dealing with laboratory and
greenhouse studies, theories and theoretical models
and/or reviews of other, like papers, only very scant
information is available on the fate of the s-triazines,
including atrazine, under actual field conditions. This
13-F
-------
is pointed out very succinctly by Kearney (44).
The persistence of atrazine in soils depends on a
number of factors including soil texture, soil fertility,
rainfall, soil moisture content, quantity of atrazine
applied, tillage practices, temperature, organic matter
content, pH, soil microbial activity, and others (43,
45). Physical, biological and chemical factors inter-
act in degrading atrazine after application. The rela-
tive importance of each of these types of influences is
largely unknown.
One important route of detoxification of atrazine
appears to be hydrolysis to hydroxyatrazine (11, 45, 46).
Photodecomposition is a physical mechanism by which atra-
zine has been shown to be detoxified under laboratory
conditions. However, most s-triazines absorb energy in
a wavelength region considerably below that of natural
sunlight. It is therefore doubtful if photodecomposition
is of major significance under field conditions, es-
pecially where the herbicide is incorporated into the
soil (44) . Volatilization has been demonstrated in
laboratory studies but again, it is not known to what
extent it may occur under field conditions (44) . Like-
wise, the importance of microorganisms in the metabolism
of atrazine is largely unknown (11, 44). Recent studies
indicate that microbial degradation in the field may
14-F
-------
less important than was previously assumed (11).
In summary, it is believed that atrazine in soil
degrades completely with time/but the pathways are not
certain. Some studies have shown that nitrogen from
the triazine ring is released and may be utilized by
plants. It is assumed that hydrolysis of atrazine to
hydroxyatrazine is followed by dealkylation, deamina-
tion and ring cleavage.
Atrazine is much more water soluble than aldrin/
dieldrin. Accordingly, "disappearance" by leaching or
horizontal transport dissolved in water are more likely
than with less soluble chemicals. However, Hayes (47)
points out that there is a lack of correlation between
water solubility and leachability. Different soil types
altered the order of leachability within the s-triazine
group. Helling (48) points out that based on -water solu-
bility aloae, only 0.75 inch of rain would totally dis-
solve 5 pounds of active atrazine per acre. Actual
field measurements indicate that atrazine is much less
mobile in the soil than would be suggested by these
figures.
Further studies on the degradation of atrazine
after application have been reported since the 1969
symposium. Soil degradation of atrazine was investi-
gated by Goswami and Green (49) and Zimdahl, et al.(50)
15-F
-------
Burnside, et al. (51) reported on the soil persistence
of repeated annual applications of atrazine in Nebraska.
Pape and Zabik (52) further investigated the photo-
decomposition of atrazine and other s-triazines. Brown
and White (53) studied the interactions of twelve dif-
ferent s-triazines with soil clays of varying miner-
alogical composition and with bentonite. Hance and
Chesters developed a method for extraction from the
soil and analysis of hydroxyatrazine (54) and studied
the fate of this atrazine metabolite in soil and lake
sediment (55). Kaufman and Blake conducted further
studies on the degradation of atrazine by soil organisms,
especially soil fungi (56).
None of these most recent studies changed the basic
conclusions as of 1969, and none of them report any
major breakthroughs in the further clarification of
the pathways of metabolism and degradation of atrazine
in the environment.
Adams and co-workers at the University of Minnesota
have reported on the interactions between atrazine and
other herbicides (57), and between atrazine and phos-
phorus and manganese, using the growth and mineral com-
position of soybeans as an indicator'(58, 59). They
observed in electron microscope studies that phosphorus
"toxicity", atrazine injury and manganese deficiency
16-F
-------
produced similar effects in chloroplasts. Atrazine or high
phosphorus induced apparent manganese deficiency without,
however, appreciably affecting the manganese composition
of the plants (60). In a growth chamber study, addition
of phosphorus to the soil increased the sensitivity of
soybeans to sublethal concentrations of atrazine. Dry
matter produced and mineral content of soybeans were
affected by atrazine as well as by phosphorus treatments
(58) .
Espinoza, et al. observed interesting interactions
between atrazine, other herbicides and fungicide seed
treatments on the growth of soybean seedlings (57). These
experiements were conducted to study the effects of
atrazine residues left in the soil from the preceding
cropping season on susceptible crops when weeds are con-
trolled in those crops by application of another herbi-
cide. The results indicate multi-lateral interactions
between these chemicals and the extremely complex soil-
plant system. Furthermore, they suggest the possibility
that a biologically active agent like atrazine may have
similar complex effects on aquatic ecosystems which it
may reach by way of leaching or run-off from treated
areas, misapplication directly to bodies of water, spill-
age, etc.
Summary and Conclusions
In line with the increasing concern about pesticides
17-F
-------
and their possible impact on the environment, a number
of recent conferences, panels and committees have ad-
dressed themselves to this problem. A large volume of
literature on this subject has been exhaustively re-
viewed, abstracted and commented upon in the recent
past. It is the general consensus of these compre-
hensive studies and reviews that present pesticide use
patterns do not adversely affect human health directly,
but that they cause adverse effects on certain species
of wildlife, and further actual or potential environ-
mental harm whose nature and extent may escape our pre-
sent capabilities of detection and/or foresight. Many
scientists working in this area are increasingly con-
cerned about possible long-term low-level environmental
effects.
Based on their volume of use on midwestern farm
crops and on their physical, chemical and biological
properties, we selected the insecticide aldrin and the
herbicide atrazine for a more extensive review of in-
formation on their degradation in the environment.
Table 1-F presents a summary and comparison, prob-
ably over-simplified, of the factors affecting the de-
gradation of aldrin, dieldrin (the principal metabolite
of aldrin) and atrazine. There are important differ-
ences in the physical and chemical properties of these
18-F
-------
TABLE 1-F
COMPARISON OF FACTORS AFFECTING THE DEGRADATION OF
ALDRIN, DIELDRIN AND ATRAZINE
Factor
Volatiliza-
tion
Metabolism
-major meta-f
bolite(s)
Leaching
Surface run-
off
-in water
Aldrin
substantial
epoxidation
dieldrin
(15-30%)
No
negligible
Dieldrin
small except
when on sur-
face
not known in
detail
"photo-diel-
drin" , diol-
compound
No
negligible
Atrazine
occurs ,
probably
not sub-
stantial
not known
in detail
hydroxy-
atrazine
Yes
Yes; may
be sub-
stantial
-on solids
may be sub-
stantial
Wind erosion possible
may be sub-
stantial
possible
Microbial
degradation
-aerobic
-anaerobic
Non-biological
degradation
Av. Half-life
in soil
Vapor pressure
demonstrated
in the lab,
but not con-
firmed in the
field
Yes
1 year
6xlO~6mmHg
at 25°C
demonstrated
in the lab,
but not con-
firmed in the
field
Yes
1 year
_T
1.8x10 mmHg
at 25°C
Yes
possible
but prob-
ably minor
possible
but prob-
ably minor
substan-
tial
1 year
3.0xlO~7mmHg
at 20°C
19-F
-------
TABLE 1-J? (Continued)
Factor
Aldrin
Dieldrin
Atrazine
Lipid solu-
bility
Water solu-
bility
Stability to
hydrolysis
-alkaline
-acid
High
0.027 ppm
at 25°C
stable
stable with
dilute acids
High
0.186 ppm
25°C
stable
stable with
dilute acids
Low
33 ppm
at 27°C
stable in
neutral
and slight-
ly alka-
line or
acid media
20-F
-------
compounds which in turn influence their persistence, de-
gradation and propensity for environmental damage.
Among pathways of "disappearance" from the site of
application, volatilization is one possible escape route
of aldrin. It has the highest vapor pressure of the
three chemicals in this comparison. Volatilization of
atrazine may occur, but it is not believed to be sub-
stantial.
The exact pathways of metabolism and degradation
and the nature of the ultimate breakdown products are
essentially unknown for all these chemicals.
Leaching and surface run-off as a solute in water
are not likely in the case of aldrin and dieldrin, but
may be substantial in the case of atrazine because of its
relatively high water solubility. Adsorption on solids
and, consequently, transport by soil erosion or wind
erosion are possible routes of escape for all three pro-
ducts.
Microbial degradation has been demonstrated in the
laboratory, but not confirmed in the field for aldrin and
dieldrin. It is possible but probably minor in the
case of atrazine.
Non-biological degradation occurs with all three
products, probably to a substantial degree, especially
in the case of atrazine.
21-F
-------
The "average half-life" information is included in
this table merely as an indication of the relative per-
sistence of these chemicals in the soil. This informa-
tion for aldrin and dieldrin is quoted from Edwards (61)
who actually gives numerical values. Following a review
of available data, he reported an "average half-life" of
0.51 years for aldrin, 2.4 years for dieldrin. We have
not included these numerical values in Table 1-F because
we agree with Lichtenstein (13) and others who point out
that it is impossible to attribute an absolute life time
(or half-life) to any of these chemicals. Observations
on persistence expressed as "half-lives" are meaningful
only in terms of and under the conditions of the parti-
cular study in which they were obtained.
Both aldrin and atrazine have been in large-scale
commercial use for many years. Yet, disturbingly little
is known about their fate in the environment after appli-
cation, or about their pathways of metabolism and degra-
dation under field conditions. Information on their
effects on non-target species consists largely of data
on the amounts of chemical lethal to various test
organisms, in the majority of cases obtained under labora-
tory conditions. There is very little information on
possible interactions between these pesticides and/or
their metabolites with other chemicals. Practically no-
22-F
-------
thing is known about possible effects of long-term low-
level residues of these pesticides and/or their meta-
bolites on the environment in general, or on aquatic
ecosystems in particular.
Thus, it is obvious that there are glaring gaps
in our knowledge of the environmental behavior of these
important pesticides. The type of research required to
fill these gaps will be complex, and it will be success-
ful only if it is planned and performed by an interdis-
ciplinary approach.
The emphasis must be on studies under actual field
conditions. Every effort should be made to encourage
interdisciplinary teams to engage in comprehensive re-
search on complete ecosystems. Work on isolated orga-
nisms in the laboratory, far removed from field reality,
with which the present literature is filled is of rela-
tively limited value unless its significance in regard
to field conditions can be clearly assessed.
In this connection, it must be recognized that the
more comprehensive, interdisciplinary approach is not
liable to produce material suitable for quick publica-
tion of simple results. The publishing incentive sys-
tems in the academic world may require some adjustments
in this regard.
The examples of the triazine symposium (43) con-
23-rF
-------
ducted by the University of California at Riverside in
cooperation with the product's manufacturer, as well as
the symposium on "pesticides in the soil" conducted at
Michigan State University through Guyer's(9) initiative
demonstrate how useful such work conferences can be in
pulling together all available data and expert opinions
on a complex problem. Prerequisites for success are
selection of a sufficiently narrow and well-defined sub-
ject, good preparation and execution of the conference,
and timely publication of the proceedings, preferable
with a good index.
Recommendations
We recommend that a massive, interdisciplinary re-
search effort be mounted to clarify the environmental
behavior of major pesticides which are expected to con-
tinue in use for the foreseeable future. Information
needed includes their fate in the environment after appli-
cation; routes of metabolism, degradation and disappear-
ance; nature of the ultimate breakdown products; effects
of long-term exposure of ecosystems to low-level resi-
dues; and interactions with other chemicals in the environ-
ment. It will be necessary to establish an order of
priority among products to be thoroughly investigated in
this fashion.
24-F
-------
We recommend that the responsibility to establish
such a priority system and to plan, spearhead and oversee
the research program itself be assigned to a specific
office or committee within the EPA.
We further recommend that actual performance of the
research work required should not be limited to tax-
supported agencies, but that all possible research capa-
cities should be mobilized including those of industry,
independent and non-profit research organizations, etc.
By and large, industrial and independent research organi-
zations have more experience and have had more success in
the management and performance of truly interdisciplinary
research than government or university laboratories.
This type of experience is greatly needed in this ex-
tremely complex area of environmental research.
25-F
-------
LITERATURE REFERENCES
1 "Scientific Aspects of Pest Control", Publication
1402, National Academy of Sciences - National
Research Council, Washington, D. C., 1966.
2 Report of Committee on Persistent Pesticides,
Division of Biology and Agriculture, National
Research Council to U. S. Department of Agri-
culture, Washington, D. C., May 1969.
3 Cleaning Our Environment - The Chemical Basis
For Action , ^A_R_gpgrt by the Subcommittee on
Environmental Improvement, Committee on Chemistry
arid Public Affairs, American Chemical Society,
Washington, D. C., 1969.
4 Report of the Secretary's Commission on Pesti-
cides and Their Relationship to Environmental
Health, Parts I and II, U. S. Department of
Health, Education, and Welfare, December, 1969.
5 Environmental Quality/ the First Annual Report
of the Council on Environmental Quality, Trans-
mitted to the Congress August 1970.
6 Environmental Quality, the Second Annual Report
of the Council on Environmental Quality, August
1971.
7 Chlorinated Hydrocarbons inthe MarineJilnyirqn-
ment , Report by the Panel on Monitoring Per-
sistent Pesticides in the Marine Environment.
Committee on Oceanography, National Academy of
Sciences, Washington, D. C., 1971.
8 Willrich, T. L. and G. E. Smith (eds.), Agri-
cultural Practices and Water Quality, The Iowa
State University Press, Ames, Iowa, 1970.
9 "Pesticides in the Soil: Ecology, Degradation &
Movement", International Symposium, Michigan
State University, East Lansing, 1970.
10 Kaufman, D. D., "Pesticide Metabolism", Inter-
national Symposium on Pesticides in the Soil,
Michigan State University, East Lansing, 1970,
pp. 73-85.
26-F
-------
11 Kaufman, D. D., and P. C. Kearney, "Microbial
Degradation of S-triazine Herbicides", Residue
Reviews, Vol. 32, 1970, pp. 235-266.
12 Biggar, J. W., "Pesticide Movement in Soil Water",
International Symposium on Pesticides in the Soil,
Michigan State University, East Lansing, 1970,
pp. 107-119.
13 Lichtenstein, E. P., "Fate and Movement of Insecti-
cides in and from Soils", International Symposium
on Pesticides in the Soil, Michigan State Univer-
sity, East Lansing, 1970, pp. 101-106.
14 Metcalf, R. L., Organic Insecticides, Their Chemis-
try and Mode of Action, Interscience Publishers,
Inc., New York, London, 1955.
15 Aldrin and Dieldrin - A Summary of Literature
Relating to Characteristics, Behavior, Occurrence,
and Significance of Residue Levels in the Environ-
ment , Shell Chemical Company, New York, New York,
May 1970.
16 Caro, J. H., and A. W. Taylor, "Pathways of Loss
of Dieldrin from Soils Under Field Conditions",
Agricultural and Food Chemistry, Vol. 19, No. 2,
1971, pp. 379-384.
17 Lichtenstein, E. P., and K. R. Schulz, "Volati-
lication of Insecticides from Various Substrates",
Agricultural and Food Chemistry, Vol. 18, No. 5,
1970, pp. 814-818.
18 Lichtenstein, E. P., J. P. Anderson, T. W. Fuhremann,
and K. R. Schulz, "Aldrin and Dieldrin: Loss
under Sterile Conditions", Science, Vol. 159, 1968,
pp. 1110-1111.
19 Shell Chemical Company/Agricultural Division,
Technical Data Bulletin, Summary of Basic Data for
Technical Aldrin, ACD:67-104 (Rev. 9-68).
20 Lichtenstein, E. P., T. W. Fuhremann, and K. R.
Schulz, "Persistence and Vertical Distribution of
DDT, Lindane, and Aldrin Residues, 10 and 15
Years After a Single Soil Application", Agricul-
tural and Food Chemistry, Vol. 19, No. 4, 1971,
pp. 718-721.
27-F
-------
21 Patil, K. E., F. Matsumura, and G. M. Boush,
"Degradation of Endrin, Aldrin, and DDT by Soil
Microorganisms", Applied Microbiology, Vol. 19,
No. 5, 1970, pp. 879-881.
22 Ma'tsumara, F., and G. M. Boush, "Metabolism on
Insecticides by Microorganism", Soil Biochemistry,
Marcel Dekker, New York, Vol. 2, 1971, pp. 320-336.
23 Spencer, W. F., and M. M. Cliath, "Vapor Density
of Dieldrin", Environmental Science & Technology,
Vol. 3, 1969, pp. 670-674.
24 Spencer, W. F., M. M. Cliath, and W. J. Farmer,
"Vapor Density of Soil-Applied Dieldrin as Re-
lated to Soil-Water Content, Temperature, and
Dieldrin Concentration", Soil Science Society of
American Proceedings, Vol. 33, No. 4, 1969, pp.
509-511.
25 "Summary of Basic Data for Technical Aldrin", Shell
Chemical/Agricultural Division, Technical Data
Bulletin, ACD; 67-105 (Rev. 2-71).
26 Matsumura, F., K. C. Patil, and G. M. Boush,
"Formation of 'Photodieldrin1 by Microorganisms",
Science, Vol. 170, 1970, pp. 1206-1207.
27 Water Quality Criteria, Report of the National
Technical Advisory Committee to the Secretary of
the Interior, Federal Water Pollution Control
Administration, Washington, D. C., 1968.
28 Wiersma, G. B., P. F. Sand, and R. L. Schutzmann,
"National Soils Monitoring Program - Six States,
1967", Pesticides Monitoring Journal, Vol. 5,
No. 2, 1971, pp. 223-227.
29 Henderson, C., A. Inglis, and W. L. Johnson,
"Organochlorine Insecticide Residues in Fish -
Fall 1969 National Pesticide Mointoring Program",
Pesticides Monitoring Journal, Vol. 5, No. 1,
1971, pp. 1-11.
30 Lichtenberg, J. J., J. W. Eichelberger, R. C.
Dressman, and J. E. Longbottom, "Pesticides in
Surface Waters of the United States - A 5-Year
Summary, 1964-68", Pesticides Monitoring Journal,
Vol. 4, No. 2, 1970, pp. 71-86.
28-F
-------
31 Johnson, L. G., and R. L. Morris, "Chlorinated
Hydrocarbon Pesticides in Iowa Rivers", Pesti-
cides Monitoring Journal, Vol. 4, No. 4, 1971,
pp. 216-219.
32 Duggan, R. E., G. Q. Lipscomb, E. L. Cox, R. E.
Heatwole, and R. C. Kling, "Pesticide Residue
Levels in Food in the United States from July 1,
1963 to June 30, 1969", Pesticides Monitoring
Journal, Vol. 5, No. 2, 1971, pp. 73-212.
33 Corneiliussen, P. E., "Pesticide Residues in
Total Diet Samples (V)", Pesticides Monitoring
Journal, Vol. 4, No. 3, 1970, pp. 89-92.
34 Buck, W. B., and W. Van Note, "Aldrin Poisoning
Resulting in Dieldrin Residues in Meat and Milk",
Journal of the American Veterinary Medical Associ-
ation, Vol. 153, No. 11, 1968, pp. 1472-1475.
35 Jager, K. W., Aldrin, Dieldrin, Endrin & Telodrin,
Elsevier Publishing Company, Amsterdam/London/New
York, 1970.
36 Pimentel, D., Ecological Effects of Pesticides on
Non-Target Species, Executive Office of the Presi-
dent, Office of Science and Technology, Washington,
D. C., 1971.
37 Sandier, B. E., G. A. Van Gelder, W. B. Buck,
and G. G. Karas, "Effect of Dieldrin Exposure
on Detour Behavior in Sheep", Psychological
Reports, 1968, 23, pp. 451-455.
38 Van Gelder, G. A., B. E. Sandier, W. B. Buck,
and G. G. Karas, "Convulsive Seizures in Dieldrin
Exposed Sheep During Photic Stimulation", Psy-
chological Reports., 1969, 24, p. 502.
39 Van Gelder, G. A., B. E. Sandier, W. B. Buck,
J. B. Maland, G. G. Karas, "Behavioral and Elec-
trophysiological Effects of Dieldrin in Sheep",
Industrial Medicine, Vol. 38, No. 3, 1969, pp.
64-67
40 Sandier, B. E., G. A. Van Gelder, D. D. Elsberry,
G. G. Karas, and W. B. Buck, "Dieldrin Exposure
and Vigilance Behavior in Sheep", Psychon. Science,
Vol. 15 (5), 1969, pp. 261-262.
29-F
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41 Van Gelder, G. A., Dieldrin Induced Behavioral
Decrement in Sheep , Manuscript in Preparation.
42 , W. B. Buck, R. Sandier, J. Maland, and
G. Karas, "The Effects of Dieldrin and Ruelene
Exposure on Experimental Behavior and the Elec-
troencephalogram" , Environmental Health Sciences
Series, No. 1, pp. 125-133.
43 Gunther, F. A. (ed.),"The Triazine Herbicides",
Residue Reviews, Volume 32, Springer-Verlag, New
York/Heidelberg/Berlin, 1970.
44 Kearney, P. C., "Summary and Conclusions", Residue
Reviews, Vol. 32, 1970, pp. 391-399.
45 Aatrex Herbicide, Technical Bulletin, Geigy Agri-
cultural Chemicals, Division of Ciba-Geigy Corpora-
tion, Ardsley, New York, May, 1971.
46 Jordan, L. S., W. J. Farmer, J. R. Goodin, and
B. E. Day, "Non-biological Detoxication of the
s-Triazine Herbicides", Residue Reviews, Vol. 32,
1970, pp. 267-286.
47 Hayes, M. H.B., "Adsorption of Triazine Herbi-
cides on Soil Organic Matter, Including a Short
Review on Soil Organic Matter Chemistry", Residue
Reviews, Vol. 32, 1970, pp. 131-174.
48 Helling, C. S., "Movement of a-Triazine Herbicides
in Soils", Residue Reviews, Vol. 32, 1970, pp.
175-210.
49 Goswami, K. P. and R. E. Green, "Microbial Degra-
dation of the Herbicide Atrazine and its 2-
Hydroxy Analog in Submerged Soils", Environmental
Science & Technology, Vol. 5, No. 5, 1971, pp.
426-429.
50. Zimdahl, R. L., V. H. Freed, M. L. Montgomery, and
W. R. Furtick, "The Degradation of Triazine and
Uracil Herbicides in Oil", Weed Research, 10,
1970, pp. 18-26.
51 Burnside, 0. C., C. R. Fenster, and G. A. Wicks,
"Soil Persistence of Repeated Annual Applications
of Atrazine", Weed Science, Vol. 19, No. 3, 1971,
pp. 290-293.
30-F
-------
52 Pape, B. E.f and M. J. Zabik, "Photochemistry of
Selected 2-Chloro and 2-Methylthio-4,6-di-
(Alkylamino)-S-Triazine Herbicides", Journal of
Agricultural and Food Chemistry, Vol. 18, No. 2,
1970, pp. 202-207.
53 Brown, C. B. and J. L. White, "Reactions of 12
s-Triazines with Soil Clays", Soil Science Society
of America Proceedings, Vol. 33, No. 6, 1969,
pp. 863-867.
54 Hance, R. J., and G. Chesters, "Extraction of
Hydroxyatrazine from Soil", Analyst, Vol. 95,
1970, p. 106.
55 , "The Fate of Hydroxyatrazine in a Soil
and a Lake Sediment", Soil Biological Biochemistry,
Vol. 1, 1969, pp. 309-315.
56 Kaufman, D. D., and J. Blake, "Degradation of
Atrazine by Soil Fungi", Soil Biological Biochemistry,
Vol. 2, 1970, pp. 73-80.
57 Espinoza, W. G., R. S. Adams, Jr., and R. Behrens,
"Interaction Effects of Atrazine and CDDA, Linuron,
Amiben, or Trifluralin on Soybean Growth", Agronomy
Journal, Vol. 60, 1968, pp. 183-185.
58 Adams, R. S., and W. G. Espinoza, "Effect of Phos-
phorus and Atrazine on Mineral Composition of
Soybeans", Agricultural and Food Chemistry, Vol.
17, No. 4, 1969, pp. 818-822.
59 Sun, C. N., and R. S. Adams, Jr., "Effects of the
Phosphorus-Manganese-Atrazine Interaction in
Soybean Plants", Agricultural and Food Chemistry,
Vol. 19, No. 2, 1971, pp. 325-330.
60 Adams, Jr., R. S., C. N. Sun, "Physiological and
Metabolic Effects of Trace Substances on Plants
and the Implication of Man", Trace Substances in
Environmental Health - IV, University of Missouri,
1971, pp. 307-317.
61 Edwards, C. A., "Soil and Fertilizers", 27, 1964,
p. 451 (quoted from 15, p. 3).
62 Weber, J. B., "Mechanisms of Adsorption of s-
Triazines by Clay Colloids and Factors Affecting
Plant Availability", Residue Reviews, Vol. 32,
pp. 93-130.
31-F
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APPENDIX G
ALTERNATIVES TO CHEMICAL CONTROL OF WEEDS AND INSECTS
An understanding of the most important weed, insect
and disease problems in the study area is essential to
an evaluation of possible alternatives to chemical con-
trol. This topic is therefore presented in this section
rather than in Appendix B of this report.
Weeds
Table 1-G summarizes the most important weeds affect-
ing field crops, especially corn, soybeans and small
grains, in the five state area as reported by weed sci-
entists in each state. It will be noted that by and
large, these weed complexes are very similar throughout
the five state area, with only relatively minor varia-
tions .
In most states, mention was made of Panicum species
as being on the increase. It was also reported that
perennial weeds are slowly becoming more prevalent, prob-
ably because the annual weeds are so effectively con-
trolled by chemical herbicides. Wild cane (Sorghum
bicolor), a relative of grain sorghum, is changing from
a mere curiosity ten to twenty years ago to a problem of
1-G
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TABLE 1-G
SUMMARY OF MAJOR WEEDS AFFECTING FIELD CROPS IN THE 5 STATE AREA
State
Minnesota
Iowa
Illinois
Missouri
Kansas
Annual
Weeds
to
i
o
Perennial
Weeds
foxtails
pigweed
lambsquarter
smartweed
ragweed
barnyard grass
crabgrass
Panicum
velvetweed
wild sunflower
cocklebur
wild oats
quackgrass
Canada thistle
nutsedge
field bindweed
giant foxtail
barnyard grass
smartweed
velvetweed
wild sunflower
cocklebur
Canada thistle
milkweed
giant foxtail
pigweed
smartweed
lambsquarter
velvetweed
pigweed
j imsonweed
cocklebur
Panicum
johnsongrass
nutsedge
Canada thistle
quackgrass
milkweed
giant foxtail
crabgrass
Panicum
barnyard grass
j imsonweed
pigweed
lambsquarter
cocklebur
velvetweed
smartweed
ragweed
johnsongrass
nutsedge
giant foxtail
other foxtails
pigweed
wild cane
Panicum
velvetweed
cocklebur
field bindweed
bur ragweed
-------
major economic importance in corn and grain sorghum,
especially in Kansas. The week thrives on the growing
conditions most favorable to the crop and therefore can-
not be controlled by cultural practices. Wild cane can
be controlled chemically in corn, but there is no herbi-
cide sufficiently selective to control it in grain sorghum.
In Minnesota, it was feared that the increasing use
of the newly developed semi-dwarf varieties of wheat will
result in greater weed problems in the future because
they are less aggressive than presently grown wheat
varieties.
Alternatives to Chemical Weed Control
Chemical herbicides have generally not caused as
much concern in regard to actual or potential environ-
mental damage as insecticides. Consequently, less
attention and effort has been devoted to the develop-
ment of non-chemical weed control methods.
Weed control at the farm level has by and large
never relied exclusively or even predominantly on the
use of chemicals, but has always been a "pest manage-
ment" or "integrated control" system, long before these
particular terms became fashionable. This is especi-
ally true of the key midwestern farm crops, corn, soy-
beans and small grains. Long before the present highly
3-G
-------
effective chemical herbicides became available, many
farming practices such as crop rotation, tillage, selec-
tion of planting date, cultivating, etc. were used in-
tentionally to supress weeds and to influence the com-
petition between crops and weeds for light, nutrients
and water in favor of the crops. These practices were
not abandoned when chemical herbicides became known,
but these new tools were truly integrated into the ex-
isting agricultural practices.
We discussed this situation with 214 farm agents
from the five state area. They indicated that cultiva-
tion for weed control and rotation primarily for corn
rootworm are practiced although as labor, costs and
materials increase these techniques are losing favor.
It is pointed out that local weather conditions may pre-
vent adequate cultivation and the farmers thus resort to
chemical treatment.
It is interesting to note in this connection that
in the U. S. Department of Agriculture's Agricultural
Research Service as well as in most state universities
and extension services, weed scientists and specialists
usually are members of Agronomy, Botany or Plant Physio-
logy departments or agencies. Perhaps this has contri-
buted to the fact that weed control appears to be re-
searched and practiced much more by an interdisciplinary
4-G
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"systems approach" than the control of insects. Entomo-
logy is usually organized in separate departments at
the universities, and there is a separate "Entomology
Research Division" within the USDA.
Biological agents to control weeds have been suc-
cessfully employed in at least two instances, i.e.,
against the prickly pear in Australia, and against the
Klamath weed in the western United States. Very little
work along these lines has been done on the weed com-
plex in the five state area, and the scientists inter-
viewed were generally not optimistic about this ap-
proach in this part of the country. At least one actual
lead which was considered proved unsuccessful. A lepi-
dopterous species affects Canada thistle once every few
years and then reduces this perennial weed significantly.
However, once the insect population builds up to the ex-
tent that the thistle supply gets low, the "beneficial"
insects begin to feed on soybeans and other crops.
One of the elements important to good "integrated
control" practices is information on economic damage
thresholds. This subject has received considerable atten-
tion by several groups of scientists in the five state
area, including Staniforth and co-workers (1, 2, 3, 4,
5, 6, 7, 8, 9). These workers studied the competitive
effects of major weed species in Iowa on soybeans and corn,
5-G
-------
Similar studies have been carried out by Feltner and
his colleagues in Kansas (10, 11, 12) on the effects
of major Kansas weeds on grain sorghum.
Insects
Table 2-G summarizes key insect pests affecting field
crops, primarily corn, in the five state area. The most
important insects are the soil insects affecting corn,
i.e., corn rootworms and the so-called "soil insect com-
plex."
There are three species of the corn rootworm in the
area, i.e., Diabrotica lonqicornis, the northern corn
rootworm; I), virgifera, the western corn rootworm; and
D^ undecimpunctata howardi, the southern corn rootworm.
The northern and the western species are highly resistant
to some organic phosphate insecticides. The northern and
western species predominate in Minnesota and Iowa. All
three species are reported in Illinois, Missouri and
Kansas. The southern species is the least damaging one.
The "soil insect complex" includes white grubs, wire-
worms, webworms, corn billbugs, cutworms and others.
Seed-corn maggot and seed-corn bettle are sometimes also
included in this complex.
Foliar insects attacking corn include the European
corn borer, the southwestern corn borer, corn earworms
6-G
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TABLE 2-G
SUMMARY OF MAJOR INSECTS AFFECTING FIELD CROPS
IN THE FIVE STATE AREA
State
Corn
soil insects
foliar
insects
Wheat
foliar
insects
Sorghum
foliar
insects
Minnesota
corn rootworms
soil insect
complex-'-
corn borers
Iowa
corn rootworms
soil insect
complex
corn borers
Illinois
corn rootworms
soil insect
complex
corn borers
corn earworm
Missouri
soil insect
complex
corn rootworm
corn borers
corn earworm
full armyworm
Kansas
corn.' rootworm
soil insect
complex
corn rootworm
adults
fall armyworm
corn borers
greenbugs
cutwonps
greenbugs
armyworms
webworms
I
o
Includes white grubs; wireworms; webworms; billbugs; cutworms; seed-corn maggots;
seed-corn bettles.
-------
and, in Missouri and Kansas, fall armyworms and corn
rootworm adults (especially in Kansas).
Soybeans in the five states are not presently af-
fected by major insect pests requiring routine insecti-
cide treatment. The same is true of small grains with
the exception of Kansas, where greenbugs are becoming
increasingly damaging on wheat and sorghum. Cutworms
on wheat and armyworms and webworms on sorghum also are
sufficiently severe in Kansas to require insecticide
treatments.
Missouri, Illinois and Kansas anticipated that the
increasing intensification of soybean growing practices
will bring about greater insect problems on this crop
in the future.
Alternatives to Chemical Insect Control
Chemical insecticides have caused far greater con-
cern than other pesticides in regard to the actual and
potential environmental damage which they may cause.
Consequently, most of the international as well as the
United States' efforts in the area of searching for al-
ternate methods of pest control have focused on insect
control. This subject has been thoroughly discussed and
reviewed at a number of recent conferences, including a
symposium on scientific aspects of pest control arranged
8-G
-------
and conducted by the National Academy of Sciences, Na-
tional Research Council at Washington, D. C. in 1966
(13), a working conference on "Insect-Plant Interactions"
sponsored by the National Academy of Sciences, held at
the University of California at Santa Barbara in 1968
(14); a symposium on potentials in crop protection held
at the dedication of a new entomology-plant pathology
laboratory at the New York State Agricultural Experi-
ment Station, Geneva, New York, in 1969 (15); and a con-
ference on concepts of pest management, co-sponsored by
North Carolina State University, the Entomological Society
of America, the Rockefeller Foundation and the National
Science Foundation, held at North Carolina State Univer-
sity at Raleigh in 1970 (15) .
Furthermore, a committee of the Agricultural Board
of the National Research Council, National Academy of
Sciences prepared and published an excellent summary on
the scientific principles of insect-pest management and
control (17).
This extensive literature contains a wealth of
basic thoughts, generalities, theories, and principles,
while there is a great scarcity of practical case his-
tories of insect management systems, of information on
how to actually develop such programs in the field, and
of other down-to-earth specifics. Problems such as, for
9-G
-------
example, organizational requirements for initiating ef-
fective programs, pest control advising systems, etc.
have received surprisingly little coverage.
There are no leads in this literature to specific
non-chemical methods of control of any of the major in-
sect problems in the five state area. However, we dis-
cussed this subject extensively with entomologists in-
side and outside of the midwest and present below some
of the facts and suggestions which emanated from these
discussions.
Soil insects in general have received little, if
any, attention thus far in regard to the development of
mibrobial, virus, or hormonal agents which might control
them selectively. Soil insects are more difficult ex-
perimental objects to work with than most other insects.
Furthermore, the soil medium itself presents a formid-
able obstacle to the success chances of such agents which
are often not very stable, may have to be ingested
orally by the target insect in order to be effective,
or are otherwise fragile. Likewise, we have not dis-
covered any evidence of work on attractants, repellents,
parasites or predators specific to corn rootworms or
other soil insects affecting corn.
Development of various resistant or more tol-
erant to the effects of insect pests appears to be a
more promising approach so far as midwestern field crops
10-G
-------
are concerned. Much success has already been achieved
in this regard in the development of corn hybrids re-
sistant to the European corn borer.
There is also optimism about the development of
corn varieties more resistant to corn rootworms. This
,/
"resistance" will probably be in the form of greater
tolerance of the plant to the effects of corn rootworm
feeding, specifically greater regenerative powers of
the corn root system. Another lead which is being pur-
sued is the observation that some corn silks may ad-
versely affect the fecundity and longevity of corn
rootworm adults.
However, improved corn varieties with these desir-
able corn rootworm resistance features are not presently
available, and these insects can and do cause severe
yield losses to presently available corn varieties.
Corn rootworms are most bothersome in "continuous
corn," i.e., when corn is followed by corn in the same
field. Crop rotation would break the insects' life cycle
and largely eliminate the need for treatment. For in-
stance, when corn is grown following soybeans, insecti-
cide treatments are often not needed at all. However,
soybeans cannot be raised successfully on all corn
fields, and there are no economically attractive crops
other than corn for some growers. Thus, the large scale
11-G
-------
use of chemical insecticides for the control of corn root-
worms in continuous corn will probably go on at least un-
til the more tolerant varieties of corn become available.
Farm agents felt that of the few cases of attempts
at biological control, most were failures. Some local
areas reported limited success with ladybugs for aphid
control and parasites to control alfalfa weevil. Part
of the reported failure of biological methods may be
the lack of familiarity with techniques, the unavail-
ability of materials or indifference to trying some-
thing new.
County agents should and probably do reflect the
current attitude of sate colleges of agriculture re-
garding biological control methods. Most of the agents
tended to scoff at the prospects for really satisfactory
controls using non-chemical methods.
Until real success is demonstrated by state and
other agricultural agencies at the local level, it is
doubtful whether biological control methods will gain
much in popularity.
Fortunately from an environmental standpoint, in-
creasing corn rootworm resistance has led to progressive
replacement of chlorinated hydrocarbon insecticides by
organic phosphates and carbamates. These latter chemicals
12-G
-------
are generally more toxic to mammals including man, but
they are less stable, degrade more rapidly in the environ-
ment, and do not biomagnify. Thus, they may be less
harmful from an environmental standpoint and pose less
of a problem in regard to potential contamination of the
aquatic environment.
The "soil insect complex" described above and in
Table 2 is most apt to cause damage to corn grown after
sod, pasture, forage crops, etc. Chlorinated hydro-
carbon insecticides are still used heavily against this
complex and against seed-corn maggots and seed-corn
bettles.
Entomologists wishing to conduct performance trials
against this problem find it most difficult to come up
with good results because these insects occur very errati-
cally and infrequently, and almost never affect a field
uniformly. If, when and where corn may be damaged by
these soil insects is quite unpredictable. Entomolo-
gists generally agree, and their difficulties in con-
ducting meaningful field performance trials against
these insects confirm, that large quantities of in-
secticides applied for the control of this soil insect
complex, probably as much as 90 percent, are applied
needlessly. This is especially deplorable because chlo-
rinated hydrocarbons are the insecticides of choice.
13-G
-------
Thus, this is an insecticide use in which the cost/bene-
fit equation is particularly disadvantageous for the
environment.
Since specific alternate methods of control for
this corn soil insect complex do not appear to be in
sight, other options to cope with this problem should
be explored. For instance, if an incentive (positive
or negative) would be supplied to growers to leave cer-
tain fields or parts of fields untreated, more informa-
tion could be gained about the extent to which the pre-
sent routine prophylactic insecticide treatments are
actually needed. At the same time, this would reduce
the total quantity of chemicals applied.
Another possibility would be a general reduction
of the amount of insecticide applied per acre and of
the number of acres receiving treatment. Illinois in
1971 (18) recommends against the use of aldrin and hep-
tachlor as soil insecticides on corn, citing several
interesting reasons. They point out that soil residues
of aldrin-dieldrin or heptachlor - heptachlor epoxide
from previous applications probably are so high in
aobut 5 million acres of corn fields in the state that
soil pests susceptible to these insecticides should be
depressed to the extent that further treatments are
not required. They also emphasize that perhaps a few
14-C
-------
hindred thousand acres of corn would warrant broadcast
aldrin or heptachlor treatment against cutworms, but
that these fields cannot be selected before the in-
sects actually appear. Therefore, control measures
should only be applied where and when insects appear,
rather than subjecting millions of acres to insecti-
cide treatments needlessly. These are very sound and
timely recommendations. It will be very interesting
to see whether or not they have been followed this year.
If so, a major reduction in the quantities of chlori-
nated hydrocarbon insecticides used in Illinois should
be apparent in the pesticide use statistics which the
state will publish in 1972.
Still another possibility might be establishment
of an insurance system similar to hail insurance,
coupled with a general ban on preventive use of chlori-
nated hydrocarbons against soil insects on corn. Grow-
ers who would actually suffer demonstrable economic
damage from not treating would be reimbursed through
the insurance fund. This possibility suggests itself
because of obvious parallels between the unpredictability
of corn soil insect damage and the similar unpredic-
tability of hail damage.
Finally, crop rotation would also be an effective
control tool, but again, as in the case of corn root-
15-G
-------
rootworms, this is not economically attractive to many
growers under present economic conditions. The consensus
of farmers and agents contacted was that ones profit margin
was keyed to the use of herbicides.
Diseases
Major field crops in the five state area are not
affected by any major plant disease organisms requiring
chemical treatment. The disease which received the
greatest attention and publicity this past year of course
was the southern corn leaf blight. It was observed very
closely, but did not become a problem of economic con-
sequence anywhere in the five state area. No signifi-
cant amounts of fungicides were used against the corn
leaf blight in the area in 1970 and 1971. It was pointed
out by plant pathologists, however, that the southern
corn leaf blight or other corn diseases could very well
become major problems in the future because all present
corn hybrids are based on only six inbred lines. This
is an exceedingly narrow genetic base for a crop cover-
ing so many millions of acres in the United States.
It was also pointed out that soybeans are similarly
subject to potential large scale disease outbreaks be-
cause of an insufficient genetic resistance base. Root
rots, stem rots and bacterial diseases are potential
major threats to soybeans.
Some of the states expressed concern about the can-
16-G
-------
cellation of the registration of mercurial fungicides
for seed treatment, especially for small grains, and
feared increased incidence of seed and seedling diseases,
Plant pathologists in other states applauded the ban of
the mercurials and stated that in their opinion, there
are effective replacement seed treatments available.
Summary and Conclusions
Field crops in the five state area are affected by
a considerable company of weeds, predominantly annual
species. However, perennial weeds are slowly becoming
more prevalent since the annual weeds are so effectively
controlled by chemical herbicides.
There are no specific non-chemical agents such as
"beneficial insects" available for control of any of
the weeds in this region, and no significant work in
this direction appears to be in progress. However, it
is noted that weed control at the farm level does not
rely exclusively on the use of chemicals, but has al-
ways been carried out by the integrated use of many
farming practices such as crop rotation, tillage,
selection of planting date, etc. This system was not
abandoned when chemical herbicides arrived, but these
products were included in it.
One of the elements important to good "integrated
17-G
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control" practices is information on economic damage
thresholds. Considerable attention has been devoted to
this question by scientists in the area, and their work
has provided useful data on the relationships between
weed infestations and yields of the major field crops.
By far the most important insect problem in the five
states are corn rootworms and soil insects on corn.
Much effort has been focused on the search for alternate
methods of insect control in general, but soil insects
have not received much attention in this regard thus
far. To the best of our knowledge, there are no rea-
listic prospects that microbial, hormonal or other agents
for selective control of soil insects will be available
in the foreseeable future.
All three economically important species of the
corn rootworm occur in the five state area. The northern
and western species are highly resistant to chlorinated
hydrocarbon insecticides and increasingly resistant to
some organic phosphate insecticides. Corn rootworms are
most damaging in "continuous corn", i.e., when corn
is grown without rotation with other crops. The develop-
ment of corn varieties more tolerant to the effects of
corn rootworm feeding is the most promising lead as an
alternative to the use of chemicals. However, improved
varieties with these desirable corn rootworm resistance
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features are not yet available. Crop rotation to break
the insects' life cycle is a presently available alter-
native, but it is not economically attractive to many
corn growers.
In the past, the European corn borer caused major
damage to corn in the midwest. DDT was used extensively
to control it. Much success has been achieved in the
development of corn hybrids resistant to this insect.
The "soil insect complex" which includes white
grubs, wireworms, sod webworms, corn billbugs, cutworms,
seed-corn maggots and seed-corn bettles is most damaging
to corn grown after sod, pasture, forage crops, etc.
Chlorinated hydrocarbon insecticides still are used
heavily against this complex. There are no practical
leads to specific non-chemical methods or agents for
the control of these insects. At the same time, they
occur so erratically and infrequently that entomologists
experience great difficulty in conducting meaningful
performance trials against them. Many entomologists
agree that a large portion of the insecticides applied
for this purpose, probably as much as 90 percent, is
applied needlessly. Discontinuation of this practice
would eliminate a major source of environmental contami-
nation in this area. Several suggestions on how this
might be accomplished are discussed above and summarized
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in the "Recommendations" section of this chapter.
Soybeans in the five states are not presently af-
fected by major insect pests requiring routine insecti-
cide treatment. However, entomologists anticipate that
the increasing intensification of soybean growing prac-
tices will bring about greater insect problems on this
crop in the future. This situation where a major crop
is not yet subject to routine insecticide applications
presents a unique challenge and opportunity for the
development of suitable "pest management" systems from
the outset. In this area, there is a great need for
practical, down-to-earth approaches, including develop-
ment of insect damage threshold data, insect damage
forecasting, improved weather forecasting, and es-
tablishment of the organizational requirements and
structures necessary for effective programs.
Furthermore, in order to use chemical insecticides
to best advantage as one element in an integrated sys-
tem, information is needed on the spectrum of selecti-
vity and the degree of effectiveness of potentially
useful products at the low end of their dosage range.
The use of presently available insecticides at lower
dosage rates is one reservoir of selectivity which is
still largely under-utilized, if not completely un-
tapped today.
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Recommendations
We recommend that a concerted effort be undertaken
to reduce or eliminate the prophylactic use of insecti-
cides, especially chlorinated hydrocarbons, for the con-
trol of the "soil insect complex" on corn. Growers
should be strongly encouraged to leave entire fields or
portions thereof untreated and/or to use insecticides
at reduced rates, to establish to what extent, if any,
prophylactic insecticide treatments are needed for this
purpose. As an alternative or additive measure, es-
tablishment of an insurance system similar to hail in-
surance, coupled with a ban on the prophylactic use of
chlorinated hydrocarbon insecticides, should be investi-
gated.
We recommend that the development of a practical,
realistic "pest management" system for soybeans receive
all necessary research, administrative and organiza-
tional attention. The present state of affairs where
this important crop is not yet subject to routine in-
secticide treatments offers a unique opportunity to
develop all aspects of a sound insect management sys-
tem for the bottom up, unincumbered by pre-existing
pesticide use patterns, vested interests, etc.
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LITERATURE REFERENCES
1 Staniforth, D. W., "Competitive Effects of Three
Foxtail Species on Soybeans", Weeds/ Vol. 13,
No. 3, 1965, pp. 191-193.
2 , and W. G. Lovely, "Preemergence Herbi-
cides in Corn Production", Weeds, Vol. 12, No. 2,
1964, pp. 131-133.
3 , and C. R. Weber, "Role of Herbicides
in Soybean Production", Weeds, Vol. 11, No. 2,
1963, pp. 96-98.
4 Staniforth, D. W., "Responses of Soybean Varieties
to Weed Competition", Agronomy Journal, Vol. 54,
1962, pp. 11-13.
5 Nieto, H. J., and D. W. Staniforth, "Corn-Foxtail
Competition Under Various Production Conditions",
Agronomy Journal, Vol. 53, 1961, pp. 1-5.
6 Staniforth, D. W., "Responses of Corn Hybrids to
Yellow Foxtail Competition", Weeds, Vol. 9, No. 1,
1961, pp. 132-136.
7 , "Soybean-Foxtail Competition Under Vary-
ing Soil Moisture Conditions", Agronomy Journal,
Vol. 50, 1958, pp. 13-15.
8 , "Effects of Annual Grass Weeds on the
Yield of Corn", Agronomy Journal, Vol. 49, 1957,
pp. 551-554.
9 Weber, C. R., and D. W. Staniforth, "Competitive
Relationships in Variable Weed and Soybean Stands",
Agronomy Journal, Vol. 49, 1957, pp. 440-444.
10 Feltner, K. C., H. R. Hurst, and L. E. Anderson,
"Tall Waterhemp Competition in Grain Sorghum",
Weed Science, Vol. 17, No. 2, 1969, pp. 214-216.
11 , "Yellow Foxtail Competition in Grain
Sorghum", Weed Science, Vol. 17, No. 2, 1969,
pp. 211-213.
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12 Vesecky, J. F., Grain Sorghum Responses to Various
Densities of Forage Sorghum and Wild Cane , Dis-
sertation, Department of Agronomy, Kansas State
University, Manhattan, Kansas, 1972 (in press.)
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APPENDIX H
REGULATIONS AND LAWS
Introduction
The implementation of laws adequate to protect the
public health is regarded as a normal function of all
levels of government. An assessment of the quality of
existing laws and the means of implementing them presents a
bewildering and complex picture to the professional and lay
person alike. The contractor has endeavored to examine and
present in concise form, the status of federal and state laws
directly pertinent to the five-state study area. By collecting
and analyzing pertinent laws and through a series of inter-
views with key people, a picture of good and bad has been
assembled; each will be presented with the contractor's
evaluation of areas of needed reform.
Included in this section will be such items as key past
events; an appraisal of conflicting interests regarding
pesticides, where they exist; trends in pesticide legislation;
effectiveness of present laws and a comparison between the
study states; and, the contractor's summary and recommendations
of needed legislation.
Of particular importance to this study is an analysis
of federal laws governing testing and registration of new
pesticides and pesticide formulations.
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Federal Organization for Pesticide Control
Federal functions for control of pesticide use are
vested primarily in the Environmental Protection Agency,
being transferred there with the establishment of EPA in
December, 1970. Those functions include: (1) the responsi-
bilities (and staff) of the Department of Agriculture under
FIFRA for pesticides label registration, (2) the responsi-
bilities of the Food and Drug Administration for pesticides
research and standards setting, and (3) certain pesticide
research functions carried out by the Bureau of Sports,
Fisheries and Wildlife of the Department of Interior.
Within EPA, there is an Office of Pesticide Programs under
a Deputy Assistant Administrator who reports to the Assistant
Administrator for Categorical Programs.
Since the formation of EPA, the Office of Pesticides
Programs has been undergoing a nearly continuous reorganization.
An organization chart essentially representative of the
current structure of the pesticides program shows three
primary divisions reporting to the Deputy Assistant Adminis-
trator through the Associate Deputy Assistant Administrator.
These divisions are the Pesticides Regulation Division, the
Pesticides Tolerances Division and the Division of Pesticides
Community Studies. Also reporting to the Deputy Assistant
Administrator are a Director of Program Development, several
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special assistants and the Assistant for Administration.
The two primary laboratories transferred to EPA, the Perrine
Laboratory and the Gulf Breeze Laboratory, have since been
shifted within EPA to the Assistant Administrator for
Research and Monitoring.
The Pesticides Regulation Division is constituted
primarily of those individuals transferred from the Agri-
cultural Research Service of the Department of Agriculture.
Their present functions are to register pesticides and
their use to assure human safety and environmental quality
and to determine compliance with pesticide labeling provisions.
The Pesticides Tolerances Division consists of personnel
transferred to EPA from the Division of Regulations and
Petitions Control, and the Residue Chemistry Branch,
Residue Toxicology Branch and Petitions Evaluation Branch
of the former Division of Pesticide Chemistry and Toxicology
of the Food and Drug Administration. This Division's
function is to establish tolerances for pesticide resi-
dues and to do research on effects of residues in humans
and animals.
The Division of Pesticides Community Studies represents
personnel from the former Office of Pesticides and Product
Safety of the Food and Drug Administration. The existing
Community Studies, State Services, and Technical Services
branches of that unit in Food and Drug continue under the
EPA organization. The Division also includes the former
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Division of Pesticide Chemistry and Toxicology, except
for the several branches that were placed in the Pesticides
Tolerances Division - as mentioned above. The function of
this Division is to conduct epidemiological studies on
acute and chronic exposure to pesticides in communities and
to study the toxic action of pesticides in small animals
from low and high level exposure.
Early in 1970 , an inter-departmental agreement was
announced establishing a working group of the Subcommittee
on Pesticides of the Cabinet Committee on the Environment.
This interdepartmental agreement was for the purpose of
coordination of the activities of the Departments of
Agriculture, Interior, and Health, Education and Welfare,
with respect to the control of economic poisons as defined
in Section 2 of FIFRA. Administrative functions of the
interdepartmental working group on pesticides is now in the
Office of Pesticides Program of EPA. Review and action on
policy matters under the working group are the responsibility
of the Council on Environmental Quality which replaced the
former Cabinet Committee on the Environment. The working
group includes representation from the Department of Agri-
culture, HEW, Interior and Defense, as well as EPA. CEQ
is an observer.
Not all functions with respect to pesticides in the
Federal Government were transferred to EPA. The responsibility
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of enforcement of EPA's tolerance levels in foods will
remain in the Food and Drug Administration. FDA will also
maintain surveillance programs to determine pesticide levels
in foods. They will also continue research to improve
analytical methods of determining pesticide levels in foods
and studies on the long-term effects of pesticides on human
health.
Although the functions of the Department of Agriculture
under FIFRA were transferred to the Administrator, Environ-
mental Protection Agency, the pesticides regulation and
part of the monitoring activities - so transferred - were
a small part of the overall responsibilities of the Agri-
cultural Research Service in pesticides and related
activities. The ARS is still responsible for research to
develop improved means for pest and disease control of
plants and animals, and to apply methods that are proven to
assist the states in their plant and animal disease control
programs. This research and assistance includes fundamental
biology, improved means of non-pesticidal control, improved
pesticide-use patterns, toxicology, pathology, metabolism,
and fate of pesticides, pest control and protection of the
environment during and after control operations, and
pesticides management.
Significant activities with respect to various aspects
of pesticide use will continue in other agencies of the
federal government. For example, the Bureau of Sports
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Fisheries and Wildlife in the Department of Interior
expects to continue a group of pesticide-wildlife research
projects, including related laboratory service work and
research contracts. These represent studies of acute and
chronic toxicity evaluations of pesticides and studies of
the ecological and physiological effects through feeding
tests and controlled plot studies using a variety of key
bird and mammal species. Nearly $1.75 million is scheduled
for this activity in Fiscal Year 1972. The Forest Service
of the Department of Agriculture has a continuing insect
and disease control program. This will include the utiliza-
tion of pesticides, as well as other means for the control
of insects or other hazards attacking the forests of the
country.
State Control Programs
As of mid-1971, 49 of the 50 states have enacted some
form of pesticide control legislation. In some states such
legislation has been on the books for at least 30 years. In
recent years, the Association of American Pesticide Control
Officials has prepared model legislation for the registration
or control of pesticides sold or offered for sale or use
within the state and for the registration or control of
pesticide applicators. All but 10 of the states have enacted
some form of registration or control of commercial applicators
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of pesticides.
The model laws endorsed by the National Association of
State Departments of Agriculture and incorporated in the
advisory material published in the Council of State Govern-
ments State Legislation have not been uniformly adopted and
implemented by the states. However, with the experience of
several years and the increasing activity and concern of
environmental and ecological groups seeking restrictions on
the use of pesticides, the AAPCO has undertaken to revise the
model laws. A draft of the AAPCO model pesticide law is
included in the following pages.
The committee of the Association charged with developing
a revision of the model law presented recommendations to the
Association in mid-1971. Although these recommendations would
normally have been accepted and distributed at that time,
the developing legislation in Congress encouraged the
Association to defer final action on the changes pending
a better definition of the probable impact of the new
Federal legislation. The chairman of the committee charged
with developing the revision worked closely with the staff
of the House Agricultural Committee throughout the hearings
and the subsequent period of developing a "clean bill." He
has endeavored to incorporate in the revised model law
provisions to be consistent with and complementary to the
anticipated new Federal statute.
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DRAFT OF MOUEL PESTICIDE USE AND APPLICATION ACT IIY THK ASSOCIATION of
AMERICAN PESTICIDE CONTROL OFFICIALS, AUGUST 1969
"An Act Relating to the application of insecticides, fungicides, herbicides, de-
foliants, desiccants, plant growth regulators, nematocides and any other pesti-
cides by aircraft or ground equipment, or manually in the state of be
it enacted by the Legislature of the state of •
Section 1. Title. This Act shall lie known as the "- • Pesticide Use and
Application Act of 10—".
Section 2. Enforcing Official. This Act shall be administered by the or
the state of , hereinafter referred to as the " ".
Section 3. Declaration of J'lirpoyc. The purpose of this Act is to regulate in
the public interest, the use and application of insecticides, fungicides, herbicides,
defoliants, desiccants. plant growth regulators, nematocidcs, rodcnticide.s, and
any other pesticides designated by the by regulation. New pesticides are
continually being discovered or synthesized which are valuable for the control
of insects, fungi, weeds, nematodes, rodents, and for xise as defoliants, desiccants,
plant regulators and related purposes. However, suoh pesticides may be in-
effective or may serious injure health, property, or wildlife if nut properly used.
Pesticides may injure man or animals, either by direct poisoning or by gradual
accumulation of poisons in the tissues. Crops or other plants may also be in-
jured by their improper use. The drifting or washing of pesticides into streams
or lakes can cause appreciable damage to nnuatic life. A pesticide applied for the
purpose of killing pests in a crop, which is not itself injured by the pesticide, may
drift and injure other crops or non-target organisms with which it comes in
contact. Therefore, if is deemed necessary to provide for regulation of the use
and application of such pesticides.
Krction //. Definitions. For the purpose of this Act—
(A) "Pest" means, but is not limited to, any insect, fungus, rodent, nematode,
snail, slug, weed and any form of plant or animal life or virus (except virus on
or in living man or other animal) which is normally considered to be .
(B) "Pesticide" means, but is not limited to, (1) any substance or mixture of
substances, including any living organism or any product derived therefrom,
intended to prevent, destroy, control, repel, attract, or mitigate any insect, rodent,
nematode, snail, slug, fungus, weed and any other form of plant or animal life or
virus (except virus on or in living man or other animal) which is normally
considered to be a i>est or which the — may declare to be a i>est, and (2)
any substance or mixture of substances intended to be used as a plant regulator,
defoliant or desiccant, and (3) any spray adjuvant, such as a wetting agent,
spreading agent, deposit builder, adhesive, emulsifying agent, de-flocculating
agent, water modifier, or similar agent with or without toxic properties of its
own intended to be used with any other pesticide as an aid to the application
or effect thereof, whether or not distributed in a package or container separate
from that of the pesticide with which it is to be used, and (4) any other s\ib-
stances intended for such use as may be named by the by regulation after
calling a public hearing for such purpose.
(C) "Insecticide" means any substance or mixture of substances intended to
prevent, destroy, repel, attract, or mitigate any insects which may be present in
any environment whatsoever.
(D) "Fungicide" means any substance or mixture of substances intended to
prevent, destroy, repel, or mitigate any fungi.
(E) "Herbicide" means any substance or mixture of substances intended to
prevent, destroy, repel, or mitigate any weed.
(P) "Defoliant" means any substance or mixture of substances intended to
cause the leaves or foliage to drop from a plant with or without causing
abscission.
(G) "Desiccant" means any substance or mixture of substances intended to
artificially accelerate the drying of plant tissues.
(H) "Plant Regulator" means any substance or mixture of substances intended
through physiological action, to accelerate or retard the rate of growth or matu-
ration, or to otherwise alter the behavior of plants but shall not include sub-
stances insofar as they are intended to be used as plant nutrients, trace elements.
nutritional chemicals, plant inoculants or soil amendments.
(I) "Rodenticide" means any substance or mixture of substances intended to
prevent, destroy, repel, attract, or mitigate rodents or any other vertebrate
animal which the may declare to be a pest
(J) "Nematocdde" means any substance or mixture of substances Intended to
prevent, destroy, repel, or mitigate nematodes.
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(K) "Insect" means any of the numerous small invertebrate animals gen-
erally having the body more or less obviously segmented, for the most part
belonging: to the class insecta. comprising six-legged, usually winged forms, as
for example beetles, bugs, wasps, flies, and to other allied classes of arthropods
whose members im> wingless and usually have more than six legs, as for example
spiders, mites, ticks, centipedes, and wood lice.
(L) "Fungi" means all nonchlorophyll-bearing tallophytes (that is, all non-
chlorophyll-bearing plants of a lower order than mosses and liverworts) as, for
exampe. rusts, smuts, mildews, molds, yeasts and bacteria, except those on or in
living man or other animals.
(M) "Weed" means any plant or part thereof which grows where not wanted.
(N) "Nematode" means invertebrate animals of the phylum nemathelminthes
and class nematoda, that is unsegmented round worms with elongated, fusiform,
or sac-like bodies covered with cuticle, and inhabiting soil, water, plants, or
plant parts ; may also be called nemas or erlworms.
(O) "Snails or slugs" include all harmful mollusks.
(P) ''Person" means any individual, firm, partnership, association, corpora-
tion, company, joint stock association, or body politic, or any organized group of
persons whether incorporated or not; and includes any trustee, receiver, as-
signee, or other similar representative thereof.
(Q) "Equipment" means any type of ground, water or aerial equipment, de-
vice, or contrivance using motorized, mechanical or pressurized power and used
to apply any pesticide on land and anything that may be growing, habitating or
stored on or in such land, but shall not include any pressurized hand-sized house-
hold device used to apply any pesticide or any equipment, device or contrivance
of which the person who is applying the pesticide is the source of power or
energy in making, such pesticide application.
(R) "Restricted use pesticide" means any pesticide, including any highly
toxic pesticide, which the • - has found and determined, subsequent to a
hearing, to be injurious to persons, pollinating insects, bees, animals, crops, or
lands, other than the pests it is intended to prevent, destroy, control, or mitigate.
(S) "Engage in business" means any application of pesticide by any person
upon lands of another.
(T) "Board" means the pesticide advisory board.
(U) "Land" means all land and water areas, including airspace, and all
plants, animals, structures, buildings, devices and contrivances, appurtenant
thereto or situated thereon, fixed or mobile, including any used for transporta-
tion.
(V) "Pesticide Applicator" means any person who owns or manages a pesti-
cicle application business which i« engaged in the business of applying pesticides
upon the Innds of another.
(W) "Pesticide Operator" means any person employed by a pesticide appli-
cator who operates equipment for the application of pesticides or applies pesti-
cides manually. This term does not include employees who work only under di-
rect "on-the-job" supervision of a licensed pesticide applicator or licensed pesti-
cide operator.
(X) "Public Operator" means any person in charge of any equipment used by
state agencies, municipal corporations, public utilities, or other governmental
agencies applying pesticides.
(Y) "Wildlife" means all living things that are neither human, domesticated,
nor, as defined in this Act, pests; including, but not limited to mammals, birds,
and aquatic life.
Section 5. - to Administer and Enforce Act and Adopt Regulations.
(A) The - shall administer and enforce the provisions of this Act and
shall have authority to issue Regulations after a public hearing following dne
notice to all interested persons to carry out the provisions of this Act and in
such Regulations may prescribe methods to be used in the application of pesti-
cides. Where the - finds that such Regulations are necessary to carry out
the purpose and intent of this Act such Regulations may relate to the time,
place, manner, and method of application of the pesticide.1', may restrict or pro-
hibit use of pesticides in designated areas during specified periods of time and
shall encompass all reasonable factors which the -- deems necessary to pre-
vent damage or injury by drift or misapplication to :
(1) Plants, including forage plants, or adjacent or nearby lands ;
(2) Wildlife in the adjoining or nearby areas ;
(3) Fish and other aquatic life in waters in reasonable proximity to the area
to be treated ;
(4) Pollinating insects, animals, or persons.
In issuing such Regulations, the - shall give consideration to pertinent
research findings and recommendations of other agencies of this state or of
the federal government.
may by Regulation require that notice of a proposed application
of a pesticide be given to land owners adjoining the property to be treated or
In the immediate vicinity thereof, if he finds that such notice is necessary to
carry out the purpose of this Act.
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(B) Tho may al*o by Regulation after a public bearing following due
notice adopt a list of ''restricted use pesticides" for the state or for designated
areas within the .state if he finds that the charatceristics of such pesticides re-
quire that Kegulatious restricting their use by any person are necessary to pre-
vent in jury on lands other than the land to which they are applied or to per-
sons, animals, crops, pests or vegetation other than the pests or vegetation which
they are intended to destroy. The may include in the Regulation the
time and conditions of use of such restricted use pesticides and may, if he deems
it necessary to carry out the provisions of this Act. require a permit for each
application of .1 restricted use pesticide. Any order issued under this section
shall be based only upon substantial evidence of record as a whole at the public
hearing.
Section 6. Classification of License. The may classify licenses to be
issued under this Act. Such classifications may include but not be limited to
pest control operators, ornamental or agricultural pesticide applicators, or right
of way pesticide, applicators. Separate classifications may be specified as to
ground, aerial, or manual methods used by any licensee to apply pesticides. Each
classification shall be subject to separate testing procedures and requirements;
PROVIDED. That no person shall be required to pay an additional license fee
if such person desires to be licensed in one or all of the license classifications pro-
vided for by the under the authority of this section.
Section T. Pesticide Applicator's License. No person shall engage in the busi-
.ness of applying pesticides to the lands of another within this state at any time
"without a pesticide applicator's license issued by the . The shall
require an annual fee of 9 for each pesticide applicator's license issued
and in addition an inspection fee of .? for each aircraft to be licensed
and S for each piece of ground equipment to be licensed. Should any
equipment fnil to pass inspection as per Section 1C, making it necessary for a
second inspection to be made, the shall require an added inspection fee
of $ . In addition to the required inspection, unannounced inspections may
be made without charge to determine if equipment is properly calibrated and
maintained in conformance with laws and regulations.
(A) AppJicntion for Pesticide Applicator's License—Form, Content. Applica-
tion for a license shall no made in writing to the on a designated form
obtained from said office. Each application for a license shall contain
information regarding the applicant's qualifications and proposed operations.
license classification or classifications the applicant is applying for, and shall
include the following:
(1) The full name of the person applying for the license:
(2) If the applicant is an individual, receiver, trustee, firm, partnership, asso-
ciation, corporation, or other organized group of persons whether or not incor-
porated, the full name, of each member of the firm or partnership, or the names
of the officers of the association, corporation, or group;
(3) The principal business address of the applicant in the State and elsewhere;
(4) The name and address of a person, who may be the Secretary of State.
whose domicile is in the State, and who is authorized to receive and accept serv-
ices of summons and legal notice of all kinds for the applicant:
(5) The model, make, horsepower, and size of any equipment used by the
applicant to apply pesticides:
(6) Any other necessary information prescribed by the ;
NOTE: Some states may wish to require all non-resident licensees to appoint
a legal resident asent upon whom process may be served, thereby, making such
non-resident amenable to the jurisdiction of the Courts of said" State.
OPTION: "Any non-resident applying for a license under this Act to operate
in the state of shall file a written power of attorney designating the
Secretary of State as the agent of such non-resident upon whom' service/ of
process may be had in the event of any suit against said non-resident person,
and such power of attorney shall be so prepared and in such form as to render
effective the jurisdiction of the Courts of the state of — over such non-
resident applicant. PROVIDED, however, that any such non-resident who has
a duly appointed resident agent upon whom process may be served as provided by
law shall not be required to designate the Secretray of State as such agent. The
Secretary of State shall be allowed such fees therefor las provided by law for
designating resident agents. The shall be furnished with a copy of such
designation of the Secretary of State or of a resident agent, such copy to be duly
certified by the Secretary of State."
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(B) Examination for Pesticide Applicator's License. The shall require
an applicant for a license to show upon examination that he possesses adequate
knowledge concerning the proper use and application of pesticides in the class.-
fications he has applied for, manually or with the various equipment that he
may have applied for a license to operate. The examination shall
(1) The proper use of the equipment.
(2) The hazards that may be involved in applying the pesticides, including:
(a) The effect of drift of the pesticides on adjacent and nearby lands and
other non-target organisms;
(b) The proper meteorological conditions for the application of pesticides
and the precautions to be taken therewith;
(c) The effect of the pesticides on plants or animals in the area, includ-
ing the possibility of damage to plants or animals or the possibility of illegal
pesticide residues resulting on them;
(d) The effect of the application of pesticides to wildlife in the area,
including aquatic life;
(e) The identity and classification of pesticides used and the effects of
their application in particular circumstances;
(f) The likelihood of contamination of water or injury to persons, plants,
livestock, pollinating insects, and vegetation.
(3) Calculating the concentration of pesticides to be used in particular
circumstances.
(4) Identification of common pests to be controlled and the damages caused
by such pests.
(5) Protective clothing and respiratory equipment required during the handl-
ing and application of pesticides.
(6) General precautions to be followed in the disposal of containers as well
as the cleaning and decontamination of the equipment which the applicant pro-
poses to use.
(7) Applicable State and Federal Pesticide Laws and Regulations.
(C) Issue Pesticide Applicator's License. If the finds the applicant
qualified to apply pesticides in the classifications he has applied for and, if the
applicant files the bond or insurance required under Section 13 of this Act, and
if the applicant applying for a license to engage in -aerial application of jx-sticidf s
has met all of the requirements of the Federal Aviation Agency and the Aeronau-
tics Commission of this state to operate the equipment described in the applica-
tion, the shall issue a pesticide applicator license limited to the classi-
fications for which he is qualified, which shall expire at the end of the calendar
year of issue unless it has been revoked or suspended prior thereto by the
for cause.
OPTION: PROVIDED such financial security required under Section 13 of
this Act is not dated to expire at an earlier date, in which case said license
shall 'be dated to expire upon expiration date of said financial security. The
licen.se may restrict the applicant to the use of a certain type or typrs of equip-
ment or pesticides or to certain areas if the finds that the applicant is
qualified to use only such type or types. If a license is not issued as applied for,
the — shall inform the applicant in writing of the reasons therefor.
OPTION SECTION 8. Pesticide Operator's License—Application Date—Fee.
It shall be unlawful for any person to act as an employee of a pesticide applica-
tor and apply pesticides manually or as the operator directly in charge of any
equipment which is licensed or should be licensed under the proviisons of this
chapter for the application of any pesticide, without having obtained an o]x>ra-
tor's license from the . Such an operator's license shall be in addition to
any other license or permit required by law for the operation or use of any
such equipment. Any person applying for such an operator's licence shall file
an application on a form prescribed by the on or boforp January 1 of
each year. Application for a license to apply pesticides shall bf m-companied by
a license fee of $ . The provisions of this subsection shall not apply to
any individual who has passed the examination provided for in Section 7 (It),
and is a licensed pesticide applicator.
If the finds the applicant qualified to apply pesticides in the clas-
sifications he has applied for after examinations as provided for in Section 7(B)
and if the applicant applying for a license to en.srage in aerial applications of
pesticides has met all of the requirements of the Federal Aviation Agency and
the Aeronautics Commission of this state to operate the equipment describwi
in the application, the shall issue a pesticide operator license limited to
the classifications for which he is qualified which shall expire at the end of the
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calendar year of issue unless it has been revoked or suspended prior thereto by
the for cause as provided for in Section 12 of this Act. If a license is
not issued as applied for, the shall inform the applicant in writing of
the reasons therefor.
Ol'TIOX SECTION 9. Application of Act to Governmental Entities—Public
Operator's License acquired—Liability. All state agencies, municipal corpora-
tions, and public utilities or any other governmental agency shall be subject to
the provisions of this Act and rules adopted thereunder concerning the applica-
tion of restricted use pesticides by any person on their own crops or land: PRO-
VIDED, That the public operators in charge of any equipment used by any state
agencies, municipal corporations, public utilities, or any governmental agencies
shall he subject to the provisions of Section 7(B) and Section 8 of the
shall issue a limited license without a fee to such public operators which shall In-
valid only when such public operators are acting as operators on equipment used
by such entities. PROVIDED FURTHER. That government research personnel
shall he exempt from this licensing requirement when applying pesticides to
experimental plots.
I A) Such agencies, municipal corporations, and public utilities shall be subject
to legal recourse by any person damaged by such application of any pe.stic.ide,
and such action may be brought in the county where the damage or some part
thereof occurred.
OPTIOX SECTION' 10. Pent Control Consultant Liccnxc
(A) Definition. As used in this Act, the term "pest control consultant''!shall
mean any person who. for a fee. offers or supplies technical advice, supervision,
aid, or recommends the use of specific pesticides for the purpose of controlling
insect pests, plant diseases, weeds, and other pests.
(B) License, Application, and Fee. No IKTSOII shall perform services as a pest
control consultant without first procuring from the a license in the clas-
sifications he has applied for as per Section C. Application for a license sliall be
on a form prescribed by the and shall include the applicable information
stipulated in Section 7(A). The application for a license shall be accompanied
by an annual fee of S .
(C) Qualifications. Each applicant for a pe«t control consultant's lie-en-v shall
be required to present to the satisfactory evidence of training and expe-
rience providing a basic background to understand pest control principles.
Such applicant shall be required to pass satisfactorily a written examination
to be prescribed by the — or his representative to demonstrate tlu> appli-
cant's speciflc knowledge as per Section 7 (B).
Section It. License Renewal*—Penalty for Delinquent Rcnrical*—Rctcnting.
tf the application for renewal of any license provided for in this chapter is not
filed prior to January 1 in any year, a penalty of twenty-five percent shall be
assessed and added to the original fee and shall be paid by the applicant before
the renewal license sball be issued: PROVIDED. That such penalty shall not
apply if the applicant furnishes an affidavit certifying that he has not engaged
in the business subsequent to the expiration of his license. Any person holding
a current valid license may renew such license for the next year without talcing
another examination unless the v determines that new knowledge related
to classifications for which the applicant has applied makes a new examination
necessary. However, if the license is notVenewed by March 1 of each year then
such licensee shall again be required to t\ke another examination.
Section 72. Ground* for Denial. Suspension, Revocation of Lice-tine. The
many suspend, pending inquiry, for not longer- than ten days, and, after oppor-
tunity for a hearing, may deny, suspend, revoke, or modify the provision of any
license issued under this Act, if he finds that the applicant or licensee has com-
mitted any of the following acts, each of which is declared to be a violation of
this Act:
U) Made false or fraudulent claims through any media, misrepresenting
the effect ;
(2) Made a pesticide recommendation or application not in accordance with
the label registered by USDA and/or a — state registered use or was not
an official recommendation of the state land grant college or university ;
(3) Applied known ineffective or improper materials;
(4) Operated faulty or unsafe equipment;
(5) Operated in a faulty, careless, or negligent manner;
(6) Refused or, after notice, neglected to comply with the provisions of this
Act, the rules adopted hereunder, or of any lawful order of the ;
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(7) Refused or neglected to keep and maintain the records required by this
chapter, or to make reports when and as required;
(8) Made false or fraudulent records, invoices, or reports;
(9) Engaged in the business of the application of a pesticide without having
a licensed applicator or operator in direct "on-the-job" supervision.
(10) Operated unlicensed equipment.
(11) Used fraud or misrepresentation in making an application for a license
or renewal of a license;
(12) Refused or neglected to comply with any limitations or restrictions on
or in a duly issued license or permit.
(13) Aided or abetted a licensed or an unlicensed person to evade the pro-
visions of this chapter, combined or conspired with such a licensed or an un-
licensed person to evade the provisions of this chapter, or allowed one's license
to be used by an unlicensed person;
(14) Made false or misleading statements during or after an inspection con-
cerning any infestation or infection of pests found on land; or
(15) Impersonated any state, county, or city inspector or official.
Section 13. Surety Jiond or Insurance Required of Pesticide Applicator Li-
censee. The shall not issue a pesticide applicator's license until the appli-
cant has furnished evidence of financial responsibility with the consisting
either of who may suffer legal damages as a result of the operations of the ap-
plicant: PROVIDED, That such surety bond or liability insurance policy need
not apply to damages or injury to agricultural crops, plants or land being worked
upon by the applicant.
(A) Amount of Bond or Insurance Required—Notice of Reduction or Can-
cellation by Surety or Insurer. The amount of the surety bond or liability in-
surance as provided for in this section shall be not less than $ for property
damage and public liability insurance, each separately, and including loss or
damage arising out of the actual use of any pesticide. Such surety bond or liability
insurance shall be maintained at not less than that sum at all times during the
licensed period. The shall be notified ten days prior to any reduction at
the request of the applicant or cancellation of such surety bond or liability insur-
ance by the surety or insurer: PROVIDED, That the toial and aggregate of the
surety and insurer for all claims shall be limited to the face of the bond or
liability insurance policy; PROVIDED, FURTHER, That the may accept
a liability insurance policy or surety bond in the proper sum which has a deduc-
tible clause in an amount not exceeding $ for aerial applicators and $
for all other applicators for the total amount of liability insurance or surety
bond required herein: AND PROVIDED FURTHER, That if the applicant has
not satisfied the requirement of the deductible amount in any prior legal claim
such deductible clause shall not be accepted by the unless such applicant
furnishes the with a surety bond or liability insurance which shall satisfy
the amount of the deductible as to all claims that may arise in his application of
pesticides.
(B) Cancellatiton of License when Bond or Insurance Reduced Below Mini-
mum Requirements. Should the surety furnished become unsatisfactory, said
applicant shall upon notice execute a new bond or insurance and shall he fail
to do so, the shall cancel his license and give him notice of said fact and
it shall be unlawful thereafter for such person to engage in said business of
applying pesticides until the bond or insurance is brought into compliance with
the requirements of Section 13 (A) and his license is reinstated by the •.
(C) Personal Liability for Damage. Nothing in this Act shall be construed to
relieve any person from liability for any damage to the person or lands of another
caused by the use of pesticides even though such use conforms to the rules and
regulations of the .
flection 14, Damaged Person Must File Report of Loss—Contents—Time for
Filing—Effect of Failure to File. The person claiming damages from pesticide
application shall have filed with the a written statement claiming that he
has bppn dnmaged, on .1 form prescribed by the within sixty (CO) dnys
after the date that damages occurred, or prior to the time that twenty-five (25)
percent of a crop damaged shall have been harvested. Such statement shall con-
tain, but shall not be limited thereto, the name of the person responsible for (he
application of said pesticide, the name of the owner or lessee of the land on which
the crop is grown and for which damages are claimed and the dnte on which it is
alleged that the damage occurred. The shall prepare a form to be furnished
to persons to be used in such cases and such form shall contain such other re-
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quirement as the may deem proper. The shall, upon receipt of such
statement, notify tho licensee :mU the owner or lessee of the laud or other person
who may he charged with the responsibility, for the damages claimed, and
furnish copies of such statements as may be repuested.
The filing of such report or the failure to file such a report need not he alleged
in any complaint which might be filed in a court of law, and the failure to file the
report shall not be considered any bar to the maintenance of any criminal or
civil action.
The failure to file such a report shall not be a violation of this Act. However,
if the person failing to lile such report is the only one injured from such use or
application of a pesticide by others, the may, when in the public interest,
refuse to hold a hearing for the denial, suspension, or revocation of a license or
permit issued under this Act until such report is filed.
Where damage is alleged to have been done, the claimant shall permit the li-
censee and his representatives, such as bondsman or insurer to observe within
reasonable hours the lands or non-target organism alleged to have been damaged
in order that such damage may be examined. Failure of the claimant to penult
such observation and examination of the damaged lands shall automatically bar
the claim against the licensee.
Section /o. Licensers to Keep Records—Duration—Submission* to . The
shall require licensees to maintain records with respect to applications of
ppslicidfs. Such relevant information as the may deem necessary may
be specified by regulation. Such records shall be kept for a period of
years from the date of the application of the pesticide to which such records
refer, and the shall, upon request in writing, be furnished with a copy
of such records forthwith by the licensee.
Section 16. J-nspcefion of Equipment. The may provide for inspection of
any equipment used for application of pesticides and may require repairs or other
changes before its further nse for pesticide application. A list of requirements that
equipment shall meet may be adopted by regulation.
Option Section 1~. License Plates lor Equipment. All licensed equipment shall
he identified by a license plate or decal furnished by the , at no cost to the
licensee, which plate shall be affixed in a location and manner upon such equip-
ment as prescribed by the .
Option Section IS. Reciprocal Agreement. The may issue a license on a
reciprocal basis with other states without examination to a non-resident who is
licensed in another state substantially in accordance with the provisions of this
Act; Provided, That financial security as provided for in Section 13 of this Act
is met.
Section 1!). Exemptions.
Option (A.) Fanner Exemption. The provisions of this Act relating to licenses
and requirements for their issuance shall not apply to any farmer owner of
ground equipment applying pesticides for himself or his farmer neighbors;
PROVIDED. That
1. He operates farm property and operates and maintains pesticide applica-
tion equipment primarily for his own use.
2. He is not regularly engaged in the business of applying pesticides for hire
amounting to a principal or regular occupation and that he shall not publicly
hold himself out as a pesticide applicator.
3. He operates his pesticide application equipment only in the vicinity of his
own property and for the accommodation of his neighbors.
OPTION (R) Landscape Gardener Exemption. The provisions of this Act shall
not apply to any person using hand-pcwered equipment, devices, or contrivances
to apply pesticides to lawns, or to ornamental shrubs and trees not in excess
of twelve feet high, as an incidental part of his business of taking care of house-
hold lawns and yards for remunerations: PROVIDED, That such person shall
not publicly hold himself out as being in the business of applying pesticides.
OPTIOX (C) PCO Exemption. (NOTE: The following exemption should be
used only if another statute regulates this classification.) This Act shall not apply
to persons applying pesticides only to prevent, destroy, repel, or mitigate insects
or fungi within or under buildings or within vehicles, ships, aircraft, or other
means of transporting persons or property by land, water, or air.
Section 20. Discarding and Storing of Pesticides and Pesticide Containers. Xo
person shall discard or store any pesticide or pesticide containers in such a man-
ner as to cause injury to humans, vegetation, crops, livestock, wildlife, pollinating
insects or to pollute any waterway in a way harmful to any wildlife therein. The
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may promulgate rules and regulations governing the discarding and storing
of such pesticides or pesticide containers.
OPTION KRCTION 21. Pexticide Advisory Board—Composition, Terms. There
is hereby created a pesticide advisory board consisting of three licensed pesticide
applicators residing in the state, one shall be licensed to operate ground equip-
ment, one shall be licensed to operate aerial equipment, and one shall be licensed
for structural pest control; one entomologist in public service; one environmental
health specialist from the state department of health; one toxicologist in
public service; one plant pathologist in public service; one member from the agri-
cultural chemical industry; one member from the food processing industry; two
producers of agricultural crops or products on which pesticides are applied or
which may be affected by the application of pesticides; one representative of
the state department of agriculture; and one representative of the
state agency responsible for the protection of fish and wildlife. Such mem-
bers shall be appointed -by the governor for terms of four years and may be ap-
pointed for successive four year terms at the discretion of the governor. The
governor may remove any member of the board prior to the expiration of his
term of appointment for cause: PROVIDED. That at the inception of this chap-
ter the governor shall appoint four members, which shall not include two mem-
bers from any one representative group for a period of two years: four members
for a period of three years which shall not include two members from any one
representative group; and five members for a period of four years which shall not
include two members from any one representative group. All subsequent terms for
appointments to such board shall be for a period of four years.
(A) Vacancies. Upon the death, resignation, or removal for cause of any mem
ber of the board, the governor shall fill such vacancy, within thirty days of its
creation, for the remainder of its term in the manner herein prescribed for
appointment to the board.
(B) General Powers and Duties. The board shall advise the on any or
all problems relating to the use and application of pesticides in the state.
(C) Officers—Meetings. The board shall elect one of its members chairman.
The members of the board shall meet at such time and at such place as shall be
specified by the call of the . chairman, or a majority of the board.
Section 22. Legal Recourse. Any person aggrieved by any action of the
may obtain a review thereof by filing in the court within thirty (30) days
of notice of the action a written petition praying that the action of the be
set aside. A copy of such petition shall forthwith be delivered to the , and
within days thereafter the shall certify and file in the court a trans-
cript of any record pertaining thereto, including a transcript of evidence received.
whereupon the court shall have jurisdiction to affirm, set aside or modify the
action of the — , except that the findings of the as to the facts, if
sunported by substantial evidence, shall be conclusive.
Section 23. Information. The may, in cooperation with the Land Grant
College (University) publish information and conduct short courses of instruc-
tion in the safe use and application of pesticides.
Section m. Penalty. Any person violating the provisions of this Act or the
Regulations issued hereunder shall be guilty of a misdemeanor. (The amount of
the fine or term of imprisonment per penalty will depend on the situation in the
state concerned.)
Section 25. Subpoenas. The may issue subpoenas to compel the attend-
ance of witnesses and/or production of books, documents, and records anywhere
in the state in any hearing affecting the authority or privilege granted by a license
or permit issued under the provisions of this Act.
Section 2G. Enforcement. For the purpose of carrying out the provisions of this
Act the may enter upon any public or private premises at reasonable times.
in order:
(1) To have net-ess for the purpose of inspecting any equipment subject to
this Act and such premises on which such equipment is kept or stored: or
(2) To inspect lands actually or reported to be exposed to pesticides; or
(3) To inspect storage or disposal a reas; or
(4) To inspect or investigate complaints of injury to humans or land; or
(5) To simple pesticides being applied or to be applied.
Should the be denied access to any land where such access was
sought for the purposes set forth in this Act, he may apply to any court of
competent jurisdiction for a search warrant authorizing access to such land
for said purposes. The court may upon such application, issue the search
warrant for the purposes requested.
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An Act relating to the application of insecticides, fungicides, herbicides,
defoliants, desk-cants, plain growth regulators, nomatoeides and any other
pesticides by aircraft or ground equipment, or manually in the state of
be it enacted by the legislature of tin: L'luteof -"
I.NTERI'KKTIVE STATEMENT
Background
The "Model Pesticide Use and Application Act" has been developed te update
and expand the 1051 act entitled "An Act Relating to the Application of Insec-
ticides, Fungicides, and Herbicides by Aircraft or Ground Equipment." This
redrafting project was undertaken by the Association of American Pesticide
Control Ollicial.s, whose members are responsible for enforcing such state laws.
In addition to review by state officials, this proposal has been studied and
amended by other interested parties such as the National Agricultural Chemi-
cals Association, National Aerial Applicators Association, United States Depart-
ment of Agriculture, Food & Drug Administration, and National Association
of State Directors of Agriculture. The authority provided in this act is in
addition to, and coordinated with, the responsibilities of the "Uniform State
Insecticide, Fungicide, and Rodenticide Act."
Problem
There is increasing need for enabling legislation that provides broad authority
at state level to regulate the application and use of pesticides. The gap in
responsibility between the Pesticide Regulations Division's federally registered
label for a pesticide formulation intended for interstate shipment and the Food &
Drug Administration's sampling and analyzing of feed and food following harvest
is continually increasing.
Historically, enactment of such laws has been within the realm of state regu-
latory responsibility. Effective control of pesticide usage can only be administered
at the local level due to tiie differences between and within states in the size and
type of agriculture, the seriousness of pest control problems, population, existing
laws, climate, and other environmental and ecological factors. Although there are
advantages to uniformity, it is apparent that model enabling legislation must be
flexible enough to allow for differing regulations, appropriate for each area with
its problems and particular needs.
Only through efficient management of pesticide usage will we be able to mini-
mize the incidents of misuse that can result in the banning of chemicals essential
for controlling pests. Approximately twenty states have no laws regulating the
use of pesticides and many of the laws enacted have limited authority. Roth the
Mrak Committee, commissioned by HEW, and the t'SDA have recommended that
states enact more comprehensive legislation and implement improved programs to
regulate pesticide usage.
Explanation
Each proposal in this act has been enacted by at least one state legislature and
has been successfully administered. While the act provides adequate authority to
protect the general public, it is reasonable and should be acceptable to state legis-
lators, growers, and the pesticide application industry. It was drafted so that
certain options could be enacted or omitted without impairing the basic continuity
of the act.
Of particular importance, this new act expands authority over the 1951 act
to:
1. Declare certain pesticides "restricted use pesticides" when the administra-
tive agency finds that the characteristics of the pesticide require additional
restrictions which may include permits for application. These restrictions apply
to growers and home owners as well as commercial applicators covered under
the prior bill.
2. To license and test commercial pesticide operators (employees) as well as
the applicator (owner or manager).
3. To license and test public operators (employees of state agencies, municipal
corporations, and public utilities).
4. To license and test "pest control consultants"; persons who tor a fee supply
technical advice, supervision, or recommend the use of specific pesticides.
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5. Establish a Pesticide Advisory Board. The makeup of this board might vary
in different states but the intent is that the board advise the administrative
agency rather than control the administrative agency, such as is suggesed in the
Model Pesticide Control Act, proposed by the Environmental Defense Fund.
6. Cover pesticide applications applied manually as well as those applied with
licensed aerial or ground equipment.
EKRETT DECK,
Chairman, Model Pesticide Use & Application Bill Committee, Association
of American Pesticide Control Officials.
(The proposed amendments are as follows:)
PROPOSED AMENDMENT SO. 1
Add the words underlined in Sec. 4(d)(2) lines IS et. seq., "As used in this
subsection, the term "approved pesticide applicator" means any person who uses
any pesticide for any purpose specified in subsection 2(a) of this Act and (a)
who has a license or certificate of competence issued by the state in which such
operations are conducted..."
PROPOSED AMENDMENT NO. 2
Add the words underlined in Sec. 4(d) (3) lines 21 et. seq., "As used in this
subsection, the term "approved pest management consultant" means any person
who has a license or certificate of competence issued by n state . . ."
PROPOSED AMENDMENT NO. 3
Add Subsection 9(f) as follows:
"TJtc administrator may require that all -warehouse*, carriers, distributors,
and dealers handling pesticides registered- for "restricted use" or "for use by
permit only" register with an appropriate agency of slate government or with
the administrator."
PROPOSED AMENDMENT NO. 4
Amend Section 16(a) by adding the words underlined as follows:
"All authority vested in the administrator by virtue of provisions of this Act
may with like force and effect be executed by such employes of the Environmental
Protection Agency or an agency of state or local government with which a con-
tract as specified in subsection 16(c) is in effect as the administrator may desig-
nate for the purpose.
PROPOSED AMENDMENT NO. 5
Add Subsection 16(c) as follows:
'•The administrator is further authorized to enter into contracts with federal,
state, or local agencies to carry out the field inspection and laboratory analyses
of pesticides, the residue monitoring programs, and the inspection of operation*
carried out by approved pesticide applicators, or approved pesticide consultants
vnder the provisions of this Act."
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The federal regulation of pesticides operates under
the Federal Insecticide, Fungicide and Rodenticide Act
(FIFRA), enacted in 1947 and amended in 1959, 1961 and 1964.
The law uses the term "economic poisons" to include: (1)
"any substance or mixture of substances intended for pre-
venting, destroying, repelling, or mitigating any insects,
rodents, nematodes, fungi, weeds, and other forms of plant
or animal life or viruses, except viruses on or in living
man or animals," and (2) "any substance or mixture of
substances intended for use as a plant regulator, defoliant
or desiccant." The act prohibits the interstate or inter-
national shipment of economic poisons unless they: are
registered pursuant to provisions of Section 4 of the act,
are in unbroken immediate containers, and are labeled
according to the provisions of the act. Authorities under
the act were assigned to the Secretary of the Department
of Agriculture and have since been transferred to the Admin-
istrator of the Environmental Protection Agency. The act
defines the process of registration and provides the mechanisms
by which the Administrator may refuse registration of an
economic poison or may cancel a registration. In the event
of a refusal or a cancellation of a registration, the appli-
cant or registrant has several courses of appeal opened to
him. These include the referral of the matter to an advisory
committee or the holding of a public hearing. If the
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applicant requests the referral to an advisory committee,
he has 30 days in which to make such a request. Thereafter,
the Administrator shall convene such advisory committee and
the committee has at least 60 days, and can have as many as
120 days, in which to file its findings with the Administrator.
The Administrator then has an additional 90 days to consider
the report and recommendations of the advisory committee and
make his determination. The applicant, thereafter, has an
additional 60 days from date of the order of the Administrator
to file objections and request a public hearing. The
Administrator shall, "after due notice," hold such public
hearing for receiving evidence relevant and material to the
issues raised by such objections. Not later than 90 days
after the hearing, the Administrator shall issue an order
based on the evidence of the hearing, including recommendations,
underlying data and reasons. Even after this lengthy procedure,
the applicant has within 60 days of the issue of such an
order the opportunity to file an appeal with the United
States Court of Appeals.
In the event of a cancellation of a registration, the
registrant may continue to sell his product during this
period of appeals. Should the Administrator find that an
imminent hazard to the public would exist, he may suspend the
registration of an economic poison immediately.
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Any person who distributes, sells or offers for sale
in interstate commerce an economic poison which is not
registered, or which is not in the unbroken labeled container,
or that is not properly labeled, or is in any fashion adulterated
or misbranded, is guilty of a misdemeanor and on conviction
can be fined not more than $1,000.
New Federal Legislation
During 1971, Congress has considered legislation to
amend or replace FIFRA. At least eight different bills
dealing with pesticides were introduced in the House of
Representatives. The primary one was H. R. 4152. In the
Senate four bills have been under consideration, two of
which (S. 600 and S. 745) would - like H. R. 4152 -
replace the present FIFRA. The other bills would either
prohibit the sale of DDT or prohibit the sale of aldrin,
chlordane, DDD/TDE, dieldrin, endrin, heptachlor, lindane,
and toxaphene. The fate of any legislation in the Congress
is to be considered uncertain until enacted by both Houses
and sent to the President. H. R. 10729, the Committee re-
write of H. R. 4152, was enacted by the House in the first
session of the 92nd Congress. There is strong expectation
that Senate action in the 1972 session will result in
enactment of a new FIFRA very similar to H. R. 10729.
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H. R. 10729 was originally an Administration bill. It
incorporates many of the provisions of the existing law
(FIFRA), but goes well beyond it in the federal regulation
of intrastate as well as interstate activities, including
registration of pesticides in intrastate commerce. It
provides for the classification of pesticides as to:
(a) "general use" or (b) "restricted use." The original
versions had a third category of "use by permit only." It
also provides for the certification of pesticide applicators.
This is particularly pertinent in the context of pesticides
registered for restricted use only. It provides for aid and
guidance to states in developing training programs for
pesticide applicators and for the certification of individuals
entitled to use restricted pesticides.
The bill also substantially increases the enforcement
powers of the federal agency. They provide authority to
stop sale, use, or removal, extend the authority of seizure
to intrastate shipments, and greatly increase the assigned
penalties. There are provisions for criminal misdemeanor
and for civil penalties, one of which is far greater than
those of FIFRA. These include not only the registrant,
wholesaler, dealer, retailer, or other distributor, but
also the commercial pesticide applicator whose liability is
in the same range as the commercial group previously cited.
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In addition, there are now provisions for penalties of the
private pesticide applicator. This can include the farmer
who "knowingly violates any provision of this Act." In
speaking to the authority of the states with respect to
pesticides, the legislation provides that a state may regulate
the sale or use of any pesticide or device in the state,
but only if and to the extent the regulation does not permit
any sale or use prohibited by the Act. Similarly, the state
is not allowed to impose requirements for labeling and
packaging in addition to or different from those required
under the Act. There is a provision, however, for the state
to assist the Administrator in the registration of pesticides
formulated for intrastate distribution to meet specific
local needs.
Impact of the Pending Legislation
A sampling of views from Congressional offices for the
five study states of Minnesota, Illinois, Iowa, Missouri,
and Kansas showed a general uniformity in rationale for and
expected impact from the legislation. There was a consistent
'view that the pesticide control legislation was an integral
part of the overall efforts at more effective pollution
control. Constructive effects of the legislation in this
respect were seen as including improved control of the prac-
tices of both commercial applicators and private applicators
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to prevent the use of excessive amounts of pesticides or
the careless application with resultant contamination of
adjacent areas and streams; more effective control in the
handling of pesticide containers; reduction in on-site
storage of pesticides; and more effective control over the
disposition of stocks of pesticides subject to recall on
order of the Administrator.
It was noted that this Congressional support represented
a response to please state officials for a national pattern
of minimum standards on pesticide management. The bill, as
finally enacted by the House, does not restrict a state
from imposing more strict controls over pesticide products
found to be particularly hazardous or unacceptable for use
in that particular state.
There seemed to be a general concurrence from the
farm community on the need for legislation of this general
nature. On the whole, the Congressional offices reported
very little reaction from constituents in their districts.
Mail or other communication they received expressed approval
for passage of the legislation. One office reported comments
that the uniform national legislation was long overdue.
It should be noted that the contractor's own survey
of farmers and agents in the five-state area strongly
reinforces these views. Farmers and agents generally saw the
need for some kind of legislation but most were afraid that
23-H
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the intended bill or some variation of it, was designed to
"take away all pesticides." They were, of course, distressed
by this prospect. Clearly, an informational gap existed
(exists) here. Farmers by and large demonstrated a real
awareness of the problems unrestricted pesticide use could
bring and further indicated a keen sense of environmental
awareness. However, it should be pointed out that very
few saw their individual acts as a part of a global picture
of pesticide accumulation and contamination. The greatest
opposition, as might have been suspected, came from some
retailers who were also applicators and some commercial
applicators - both saw impending legislation as entirely
too restrictive upon them and without foundation. In defense
of an equally large number of commercial applicators who
honestly try to perform a service for farmers, it can be
said that many are conscientious, dedicated entrepeneurs who
dislike being blamed for the carelessness of others.
The contractor received numerous comments about un-
scrupulous activities of a minority of operators who crossed
and recrossed state lines without proper authority, spraying
from unlabeled bags of unidentified materials and moving on.
Farmers and agents alike seemed aware of these practices and
the more responsible ones condemned them. The provisions
of the new bill (10729) specifically cover such activities
and aside from the educational benefits and cost savings to
farmers resulting from more efficient use, provide such
24-H
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penalties as to make clandestine activities quite unpro-
fitable if apprehended.
Several of the Congressional offices stressed the anti-
cipated role of the Department of Agriculture and, in
particular, the Federal-State-County system of agricultural
extension agents in the education of farmers on more
effective use of pesticides. The Department of Agriculture
was reported as committing itself to a major effort in
preparing the farmers who will seek certification as
private applicators for the use of restricted category
pesticides. Numerous side benefits, in terms of more
efficient use of agricultural chemicals, are anticipated
from this effort. Also stressed was the intent to stimulate
greater efforts on alternative methods of control. The
research support provisions in the legislation were
specifically pointed out in this context.
With respect to the potential impact of the legislation
on state programs, each office seemed to feel that the
legislation in no way diminished the role of the states in
pesticide control. It was pointed out that the states play
a major role in the agricultural extension service and, thus,
would have major responsibilities with respect to the
certification of pesticide applicators. Beyond this, the
nature of any modification that might be called for will be
better determined when the program has been implemented and
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FEDERAL INSECTICIDE, FUNGICIDE, AND RODENTICIDE ACT
(7U.S.C. 13S-135k)
Approved June 25, 1947 (61 Stat. 163) as amended by the
Nematocide, Plant Regulator, Defoliant, and Desiccant
Amendment of 1959 (73 Stat. 286) as amended by the Act
of March 29, 1961 (75 Stat. 18) snd the Act of April 7,
1961 (75 Stat. 42) and the Act of May 12, 1964 (P.L
88-305,78 Stat. 190)
An Act to regulate the marketing of economic poisons and
devices, and for other purposes
Be it enacted by the Senate and House of Representa-
tives of the United States of America in Congress as-
sembled.
Title
Sec. 1. This Act may be cited as the "Federal Insecti-
cide, Fungicide, and Rodenticide Act."
Definitions
Sec. 2 For the purposes of this Act-
a. The term "economic poison" means (1) any substance
or mixtures of substances intended for preventing, destroy-
ing, repelling, or mitigating any insects, rodents, nematodes,
fungi, weeds, and other forms of plant or animal life or
viruses, except viruses on or in living man or other animals,
which the Secretary shall declare to be a pest, and (2) any
substance or mixture of substances intended for use as a
plant regulator, defoliant or desiccant.
b. The term "device" means any instrument or contriv-
ance intended for trapping, destroying, repelling, or mitigat-
ing insects or rodents or destroying, repelling, or mitigating
fungi, nematodes, or such other pests as may be designated
by the Secretary, but not including equipment used for the
application of economic poisons when sold separately
therefrom.
c. The term "insecticide" means any substance or
mixture of substances intended for preventing, destroying,
repelling or mitigating any insects which may be present in
any environment whatsoever.
d. The term "fungicide" means any substance or mix-
ture of substances intended for preventing, destroying,
repelling, or mitigating any fungi.
e. The term "rodcnticidc" means any substance or
mixture of substances intended for preventing, destroying,
repelling, or mitigating rodents or any other vertebrate
animal which the Secretary shall declare to be a pest.
f. The term "herbicide" means any substance or mixture
of substances intended for preventing, destroying, repelling,
or mitigating any weed.
g. The term "Nematocide" means any substance or
mixture of substances intended for preventing, destroying,
repelling, or mitigating nematodes.
h. The term "plant regulator" means any substance or
mixture of substances intended through physiological
action, for accelerating or retarding the rate of growth or
rate of maturation, or for otherwise altering the behavior of
ornamental or crop plants or the produce thereof, but shall
not include substances to the extent that they are intended
as plant nutrients, trace elements, nutritional chemicals,
plant inoculants, and soil amendments.
i. The term "defoliant" means any substance or mixture
of substances intended for causing the leaves or foliage to
drop from a plant, with or without causing abscission.
j The term "desiccant" means any substance or mixture
of substances intended for artificially accelerating the
drying of plant tissue.
k. The term "nematode" means invertebrate animals of
the phylum nemathclminthes and class nematoda. that is,
unsegmentcd round worms with elongated, fusiform, or
saclike bodies covered with cuticle, and inhabiting soil,
water, plants or plant parts; may also be called nemas or
eclworms.
I. The term "weed" means any plant which grows where
not wanted.
m. The term "insect" means any of the numerous small
invertebrate animals generally having the body more or less
obviously segmented, for the most part belonging to the
class insecta, comprising six-legged, usually winged forms.
as, for example, beetles, bugs, bees, (lies, and to other allied
classes of arthropods whose members are wingless and
usually have more than six legs, as, for example, spiders,
mites, ticks, centipedes, and wood lice.
n. The term "fungi" means all non-chlorophyll-bearing
thallophytes (that is, all non-chlorcphyll-bearing plants of a
lower order than moscs and liverworts) as, for example,
rusts, smuts, mildews, molds, yeasts, and bacteria, except
those on or in living man or other animals.
o. The term "ingredient statement" means either—
(1) a statement of the name and percentage of each
active ingredient 'ogether with the total percentage
of the inert ingredients, in the economic poison; or
(2) a statement of the name of each active ingredient,
together with the name of each and total percentage
of the inert ingredients, if any there be, in the
economic poison (except option 1 shall apply if the
preparation is highly toxic to man, determined as
provided in section 6 of this Act); and, in addition
to (1) or (2) in case the economic poison contains
arsenic in any form, a statement of the percentages
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of total and water soluble arsenic, each calculated as
elemental arsenic.
p. The term "active ingredient" means-
(1) in the case of an economic poison other than a
plant regulator, defoliant or desiccant, an ingredient
which will prevent, destroy, repel, or mitigate
insects, nematodcs, fungi, rodents, weeds, or other
pests:
(2) in the case of a plant regulator, an ingredient
which, through physiological action, will accelerate
or retard the rate of growth or rate of maturation or
otherwise alter the behavior or ornamental or crop
plants of the produce thereof:
(3) in the case of a defoliant, an ingredient which will
cause the leaves or foliage to drop from a plant;
(4) in the case of a desiccant, an ingredient which will
artificially accelerate the drying of plant tissue.
q. The term "inert ingredient" means an ingredient
which is not active.
r. The term "antidote" means a practical immediate
treatment in case of poisoning and includes first-aid
treatment.
s. The term "person" means any individual, partnership,
association, corporation or any organized group of persons
whether incorporated or not.
t. The term "Territory" means any Territory or posses-
sion of the United Stoles, excluding the Canal Zone.
u. The term "Secretary" means the Secretary of Agri-
culture.
v. The term "registrant" means the person registering
any economic poison pursuant to the provisions of this Act.
w. The term "label" means the written, printed, or
graphic matter on, or attached to, the economic poison or
device or the immediate container thereof, and the outside
container or wrapper of the retail package, if any there be,
of the economic poison or device.
x. The term "labeling" means all labels and other
written, printed, or graphic matter-
(1) upon the economic poison or device of any of its
containers or wrappers;
(2) accompanying the economic poison or device at
any time;
(3) to which reference is made on the label or in
literature accompanying the economic poison or
device, except to current official publications of the
United States Department of Agriculture and In-
terior, the United States Public Health Service,
State experiment stations, State agricultural
colleges, and other similar Federal or State institu-
tions or agencies authorized by law to conduct
research in the field of economic poisons.
y. The term "adulterated" shall apply to any economic
poison if its strength or purity falls below the professed
Standard of quality as expressed on its labeling or under
which it is sold, or if any substance has been substituted
wholly or in part for the article, or if any valuable
constituent of the article has been wholly or in part
abstracted.
z. The term "misbrandcd" shall apply-
(I) to any economic poison or device if its labeling
bears any statement, design, or graphic representa-
tion relative thereto or to its ingredients which is
false or misleading in any particular;
(2) to any economic poison-
fa) if it is an imitation of or is offered for sale under
the name of another economic poison;
(b) if its labeling bears any reference to registration
under this Act other than the registration number
assigned to the economic poison;
(c) if the labeling accompanying it does not contain
directions for use which are necessary and if
complied with adequate for the protection of the
public;
(d) if the label does not contain a warning or caution
statement which may be necessary and if complied
with adequate to prevent injury to living man and
other vertebrate animals, vegetation, and useful
invertebrate animals;
(e) if the label docs not bear an ingredient statement
on that part of the immediate container and on the
outside container or wrapper, if there be one,
through which the ingredient statement on the
immediate container cannot be clearly read, of the
retail package which is presented or displayed under
customary conditions of purchase: Provided That
the Secretary may permit the ingredient statement
to appear prominently on some other part of the
container, if the size or form of the container
makes it impracticable to place it on the part of the
retail package which is presented or displayed under
customary conditions of purchase;
(Q if any word, statement, or other information
required by or under authority of this Act to appear
on the label or labeling is not prominently placed
thereon with such conspicuousness (as compared
with other words, statements, designs, or graphic
matter in the labeling) and in such terms as to
render it likely to be read and understood by the
ordinary individual under customary conditions or
purchase and use;
(g) if in the case of insecticide, nematocide, fungicide,
or herbicide when used as directed or in accordance
with commonly recognized practice it shall be
injurious to living man or other vertebrate animals,
or vegetation, except weeds, to which it is applied,
or to the person applying such economic poison; or
(h) if in the case of a plant regulator, defoliant, or
desiccant when used as directed it shall be injurious
to living man or other vertebrate animals, or
vegetation to which it is applied, or to the person
applying such economic poison: Provided, That
physical or physiological effects on plants or parts
thereof shall not be deemed to be injury, when this
is the purpose for which thp plant regulator,
defoliant, or desiccant was applied, in accordance
with the label claims and recommendations.
Prohibited Acts
Sec. 3. a. It shall be unlawful for any person to
distribute, sell, or offer for sale in any Territory or in the
District of Columbia, or to ship or deliver for shipment
from any State, Territory, or the District of Columbia to
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•ny other State, Terrilory, or Ihc District of Columbia, or
to any foreign country, or to receive in any State,
Territory, or the District of Columbia from any other State,
Territory, or the District of Columbia, or foreign country,
and having so received, deliver or offer to deliver in the
original unbroken package to any other person, any of the
following:
(I) Any economic poison which is not registered
pursuant to the provisions of section 4 of this Act,
or any economic poison if any of the claims made
for it or any of the directions for its use differ in
substance from the representations made in con-
nection with its registration, or if the composition
of an economic poison differs from its composition
as represented in connection with its registration:
Provided, That in the discretion of the Secretary, a
change in the labeling or formula of an economic
poison may be made within a registration period
without requiring rercgistration of the product.
(2) Any economic poison unless it is in the regis-
trant's or the manufacturer's unbroken immediate
container, and (here is affixed to such container,
and to the outside container or wrapper of the retail
package, if there be one, through which the
required information on the immediate container
cannot be clearly read, a label bearing-
(a) the name and address of the manufacturer, regis-
trant, or person for whom manufactured;
(b) the name, brand, or trade-mark under which said
article is sold;
(c) the net weight or measure of the content: Pro-
vided, That the Secretary may permit reasonable
variations; and
(d) when required by regulation of the Secretary to
effectuate the purposes of this Act, the registration
number assigned to the article under this Act.
(3) Any economic poison which contains any sub-
stance or substances in quantities highly toxic to
man, determined as provided in section 6 of this
Act, unless the label bear, in addition to any other
matter required by this Act-
(a) the skull and crossbones;
(b) the word "poison" prominently (IN RED) on a
background of distinctly contrasting color; and
(c) a statement of an antidote of the economic
poison.
(4) The economic poisons commonly known as stand-
ard lead arsenate, baisc lead arscnate, calcium
arsenate, magnesium arsenate, zinc arscnate, zinc
arscnite, sodium fluoride, sodium flousilicatc, and
barium fluosilicate unless they have been distinctly
colored or discolored as provided by .regulations
issued in accordance with this Act, or any other
white powder economic poison which the Secre-
tary, after investigation of and after public hearing
on the necessity for such action for the protection
of the public health and the feasibility of such
coloration or discoloration, shall, by regulation,
require to be distinctly colored or discolored, unless
it has been so colored or discolored: Provided, That
the Secretary may exempt any economic poison to
the extent that it is intended for a particular use or
uses from the coloring or discoloring required or
authorized by this section if he determines that
such coloring or discoloring for such use or uses is
not necessary for the protection of the public
health.
(5) Any economic poison which is adulterated or
misbranded or any device which is misbranded.
b. Notwithstanding any other provisions of this Act, no
article shall be deemed in violation of this Act when
intended solely for export to any foreign country and
prepared or packed according to the specifications or
directions of the foreign purchaser.
c. It shall be unlawful-
(1) for any person to detach, alter, deface, or destroy,
in whole or in part, any label or labeling provided
for in this Act or the rules and regulations promul-
gated hereunder, or to add any substance to, or take
any substance from an economic poison in a
manner that may defeat the purpose of this Act;
(2) for any manufacturer, distributor, dealer, carrier,
or other person to refuse, upon a request in writing
specifying the nature or kind of economic poison or
device to which sucli request relates, lo furnish to
or permit any person designated by the Secretary to
have access to and to copy such records as
authorized by section 5 of this Act:
(3) for any person to give a guaranty or undertaking
provided for in section 7 which is false in any
particular, except that a person who receives and
relics upon a guaranty authorized under section 7
may give a guaranty lo the same effect, which
guaranty shall contain in addition to his own name
and address the name and address of the person
residing in the United States from whom he
received the guaranty or undertaking; and
(4) for any person to use for his own advantage or to
reveal, other than to the Secretary, or officials or
employees of the United States Department of
Agriculture or other Federal agencies, or to' the
courts in response to a subpoena, or to physicians,
and in emergencies to pharmacists and other quali-
fied persons, for use in the preparation of antidotes,
in accordance with such directions as the Secretary
may prescribe, any information relative to formulas
of products acquired by authority of section 4 of
this Act.
.Registration
Sec. 4. a. Evoy economic poison which is distributed,
sold, or offered fcr sale in any Territory or the District of
Columbia, or which is shipped or delivered for shipment
from any State, Territory, or the District of Columbia to
any other State, Territory, or the District of Columbia, or
which is reccivei from any foreign country shall be
registered with one Secretary: Provided, That products
which have the same formula, are manufactured by the
same person, the labeling of which contains the same
claims, and the Isftels of which bear a designation identify-
ing the product as the same economic poison may be
registered as a angle economic poison: and additional
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names and labels shall be added by supplement statements;
the applicant for registration shall file with the Secretary a
statement including
(1) the name and address of the registrant and the
name and address of the person whose name will appear
on the label, if other than the registrant:
(2) the name of the economic poison.
(3) a complete copy of the labeling accompanying the
economic poison and a statement of all claims to be
made for it, including the directions for use; and
(4) if requested by the Secretary, a full description of
the tests made and the results thereof upon which the
claims are based.
b. The Secretary, whenever he deems it necessary for the
effective administration of this Act, may require the
submission of the complete formula of the economic
poison. If it appears to the Secretary thai the composition
of the article is such as to warrant the proposed claims for
it and if the article and its labeling and other material
required to be submitted comply with the requirements of
section 3 of this Act, he shall register it.
c. If it does not appear to the Secretary that the article
is such as to warrant the proposed claims for it or if the
article and its labeling and other material required to be
submitted do not comply with the provisions of this Act,
he shall notify the applicant for registration of the manner
in which the article, labeling or other material required to
be submitted fail to comply with the Act so as to afford the
applicant for registration an opportunity to make the
corrections necessary. If, upon receipt of such notice, the
applicant for registration does not make the corrections,
the Secretary shall refuse to register the article. The
Secretary, in accordance with the procedures specified
herein, may suspend or cancel the registration of an
economic poison whenever it does not appear that the
article or its labeling or other material required to be
submitted complies with the provisions of this Act.
Whenever the Secretary refuses registration of an economic
poison or determines that registration of an economic
poison should be cancelled, he shall notify the applicant for
registration or the registrant of his action and the reasons
therefor. Whenever an application for registration is re-
fused, the applicant, within thirty days after service of
notice of such refusal, may file a petition requesting
that the matter be referred to an advisory committee
or file objections and request a public hearing in
accordance with this section. A cancellation of registration
shall be effective thirty days after service of the foregoing
notice unless within such time the registrant (1) makes the
necessary corrections; (2) files a petition requesting that the
matter be referred to an advisory committee; or (3) files
objections and requests a public hearing. Each advisory
committee shall be composed of experts, qualified in the
subject matter and of adequately diversified professional
background selected by the National Academy of Sciences
and shall include one or more representatives from land-
grant colleges. The size of the committee shall be deter-
mined by the Secretary. Members of an advisory committee
shall receive as compensation for their services a reasonable
per diem, which the Secretary shall be rules and regulations
prescribe, for time actually spent in the work of the
committee, and shall in addition be reimbursed for their
necessary traveling and subsistence expenses while so
serving away from their places of residence, all of which
costs may be assessed against the petitioner, unless the
committee shall recommend in favor of the petitioner or
unless the matter was referred Co the advisory committee
by the Secretary. The members shall not be subject to any
other provisions of law regarding the appointment and
compensation of employees of the United States. The
Secretary shall furnish the committee with adequate clerical
and other assistance, and shall by rules and regulations
prescribe the procedures to be followed by the committee.
The Secretary shall forthwith submit to such committee the
application for registration of the article and all relevant
data before him. The petitioner, as well as representatives
of the United States Department of Agriculture, shall have
the right to consult with the advisory committee. As soon
as practicable after such submission, but not later than
sixty days thereafter, unless extended by the Secretary for
an additional sixty days, ihe committee shall, after indepen-
dent study of the data submitted by the Secretary and all
other pertinent information available to it, submit a report
and recommendation to ihe Secretary as to the registration
of the article, together with all underlying data and a
statement of the reasons or basis for the recommendations.
After due consideration of the views of the committee and
all other data before him, the Secretary shall within ninety
days after receipt of the report and recommendations of
the advisory committee, make his determination and issue
an order, with findings of fact, with respect to registration
of the article and notify the applicant for registration or
registrant. The applicant for registration, or registrant, may
within sixty days from the date of the order of the
Secretary, file objections thereto and request a public
hearing thereon. In the event a hearing is requested, the
Secretary shall, after due notice, hold such public hearing
for the purpose of receiving evidence relevant and material
to the issues raised by such objections. Any report,
recommendations, underlying data, and reasons certified to
the Secretary by an advisory committee shall be made a
part of the record of the hearing, if relevant and material,
subject to the provisions of section 7(c) of the Administra-
tive Procedure Act (5 U.S.C. 1006 (c)). The National
Academy of Sciences shall designate a member of the
advisory committee to appear and testify at any such
hearing with respect to the report and recommendations of
such committee upon request of the Secretary, the petit-
ioner, or the officer conducting the hearing: Provided, That
this shall not preclude any other member of the advisory
committee from appearing and testifying at such hearing.
As soon as practicable after completion of the hearing, but
not later than ninety days, the Secretary shall evaluate the
data and reports before him, act upon such objections and
issue an order granting, denying, or cancelling the registra-
tion or requiring modification of the claims or the labeling.
Such order shall be based only on substantial evidence of
record of such hearing, including any report, recommenda-
tions, underlying data, and reason certified to the Secretary
by an advisory committee, and shall set forth detailed
findings of fact upon which the order is based. In
connection with considerations of any registration or
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application for registration under this section, the Secretary
may consult with any other Federal agency or with an
advisory committee appointed as herein provided. Notwith-
standing the provisions of section 3.c. (4), information
relative to formulas of products acquired by authority of
this section may be revealed, when necessary under this
section to an advisory committee or to any Federal agency
consulted, or at a public hearing, or in findings of fact
issued by the Secretary. All data submitted to an advisory
committee in support of a petition under this section shall
be considered confidential by such advisory committee:
Provided, That this provision shall not be construed as
prohibiting the use of such data by the committee in
connection with its consultation with the petitioner or
representatives of the United States Department of Agri-
culture, as provided for herein, and in connection with its
report and recommendations to the Secretary. Notwith-
standing any other provision of this section, the Secretary
may, when he finds that such action is necessary to prevent
an imminent hazard to the public, by order, suspend the
registration of an economic poison immediately. In such
case, he shall give the registrant prompt notice of such
action and afford Ihe registrant the opportunity to have the
matter submitted to an advisory committee and for an
expedited hearing under this section. Final orders of the
Secretary under this section shall be subject to judicial
review, in accordance with the provisions of subsection d.
In no event shall registration of an article be construed as a
defense for the commission of any offense prohibited under
section 3 of this Act.
d. In a case of actual controversy as to the validity of
any order under this section, any person who will be
adversely affected by such order may obtain judicial review
by filing in the United States court of Appeals for the
circuit wherein such person resides or has his principal place
of business, or in the United States Court of Appeals for
the District of Columbia Circuit, within sixty days after the
entry of such order, a petition praying that the order be set
aside in whole or in part. A copy of the petition shall be
forthwith transmitted by the clerk of the court to the
Secretary, or any officer designed by him for that purpose,
and thereupon the Secretary shall file in the court the
record of the proceedings on which he based his order, as
provided in section 2112 of title 28, United States Code.
Upon the filing of such petition the court shall have
exclusive jurisdiction to affirm or set aside the order
complained of in whole or in part. The findings of the
Secretary with respect to questions of fact shall be
sustained if supported by substantial evidence when con-
sidered on the record as a whole, including any report and
recommendations of an advisory committee. If application
is made to the court for leave to adduce additional
evidence, the court may order such additional evidence to
be taken before the Secretary, and to be adduced upon the
hearing in such manner and upon such terms and conditions
as to the court may seem proper, if such evidence is
material and there were reasonable grounds for failure to
adduce such evidence in the proceedings below. The
Secretary may modify his findings as to the facts and order
by reason of the additional evidence so taken, and shall file
with the court such modified findings and order. The
judgment of the court affirming or setting aside, in whole
or in part, any older under this section shall be final,
subject to review by the Supreme Court of the United
States Code. The commencement of proceedings under this
section shall not, unless specifically ordered by the court 1o
the contrary, operal* as a stay of an order. The court shall
advance on the docket and expedite that disposition of all
causes filed therein pursuant to this section.
e. Notwithstanding any other provisions of this Act,
registration is not required in the case of an economic
poison shipped from one plant to another plant operated
by the same person and used solely at such plant as a
constitutcnt part to make an economic poison which is
registered under this Act.
f. The Secretary B authorized to cancel the registration
of any economic poison at the end of a period of five years
following the registration of such economic poison or at the
end of any five-year period thereafter, unless the registrant,
prior to the expiration of each such five-year period,
requests in accordance with regulations issued by the
Secretary that such registration be continued in effect.
Books and Records
Sec. 5. For the purposes of enforcing the provisions of
this Act, any manufacturer, distributor, carrier, dealer, or
any olhcr person who sells or offers for sale, delivers, or
offers for delivery, or who receives or holds any economic
poison or device subject to this Act, shall, upon request of
any employee of the United States Department of Agri-
culture or any employee of any State, Territory, or political
subdivision, duly designated by the Secretary, furnish or
permit such person at all reasonable times to have access to,
and to copy all records showing the delivery, movement, or
holding of such economic poison or device, including the
quantity, the date of shipment and receipt, and the name of
the consignor and consignee; and in the event of the
inability of any person to produce records containing such
information, all other records and information relating to
such delivery, movement, or holding of the economic
poison or device. Notwithstanding this provision, however,
the specific evidence obtained under this section shall not
be used in a criminal prosecution of the person from whom
obtained.
Enforcement
Sec. 6. a. The Secretary (except as otherwise provided
in this section) is authorized to make rules and regulations
for carrying out the provisions of this Act, including the
collection and examination of samples of economic poisons
and devices subject to this Act and the determination and
establishment of suitable names to be used in the ingredient
statement. The Secretary is in addition, authorized after
opportunity for hearing—
(I) to declare a pest any form of plant or animal life
or virus which is injurious to plants, man, domestic
animals, articles, or substances;
(2) to determine economic poisons, and quantities of
substances contained in economic poisons, which
are highly toxic to man; and
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(3) to determine standards of coloring or discoloring
for economic poisons, and to subject economic
poisons to the requirements of section 3.a. (4) of
this Act.
b. The Secretary of the Treasury and the Secretary of
Agriculture shall jointly prescribe the regulations for the
enforcement of section 10 of this Act.
c. The examination of economic poisons or devices shall
be made in the United States Department of Agriculture or
elsewhere as the Secretary may designate for the purpose of
determining from such examination whether they comply
with the requirements of this Act, and if it shall appear
from any such examination that they fail to comply with
the requirements of this Act, the Secretary shall cause
notice to be given to the person against whom criminal
proceedings are contemplated. Any person so notified shall
be given an opportunity to present his views, either orally
or in writing, with regard to such contemplated proceed-
ings, and if in the opinion of the Secretary it appears that
the provisions of this Act have been violated by such
person, then the Secretary shall certify the facts to the
proper United States attorney, with a copy of the results of
the analysis of the examination of such article: Provided,
That nothing in' this Act shall be construed as requiring the
Secretary to report for prosecution or for the institution of
libel proceedings minor violations of this Act whenever he
believes that the public interest will be adequately served
by a suitable written notice of warning.
d. It shall be the duty of each United States attorney, to
whom the Secretary or his agents shall report any violation
of. this Act, to cause appropriate proceedings to be
commenced and prosecuted in the proper courts of the
United States without delay.
e. The Secretary shall, by publication in such manner as
he may prescribe, give notice of all judgments entered in
actions instituted under the authority of this Act.
Exemptions
Sec. 7. a. The penalties prbvided for a violation of
section 3.a. of this Act shall not apply to-
(1) any person who establishes a guaranty signed by,
and containing the name and address of, the
registrant or person residing in the United States
from whom he purchased and received in good faith
the article in the same unbroken package, to the
effect that the article was lawfully registered at the
time of sale and delivery to him, and that it
complies with the other requirements of .his Act,
designating this Act. In such case the guarantor shall
be subject to the penalties which would otherwise
attach to the person holding the guaranty under the
provision of this Act;
(2) any carrier while lawfully engaged in transporting
an economic poison or device if such carrier upon
request by a person duly designated by the Secie-
tary shall permit such person to copy all records
showing the transactions in and movement of the
articles:
(3) to public officials while engaged in the perform-
ance of their official duties;
(4) to the manufacturer or shipper of an economic
poison for experimental use only by or under the
supervision of any Federal or State agency author-
ized by law to conduct research in the field of
economic poisons; or by others if a permit has been
obtained before shipment in accordance with regu-
lations promulgated by the Secretary.
Penalties
Sec. 8. a. Any person violating section 3.a. (1) of this
Act shall be guilty of a misdemeanor and shall on
conviction be fined not more than $ 1,000.
b. Any person violating any provision other than section
3.a. (1) of this Act shall be guilty of a misdemeanor and
shall upon conviction be fined not more than $500 for the
first offense, and on conviction for each subsequent offense
be fined not more than SI,000 or imprisoned for not more
than one year, or both such fine and imprisonment:
Provided, That an offense committed more than five years
after t!ie last previous conviction shall be considered a first
offense. An article the registration of which has been
terminated may not again be registered unless the article, its
labeling, and other material required to be submitted
appear to the Secretary to comply with all the requirements
of this Act.
c. Notwithstanding any other provision of this Section,
in case any person with intent to defraud, uses or reveals
information relative to formulas of products acquired under
the authority of section 4 of this Act, he shall be fined not
more than S 10,000 or imprisoned for not more than three
years, or both such fine and imprisonment.
d. When construing and enforcing the provisions of this
Act, the act, omission or failure, of any officer, agent, or
other person acting for or employed by any person shall in
every case be also deemed to be the act, omission, of failure
of such person as well as that of the person employed.
Seizures
Sec. 9. a. Any economic poison or device that is being
transported from one State, Terrirory, or District to
another, or having been transported, remains unsold or in
original unbroken packages, or that is sold or offered for
sale in the District of Columbia or any Territory, or that is
imported from a foreign country, shall be liable to be
proceeded against in any district court of the United States
in the district where it is found and seized for confiscation
by a process of libel for condemnation-
(1) in the case of an economic poison-
(a) if it is adulterated or misbranded;
(b) if it is not registered pursuant to the provisions'of
section 4 of this Act;
(c) if it fails to bear on its label the information
required by this Act;
(d) if it is a white powder, economic poison, and is not
colored as required under this Act; or
(2) in the case of a device if it is misbranded.
b. If the article is condemned it shall, after entry of the
decree, be disposed of by destruction or sale as the court
may direct and the proceeds, if sold, less the legal costs,
shall be paid into the Treasury of the United States, but the
article shall not be sold contrary to the provisions of this
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Act or of the laws of the jurisdiction in which it is sold;
Provided. That upon the payments of the costs of the libel
proceedings and the execution and delivery of a good and
sufficient bond conditioned that the article shall not be
sold or otherwise disposed of contrary to the provisions of
this Act or the laws of any State, Territory, or District in
which sold, the court may direct that such articles be
delivered to the owner thereof. The proceedings of such
libel cases shall conform, as near as may be, to the
proceedings in admiralty, except that either party may
demand trial by jury of any issue of fact joined in any case,
and all such proceedings shall be at the suit of and in the
name of the United States.
c. When a decree of condemnation is entered against the
article, court costs and fees, storage, and other proper
expenses shall be awarded against the person, if any,
intervening as claimant of the article.
Imports
Sec. 10. The Secretary of the Treasury shall notify the
Secretary of Agriculture of the arrival of economic poisons
and devices offered for importation and shall deliver to the
Secretary of Agriculture, upon his request, samples of
economic poisons or devices which are being imported or
offered for import into the United States, giving notice to
the owner or consignee, who may appear before the
Secretary of Agriculture and have the right to introduce
testimony. If it appears from the examination of a sample
that it is adulterated, or misbranded or otherwise violates
the prohibitions set forth in this Act, or is otherwise
dangerous to the health of the people of the United States,
or is of a kind forbidden entry inio or forbidden to be sold
or restricted in sale in the country in which it is made or
from which it is exported, the said article may be refused
admission, and the Secretary of the Treasury shall refuse
delivery to the consignee and shall cause the destruction of
any goods refused delivery which shall not be exported by
the consignee within three months from the date of notice
of such refusal under such regulations as the Secretary of
the Treasury may prescribe: Provided, That the Secretary
of the Treasury may deliver to the consignee such goods
pending examination and decision in the matter on execu-
tion of penal bond for the amount of the full invoice value
of such goods, together with the duty thereon, and on
tefusal to return such goods for any cause to the custody of
the Secretary of Treasury, when demanded, for the purpose
of excluding them from the country, or for any other
purpose, said consignee shall forfeit the full amount of said
bond: and provided further, That all charges for storage,
cartage, and labor on goods which are refused admission or
delivery shall be paid by the owner or consignee and in
default of such payment shall constitute a lien against any
future importation made by such owner or consignee.
Delegation of Duties
Sec. 11. All authority vested in the Secretary by virtue
of the provisions of this Act may with like force and effect
be executed by such employees of the United States
Department of Agriculture as the Secretary may designate
for the purpose.
Authorization for Appropriations and Expenditures
Sec. 12. a. There is hereby authorized to be appropri-
ated, out of any moneys in the Treasury not otherwise
appropriated, such sums as may be necessary for the
purposes and administration of this Act. In order to carry
out the provisions of this Act, which take effect prior to
the repeal of the Insecticide Act of 1910, appropriations
available for the enforcement of such Act are authorized to
be made available.
b. The Secretary is authorized from the funds appropri-
ated for this Act to make such expenditures as he deems
necessary, including rents, travel supplies, books, samples,
testing devices, furniture, equipment, and such other
expenses as may be necessary to the administration of this
Act.
Cooperation
Sec. 13. The Secretary is authorized to cooperate with
any other department or agency of the Federal Government
and with the official agricultural or other regulatory agency
of any State, or any State, Territory, District, possession, or
any political subdivision thereof, in carrying out the
provisions of this Act, and in securing uniformity of
regulations.
Separability
Sec. 14. If any provision of this Act is declared unconsti-
tutional, or the Applicability thereof to any person or
circumstances is held invalid, the constitutionality of the
remainder of this Act and the applicability thereof to other
persons and circumstances shall not be affected
thereby.
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INTERDEPARTMENTAL AGREEMENTS ON PESTICIDES
(Interdepartmental Agreement for Protection of Public Health and Quality of
Environment announced March 3, 1970, and establishment of a working group of the
Subcommittee on Pesticides of the Cabinet Committee on the Environment announced
March 26,1970)
INTERDEPARTMENTAL AGREEMENT
.Purpose. Coordination of the activities of the three
Departments pertaining to economic poisons as defined in
section 2 of the Federal Insecticide, Fungicide, and
Rodenticide Act (7 U.S.C. 135), hereinafter referred to as
pesticides, with reference to the review of current or
proposed registrations to assure maximum protection of the
public health, the well being of man, and the quality of the
environment.
Existing departmental responsibilities. Each of the three
Departments has certain statutory authority and responsi-
bility relating to pesticides in the environment, as set forth
below:
Department of Agriculture
1. Statutory authority under the Federal Insecticide,
Fungicide, and Rodenticide Act for registration of pesti-
cides.
2. Responsibility for research, education, information,
regulatory, and action programs designed to protect the
well being of man, crops, livestock, forests, ranges, habitats,
products, structures, and premises against arthropod and
other invertebrate pests, weeds, and fungi with equal
concern for the protection of beneficial nontarget organ-
isms and the quality of the environment.
Department of Health, Education, and Welfare
DHEW has the statutory authority and responsibility
under the Federal Food, Drug, and Cosmetic Act for,
establishing safe tolerances for pesticides in or on raw
agricultural commodities, processed food and potable
water. The Department also has responsibilities for protect-
ing the public from health, occupational, and environ-
mental hazards related to the use and disposal of pesticides,
and for other public health aspects such as the control of
diseases and their vectors.
Department of Interior
USD! has statutory authority and responsibility under
the Federal Water Pollution Control Act to carry out
programs, to protect and enhance the quality of the
Nation's waters including determining the effects of pesti-
cides in water on health, welfare, and aquatic life. These
responsibilities include establishing water quality standards
for interstate waters. The Department also has statutory
authority for the conservation of wild birds, fish, mammals,
their food organisms and their environment as affected by
pesticides and the appraisal of effects of pesticides on fish
and wildlife.
Information. Each Department will keep each of the
other Departments fully informed of developments in
knowledge from research or other sources which may come
into its possession in connection with matters referred to in
this agreement. High priority shall be placed by each
Department representative to respond to each of the other
Departments' requests, whether written or oral, for any and
all information concerning action pending or taken on
pesticide matters.
Procedures - A. General. 1. Each Department will desig-
nate a qualified representative to act on behalf of such
Department in carrying out the terms of this agreement. All
communications from USDA, DHEW, and USDI will be
directed to these representatives.
2. USDA shall furnish to the other Departments copies
of each proposal received for registration or reregistration
with the accompanying safety data (if any) and a request
for an opinion from DHEW and USDI on the requested
action in their areas of responsibility.
3. Within IS working days, DHEW and USDI shall
evaluate each registration or reregistration proposal in light
of the data supplied and offer an opinion or provide a
status report as to whether or not the registration should be
granted or specify the additional data deemed necessary
before such evaluation can be made. When either is unable
to assess the public health or environmental risk without
additional data, USDA shall advise the registrant of its
inability to consider registration of the pescicide until the
additional data requested have been received and reviewed
by the respective Departments according to the following
procedures described below.
B. Specific. 1. The Departmental Representative will
accomplish review by his agency of each proposal and
report results of such review to each of the other agencies
within IS working days of the receipt of the proposal. If
there is insufficient information to reach a decision of, the
proposal, USDA will be contacted within such period of IS
working days and advised with particularity what additional
information is needed for the necessary evaluation. Appli-
cants for registration should not be discouraged from
communicating with DHEW or USDI on registration mat-
ters of mutual interest, so long as the other representatives
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are informed of the details of such contact by memoran-
dum thereof.
2. Upon receipt of such a request for further informa-
tion, USDA will make arrangements to obtain the addi-
tional information, if available, and furnish it to the
Department making the request. USDA will withhold final
action on the matter for 15 working days, from the date of
furnishing the requested information or advice that such
information is not available, pending receipt of the report
of the other Department of the results of further review.
3. If a Department concludes that the registration
should be rejected in whole or in part, this view shall be
expressed in writing along with a statement of the reasons
for the conclusion including the specific information, lack
of information, or scientific judgment upon which these are
based.
Upon being so notified, USDA will notify the party
involved, i.e., the applicant or registrant, and offer him an
opportunity to submit any data, views or arguments with
respect to the proposed rejection and any such submission
shall be promptly referred to the other Department
representatives who shall report to USDA the results of
their review of the submission.
4. In the event that after the review of the additional
data the Departments cannot agree on the approval of the
proposal, any Department may request the formation of a
Registration Review Panel for the purpose of making a
complete review of the issues and related information or
lack thereof and submit a detailed report of their findings.
Each Registration Review Panel shall be composed of two
representatives from each of the three Departments with
the chairman to be selected from the respresentatives of the
Department from which the objections have come.
The Registration Review Panel shall prepare its report
within 20 working days, including any minority opinions,
and submit it to each of the three Departments.
5. The report(s) of the Registration Review Panel shall
be reviewed by each Department'within 15 working days of
its receipt.
6. If significant differences between the Departments
remain still unresolved, all data and information submitted
by all parties shall be reviewed at the first monthly
Intcrdepartment Pesticide Meeting after the reviews of the
Registration Review Panel reports have been made.
7. In the event agreement is not reached among the
Department representatives at the monthly Inter-
department Pesticide Meeting, a submission of the reports
of the reviews referred to in paragraphs B-l through B-6
above, will be referred at the request of the Secretary of the
objecting Department to the Cabinet Committee on Envi-
ronmental Quality. The referral shall be accompanied by a
statement prepared by each Department analyzing the
issues involved and setting forth the decision it recom-
mends. The Cabinet Committee on Environmental Quality
will consider such recommendations and make a written
report, cither accepting, rejecting, or modifying them.
. 8. Based upon consideration of the action of the Cabinet
Committee, the Secretary of Agriculture will make the
decision as to the specific action to be taken with respect to
the matter on which the Department representatives were
not in agreement, and will thereupon notify the other two
Secretaries in writing in advance of the publication of the
final determination if he has not followed the recommenda-
tions made by the objecting Department(s), specifically
stating his reasons for such action.
9. When registration is granted, USDA shall supply to
DHEW and USDI final printed labeling at the time of
registration with a copy of the final letter to the registrant.
10. The Departmental representatives may review exist-
ing patterns of usage and registrations for particular
pesticides. A conclusion by USDA, DHEW, or USDI that an
existing pesticide use or registration may be detrimental to
the public health or to the quality of the environment shall
be transmitted to the other two Departments together with
the supporting reasoning and information, with a recom-
mendation for corrective action. Written information from
all sources on the health or environmental aspects of such
pesticides shall be submitted to a Registration Review Panel
for review and recommendations. If USDA, DHEW, or
USDI disagrees with the recommendations of the Registra-
tion Review Panel, that Department can initiate further
review by the procedural steps described in paragraphs B-6
through B-8 above.
Intcrdepartment pesticide meetings and conferences. The
Department representatives will meet jointly at an Inter-
department Pesticide Meeting once a month to provide a
continuous dialogue concerning all aspects of their current
activities and to promote cooperation and understanding
among the Departments. Monthly reports concerning their
activities will be made to the Secretaries of the three
Departments, according to a mutually agreed upon format.
The Departmental representatives will arrange a general
conference at least once each year to discuss research needs,
research program and policy, and the application of
research findings in action programs, including public
information relating to pesticides. The Interdepartment
Pesticide Conference will consider broad questions on
policies relating to pesticides involving the interrelation-
ships of control programs, research, registration, tolerances,
the public health, and general departmental recommenda-
tions to the public.
In order to promote free interchange or information
among the Departments involved under this agieemcnt,
each Department representative should be invited and
encouraged to participate in conferences, meetings, and
various symposiums with Federal, State, university, or
industry people on possible matters of mutual interest.
Effective date and stipersedure. This agreement shall
become effective upon signature by the Secretaries of
USDA, USDI, and DHEW, and shall supersede the agree-
ment entitled "Interdepartmental Coordination of Activi-
ties Relating to Pesticides by the Department of Agricul-
ture, the Department of Health, Education, and Welfare,
and the Department of the Interior,'1 published in the
FEDERAL REGISTER on May 1, 1964 (29 F.R. 5808).
CHARTER OF THE WORKING GROUP
A. Establishment. A working group of the Subcommit-
tee on Pesticides of the Cabinet Committee on the
Environment (formerly Environmental Quality Council) is
established pursuant to action of the Committee (Council)
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announced on November 20, and the Federal Committee
on Pest Control is hereby abolished.
The working group will: (1) Provide day-to-day coordina-
tion of Federal agency pesticide activities; and (2) develop
program and policy proposals for consideration by the
Subcommittee on Pesticides.
The following agencies will have membership on the
working groups:
Department of Agriculture.
Department of Health, Education, and Welfare.
Department of the Interior.
Department of Defense.
Department of Transportation.
Department of State.1
The Office of Science and Technology, the Bureau of the
Budget, and the Office of Intergovernmental Relations will
be invited to designate an observer at the meetings of the
working group. Other agencies will be invited to participate
in meetings when matters of significant concern to them are
to be discussed.
The working group will consist of one principal autho-
rized to commit his agency in routine coordination and on
most issues and to make reservations on behalf of his
agency on controversial issues. At the request of any
principal, Departmental or agency issues will be referred to
the Subcommittee on Pesticides for review prior to imple-
mentation.
Each member agency will name one or more alternates to
speak for that agency in the absence of the principal. Other
individuals, cognizant of the pesticide programs and respon-
sibilities of their agencies, may attend meetings to provide
technical support for the principal.
It is recognized that the use of pesticide chemicals is
necessary to protect man, animals, plants, and the environ-
ment against harmful insects, rodents, other vertebrate
pests, weeds, and diseases. It is further recognized that use
of pesticide chemicals, especially careless and unauthorized
use, is hazardous to nontarget man, plants, and animals, and
the environment. It is, therefore, essential that any use of a
pesticide chemical be evaluated as to the necessity for its
use, the harm which may result, and the precautions which
must be taken to minimize harmful effects.
B. Purpose. The working group is the primary staff level
coordinating mechanism for Federal activities concerning
pesticides, pests, and their control. The activities coordi-
nated by the working group include, but are not limited to:
(1) Pest control programs in various parts of the world
in which there is active participation on the part of the
Federal Government, either in funding or in supervision;
(2) Research on pests and their control and effects of
control procedures, whether by chemical or other methods;
(3) Monitoring of the environment for pesticides and
their residues;
(4) Establishment of pesticide investigation teams to
conduct special investigations of pesticide problems which
arise or which may be anticipated;
'The intent is to assure adequate consideration of international
concerns which arc largely but not wholly represented within the
Agency for International Development.
(5) Public information on pest control and the use of
pesticides;
(6) Evaluation of economic and social values and risks
involved in the control of pests by various methods; and
(7) Advice to the interdepartmental group on pesticide
registration on problems that it believes should be consi-
dered by that group.
The working group shall advise the Subcommittee on
Pesticides and the appropriate Federal departments and
agencies concerning matters of common interest. In no
case, however, will the working group supersede the
responsibility of each department and agency to carry out
the functions assigned to it by legislative and executive
mandates. The working group will encourage exchange of
information among international, Federal, State, and local
agencies and may participate with them as appropriate.
C. Procedures- 1. Review of programs, a. On request,
any Federal agency shall submit to the working group for
review a detailed description of its proposed and current
pest control programs and monitoring, research, education,
and other programs pertaining to pest control.
b. The working group will review such programs from
the standpoint of effectiveness, economic impact and
hazards to human health, to livestock and crops, to fish or
wildlife, and to other elements of the environment.
c. Based on such review, the working group shall
recommend to the heads of the departments or agencies
concerned such modifications in the programs as the
working group feels will best serve the public interest.
2. Intergovernmental cooperation, a. The working
group shall promote or encourage review of both Federal
and non-Federal programs by State and local groups
representing a broad spectrum of interests and responsibili-
ties.
b. The working group may communicate with such State
and local groups to receive their recommendations and to
make recommendations to them either directly or through
member departments, whichever seems most expeditious
and effective.
c. Subject to foreign policy guidance from the Depart-
ment of State, the working group may participate in joint
activities with foreign or international groups having similar
interests and will coordinate these activities among Federal
and State agencies. Informal recommendations arising from
such joint activities may be directed by the working group
to the concerned Federal department or agency. No formal
recommendations shall be transmitted directly to any
foreign government or international agency.
3. Stimulation of new activities, a. Whenever the work-
ing group feels that the public interest will be served by the
initiation of new activity, such as interdepartmental partici-
pation in integrating a variety of control methods or in
analyzing jointly the efforts of such integrated control on
all aspects of the environments, the working group may
recommend appropriate action to the Subcommittee on
Pesticides and to the concerned departments or agencies
and representatives of States.
, 4. Mechanisms available to the working group, a. The
working group may establish ad hoc groups or panels of
specialists to assist in discharging the working group's
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responsibilities. Membership on such ad hoc groups need
not be limited to representatives of Federal departments.
b. The working group may request the appropriate
agencies to provide special services, consultation, staff,
facilities, publications, conferences, etc., as may facilitate
the work of the working group. Expenditure of appropri-
ated funds for such activities of the working group must be
within the authority and area of responsibility of the
contributing department or agency and must remain within
its individual fiscal control, even though the technical
supervision may be provided by the working group.
D. Membership. Membership and observer status on the
working group is by appointment of principals and alter-
nates by letter, to the Chairman of the Subcommittee on
Pesticides, from the heads of agencies concerned. On
invitation of the working group, a liaison representative
may be similarly appointed by other Government agencies
having an interest in problems related to pest control.
E. Officers and staff. l.The officers of the working
group shall be:
Chairman.
Vice Chairman.
Executive Secretary.
The Chairman and Vice Chairman shall be elected from
among members of the working group.
2. The staff of the working group shall include such
professional and other staff as may be required.
3. It shall be the duty of the Chairman to preside at all
meetings and to assure compliance with the charter of the
working group. He shall call meetings of the working group
when he deems it necessary or on request of any member
department. The Chairman shall exercise leadership in
seeking timely intcragency coordination on items of con-
cern to the working group. The Chairman shall communi-
cate directly with the Chairman of the Subcommittee on
Pesticides as needed.
4. In the absence of the Chairman, the Vice Chairman
will perform the functions of the Chairman.
5. The Executive Secretary will be responsible for:
a. Preparation of agenda, notice of meetings, corres-
pondence, coordination of administrative matters and
representation of the working group as requested by the
Chairman.
b. Preparation and recommendation to the working
group of pertinent policies and plans to meet the working
group requirements. To tlu's end, the Executive Secretary
may request the Chairman to appoint advisory and other ad
hoc groups as required.
c. Maintenance of minutes, sufficient other records and
accounts to provide an annual report of the working group
activities for such distribution as recommended by the
working group.
F. Meetings. 1. Meetings shall be held at the call of the
Chairman, following coordination with members regarding
time, place, and date.
2. Decisions of the working group usually shall be made
at regular meetings where there is an opportunity for
discussion and not by correspondence or telephone calls,
except in rare cases of urgency.
3. Minutes of meetings shall consist of a record of
important discussions and decisions of the working group,
but need not be a verbatim record. Minutes shall be
distributed to principals, alternates, and observers.
G. Quorum. A majority of the members of the working
group shall constitute a quorum authorized to transact any
business duty presented at any meeting of the working
group.
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the method of administration from the federal level is more
clearly defined.
The key role seen here for all state Departments of
Agriculture and Extension Services cannot be minimized. It
is hoped that legislators from both the state and federal
level can be encouraged to lend their support to auxiliary
programs, such as the reporting of human and livestock
injury resulting from pesticide use or misuse. Such support
is not desired to further restrict pesticide use, but
rather as an aid in identifying additional problem areas
where the full educational and service resources of each
state can be focused.
A copy of FIFRA is included for reference. Terms such
as environment, imminent hazard, protect health and
environment, substantial adverse effects on the environment
are conspicuous by their absence in FIFRA. The inclusion
of these words in H. R. 10729 tends to bring the problem
into focus. H. R. 10729 appears to be,in the final analysis,
the best compromise legislation at the present time.
Provisions for classification and registration of pesticides
and applicator certification, although treated as a burden
by one segment of the community, are regarded as too lenient
by another (for a copy of H. R. 10729 see Volume II).
Section 20, Research and Monitoring, and Section 23,
State Cooperation and Training, are particularly attractive.
37-H
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The provisions which specifically empower the
Administrator to foster research in biologically integrated
alternatives for pest control are deemed necessary to the
success of such endeavors. Hopefully, parts of 20 (b) -
The Administrator shall formulate and periodically revise
(emphasis ours)...national plan for monitoring - will be
implemented. The contractor believes that parts of the
present plan are woefully inadequate, cumbersome, and
ineffectual in assessing environmental contamination.
The provisions of Section 23 which specifically allow
the Administrator to expend public funds in the implementation
of expanded state programs, particularly those provisions
which seek to encourage training of certified pesticide
applicators, are viewed as necessary and desirable. The
expenditure of public monies for such purposes is seen as
ultimately benefiting all mankind and the total environment,
not just the recipient.
Testing and Registration of New Pesticides
Section 3. Registration of pesticides appears to
provide for sufficient information to allow the Administrator
to make adequate judgments regarding new compounds. The
provisions which allow a full description of tests performed,
3 (c)(1)(D), and the results thereof to the Administrator
as he desires and 3 (c)(1), wherein the Administrator shall
38-H
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publish guidelines specifying the kinds of information
required in support of registration, are regarded as
particularly important. The further provision that the
Administrator shall make public all scientific information
relating to the registration of any particular compound
is viewed as an absolute necessity and long overdue
(S 23(c)(2), p. 18, lines 4-9). Although the contractor is
sympathetic with industry's mounting registration costs,
it feels that the publication of full scientific information
relating to any new pesticide must be made so that the at-
large scientific community has an opportunity to assess its
validity. The contractor had no desire to infringe on the
manufacturers' confidential information, but felt that there
were times when access to such information could have made
a valuable contribution to the total assessment of pesti-
cide effects on test organisms.
In the event that the provisions in Section 10, Protection
of Trade Secrets and Other Information, shall come into
conflict with the above, the Administrator should code
such compounds and seek additional outside scientific
judgment. The contractor does not believe that information
relating to adequately chosen test animals (including a
sufficient number of aquatic organisms) should qualify as
trade secrets, or commercial or financial information.
39-H
-------
As indicated previously, rural constituencies were
overwhelmingly in favor of H. R. 10729. A synopsis of the
congressional tally on H. R. 10729 is presented in Table 1-H
a detailed record of individual votes on the total bill
and three amendments is shown in Table 2-H. "No" votes were
predominantly from urban areas and attempted contacts with
these lawmakers failed to disclose the reason for such a
vote.
State Laws
A wide variation in laws is seen in the five-state
study area. It should be remembered that the existence of
a law does not, of itself, insure that the provisions will
be carried out.
Illinois
The State of Illinois appears to have reasonably sound
laws on record. Short courses conducted by the University
of Illinois to implement the provisions covering commercial
applicators appear excellent in content, although they are
not specified in the Act. The creation of an interagency
committee on pesticides and a state environmental protection
agency are seen as forward steps toward safer use of pesti-
cides. The present law is not inconsistent with the proposed
bill (H. R. 10729).
40-H
-------
TABLE 1-H
SYNOPOSIS OF
CONGRESSIONAL TALLY ON H.R. 10729
November 9, 1971
State
Illinois
Voting Yes
No
Not Voting
Absent
Iowa
Kansas
Minnesota
Missouri
Yes
No
Yes
No
Vote
12
3
8
1
Remarks
6
2
8
2
(9D, 3R)
(3D) All from City of
Chicago
Yes
No
Yes
5
1
5
(ID, 4R)
(ID)
(ID, 4R)
(2D, 4R)
(2D) Both from metropolitan
Area
(7D, 1R)
(2D) (1 from St. Louis)
(1 rural area, 5th
District)
41-H
-------
TABLE 2-H
U. S. HOUSE OF REPRESENTATIVES
Consideration of "Federal Environmental Pesticide Control Act of 1971"
(As taken from Congressional Record of November 9, 1971)
State
Illinois
_.
Congressman
Ralph H. Metcalfe (D)
1st District - City
of Chicago
Abner J. Mikva (D)
2nd District - City
of Chicago
Morgan Francis Murphy
(D) — 3rd District -
City of Chicago
Edward J. Derwinski
(R)--4th District -
Cook County
John C. Kluczynski
(D) — 5th District -
City of Chicago
George W. Collins (D)
6th District - City
of Chicago
Frank Annunzio (D)
7th District - City
of Chicago
Dan Rostenkowski (D)
8th District - City
of Chicago
Sidney R. Yates (D)
9th District - City
of Chicago
Kyi's
Amendment
(Registration)
Not voting
Yes
Yes
Not voting
Yes
Yes
Yes
Yes
Yes
Dow1 s
Amendment
(Judicial
Review)
Not voting
Yes
Yes
Not voting
Yes
Yes
Yes
Yes
Yes
Eckhdrdt 's
Amendment
(Indemnities)
Yes
Yes
Yes
Not voting
Yes
Yes
Yes
Yes
Yes
Entire Bill
No
No
Yes
Not voting
Yes
Yes
Yes
Yes
No
to
I
a
-------
Consideration of
TABLE 2-H
U. S. HOUSE OF REPRESENTATIVES
"Federal Environmental Pesticide Control Act of 1971"
(As taken from Congressional Record of November 9, 1971)
State
Illinois
Congressman
Ralph H. Metcalfe (D)
1st District - City
of Chicago
Abner J. Mikva (D)
2nd District - City
of Chicago
Morgan Francis Murphy
(D) — 3rd District -
City of Chicago
Edward J. Derwinski
(R) — 4th District -
Cook County
John C. iSluczynski
(D) — 5th District -
City of Chicago
George W. Collins (D)
6th District - City
of Chicago
Frank Annunzio (D)
7th District - City
of Chicago
Dan Rostenkowski (D)
8th District - City
of Chicago
Sidney R. Yates (D)
9th District - City
of Chicago
Kyi's
Amendment
(Registration)
Not voting
Yes
Yes
Not voting
Yes
Yes
Yes
Yes
Yes
Dow's
Amendment
(Judicial
Review)
Not voting
Yes
Yes
Not voting
Yes
Yes
Yes
Yes
Yes
Eckhardt ' s
Amendment
(Indemnities)
Yes
Yes
Yes
Not voting
Yes
Yes
Yes
Yes
Yes
Entire Bill
No
No
Yes
Not voting
Yes
Yes
Yes
Yes
No
t
ffi
-------
State
Illinois
(continued)
Congressman
Harold R. Collier (R)
10th District - City
of Chicago
Roman C. Pucinski (D)
llth District - City
of Chicago
Robert McClory (R)
12th District
Philip M. Crane (R)
13th District -
Cook County
John N. Erlenborn
(R)— 14th District
Charlotte T. Reid
(R) — 15th District
John B. Anderson
(R) — 16th District
Leslie C. Arends (R)
17th District
Robert H. Michel (R)
18th District
Thomas F. Railsback
(R) — 19th District
Paul Findley (R)
20th District
Kenneth J. Gray (D)
21st District
William L. Springer
(R)— 22nd District
Kyi's
Amendment
(Registration)
Not voting
Yes
Not voting
Not voting
No
Absent
No
Not voting
Not voting
Not voting
No
No
Not voting
Dow's
Amendment
(Judicial
Review)
Not voting
Yes
Not voting
Not voting
Yes
Absent
No
Not voting
Not voting
Not voting
No
No
Not voting
Eckhardt ' s
Amendment
(Indemnities)
Not voting
Yes
Not voting
Not voting
No
Absent
No
Not voting
Not voting
Not voting
No
No
Not voting
Entire Bill
Not voting
Yes
Not voting
Not voting
Yes
Absent
Yes
Not voting
Not voting
Not voting
Yes
Yes
Not voting
-------
Ul
a
State
Illinois
(continued)
Iowa
Kansas
Congressman
George Edward Shipley
(D)— 23rd District
Charles Melvin Price
(D) — 24th District
Fred Schwengel (R)
1st District
John C. Culver (D)
2nd District
H. R. Gross (R)
3rd District
John Henry Kyi (R)
4th District
Neal Smith (D)
5th District
Wiley Mayne (R)
6th District
William J. Scherle (R)
7th District
Keith G. Sebelius (R)
1st District
William Robert Roy (D)
2nd District
Larry Winn, Jr. (R)
3rd District
Garner E. Shriver (R)
4th District
Joe Skubitz (R)
5th District
Kyi's
Amendment
(Registration)
No
Yes
Not voting
Yes
No
No
No
No
No
No
No
No
No
No
Dow's
Amendment
(Judicial
Review)
Yes
Yes
Not voting
Yes
No
No
No
No
No
No
No
No
No
No
Eckhardt * s
Amendment
(Indemnities)
No
Yes
Not voting
Yes
No
No
No
No
No
No
No
No
Yes
No
Entire Bill
Yes
Yes
Not voting
No
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
-------
a\
I
a
State
Minnesota
Missouri
Congressman
Albert Harold Quie
(R)--lst District
Ancher Nelsen (R)
2nd District
Bill Frenzel (R)
3rd District
Joseph E. Karth (D)
4th District
Donald MacKay Fraser
(D) — 5th District
John M. Zwach (R)
6th District
Bob Selmer Bergland
(D) — 7th District
John A. Blatnik (D)
8th District
William L. Clay (D)
1st District
James Wadsworth
Symington (D) — 2nd
District
Leonor Kretzer
Sullivan (D)--3rd
District
William J. Randall
(D) — 4th District
Kyi's
Amendment
(Registration)
No
No
No
Yes
Yes
No
No
No
Not voting
Yes
Yes
No
Dow' s
Amendment
(Judicial
Review)
Yes
No
Yes
Yes
Yes
No
No
Yes
Not voting
Yes
Yes
No
Eckhardt 's
Amendment
(Indemnities)
No
No
Yes
Yes
Yes
No
No
Not voting
Not voting
Yes
No
No
Entire Bill
Yes
Yes
Yes
No
No
Yes
Yes
Yes
No
Yes
Yes
Yes
-------
It can be pointed out that many farmers and agents
from this state feel that even though the applicator (as a
corporate entity) is licensed, many of his workers are not
and that damage could and did occur due to lack of pre-
cautions on this person's part. The provisions of the
existing law are rather weak in this regard and the penalties
for abuse are insignificant. Compliance with the Administration
bill should insure more strict compliance with training and
safety precautions through increased penalties and additional
educational effort.
When asked about this issue. Congressman Findley was
not available but his legislative assistant, Mr. Madson,
answered for the Congressman. The Congressman had voted
for H. R. 10729 but had voted against the amendments including
the one which did pass to give states the authority on general
use pesticides. Mr. Madson indicated that the Congressman
felt the state authority amendment would contribute to a
continued fractionation or diversity of regulation in the
several states, and that a uniform and reasonable control on
a national basis is needed.
With respect to inputs received by the Congressman
since the action on the bill, the response from his district
has been favorable to his having supported the legislation.
Only a few letters have been against his position.
47-H
-------
Prior to the action on the floor of the House, the
Congressman had numerous inputs from individual farmers and
others in his district, and in particular, from farmer
organizations and farmers' cooperatives. Mr. Madson indi-
cated that they have found the inputs from the FS Services,
Inc., a three-state farm cooperative, particularly helpful.
Mr. Madson stressed that the bulk of the farmers and
the organizations and farm cooperatives recognize the need
to work within a regulatory framework as provided by the
new legislation, in order to preclude more restrictive
limitations on their use of agricultural chemicals. He
stated that the farmers' cooperatives, in general, are
gearing up to assist the farmers through educational means
to qualify under any registration system that may result
from the eventual legislation. The Congressman's office
feels that this type of approach will be of direct assistance
to more effective, safe, and economic use of agricultural
chemicals. No suggestions were offered for companion state
legislation.
A synopsis of Illinois laws is included on the following
pages.
Iowa
The Pesticide Act of Iowa is a combined registration
(use) and applications law. Licensing provisions need to
48-H
-------
SYNOPSIS OF ILLINOIS LAWS
Title
Prohibited acts
Custom Application of Pesticides
LIU. Ann. St. (1966), ch. 5,
s 87(d) (1) et sea.]
Exemptions
Licensing
qualifications
application
examination
fees
issuance
Unlawful to engage in custom
application of pesticides unless
licensed by the Director of the
Department of Agriculture.
Structural pest control operators,
fumigators, governmental bodies,
tree experts, farmers, canning
establishments, veterinarians in
practice, farmer or grower apply-
ing pesticides to not more than
two neighbors land each year and
general pest control operators
(nuisance pests or disease vectors)
Must possess "adequate knowledge"
concerning proper use and application
of pesticides.
Must contain information regarding
applicants' qualifications and pro-
posed operations and other informa-
tion deemed necessary by the Director,
Applicant required to "pass the
examination."
Annual license fee $25.
If found qualified, applicant shall
be issued license valid for one
year from date of issue, renewable
w/o examination if fee paid and
valid bond in effect. Director may
restrict licensee to the use of
certain types of material or equip-
ment. Director may revoke license
for listed statutory reasons, but
must provide administrative hearings
and appeal procedures.
49-H
-------
nonresidents
Financial
responsibility
Authority granted
to;
issue regulations
enforce the act
delegate duties
restruct usage
inspect property
require records
cooperate with
others
Required to pass the examination
annually.
"Reasonable performance bond" re-
quired, or a deposit of cash or
collateral in lieu of bond.
Yes.
Yes.
Yes.
Yes.
Yes.
Yes.
Yes.
publish information Yes.
conduct courses Not specified in act.
regulate storage,
transportation, or Not specified in act.
disposal of pesticides
require compliance
with label Not specified in act.
license equipment Not specified in act.
subpoena persons
or records
report losses
investigate
damages
Pesticide board
Not specified in act.
Not specified in act.
Not specified in act.
Interagency Committee on Pesticides
LIU. Ann. St. (1965) , ch. 5, s
271 to 276]
50-H
-------
Definitions
Penalties
"An act to create an interagency
committee on pesticides to study,
advise and recommend any needed
legislation concerning pesticides,
and to approve all proposed rules
and regulations pertaining to the
labeling, sale, use or application
of pesticides." The Act creates a
7-man committee representing
Departments of Agriculture, Con-
servation, Public Health, Public
Works and Buildings, Natural History
Survey, College of Agriculture, and
Illinois Environmental Protection
Agency whose duties are to: (1) re-
view the sale and use of pesticides,
(2) review governmental sponsored
or directed pesticide programs, (3)
consider hazards of pesticide use,
(4) recommend pesticide legislation,
(5) obtain the views of interested
parties, (6) advise and approve all
programs (except research) involving
pesticides on State property, and
(7) meet quarterly or at the call of
the Chairman or any member and report
annually to the Governor. "All pro-
posed rules and regulations pertain-
ing to the regulations or prohibitions
of the sale, use or application of
pesticides and labeling of pesticides
shall be submitted to and approved
by the committee before they are
promulgated and made effective."
1. pesticide
2. insecticide
3. fungicide
4. Nematocide
5. herbidide
6. insect
7. fungus
8. Nematode
9. weed
10. person
11. Director
12. custom appli-
cation of
pesticides
aircraft
ground equip-
ment
structures
13
14
15.
Violation of the Act is a mis-
demeanor subject to a fine of not
more than $200 for the first
51-H
-------
offense, and not more than $400
for each sul: ?equent offense.
Relevant laws Use and Application of 2, 4-D and
Related Herbicides LIU- Ann. St.
(1966), ch. 5, s 87(a) (1) to
87 (a) (8)]
Provides that county boards, or 10
or more commercial fruit or vege-
table producers, may petition the
Director of Agriculture, who may,
upon the finding of certain facts,
restrict or prohibit the use of
hormone-type herbicides in the area
set out in the petition.
"Economic Poison Law"
LIU. Ann. St. (1966) , ch. 5, s 87
(c) (1) to 87 (c) (13)3
Requires the registration and label-
ing of economic poisons (exempts
pesticides properly registered
under the USDA-FIFRA).
"Pesticides Control Law"
LIU. Ann. St. (1969), ch. 5, s 256
to 267H
The act authorizes the Director of
the Department of Agriculture or
the Director of the Department of
Public Health to issue regulations
relating to labeling, sale, use or
application of pesticides, and when
approved by the Interagency Committee
on Pesticides, to restrict or pro-
hibit the use and appleiaton of a
pesticide.
Tree Experts
LIU. Ann* St. (1967), ch. 5, s
163 et seq.]
The act requires examination,
licensing and regulation of per-
sons who diagnose, recommend treat-
ment, or provide care for ornamental
or shade trees.
52-H
-------
"Pest Control Compact"
LIU. Ann. St. (1968) , ch. 5, s 281]
An act to provide financial assis-
tance for timely and coordinated
effort of neighborhood States in
conducting effective pest control
activities when the State is
threatened by pest outbreaks (from
within or without) of more than lo-
cal concern. Provides for an
"insurance fund" with contributions
from members of the compact, from
which funds can be withdrawn for
financial support of pest control
or eradication activities. Pro-
vides for a governing body and a
formula by states for contribution
to the insurance fund. Law becomes
operative when enacted by 5 or more
states.
"The Insect Pest and Plant Disease
Act"[Ill. Ann. St.(1966), ch. 5,
s 61 ejt seq.]
Primarily a nursery inspection and
pest quarantine act. Amendments of
1969 authorize the Department of
Agriculture to prohibit in quaran-
tined areas farm practices favorable
to the development of pests, and to
require certain crop disposal
practices or crop treatments to
control or eradicate pests.
"Uniform Hazardous Substances Act
of Illinois'1'
[111. Ann. St. (1959), ch. Ill 1/2,
s 251 to 266 (a)]
Relates to "household type" chemi-
cals and exempts economic poisons
registered under the USDA Federal
Insecticide, Fungicide, and
Rodenticide Act. [Historical note -
An act to regulate the sale of Paris
Green was approved April 22, 1907,
and repealed in 1967].
53-H
-------
"Environmental Protection Act"
[111. Ann. St. (1966), ch. Ill 1/2,
s 1001 to 1051]
54-H
-------
be strengthened although financial responsibility and penalties
for misuse or violation are considerably more stringent than
those in Illinois. Laws passed in 1971 strengthen the
rules governing aerial application. Laws failing in 1971
would have materially strengthened the existing law, but
would be covered to some extent in the Administration bill.
The institution of a chemical technology review board
was regarded as a strong step forward. This board seemed
fairly constituted and with the advice of the advisory
committee, more than adequate to allow the Secretary of
Agriculture to promulgate additional laws and regulations.
Authority granted to the board interalia, to "adopt
rules relating to the sale, use, and disuse of agricultural
chemicals," has since been judged unconstitutional by the
Iowa Supreme Court. This rather effectively reduces the power
of the board. The vote for the Administration bill would
suggest that such powers might be restored to the board
when new state laws are formed in compliance with federal
regulations.
The contractor was unable to contact legislators from
Iowa for their views.
Kansas
Stringent financial responsibility marks the Kansas
Pesticide Use Law. Provisions for a pesticide board
55-H
-------
SYNOPSIS OF IOWA LAWS
Title
Prohibited acts
Exemptions
Licensing
qualification
application
examination
fees
issuance
nonresidents
Financial
responsibility
"Pesticide Act of Iowa"
Llowa Code Ann.(1969), s 206.1 to
206.12] Combination registration law and
commercial applicators law.
Unlawful to engage in custom application
of pesticides unless licensed by the
Secretary of Agriculture.
Farmer trading work with another and
State and Federal employees engaged in
research.
Proof of competency and responsibility
required.
"...properly executed application..."
required.
Written examination may be required.
Initial fee $10; renewal fee $5.
An annual license, expiring October 31,
shall be issued upon receipt of properly
executed application and payment of fee.
Secretary may refuse to renew license
during a period of investigation of
applicator's wrongdoing and may cancel
license if applicator is convicted of
a violation of the act. Aerial commer-
cial applicators must also be registered
with the Iowa Aeronautics Commission.
Licensing of a nonresident implies con-
sent to the appointment of the Secretary
of Agriculture as his agent for service
of legal process.
Proof of unencumbered net financial worth
of $5,000, or surety bond of $5,000, or
liability insurance policy of $5,000.
56-H
-------
Authority granted
to;
issue
regulations Yes.
enforce the act Yes.
delegate duties Yes.
restrict usage Secretary may ban pesticides in specific
areas or during certain periods of time
upon evidence of damage to crops or
livestock and may determine "...proper
use of pesticides..."
inspect
property Yes.
require records Yes.
cooperate
with others Yes.
publish
information Not specified in act.
conduct
courses Not specified in act.
regulate
storage, trans-
portation, dis-
posal of
pesticides Yes.
require
compliance
label Not specified in act.
license
equipment Not specified in act.
subpoena persons
or records Not specified in act.
report losses Not specified in act.
investigate
damages Not specified in act.
57-H
-------
Pesticide board (Text at end of Iowa digest).
Definitions
1. active
ingredient
2. adulterated
3. antidote
4. commercial
applicator
5. department
6. device
7. inert
ingredient
8. ingredient
statement
9. label
10. labeling
11. misbranded
12. person
13. pesticide
14. plant growth
15
regulator
registrant
16. Secretary
Penalties
Relevant laws
Title
Prohibited Acts
[Various] from $100 to $1,000 fine and
imprisonment for up to one year.
None.
LAWS PASSED IN 1971
Amendment to "Pesticides Act of Iowa"
House Bill No. 39.
Permits nonresident aerial applicator
who is licensed in his home state to
operate in Iowa.
Unlawful to operate unless he works
under the direct supervision of a
person holding a valid Iowa aerial
commerical applicator's license, or,
unless he acquires an Iowa aerial
applicator's license, posts bond in an
amount determined by the Secretary of
Agriculture, and registers with the
Iowa Aeronautics Commission.
Authority Granted
To;
report losses Yes.
investigate
damages
Yes, the losing party is required to
pay the cost of the claims investigation,
58-H
-------
Title An Act Relating to the Authority of the
Chemical Technology Review Board.
Senate File No. 326.
Amends the existing law to provide
specifically that the Chemical Techno-
logy Review Board can restrict or pro-
hibit the sale or use of any agricultural
chemical, and provides for a public
hearing on proposed regulations.
BILLS PROPOSED BUT NOT PASSED IN 1971
Title House Bill No. 602.
Defines "restricted use pesticides" as
any which the Secretary of Agriculture
specifies and as injurious to any-
thing other than the target pests.
Amends custom applicators law.
Title Senate Bill No. 85 (House Bill No. 269)
Creates a Department of Environmental
Quality with a Chemical Technology
Committee with poser to adopt rules on
sale, use and disuse of pesticides.
Provides for registration of pesticides
and for commercial applicator licensing.
59-H
-------
PESTICIDE BOARD
[Iowa Code Ann. (1969), s 206A-1 to 206A-6]
A chemical technology review board has been established
in the Department of Agriculture and consists of the
Secretary of Agriculture, the Commissioner of Public Health,
Director of the Iowa Natural Resources Council, Chairman
of the State Soil Conservation Committee, Chief Executive
of the League of Iowa Municipalities, State Conservation
Director, Dean of the College of Agriculture of Iowa State
University, a representative of a firm in Iowa actively
engaged in the manufacture of formulation of agricultural
chemicals, and a farmer experienced in the application of
agricultural chemicals.
The board has authority, interalia, to "adopt rules re-
lating to the sale, use, and disuse of agricultural
chemicals." (Agricultural chemicals are defined so as to
include pesticides and fertilizers).
There is also an advisory committee to the chemical
technology review board which consists of the Dean of
the College of Veterinary Medicine, the Dean of the
College of Medicine, an entomologist, botanist, geneticist
and an agronomist all from Iowa State University, plus
the technical secretaries of the Iowa Air Pollution Control
Commission, and two ecologists. The advisory committee
is charged with the responsibility of obtaining scientific
data and recommending rules regarding control of agri-
cultural chemicals.
60-H
-------
CHEMICAL TECHNOLOGY REVIEW BOARD
Secretary of Agriculture
L. B. Liddy (or designee, Robert H. Lounsberry)
State Capitol
Des Moines, Iowa 50319 Phone: 515/281-5321
Commissioner of Public Health
Dr. Arnold Reeve
State Health Department
Lucas Building
Des Moines, Iowa 50319 Phone: 515/281-5605
Director of Iowa Natural Resources Council
Othie R. McMurry - Vice-Chairman
Natural Resources Council
Grimes Building
Des Moines, Iowa 50319 Phone: 515/281-5914
Chairman of State Soil Conservation
George Annan
Clarinda, Iowa 51632 Phone: 712/542-2451
or
Designee Fred Cherry
Rowley, Iowa - Chairman Phone: 319/938-2721
Chief Executive of League of Iowa Municipalities
Robert E. Hays
444 Insurance Exchange Building
Des Moines, Iowa 50309 Phone 515/288-2119
Director of Iowa State Conservation Commission
Fred Priewert
Valley Bank Building
Des Moines, Iowa 50309 Phone: 515/281-5384
Dean, College of Agriculture, ISU of Science & Technology
Dr. Floyd Andre (or designee, Dr. S. A. Ewing)
123 Curtiss
Iowa State University
Ames, Iowa 50010 Phone 515/294-2518
Rep. of firm in Iowa actively engaged in manufacture
or formulation of agricultural chemicals appointed
by the Governor
Robert C. Yapp Chevron Chemical Company
2602 S.W. Caulder 7524 Hickman Rd.
Des Moines, Iowa 50321 Des Moines, Iowa 50321
Phone: 515/285/2829 Phone 515/276-6726
61-H
-------
Farmer experienced in application of agricultural
chemicals appointed by the Governor
Gordon E. Mau
R. R. #3
New Hampton, Iowa 50659 Phone: 515/394-3281
62-H
-------
ADVISORY COMMITTEE
CHEMICAL TECHNOLOGY REVIEW BOARD
Dean, College of Veterinary Medicine, ISU represented by
Dr. William B. Buck
Professor of Veterinary Toxicology
Veterinary Diagnostic Laboratory
College of Veterinary Medicine
Iowa State University
Ames, Iowa 50010 Phone: 515/294-1950
Dean, College of Medicine, University of Iowa represent-
ed by
Dr. Keith R. Long - Vice Chairman
Dept. of Preventive Medicine & Environmental Health
University of Iowa
Iowa City, Iowa 52240 Phone: 319/353-3616
Appointed by Dean, College of Agriculture, ISU
Entomologist
Dr. Harold Gunderson
104 Insectary, ISU, Ames, Iowa 50010
Phone: 515/294-1101
Agronomist
Dr. Regis Voss
117 Agronomy, ISU, Ames, Iowa 50010
Phone: 515/294-1923
Botanist
Dr. David Staniforth - Chairman
457 Bessey, ISU, Ames, Iowa 50010
Phone: 515/294-3870
Geneticist
Dr. John D.Imsande
8 Curtiss, ISU, Ames, Iowa 50010
Phone: 515/294-3908
Technical Secretary, Iowa Air Pollution Control
Commission
Dr. Charles L. Campbell, Technical Secretary
State Department of Health
Lucas Building
Des Moines, Iowa 50319 Phone: 515/281-5345
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Technical Secretary, Iowa Water Pollution Control
Commission
Mr. R. J. Schliekelman, Technical Secretary
State Department of Health
Lucas Building
Des Moines, Iowa 50319 Phone: 515/281-5345
Ecologist appointed by Dr. W. Robert Parks, Pres. of ISU
Dr. Larry D. Wing
62 Science
Iowa State University
Ames, Iowa 50010 Phone: 515/294-5176
Ecologist appointed by Dr. Willard Boyd, Pres. of U cf I
Dr. Richard V. Bovbjerg
224 Zoology Building
University of Iowa
Iowa City, Iowa 52240 Phone: 319/353-3421
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constructed similar to the Iowa law is viewed as a strong
point. Kansas is the only one of the five states in which
the Secretary is specifically required to issue regulations
relating to the storage and discarding of pesticides or
containers.
House Bill 1425, which did not pass in 1971, is seen
as an outgrowth of revived efforts on the part of health
officials in this state to identify and remedy the increasing
number of human injuries reported over the past several
years.
Although favored by all the congressmen from Kansas,
H. R. 10729 is seen as something of an intrusion on the
state's own pesticide law which two of the lawmakers see
as effective for their needs.
When interviewed in Washington, Mr. Thompson, Legis-
lative Assistant to Congressman Sebelius, indicated that
the Congressman's office had put out no statement of
views on the legislation since its passage, feeling that to
do so would be premature until action on the legislation
was taken by the Senate and the views of the two bodies
resolved in a bill sent to the President for signature.
He stated that the Congressman felt the most critical feature,
in terms of how states should structure their legislation
to coordinate with the federal, would depend on the method
used by the Federal agency in administering the legislation.
65-H
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Mr. Thompson indicated that the views reflected by
constituents of the First District of Kansas were consistently
to minimize the degree of federal intervention into local
activities. He stated that the farmers and their organized
groups recognize the need to provide sufficient regulation , so
that adverse actions by environmental groups would not
preclude the availability of pesticides. He stressed
the intention of the House Agriculture Committee to promote
effective education efforts by farm extension agents to
ensure adequate preparation of farmers desiring to qualify
for the use of pesticides under the applicator regulation
provisions of the legislation. He stated that the Congressman
felt there is a well established and effective means of such
education through the extension service and that this would
go a long way in preventing misuse of pesticides through
carelessness or ignorance. He foresaw concurrent benefits
in the more economic use of pesticides.
Mr. Cooper, Legislative Assistant to Congressman Skubitz,
indicated that the Congressman's mail, in general, had been
very light on the subject of the pesticide control legis-
lation. Most of the letters were from such groups as women's
garden clubs who were strongly in favor of passage of H. R.
10729. Mr. Cooper did not respond to any effort to get an
explanation of the Congressman's negative vote on the
amendment to provide state authority over and beyond that
which might be imposed by EPA. He indicated, however, the
66-H
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general feeling that Kansas has had a strong and effective
regulation of pesticides. He indicated a general favoring
of national standards on labeling and felt that the State
of Kansas could work within the legislation if the Senate
version were essentially that of H. R. 10729.
Minnesota
Minnesota's Spraying and Dusting Law was the first law
in the five-state study area to employ restricted use
pesticide classification. DDT and its metabolites and the
cyclodiences were severely restricted as of July, 1970.
Congressman Bergland's comments on the possible disadvantage
Minnesota farmers may have felt under such restricted use
were of particular interest and are included in their
entirety, as they show a rather complete grasp of the
entire environmental question - the total view possessed by
many lawmakers.
In total view, Minnesota already has more stringent
control than most states and compares favorably with the
Administration bill. No difficulty is seen in field
implementation of that legislation.
It should be admitted that Minnesota does not have the
same degree of agricultural involvement, as say, Iowa or
Illinois, as far as corn and soybeans are concerned. This
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SYNOPSIS OF KANSAS LAWS
Title
Prohibited acts
Exemptions
Licensing
qualifications
application
examination
fees
issuance
nonresidents
"Kansas Pesticide Use Law"
[1970 Session Laws of Kansas, Chapt. 2]
Unlawful to engage in the business of
applying pesticides to the land of
another unless licensed by the Secre-
tary of the State Board of Agriculture
Structural pest control operators,
persons working on own premises or
those of another in an exchange of
work, shade tree and ornamental
shrub work, and Government research
personnel
Must possess adequate knowledge con-
cerning proper use and application
of pesticides.
Must be in writing to the Secretary
on a designated form furnished by
the Secretary's office.
Type not specified, but a number of
subjects are included in the exami-
nation.
Pesticide business applicator $10;
pesticide equipment operator $10;
public equipment operator $10; busi-
ness license $25; government agency
registration $25; each unit of equip-
ment $10.
Issued upon being found qualified,
and filing of bond or insurance;
licenses expire at erid of calendar
year in which issued.
Must file written consent to accept
service of legal process and to be
sued for damages in Kansas courts.
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Financial
responsibility
Authority granted
to:
Aggregate amount of'liability insur-
ance to be not less than $25,000.
First unit of equipment shall carry
$8,000 liability insurance; addi-
tional units to carry $2/000.
issue regulations Yes.
enforce the act Yes.
delegate duties Yes.
restrict usage
inspect property
require records
cooperate
with others
publish
information
conduct courses
regulate storage
require
compliance
with label
license
equipment
subpoena persons
or records
report losses
investigate
damages
Yes; additionally county commissioners
may restrict pesticides in their
county if such restrictions are ap-
proved by the Secretary of Agriculture,
Yes.
Yes.
Yes
Yes.
Not specified in act.
The Secretary "shall" issue regula-
tions governing discarding and stor-
ing pesticides or pesticide containers
Implied.
Yes.
Yes.
Yes.
Yes.
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Pesticide board
Definitions
Penalties
Relevant laws
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
board
defoliant
desiccant
equipment
fungus
insect
land
nematode
person
pest
12
13
14
15
16
17
18
Thirteen-member board representing
(1) health, (2) water resources,
(3) forestry, fish and game, (4)
geological survey, (5) agriculture,
(6) soil conservation, (7) live-
stock commission, (8) House of
Representatives, (9) Senate, (10)
custom ground applicator, (11) cus-
tom aerial applicator, (12) pesti-
cide industry, and (13) an agri-
cultural user of pesticide. The
board is advisory in nature and
has no regulatory authority.
pesticide business
applicator
pesticide equipment
operator
pesticide public
operator
plant regulator
rodent
Secretary
snails or slugs
11. pesticide 19. weed
Violation of the act or regulations is
an unclassified misdemeanor, subject
to a fine of not less than $100 and
not more than $500.
"Kansas Pest Control Act"
[Kan. Stat. Ann. (1964), s 2-2401
et seg.]
Licenses and regulates:
1. termite control
2. structural insect control
3. fumigation, and
4. tree pest control
"Kansas Agricultural Chemical Act
of 1947"
[Kan. Stat. Ann. (1964), s 2-2001
et seq.]
"Kansas Food, Drug, and Cosmetic Act"
[Kan. Stat. Ann. (1964), s 65-619
et seq.]
Hazardous Household Articles
[Kan. Stat. Ann. (1964) , s 65-2701
et seq.]
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LAWS PASSED IN 1971
Title
Exemptions
Title
Exemptions
Title
House Bill 1523
Those persons who apply pesticide
to shade trees and ornamental shrubs,
if they are licensed under Pest Con-
trol Act as pest control operators,
are exempt from custom applicator's
license requirement.
House Bill 1524
Persons who apply pesticides to
shade trees and ornamental shrubs
if they are licensed under the
Pesticide Use Law are exempt from
Pest Control Act licensing require-
ment.
House Bill 1622
Postpones effective date of Pesti-
cide Use Law from January 1, 1972
to January 1, 1973.
BILLS PROPOSED BUT NOT PASSED
Title
Licensing
conditions
Authority granted
to:
restrict usage
require records
publish informa-
tion
House Bill 1425
sale, purchase and use by permit only
Secretary of Health
Yes.
Yes.
Yes.
72-H
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state is richly endowed with natural waters and as a
consequence is quite sensitive to the preservation of this
resource. In a sense they can "afford" to be more restrictive
in their thinking than the other states mentioned.
Congressman Bergland is a member of the House Agriculture
Committee which developed H. R. 10729. He indicated that
he saw the pesticide control legislation as a part of the
overall effort in pollution control. The states have
repeatedly urged Congress to act on minimum federal
standards in all areas of pollution control. One of the
viewed objectives of such action is to avoid the situation
where an industry or comparable group takes advantage of
the differences in state regulatory control to gain special
concessions under the threat of moving their activities
and the economic benefits thereof to a state with less
strict regulations.
Mr. Bergland did not feel that the farmers of Minnesota
have been at any disadvantage to farmers from other states
because of the restrictions on the use of certain pesticides.
He stated that the contacts he has had with farmers and farm
organizations have at no time indicated such a disadvantage.
The general tenor of comments from his home district during
the period when the legislation was under consideration was
favorable to passage. The only comments he has received
since he voted for the bill have been from individuals who
73-H
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expressed the view that legislation along the line of H. R.
10729 has been long overdue.
The Congressman continually stressed the relationship
of this legislation to the total pollution control effort.
He used as an example the provision for indemnification of
those holding stocks of a pesticide that has been subsequently
banned from use by the EPA Administrator. As he put it,
without indemnification the holder of such unusable supplies
would undoubtedly take the cheapest means of disposing of
this excess stock. The result might well be indiscriminate
dumping into an adjacent water course or disposal within a
city dump with the potential for seriously contaminating
both subsurface waters and surface waters by virtue of
run-off. To qualify for the indemnification the holder
of the pesticides stocks will need to return them to a
designated point where EPA will be able to dispose of them
without hazard to the environment.
The Congressman also stressed the efforts to avoid
arbitrary or capricious action on the part of the Administrator.
One specific exampled cited was the retention of the require-
ment for scientific review to a panel of the National
Academy of Science. He favored the retention of this
provision as a protection equally for the Administrator in
documenting the background of his decisions and for the
public in ensuring careful evaluation of the scientific
74-H
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basis for any action with respect to pesticides.
Mr. Bergland saw no interference in the role of state
agencies. He indicated that with the exception of one or
two states, all states have some organization for pesticide
control and viewed these as being a part of the total state
pollution control effort. He stressed the role of the
Department of Agriculture and the commitment of the
Department to an extensive effort by the extension service
in connection with the certification of private applicators
as well as commercial applicators. He views the network
of Federal, state, and county agricultural extension agents
as a major resource in educating the users of pesticides
to such practices as will provide for the concurrent
accomplishment of improved agricultural production and
protection of the environment. He stressed the need for more
research on alternate means of control of agricultural pests
through the research efforts of the Department of Agriculture.
In commenting on the declining research efforts of pesticide
manufacturers, he defended the provision for protecting the
research data submitted by a pesticide manufacturer in
connection with a registration application. He pointed out
that under a pattern of limiting use of pesticides the oppor-
tunity of the manufacturer to recover his research and
development costs is diminishing and cannot stand the
competition of small manufacturers utilizing data which
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SYNOPSIS OF MINNESOTA LAWS
Title
Prohibited acts
Exemptions
Licensing
qualifications
application
examination
fees
issuance
nonresidents
Financial
responsibility
Authority granted
to;
issue regulations
enforce the act
delegate duties
Minnesota Spraying and Dusting Law
LMinn. Stat.(1969), s 18.031 to
18.0363
Unlawful to spray or dust for hire
unless licensed by the Commissioner
of Agriculture.
Homeowners and farmers on own pre-
mises, or on neighbors' premises
when not for hire.
Determined by Commissioner to be
"qualified."
To be made on form provided by
Commissioner.
Written.
Original license or renewal $5;
each machine $2.
Issued annually on calendar year
basis, renewable by examination
or by evidence of having completed
approved training.
No provision for reciprocity.
Not specified in act.
Yes.
Yes.
Yes.
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restrict usage
inspect property
require records
cooperate with
others
publish information
conduct courses
regulate storage,
transportation, or
disposal of pesti-
cides
require compliance
with label
license equipment
subpoena persons
or records
report losses
investigate
damages
Pesticide board
Definitions
Yes.
Not specified in act.
Yes.
Not specified in act.
Not specified in act.
Not specified in act.
Yes.
Yes.
Not specified in act.
Not specified in act.
Not specified in act.
Not specified in act.
None.
1. act
2. aerial applicator
3. aircraft
4. application
5. application and use
6. applicator
7. approved agency
8. authorized agent
9. commissioner
10. custom spraying or dusting
11. dealer's permit
12. device
13. economic poison
14. equipment
15. license
16. permit
77-H
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Definitions
Penalties
Relevant laws
17. person
18. pest
19. pesticide
20. pollution
21. registered approved use
22. restricted use
23. spraying or dusting
operations for hire
24. users permit
Violation of the act is a misdemeanor,
Minnesota Economic Poisons and
Devices Law LMinn. Stat. (1969) , s
24.069 to 24.077]
Structural Pest Control
LMinn. Stat. (1969), s ISA.01 to
ISA.11]
Interstate Pest Control Compact
LMinn. Stat. (1969), s 18.62 to
18.71]
"Hazardous Substances Labeling
Act" [Minn. Stat.(1969), s
24.32 to 24.42]
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BILLS PASSED IN 1971
Title
Licensing
examination
fees
issuance
Authority granted
to;
enforce the act
delegate duties
inspect property
require records
Title
administration
Senate Bill No. 624
Yes.
Registration fee of $7.00.
Upon examination. Custom applicators
must have license endorsed to apply
pesticides to waste. Requires identi-
fication card for custom applicators
and licensing of dealers of restrict-
ed use pesticides.
Yes.
Yes.
Yes.
Yes.
House Resolution 1-Y.
Provides for supervision of stand-
ing committees during interim be-
tween regular sessions and that
permissible studies may include
"Economic Poisons," "Pollution
Control Agency Role as it Relates
to Agricultural Practices," and
"Monitoring and Enforcement of
Pollution Standards."
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BILLS PROPOSED BUT NOT PASSED
Title
Prohibited acts
Title
Prohibited acts
Title
Provisions
Title
Provisions
Title
Prohibited Acts
House Bill No. 163 (Senate Bill
No. 1938).
Bans sale or use of mercury, DDT,
aldrin, heptachlor, endrin, dieldrin,
lindane and DDE (any any other
pesticide viewed as environmentally
harmful in opinion of the Board of
Health) except under permit in
extreme emergency.
House Bill No. 365 (Senate Bill
No. 1772).
Bans sale or use of pesticides in
cities unless approved by Commissioner
of Agriculture.
House Bill No.
No. 624).
606 (Senate Bill
Enacts AAPCO Model Pesticide Use
and Application Act with modifi-
cations. Adds dealer licensing
provision.
House Bill No. 14X
Sale or use of pesticides contain-
ing mercury or DDT would be mis-
demeanor except for extreme
emergency authorized by environ-
mental pesticide review committee
created by the bill. Committee
may add other pesticides to the
restricted list.
Senate Bill No. 650 (House Bill
No. 927)
Bans use of chemical pesticides or
defoliants by public service
corporations on rights-of-way.
80-H
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they did not themselves develop to register and produce the
new pesticide. During the interview the Congressman also
turned attention to other aspects of pollution control of
impact on his farm constituency. These included the problems
of run-off from feed lots, the investment required by dairy
farmers in controlling discharge of wastes from their dairy
barns, and the increasing problem that the State of
Minnesota is having with the eutrophication of its many
valuable lakes.
Missouri
Missouri holds the distinction of having the weakest
of the state laws. Two bills introduced in 1971 were fought
strenuously by dealers and manufacturers. At first, public
hearings were held and testimony received. Finally the
manufacturers and applicators acquiesced, reportedly feeling
they could live with the House committee substitute for
315 and 571. Biologists and environmentalists were also
satisfied. However, when brought to a vote, the bill
failed to pass and both sides appeared to be surprised. At
a special session (November 18, 1971) it was decided that
proponents of the bill(s) would wait and see what happened
to the Administration bill in the Senate (H. R. 10729).
Thus, Missouri is left with the old economic poison law of
1955, as revised in 1969. It does specify that pesticides
81-H
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be registered and provides for understandable labeling,
packages, transport and sale.
The contractor, in its search for information in the
five states, was impressed by the relationship between no
law or an ineffective pesticide law and some other factors.
For example, all states responded with lists of registered
commercial applicators when asked, except Missouri, which
apparently does not even have such a list. Missouri
farmers of the five states appeared to be the most uninformed
about pesticide use, and investigations indicated that some
of the most flagrant violations of use, including
container disposal, tank flushing, etc., occurred in
Missouri. In addition to this general picture, examples of
unlicensed operators who utilized unbranded bags of "material"
were related to more frequently from Missouri.
The House Committee Substitute Bill is based on the
AAPCO Model Bill; thus it would appear to have little problems
of passage with needed revision if the Administration bill
(H. R. 10729) is passed by the Senate.
Effects of Laws on Environmental Quality
The following Notice to Manufacturers, Formulators,
Distributors and Registrants of Economic Poisons of
Cancellation of Registration Under the Federal Insecticide,
Fungicide and Rodenticide Act (FIFRA) of Products Containing
82-H
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MISSOURI
(No pesticide use and application
law)
Relevant laws "Missouri Economic Poison Law of
1955" [.Mo. Rev. Stat.(1969), s
263.270 to 263.380]
BILLS PROPOSED BUT NOT PASSED, 1971
Title House Bill No. 315
enacts AAPCO Model Pesticide Use and
Application Act including restrict-
ed use/permit section; adds dealer
licensing provision.
Title House Bill No. 571
prevents Undesirable effects from pesticide
which degrade environment and are
a menace to health, safety and
welfare.
power to regulate Yes.
power to register Yes, after hearing to determine
potential degradation of environ-
ment.
to restrict/prohibit
use Yes.
to license Yes.
Title House Committee Substitute Bill
for House Bill No. 315 and House
Bill No. 571.
enacts AAPCO Model Pesticide Use and
Application Act with Modifications,
power to regulate Yes. Use and sale in the public
interest.
83-H
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grants authority
tO: Commissioner of Agriculture to
regulate handling, transportation,
storage, disposal, display, and
distribution of pesticides and con-
tainers and to regulate type of
containers. Includes restricted
use/permit, dealer licensing and
stop sale provisions.
84-H
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DDT, dated January 15, 1971 (reprinted on the following pages)
and the accompanying statement of reasons underlying the
registration decisions are presented in their entirety
since these decisions represent the result of several court
decisions, volumes of scientific testimony, public hearings,
etc. Initiation of the administrative process whenever
there is a substantial question about the safety of a
registered pesticide is the key to control under the old
FIFRA. Such a substantial question concerning the safety
of DDT was raised and the subsequent action taken. It
should be noted that many lawmakers view this provision of
FIFRA as sufficient and, as a result, were not willing to
vote for the current Administration bill, feeling that its
additional restrictions were unwarranted. In any event the
contractor views the current Administration bill as far
less cumbersome and totally a more workable instrument for
environmental protection under present conditions.
The recent decision (December 12, 1971) that DDT may
be used only in interstate or export markets is viewed by
the contractor as a wise administrative decision. On a
number of occasions we were informed of abuses in local
formulation or repackaging of DDT-containing products which
were then used entirely within that state and since the
state had no adequate laws for registration, a potentially
harmful product was given free use.
85-H
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ENVIRONMENTAL PROTECTION AGENCY
Washington, D.C. 20250
Pesticides Regulation Division
PR Notice 71-1
January 15, 1971
NOTICE TO MANUFACTURERS, FORMULATORS, DISTRIBUTORS
AND REGISTRANTS OF ECONOMIC POISONS
Attention: Person Responsible For Federal Registration
of Economic Poisons
Cancellation of Registration Under the Federal
Insecticide, Fungicide, and Rodenticide Act of Products
Containing DDT
The insecticide DDT has been used extensively in the control of
agricultural pests and insect vectors of diseases. The continued
widespread use and the relatively slow rate of dissipation have
resulted in contamination of the environment with low levels of DDT.
Residues of this chemical are widespread in the environment and can
be detected in areas far removed from sites of any known application.
Although the levels of DDT in the environment are in most cases
relatively low, they have been of concern to the scientific community
for several years.
Recognizing the importance of this issue, the Department of
Agriculture took steps to restrict the uses of DDT. These included
the cancellation of registration for certain DDT products, and the
publication of a notice in the Federal Register on November 25, 1969,
proposing to eliminate other uses at a future date. This notice
afforded interested persons an opportunity for a period of 90 days to
submit views and comments. After consideration of the comments
received, additional cancellation actions were taken in August 1970.
On December 2, 1970, the functions of the Secretary of Agriculture
and the Department of Agriculture under the Federal Insecticide,
Fungicide, and Rodenticide Act (FIFRA) were transferred to the
Administrator of the Environmental Protection Agency. Since that
date, this Agency has been reviewing previous actions and recommenda-
tions relating to the use of DDT, together'with the relevant information
available to the Agency. It has been our intention to issue at the
earliest possible date a notice covering all of the remaining uses of
DDT.
On January 7, 1971, the United States Court of Appeals for the
District of Columbia Circuit in the case of Environmental Defense
Fund, et al. v. William D. Ruekelshaus. Administrator of the
Environmental Protection Agency, et al.. held that the FIFRA requires
80-H
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the Secretary "to issue notices and thereby initiate the
administrative process whenever there is a substantial question
about the safety of a registered pesticide." The Court further
stated that "when, as in this case, he reaches the conclusion
that there is a substantial question about the safety of a
registered item, he is obliged to initiate the statutory
procedure. . ." The Court found that the statement of the
Secretary of Agriculture filed in the case "makes it plain that
he found a substantial question concerning the safety of DDT. . ."
The Court then ordered that the Administrator issue notices of
cancellation of registration with respect to the remaining uses
of DDT, and thereby commence the administrative process.
In view of the above, and in accordance with the provisions of
Section 4c of the Federal Insecticide, Fungicide, and Rodenticide
Act (7 U.S.C. 135b(c)), it has been determined that all
registrations of DDT products should be canceled for the reason
that continued registration of these products is contrary to the
provisions of Sections 2z(2)(c), 2z(2)(d), and 2z(2)(g) of the Act
(7 U.S.C. 135(z)(2)(c), 135(z)(2)(d), 135z(2)(g)). Accordingly,
you are hereby notified that the registrations of all products
containing DDT not heretofore the subject of a cancellation notice
are canceled, effective 30 days following receipt of this notice,
unless the procedures set forth in Section 4c of the Act are invoked.
Lowell'E. Miller
Acting Director
87-H
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Environmental Protection Agency
REASONS UNDERLYING THE
REGISTRATION DECISIONS
CONCERNING PRODUCTS CONTAINING
DDT. 2.U.5-T. ALDRIN AND DIELDRIN
March 18, 1971
INTRODUCTION
Reorganization Plan No. 3 of 1970 transferred to the Environmental
Protection Agency the principal responsibility for Federal regulation
of "economic poisons" — a term which includes those chemical substances
which are commonly called pesticides. This regulation is conducted
under (l) the Federal Insecticide, Fungicide and Rodenticide Act (7
U.S.C. 8§ 135-13$k) ("FIFRA") which requires registration of all
pesticides introduced into interstate commerce, and (2) SB U06,
and U09 of the Food, Drug and Cosmetic Act (21 U.S.C. §8 &6,
and 3U8), which provides for the establishment of maximum tolerances
for residues of such economic poisons in or on food.
Under these provisions, this Agency is required initially to pass
upon requests from manufacturers for registration of new economic
poisons to determine whether they meet a variety of statutory require-
ments concerning safety and efficacy. The Agency must also review
continuously previously registered economic poisons in order to insure
continued compliance with these requirements in the light of the
developing scientific data and concern for the public health. If
this continuing review raises any substantial questions of safety,
notices of cancellation must be issued which initiate the administrative
process of review. If the threat is so immediate that it cannot await
the resolution of this administrative procese, registration of the
pesticide must be suspended. At the conclusion of the administrative
process, a final order with respect to registration is issued. In
addition, a vigorous research and monitoring program is contemporaneously
required to review the knowledge necessary to set meaningful tolerances.
This statement of reasons deals with particularity with the extent
to which the registration should be continued for the following pre-
sently registered economic poisons: products containing DDT, 2,U,5>-T,
aldrin or dieldrin.
The economic poison DDT (Dichloro-diphenyl-triohloroetliane) was
the subject of a decision announced by the United States Court of Appeals
for the District of Columbia Circuit on January 7, 1971 (Environmental
Defense Fund. Inc. v. Ruokelshaus, _F.2d (D.C. Cir., January 7,
1971).This decision required this Agency to take two steps: (l) to
commence the administrative process for cancelling the registrations of
all products containing DDTj and (2) to consider whether the present
-------
information available to this Agency warrants suspending the regis-
tration of these products immediately. Pursuant to this order of the
court, notices of cancellation were issued January l£ of this year.
(PR Notice 71-1).
The economic poison 2,ii,5-T (2,^,5-trichlorophenoxyacetic acid)
was the subject of a separate decision of the same court also announced
on January 7, 1971. (Vellford v. Ruckelshaus, F.2d (D.C.
Cir. January 7, 1971).) tinder this latter decision, this Agency is
required to consider further the earlier decisions of the Government
regarding registration of this economic poison for use on food crops,
and to articulate the factors considered by this Agency in arriving at
such decision.
*/ *-»/
The economic poisons dieldrin and aldrin have been the subjects
of particular administrative investigation in the' last year. This review
has resulted in cancellation of the registrations for some uses of these
products as well as an ongoing analysis at both the state and local level.
In addition, a petition addressed to the Administrator of this Agency
was filed on December 2, 1970» by the Environmental Defense Fund,
Incorporated. This petition requested both suspension and cancellation
of all products containing these two economic poisons.
In order to comply both with the orders of the court referred to
above, and in order to articulate more fully the legal, scientific, and
policy considerations on which our decisions are based, we have pre-
pared the following statement.
I
THE STATUTORY MANDATE
Prior to the transfer of the responsibility to administer the FIFRA
to this Agency, such duty was the responsibility of the Secretary of
Agriculture.Zll/ Tn the administration of the statute before 1961;, the
Secretary of Agriculture was compelled to register any economic poison
upon the demand of any applicant for registration. In the case of a
registered product which did not appear to comply with the provisions
jj/ l,2,3,li,10,10-hexachloro-6,7 epoxy-l,i|,Ua,£,6,7,8,8a-ootahydro-
exo-1, i|.-endo-$, 8-dimethanonaphthalene.
**/ l,2,3,^,10,10-hexachloro-6,7 epoxy-l,U,Ua,5,8,8a-hexa-hydro-exo-l,
il-endo-5 > 8-dimethanonaphthalene.
*•**/ The responsibility for the establishment of tolerances under the Pood,
Drug and Cosmetic Act was previously assigned to the Department of Health,
Education and Welfare. Part of the rationale in establishing the Environ-
mental Protection Agency was to consolidate these functions.
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of the FIFRA, the Secretary was authorized to cancel the registration,
bus was required to issue a registration under protest, and to pursue
any actual withdrawal of the chemical in a judicial forum.
In response to increased concern about the hazards of pesticides,
the PIFRA was amended in 1961+ by striking the requirement to register
under protest and by providing instead mechanisms whereby the Secretary
could initially refuse to register an economic poison, or could cancel
or suspend an existing registration. The amendments provided adminis-
trative procedures by which an applicant or registrant could challenge
the determination of the Secretary. The legislative purpose in enacting
these amendments was to grant to the administrative officer charged
with enforcement of the Act more effective procedures by which to pro-
tect the public by removing from the channels of interstate commerce
any economic poison whose safety or effectiveness was open to sub-
stantial doubt (H.R. Rep. No. 11?$, 88th Cong., ?d Sese. (196U)).
Statutory Teetn
The statutory scheme pertaining to registration is complex. The
hrust of the present PIPRA is to prohibit;/
i-f;
. those economic poisons which do not contain directions for use
which are necessary and adequate for the protection of the public;
. those economic poisons which do not contain a warning or caution
statement which is adequate to prevent injury to man, vertebrate animals,
vegetation and useful invertebrate animals; and
. those insecticides or herbicides which, when used as directed
or in accordance with commonly recognized practice,, are injurious to man,
vertebrate animals or vegetation (except
In applying these statutory tests.; the final decision with respect
to whether a particular product should be registered initially or should
continue to be registered depends on the intricate balance struck between
the benefits and dangers to the public health and welfare resulting from
its use. The concept of the safety of the product is an evolving one
which is constantly being further refined in light of our increasing
knowledge. These considerations formed the basis of the Administrator's
first final cancellation order issued after completion of the adminis-
trative procedures set forth in the statute. In re Stearns Electric
Paste Company, I.P.&R. Dirt. 13, entered January k, 1971-
*/Section UG of the amended FIPM authorizes the Administrator to refuse
to register an economic poison if the data presented is insufficient to
support the claims made for it, or if its proposed label does not comply
with the various provisions of the Act.
**/ The Act provides that products x^'hich do not conform with these pro-
visions are "misbranded" and may not be registered pursuant to the Statute.
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Burden of Proof
A product which has previously been registered may either be
cancelled or suspended if the Administrator determines that the product
doea not comply with these same provisions. It is clear from the sta-
tute, the legislative history, and judicial construction that the burden
of establishing the safety and effectiveness of a product remains with
the registrant from the time of initial application through continued
registration of the product.jy
Cancellation
Recognition of the burden of proof is crucial to an understanding
of the cancellation process. Judicial interpretations have emphasized
that this initial step in the administrative process of deregistration
is triggered whenever the Administrator determines from all the data
before him that there is a substantial question as to the safety of a
product. Issuance of a notice of cancellation is appropriate whenever
it is decided that it appears that the registrant has failed to discharge
his continuing burden of proof that the product meets the statutory
standards including those pertaining to safety and efficiency.
Environmental Defense Fund. Inc. v. Ruckelsnaus. supra, Slip op. at lk
Recognizing the various considerations which must necessarily underlie
final decisions as to a particular product, the Court also stated that
the
"cancellation decision does not turn on a scientific
assessment of hazard alone. The statute leaves room
to balance the benefits of a. pesticide against its risks."
Slip op., p. 15. See also S. Rep. No. 1379, 89th Cong.,
2d Sess. 13, 27, 52, 6U-65
S. Rep.
(1966).
The cancellation decision is effective thirty days from the receipt
of notice of cancellation by the registrant unless challenged by the
registrant. Extensive administrative procedures are available to a
registrant who chooses to challenge the notice of cancellation of
^/See, £.£., S. Rep. No. 573» 88th Cong., 1st Sess. 5 (1963); H.R. Rep. No.
1125, 88th Cong., 2d Sess. 1+ (196^); llth Rep. of the Commission on Govern-
ment Operations, H.R. Rep. No. 91-637, 91st Cong., 1st Sess. (1969);
Environmental Defense Fund, Inc. v. Ruckelsnaus, supra; Wellford v.
Ruckelshaus, supra; In Re Stearns Electric Paste Company, supra; 7 C.P.R.
276^.1, et seq., formerly 361^.1, et seq.
**/ Acting pursuant to this standard and as directed by the court, the
Administrator has issued notices of cancellation for all registered
domestic uses of DDT.
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registration of his product (as well as for an applicant who challenges
a refusal to register). He may exercise his statutory right to have a
scientific advisory committee convened, or to have a public hearing
held, or both.
Scientific Advisory Committee
When a statutory scientific advisory committee is convened, it is
charged to receive and consider all scientific evidence concerning the
registration of the economic poison in question. After consideration
of all such data, the advisory committee presents its report and recom-
mendations as to the scientific questions posed by the registration to
the Administrator. The Administrator then makes a final policy judgment
based on the scientific assessment and "all other data before him" as
to whether to affirm the initial refusal to register or notice of can-
cellation or suspension. The registrant has the further option of
requesting that the question be examined at a public hearing. At the
conclusion of these administrative proceedings, judicial review is available
*o a registrant or applicant. (Section Ud.)jy Pending the issuance of
a final cancellation order at the conclusion of the administrative
process, the economic poison may still be shipped in interstate commerce.
Suspension
The FIFRA also provides that the Administrator may suspend the
registration of an economic poison immediately if he determines that
such action is necessary to prevent an "imminent hazard to the public."
This provision permits the Administrator to protect the public by
prohibiting further interstate shipments of an economic poison so
dangerous that its continued use should not be tolerated during the
pendency of the administrative process.
The articulation of the criteria employed in applying the legal
standard for suspension first adopted by the Seventh Circuit Court of
Appeals^/is now well established. It was drawn from the legislative
history of the 1962 amendments to the Food, Drug, and Cosmetic Act,
which inserted a similar phrase in that statute,iUfy since the
*/However, section lj.d provides that a final cancellation order may be
stayed only by court order.
**/ Nor-Am Agricultural Products, Inc. v. Hardin, _ F.2d (July l£,
1970), vacated on other grounds en bane, F.2d ~ (7th Cir. Nov. 9, 1970).
•*•**/ On December 7, 1970, the Food and Drug Administration published in
the Federal Register a definition of "imminent hazard to the public
health" which invited public comment thereon. Both the FDA proposal and
the comments have been reviewed by this Agency.
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legislative history of the FIFRA amendments is silent on the point.
These criteria received tacit judicial acquiescence in Wellford v.
Ruckelshaua, supra, Slip op., at p. %.
Based upon these legal guidelines, this Agency will find that an
imminent hazard to the public exists when the evidence is sufficient
to show that continued registration of an economic poison poses a
significant threat of danger to health, or otherwise creates a hazardous
situation to the public, that should be corrected immediately to prevent
aeriouo injury, and which cannot be permitted to continue during the
pendency of administrative proceedings. An "imminent hazard" may be
declared at any point in a chain of events which may ultimately result
ir. harm to th^ nublie. It is not necessary that the final anticipated
injury actually have occurred prior to a determination that an "imminent
hazard" exists. In this connection, significant injury or potential injury
to plants or animals alone could justify a finding of imminent hazard
to the public from the use of an economic poison. The type, extent,
probability and duration of potential or actual injury to man, plants
and animals will be measured in light of the positive benefits accruing
fxvaa. for example, use of the responsible economic poison in human or
animal disease control or food production.
This Agency's responsibility for the setting of tolerances for
economic poison residues in or on foodstuffs compliments the registration
program. Safety from the perspective of the remote consumer is, of
course, the primary and most pervasive criterion. Review must be
continuous to reflect constantly changing knowledge upon whioh to base
a determination of safe residues. As the Court of Appeals for the
District of Columbia Circuit recognized, if there is no scientific
basis for a reasonable estimate of safe dosage level "it would obviously
be impossible to meet the congressionally imposed burden of establishing
the safety of a residue of such a pesticide." Environmental Defense
Fund, Inc. v. Dept. of Health, Education, and Welfare, U28 F.2d 1083,
at 1092 (1970)- Thus the tolerance mechanism functions to prevent
unwanted residues from entering the human food chain and to reinforce
the restrictions placed on a registered pesticide.
II
FORMPfLATION OF STANDARDS
The Court directed in Environmental Defense Fund, Ino. v. RuckelBhttUB.
that the "formulation of standards" applicable to the translation of the
statutory standards to given factual situations be entrusted to the
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Administrator, who "has an obligation to articulate the criteria that be
develops in making each individual decision." Slip op., pp. 19, 20.
The Court directed that consideration be given to the question of whether
general standards could be promulgated UHat will determine whether
cancellation or suspension was warranted in specific cases. However,
the Court further recognized that such general standards might not be
feasible. As an alternative, the Administrator was directed to articulate
in each case the criteria applied. After intensive review of this issue,
the Administrator has determined that it is not at this time feasible
to articulate meaningful general standards which can be dispositive of
all cases of cancellation or suspension. Rather, the Administrator
has determined that the criteria applied to particular products be
articulated on a case-by-case basis.
The problem of universally applicable criteria is also acute when
facing the question of determining tolerances for pesticide residues on
foodstuffs. In Environmental Defense Fund, Inc. v. Department of Health.
Education, and Welfare. U28 F.2d 1081 fD.G. Cir. 1970), the Court ar-
ticulated the concerns which bear upon the determination of tolerances
for DDT on foodstuffs and ordered that the Administrator consider the
feasibility of adopting zero tolerances for that economic poison. The
Pood and Drug Administration, the predecessor of this Agency in adminis-
tering the Act, proposed reduced tolerances for DDT on December 5, 1970
(35 F-R- 18,531)» prior to the issuances of notices of cancellation as
to all registrations of DDT.i/
After balancing the desirability of giving general guidance and the
magnitude of the variables intrinsic j.n particular decisions, the
Administrator has determined that the standards and criteria necessary
for setting pesticide tolerances on foodstuffs must also be developed
on a case-by-case basis.
Despite the impossibility of articulating meaningful criteria that
can provide a formula for the decision of the particular case, as
discussed above, certain general factual and policy variables
can be stated. For example, any discussion of the term "safety"
in the context of chemical economic poisons must recognize that each
of these substances is by design toxic to some form of life. It is
designed to kill or otherwise adversely affect a particular pest.
Modern technology has not yet developed to the point where such toxic
^/On January U, 1971. "the Environmental Defense Fund and the other
parties to that litigation filed comments opposing this proposal.
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substances can be designed with scalpel-like precision — that is,
toxic only to one discrete pest. Thus, economic poisons are to some
degree ecologically crude because they have some undesired effect on
various non-target species or strains of vegetation.
These unwanted side effects — danger to non-target species —
are acceptable only to the extent that the benefits accruing from
use of a particular economic poison outweigh these adverse results.
For example, certain classes of economic poisons are particularly
effective against disease-bearing insects. This class of economic
poisons has permitted the dramatic steps in disease control which
have been realized on a worldwide scale in the last two decades.
Certain economic poisons have been vital to the general well-being of
mankind by permitting vast increases in the amount and quality of produce
available. The dramatic increases in yields per acre in the agricultural
sector achieved in the last generation are to some degree due to use of
various economic poisons. The chronic problem of world hunger has thus,
to some extent, been ameliorated by use of these chemical substances.
In addition, the persistent economic poisons — those whose chemical
characteristics permit their continued toxicity to pests over a rela-
tively long period of time — have the added economic benefit of reducing
the number of applications of the chemical needed, and thereby lowering
labor costs, and additionally lowering initial application rates.
Nonetheless, this Agency will not permit the triumphs of public health
achieved in the past to be a continuing justification for use of a par-
ticular substance in the future. To this extent, the requirements for
use of economic poisons in a relatively developed country such as the
United States may force a divergence from what is permitted in the
developing countries where the public health impetus for control of such
diseases as malaria may require continuing use of pesticides whose side
effects would no longer be tolerable here.jy This Agency is fully
aware of its statutory directive and duty to the public to place the
dictates of health and safety over economic considerations in its scale
of values. But health narrowly defined must be distinguished from the
broader concern of environmental quality — the synthesis of all of the
variables in the ecosystem.^J
j*7As the Surgeon General pointed out in a letter to this Agency dated
February 3» 1971» DDT is presently being used in foreign countries to pro-
tect some 350,000,000 people from the scourge of malaria. Ninety percent
of this DDT is produced in the United States, and is distributed through
AID and UNICEF. This cardinal role in world health is unaffected by our
decisions as to domestic use. We do not presume to regulate the felt
necessities of other countries.
**/ See Report of the Secretary's Commission on Pesticides and Their Rela-
tionship to Environmental Health, p. 261. (Hereinafter cited as Mrak
Commission Report.)
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Present use of the economic poisons in the United States is, of
course, widespread. These substances are applied to approximately five
percent of the total land area of the continental United States. At
the present time, hundreds of chemical substances are used against over
2,000 particular insect and plant pests. There are presently nearly
llS.OOO individual registrations.
The particular products registered vary tremendously as to initial
toxicity, persistence in the environment, and effect on non-target species.
One of the reasons why the governmental decisions as to registrations and
tolerances are most critical is that once certain economic poisons are
introduced into the environment remote from the consumer, the individual
has no choice as to whether or not to accept substances contaminated
thereby. For example, in the Mrak Commission Report, the observation
is made that "the hazards to health that stem from environmental exposure
to chemical agents are usually beyond the capacity of the individual to
control." This is particularly true for the persistent pesticides, such
as DDT, the residues of which are now found in many foodstuffs and
especially animal products available in the United States and in the
adipose tissue of humans and other biota. Certain classes of health
threats deserve particular searching. Positive results on laboratory
animals from tests for carcinogenicity, teratogenicity and mutagenicity
are particularly disturbing because effects are generally irreversible
when discovered.
Yet it is not merely the chemical characteristics of a given economic
poison which control its dispersion in the environment, since the means
of application of the particular economic poison are also of cardinal
importance. Introduction of a particular product by air or directly
into the water will usually cause a much wider and faster dispersal
than that of the same substance inserted into the ground.
In general the presently used insecticides vary in toxicity as one
moves up the biological chain to more complicated animal life. Due to
the persistence of certain substances and their accumulation in the
food chain, some higher life forms may receive dosages of a particular
substance manyfold more concentrated than is found in the ambient en-
vironment. Certain predatory animals are particularly vulnerable to
a buildup of a particular substance.
As with any generalizations of this magnitude, the foregoing analysis
is not dispositive in the particular since the number of variables under-
lying each assumption is so vast. For example, both dispersal of a parti-
cular pesticide and its effect on the life chain of other vertebrate nbn-target
-------
species vary with climatic a^fl ^eographic factors, and a host of other
considerations not susceptible to generalization. The concentration
in a single food source for an omnivorous species does not determine
the total intake of that pesticide for individuals of that species.
In addition, generalizations drawn from the accumulation in food chains
of the persistent economic poisons must take into account both world-
wide ueee which contribute to the maintenance of a low level background
accumulation, and changing domestic use patterns. Use in this country
of herbicide economic poisons exceeded that for insecticides for the
first time in 196?.
Although the drafting of detailed criteria has been found to be a
practical impossibility, the following general considerations are among
those which will be weighed in determining the need for initial or
continued registrations of particular economic poisons:
(l) The nature and magnitude of the foreseeable hazards associated
with use of a particular product. Such hazards may apply directly to
human health, or to domestic plants and animals, or to wildlife, or to
the environment generally. It is relevant to consider also whether
the hazard is inherent in the normal use of the product or whether it
results solely from misuse. The fact that danger results solely from
misuse does not determine that such danger is to be ignored but that this
consideration has a possible bearing on the magnitude and possibility
of occurrence of the risk.
The consideration of human health hazards underlines dramatically
the impossibility of setting up value weighted general criteria. It is
possible to determine with some degree of scientific precision the acute
oral, dermal and respiratory toxicities of particular economic poisons.
However, quantification of the damage from possible subtle health effects
resulting from long term low level effects, in particular, carcino-
genicity, mutagenicity, and teratagenicity (proclivity of the chemical
to cause cancer, mutations or birth defects, respectively) are often
beyond the present scientific state of the art. In projecting the
magnitude of risk from these sources, two extremes must thus be avoided:
insistence on final hard scientific evidence of occurrence of the injury
in humans, which may only occur when the process leading to this result
is irreversible; and action based only on anxiety, which may deprive
mankind of a badly needed control mechanism.
Attention has also been directed to long term genetio, behavioral or
synergistic effects of certain economic poisons alone or in concert.
However, scientific analysis of these possibilities is still in a primi-
tive state and the extensive testing necessary has not been undertaken.
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Rectification of this omission in the available data is a matter of
utmost concern to this Agency. Development of adequate testing protocols
and facilities is a priority undertaking. But in the short term,
extrapolation from small scale laboratory analysis must err on the side
of safety.
Because it is easier to test plants and animals in a laboratory
setting than in the biosystem, most of the available data are generali-
zations and projections based on such experimentation. The question
of the gross effects of introduction of these artificial controls into
the environment is still largely a matter of controversy. Furthermore,
there is much debate over how to relate laboratory results on small
numbers of test animals at high dosage levels to low-level long term
human exposure.
Concurrently, the nature of the benefit conferred by use of
a given product must be weighed. Pesticides are used for a variety of
purposes in a multitude of situations. Some uses are obviously more
ixraortant to the public health and well being than others. It is
Accessary in each instance to detail with particularity the nature of the
benefit. Some pesticides play a major role in the control of important
disease vectors. Others play important roles in the production and
protection of adequate supplies of essential food products. These two
uses are probably the most important benefits man has gained from
pesticide use. There are also important uses in the production and
protection of forest resources and fiber crops. Other uses are
directed toward what may be called nuisances, such as insects or weeds
that annoy or inconvenience man.
Not only the nature of the benefit must be weighed. The other side
of the coin is to assess the magnitude of the social cost of foregoing
the use of a given economic poison. Thus, an estimation must be made
of the effect of absence of the economic poison: whether it would merely
cause some inconvenience to would-be users, or would cause serious risk
to public health, or disruption of important social needs.
A further consideration in this regard is the alternative, if any,
to use of a given economic poison and any problems associated with such
substitution. Such alternatives may be other toxic chemicals, which may
themselves cause greater or lesser problems, biological control of
insects, or physical removal of plants in place of herbicide usage.
Another factor is the desirability and feasibility of increased use of
manual labor as an alternative to technological control.
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In summary, each question of initial registration, or cancellation
or suspension of an existing registration must be individually addressed.
The range of variables in the chemical formulation, pattern of use, risk
and benefit is too broad to permit responsible general criteria. This
Agency will discharge its duty to coordinate the various indicia of
environmental quality — both positive and negative — that flow from
a particular registration decision mindful of the requirement to set
forth the rationale upon which its action is based. Prom such decisions,
forged in the administrative forum provided by statute, should evolve
the standards for rational use of the products which will permit maxi-
mizing overall environmental quality.
Ill
DDT
After applying the foregoing analysis and the criteria of risk and
v•-'r.efit to the products containing DDT, this Agency has determined that
i... .ac.pension of such products is warranted pending completion of the
administrative process of cancellation which has been commenced. For
the reasons stated herein, the hazard to the public is not found to be
imminent so as to require suspension during the pendency of the adminis-
trative determinations.
In January, 1971, this Agency issued notices of cancellation with
^respect to all registrants of products containing DDT. Many of these
registrants have filed objections and requested a public hearing as
provided in the PIFRA. Answers and motions are presently being prepared
by the Agency and. every effort will be made to ensure that these cases
are brought bo public hearing as soon as possible. Section Uc sets forth
a complex procedure culminating in a final, order by tha Administrator.
We anticipate that, in the absence of unforseen delays, these administra-
tive procedures may be concluded within one year. Unless the regis-
trants can discharge their burden of proof regarding the safety and
efficacy of such products, all registrations will be cancelled at the
conclusion of the administrative process.
Such a procedure, despite the time required, offers the opportunity
for a full presentation of the conflicting views of all concerned parties
with relevant data to be made part of the record, and for an orderly
consideration of all the evidence which has been amassed concerning DDT.
Because suspension may be ordered at any time, our present decision does
not foreclose the possibility of suoh an action in the event that evidence
adduced during the administrative process meets the test for suspension.
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The question presented now is whether the continued use of products
containing DOT constitutes an "imminent hazard to the public," which
requires immediate suspension prior to conclusion of the administrative
proceedings. After review of all relevant data bearing on the nature
of DDT and its effect on man and the biota, this Agency has determined
that the uaes which will be permitted to continue do not present such
an imminent hazard to the public..*'
Environmental Data
This determination is supported by the nature of the present
effects of DDT. DDT is a hazard by virtue of its potential toxicity
at prolonged low levels of exposure. This hazard is made acute by the
persistence, mobility, and biomagnification of DDT in the environment.
Recognizing these characteristics, the four governmental committees
which have studied the DDT problem in depth between 1963 and 1969 have
all recommended that its use be phased out over a period of time.iV
None have recommended an immediate ban. However, the time has come
for resolution of the DDT issue in light of the standards set out in
the FIFRA. This is now being done through the orderly administrative
forum provided by the statute in the cancellation proceedings.
DDT has been a topic of special concern as an environmental contami-
nant because it has been the most widely used pesticide and is thus
presently the most ubiquitous in the environment. Like other broad
spectrum pesticides, it is ecologically crude in that it is not wholly
specific to insect pests, but has a variety of effects on many non-
target organisms as well. Although its initial use was mainly for
disease vector control during and immediately after World War II, it
is presently used in the United States for a variety of uses including
the control of a variety of insect pests on various agricultural crops.
Domestic use of DDT has declined notably in recent years. Prom a peak
of 79 million pounds in 1959» domestic use dropped to approximately
10 million pounds in 1970- Correspondingly, there has been a drastic
*/ In contemplation of this decision, this Agency published in the
Federal Register a request for comment as to the imminence of the hazard.
With respect to DDT, over 500 responses have been received from individuals,
civic organizations, manufacturers, universities, and state and local
government agencies. Review and analysis of these responses has proved
useful in arriving at our present decision.
^-*/ "Use of Pesticides," A Re^T-h ~f the President '* Science Advisory
Committee (l'ia% , 1963;} ''itebuoi'j.i-^ >.-.& Quality of our Environment," Report
of the Environmental Pollution Panel, President's Soienc... ^d/isory Committee
(November, 19^5) » Report of the Committee on Persistent Pesticides, Division
of Biology and Agriculture, National Reaciaroh Council, to U.S. Department
of Agriculture (May, 19^9 )» JMrak Commission Report (December > 1969).
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reduction in the number of registered uses for DDT as a result of
cancellation actions which have already taken effect.-/
The two most common allegations concerning the hazards resulting
from use of DDT are that it has detrimental effects on many non-target
organisms, especially birds, fish, and crustaceans, and that it is
possibly a carcinogen to man.
A substantial question has been raised that DDT and its metabolites
(such as DDE) are "highly injurious to some non-target species and
threaten other species and biological systems."^/ DDT has apparently
contributed to reproductive failure in many raptorial birds* such as the
bald eagle, the peregrine falcon and in the brdwn pelican. In addition,
it has either potential or actual deleterious effects upon many species
of fish fry and other aquatic organisms.
It is more difficult to draw hard conclusions as to the allegations
concerning human health effects of DDT use. There is scientific support
Tor the proposition that DDT poses no significant hazard to human health.1
'he most widely accepted scientific assessment of the carcinogenic threat
from DDT is the one which concluded the report on that subject by the
Mrak Commission:
"Accordingly, with the evidence now in, DDT can be regarded
neither as a proven danger as a carcinogen for man nor as an
assuredly safe pesticide; suspicion has been aroused and it
should be confirmed or dispelled." Mrak Commission Report,
p. U71-
*/See, e_.£., PR Notice 69-17» November 20, 1969> which cancelled all DDT
products for use on tobacco and shade trees, for use in or around the
home, and all uses in aquatic environments, except those essential for
the control of disease vectors as determined by Public Health officials;
PR Notice 70-19, August 18, 1970, which cancelled the registration of DDT
products for certain uses on a wide variety of crops, animals, and products.
**/ Mrak Commission Report at p. 9; see also p. 180.
*-*»/ A notable example is Dr. Wayland Hayes, Jr., formerly of the U.S.
Public Health Service and now of the Vanderbilt University School of
Medicine. See, £•£•» Hayes, "Toxicity of Pesticides to Man: Risks from
Present Levels,"""lot Royal Soc. (London) Proc. Ser. B. 101 (1967). In
addition, the Committee on Occupational Toxicology of the American Medical
Association has recently characterized the statement that "DDT is carcino-
genic + 0 rn.n" as P. "sp^cnlatior1. ->n ye+ improved" and calls it merely &
"generax accusation and anxieuy-provoking statement." J.A.M.A. 212(6); 10£6
(May 11, 1970)' However, for the lepal end policy reasons d.ir.o'.-...ued aiova,
this Agency will not permit its administrative action to await positive
scientific assurance in the face of pervasive risks to health and welfare.
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The "suspicion" referred to is the result of tests with animals
which indicate DDT in high dosages is a carcinogen as to particular
species. See Innes, et al., "Biossay of Pesticides and Industrial
Chemicals for Tumorigenicity in Mice: A Preliminary Note." U2 J. Nat.
Cancer Inst. 1101 (June. 1969). Some studies have also shown DDT to be
more highly concentrated in the tissue of cancer victims than in the
general populace. However, the relevance of such studies to human health
continues to be in debate. One of the scientists responsible for the
latter study has expressly disavowed, in a letter to this Agency, tl
relevance of such findings to causation of cancer in human beings.*/
In addition, there are unpublished studies conducted under the
auspices of the Pood and Drug Administration showing a percentage
increase, in comparison to a contro^ group, in fetal mortality in rats
administered large doses of DDT.^jy Allegations have also been made
that some data suggests that relatively low level exposure may cause
subtle behavioral changes and that DDT and its metabolites in laboratory
tests have been observed to cause alterations in steroid balance.JLli/
DDT continues to find strong support in some segments of the scientific
community. Its low direct toxicity to man and other higher forms of
animal life has made it easily accessible to the mass of users without
short-range hazard. Despite the large number of other chemical pesticides
developed and introduced since 19U5> and the strides made in research
and introduction of biological control of certain discrete pests, DDT
remains the only practical pesticide which is effective against certain
species of insect pAg-h
^f Letter of December 22, 1970 to Dr. Raymond Johnson, Environmental
Protection Agency, from William B. Deichmann, Ph.D.
Legator, "Mutagenic Effects of DDT and other Pesticides in Rodents and
Cultures of Mamalian Cells" (Seminar: Brookhaven National Laboratory, 1970)•
*•**/ Affidavit of Charles P. Wurster, Ph.D., at p. 3; Comments to De-
partment of Health, Education and Welfare by Environmental Defense Fund,
et al., dated January U, 1971-
*•*•**/ Though numerous jurisdictions in the United States and abroad have
experimented with radical restriction*of the use of DDT, most have foxuid
it necessary to provide for exceptions to control particular pests. Thus,
for example, Michigan permits use of BDT for the control of mice and bats,
Sweden permits its use for the control of the large pine weevil and the
Province of Ontario in Canada permits its use for-control of the cutworm
on onions.
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Other Factors
Precipitous removal of DDT from interstate commerce would force
widespread resort to highly toxic alternatives in pest control on certain
crops. The widespread poisonings, both fatal and non-fatal, which may
reasonably be projected present an intolerable short-term health hazard.
During this period of withdrawal from the broad spectrum applications
of DDT, and in anticipation of the probability that DDT will shortly
become unavailable for the majority of its present mass uses by virtue
of state and federal restrictions, this Agency will strongly support
the continuing efforts to educate pesticide users to the dangers in-
herent in certain substitute economic poisons in order to reduce this
danger.
Finally, the very characteristics of DDT which raise fears of its
effect as an environmental contaminant — its persistence, broad dis-
tribution and usage — have made it the most economically attractive
pesticide for a variety of uses. Its persistence permits relatively long
intervals between applications, while broad usage has dramatically lowered
the cost per pound. However, as in other areas of environmental pollution,
if a product contributes to contamination or degradation of the ecosystem,
an assessment of its true economic cost must take these adverse effects
into account. Thus while economic considerations have a place in the
policy-balancing functions which this Agency is charged to perform, the
economic factor is much more complex than a simple estimate of unit
production cost. In addition, any rational balance must recognize the
clear predominance of environmental concerns over purely economic con-
siderations. Thus the economic data regarding DDT is not the gravamen of
our decision.
Complementary Aptlone
Our review of this question is strictured by the present statutory
framework. The most logical course of action would be to restrict uses
to situations of real need, thus reducing the possibility of inadvertent
overuse. In addition, it would be preferable to have definite control
of particular uses, rather than tha present authority to act merely
through labeling.
The present scientific evidence indicates that there would be no
significant hazard if only carefully limited amounts of DDT were released
into the environment by virtue of restriction pf DDT to the most critical
uses. Achievement of this goal would require that fields be checked to
assure that the infestation justified treatment and that the dosage and
application methods were not wasteful. Without such assurance, experience
ban £ ;v,i '.,. it ..:... >_ ^.ioeB£ • • , : .r ^culd b«cc .a-s routine and that
the ease of availability of DDT would permit much of it to be unnd for
nonregistered purposes.
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Federal authority is presently focused on controlling the entry of
hazardous or ineffective products into the marketplace. A more limited
control of the use of a pesticide is achieved by specific instructions
on the label and the enforcement of residue limits on and in food
products. Actual control of use by these methods is far from adequate.
In order to remedy these imprecise administrative tools, the President
recently recommended to the Congress a legislative revision which would
allow this Agency to make more focdsed individual determinations.
Under this legislation, economic poisons are assigned to various cate-
gories. The most potentially hazardous product could not be purchased
without a certification by a pest control consultant that the appli-
cation of that pesticide to a particular location at that particular
time is appropriate. This more selective control of ultimate use will
permit our society to reap the benefits of scientific advances without
paying an intolerable environmental price.
Another aid to rational utilization of DDT is through enlightened
control by the states. In the light of present information concerning
the health hazards associated with mass uses of DDT, we hereby encourage
each state to scrutinize its own needs for the substance and to reduce
its use as drastically as is consistent with the health and well being
of its citizens. It is recognized, however, that at present techniques
of state control of use patterns are neither well enough tested nor
widely enough available to assure the protection of the environment
from DDT. Since, as discussed above, the hazard to the public is not
imminent, and present federal law offers no mechanism whereby'the
Environmental Protection Agency can effectively register pesticides
for particularized restricted uses and assure compliance, we have
been compelled to cancel all uses of DDT, to initiate the administra-
tive process, and to stimulate the resourcefulness of the states, the
manufacturers, and the scientific community to find acceptable sub-
stitutes.
IV
In early 1970, based on a concern to restrict aldrin and dieldrin,
two chemically similar chlorinated hydrocarbon pesticides, from wide
dispersal in the environment, the United States Department of Agriculture
cancelled all registrations for these products in or on aquatic areas — f
*/ PR Notice 70-6.
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In May of last year, TJSDA published in the Federal Register a request
for public comment on the question of what revisionary uses should be
continued. A list of possible substitutes for aldrin and dieldrixi
were circulated to both state and federal agencies fox' comment. A
special review group was established within the Department to evaluate
these data. Their report was forwarded to this Agency in January of
this year.
In December of 19/0 the Environmental Defense Fund, Ino. filed a
petition with the Administrator of this Agency requesting immediate
cancellation and suspension of all registrations of dieldrin and aldrin.
The petitioner contends that each substance causes severe environmental
damage and that each is a potential carcinogen.
The material relating to the general impact of these substances on
the environment contained both in this petition and in the entire body
of scientific literature which has been developed regarding these sub-
stances, raises a substantial question as to the safety of the regis-
tered products which has not been effectively countered by the registrant.
This Agency has thus determined to commence the administrative process
in order to resolve these questions by issuing notices of cancellation .
as to all registrations of the products containing aldrin and dieldrin.-/
Because, for the reasons set out below, this Agency has determined that
the present uses do not pose an imminent threat to the public suoh as
bo inquire immediate action pending the outcome of the administrative
process, the statutory remedy of suspension will not be ordered.
Use of dieldrin and aldrin has declined greatly in recent years.
In 1956, dieldrin usage in the United States reached a peak of 3»635i000
pounds applied. By 1970, usage had declined to 7lU,000 pounds. Aldrin
usage peaked at 19,000,000 pounds in 1966 and declined l±,500,000
pounds in 1970. Dieldrin is used primarily for termite control, as a
seed treatment, on nursery stock, ornamentals and turf. Aldrin is used
primarily as a soil treatment for corn and citrus, for termite control,
as a seed treatment, and on nursery stock, ornamentals and turf. The
largest volume of use is as an insecticide for corn (aldrin); the
second largest volume is applied for termite control (both aldrin and
dieldrin).
jj/ The registration of a house paint containing dieldrin was cancelled
on April 28, 1970. This action was challenged administratively by
the registrant and a public hearing was held on November 17, 1970. A
f'.ral p --•-'.-'•o \v*lr> Tir-ict- t« '•" i -••':•'•••-r.t.i "^ v.iTI TJ*> announced
shor-i;j.y -
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Environmental Data.
The questions raised concerning the safety of these products are
similar to those encountered with DOT in that they result from the
persistence of dieldrin (since aldrin residues quickly break down into
dieldrin) in the environment and its potential toxicity at low levels.
Some studies indicate that dieldrin alone, or in possibly synergistic
combination with DDT, has an equivalent potential for adverse effect
on non-target predatory wildlife resulting from its low level toxicity
intensified by its mobility and concentration up certain food chains-
The scientific data also indicate that dieldrin, again like DDT, has an
affinity for storage in the fatty tissue of a number of animals, in-
cluding humans—/ There are also similar carcinogenic data developed
in the laboratory from high dosage rates of dieldrin administered to
test animals.
Dieldrin and aldrin apparently have a lower threshold of toxicity
to warm-blooded animals than does DDT. In fact, instances of non-
lethal human poisoning have occurred in those occupationally exposed
to heavy concentrations of dieldrin for protracted periods. Recovery
following removal from exposure was slow but apparently complete.^Jy
These potential hazards deserve a full public airing in the adminis-
trative forum provided by the cancellation proceeding.t^L/
But because the vast majority of the present use of these products
is restricted to ground insertion, which presents lit.tle foreseeable
damage from general environmental mobility, because of the pattern of
declining gross use, and because the lower historic introduction of
these products into the environment has left a significantly lower
environmental residue burden to be faced by man and the other biota,
the delay inherent in the administrative process does not present an
imminent hazard. Thus the substantial question of the safety of these
registrations is primarily raised by theoretical data, while review
of the evidence from the ambient environment indicates that such potential
hazards are not imminent in light of the present registrations.
It is significant to note that no residues of either aldrin or
dieldrin are now permitted on corn, eggs, milk, poultry, or animal fats
shipped in interstate commerce. Because of the use patterns of aldrin
and dieldrin, these products constitute the major sources whereby these
substances would find their way into human food chains. During the
pendency of the administrative process hereby initiated, this Agency
*/Mrak Commission Report, pp. 265, et seq.
*-*/ Wayland J. Hayes, Jr., "Dieldrin Poisoning in Man," Public Health
Report No. 72, pp. 1087-1091, Dec., 1957-
***/ See Environmental Defense Fund, Inc. v. RuckelBhaus, supra.
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wi 1 ] take no action to grant any residue tolerances for thene
foodstuffn pursuant to the Food, Drug and Cosmetic Act, although
initial tolerances have been requested by the manufacturer.
2.U.5-T
Notices of cancellation and suspension for products registered
for certain uses of 2,lj,5-T were issued in May of 1970.-V This action
has been challenged by four manufacturers of the products who have
requested review pursuant to the statute by a scientific advisory
committee. This advisory committee first met on February 1, 1971*
and its evaluation of the scientific evidence relating to products
containing 2,J4,5-T is expected shortly. While these procedures were
being prosecuted, certain petitioners commenced a court action which
sought to broaden the suspension notices to includ- all registered
products containing 2,^,5-T for any use. Although approving the
standard for suspension applied under the FIFRA in the case of
2,1|,5-T, the court remanded the case to this Agency for further
consideration of that legal standard as applied to the relevant facts
in this case. After careful consideration of the petitioners'
allegations and of all other relevant factors, the Administrator
has determined that, for the reasons detailed below, the uses of
2',ij., 5>-T which have not_ been suspended pose no imminent threat to
the public, and should be permitted to continue during the pendency
of the administrative proceedings now in progress.
The compound 2,14.,5-T.fJ!/ is a herbicide used for a v/ide variety of
brush and .veed control in the United States, primarily for nonagricul-
tural purposes.
_f/ Suspension was noticed for uce of products containing 2,i4,5-T in
lake-, ponds, and ditch banks, and in liquid formulations around the home,
in recreational areas, and similar sites. Cancellation was noticed for
the u:;e of nuch products on food crops intended for human consumption and
for all granular formulations around the home, in recreational areas and
similar sites. In addition, the next month the Secretary of the Interior
banned all use of 2,I(.,5-T on lands under the control of the Department
of the Interior and the Department of Defense ordered th~ immediate
cessation of the use of 2,i4.,5-T in the defoliation program in Vietnam.
**/ ^,4»5-T is not a chlorinated hydrocarbon like DDT, aldrin and dieldrin.
It is a phenoxy herbicide.
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Environmental Data
Acting under contract to the National Cancer Institute, Bionetics
Research Laboratories, Inc. undertook a large-scale screening study of
86 chemical compounds. In 19&9, the results of the Bionetics studies
showed 2,1|,5-T to be "causing significantly more deformities than
expected" to strains of mice and rats. Cleft palate and cystic kidney
were the teratogenic effects shown. Subsequent studies were undertaken
by both governmental and private organizations when it became known
that the Bionetics 2,U,5-T samples contained 2?±8 parts per million
(ppm) of the highly toxic contaminant 2,3,7,8-tetrachlorodibenzopara-
dioxin (TCDD). Tests by other researchers indicated no teratogenic
effects at dosage levels of 2k mg.kg. per day with TCDD levels below
1 ppm. However, the National Institutes of Environmental Health
Sciences conducted tests which showed 2,U,5-T to be teratogenic to
rats, though not mice, at levels of 100 mg./kg. (though not at lower
levels, suggesting the existence of a "no effect" level for 2,U»5-T),
with the purest commercial samples of 2,l;,5~T available. Subsequent
tests announced in a report issued in December, 1970 by Bionetice show
no teratogenic effect from commercially pure 2,U»5-T, apparently at
the lower dosage level of 10 mg./lcg.-./
Since 2,U,5-T is not directly toxic to man or other spocies of
animals, and is not persistent in the environment, there are but two
health insues to be considered in the controversy over 2,U,$-T: (l)
whether 2,1^,5-T alone or in concert with its dioxin, TCDD, is actually
a teratogen, and (2) if so, what action is necessary to eliminate the
hazard to human health (particularly to field workers and consumers).
The question of the teratogenicity of 2,U,5-T and TCDD is presently
before the scientific advisory committee appointed pursuant to the PIPRA.
Its report is due on or before May lU» 1971- Prior to this complete
explication of the present scientific judgment relating to these matters,
this Agonoy has undertaken Its own review of the presently available
data. A notion nolioittng iho viswtt of tnt*r*it*
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that any positive evidence of teratogenicity in test animals exists,
it is clearly dose-related. To the extent that the restrictions
presently applicable to human exposure to products containing 2,14.,5-T
are based on incomplete scientific data, they err on the side of
safety. .The data shows that even direct accidental spraying of
workers in the field would yield oral equivalent dosages hundreds of
times below the levels at which the laboratory tests produced the
teratogenic results. The suspension of liquid formulants for use in
the home was based on restricting the possibility of direct oral
ingestion of high concentrations of 2,1^,5-T by pregnant women while
exploration of its possible teratogenic effect was under study. The
epidemiological data from the experience of extremely heavy dosages
of 2,i|,$-T in Vietnam on humans as a by-product of the defoliation
program has shown no cause for further domestic restrictions.
Thus the restrictions now in effect, which obviate direct water
contamination and virtually eliminate the threat of dangerous direct
exposure to the one group who might receive adverse effects if the
substance were shown to be teratogenic — pregnant women — provide
vo vast a margin of safety as to permit the benefits from use of
2,^,5-T for the control of unwanted vegetation to be continued pending
resolution of the administrative proceedings.
VI
FDTOEE ACTIONS BY THIS AGENCY
IN REGARD TO PESTICIDES
Because of our statutory mandate to protect the public health and
well-being by the rational control of economic poisons, this Agency is
iqndertaking a comprehensive review of its administrative mechanisms in
order to ensure intensive and regular review of all economic poisons
•that *°ay be identified as possibly significant environmental contami-
nants. Active internal review is being initiated as to the registrations
of products containing benzene hexachloride, lindane, chlordane, endrin,
heptachlor and toxaphene, all products containing mercury, arsenic or
lead, and all others deemed necessary for review.^/ The function of
this review is not to make another study of pesticides (which function
the Report of the Mrak Commission already admirably serves), but to
identify which, if any, of the presently registered products present
substantial questions of safety that' should trigger the administrative
process of cancellation.
_ycT- . ~^.. JciMua.-..Lon Roper,., .^.
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In this undertaking, this Agency welcomes additional submissions
with regard to particular products from other governmental sources,
manufacturers, the scientific community, or concerned citizens to
assist in the task of accommodating the needs of mankind to the demands
of the environment. R-.t, if we are to do more than merely stultify the
needed search for agricultural improvement in the face of the intensi-
fying world hunger problem, and protection from insect-borne disease
vectors, we must do more than subject our present ohemical products to
a continuing review. These same sources of information whose views
we hereby solicit must be encouraged to push the search, not only for
safer chemical control agents, but for bioenvironment controls!/ and
improved growing practices.
^/"Restoring the Quality of Our Environment," President's Science
Advisory Committee, p. 230 et seq. (19&5)-
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The contractor does, however, wonder why the Administrator
had no objection to the continued export of DDT if, as the
abundant testimony received before the hearings held during
the first session of the 97th Congress (Committee on
Agriculture, House of Representatives and Subcommittee on
Agricultural Research and General Legislation of the Committee
on Agricultural and Forestry, United States Senate, and others)
show that DDT and the cyclodienes have created a global
problem as well as a national problem. The scientific
testimony would seem to indicate that global influence of
these chemicals may be of far greater magnitude than any
local considerations.
Identity of Favorable Types of Laws
As stated above, the contractor supports the
Administration bill (H. R. 10729); although some states
presently have laws which appear to control use and appli-
cation, it is seen that sufficient control is not observed
in practice at all times. The provisions of H. R. 10729
will undoubtedly result in increased financial responsibility
in written state laws. Hopefully the provisions of the bill
which would strengthen or reinforce federal aid to educational
programs designed to improve methods of application and human
safety would have their impact in increased environmental
protection as well.
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The inclusion of specific restrictions into updated
state laws is seen as a function of state government. All
states, it would appear, should be able to make laws more
restrictive than the federal law.
Some of the verbiage of the existing state laws is
rather loose in the interpretation of how to dispose of
containers and unused pesticide. Hopefully this major source
of environmental contamination will be solved by more useful
state laws in the future. As indicated in another section
of this report, many farmers have expressed an earnest
desire to dispose of their material in a suitable way but
do not know of a practical solution. Aid in this matter
should come from all states as soon as possible.
Assistance to farmers by way of increasing their
ability to implement soil erosional control techniques
would have the multiple advantage of increasing crop yield,
keeping soil loss to a minimum and, most importantly,
keeping pesticides used on the land where they are normally
effective. An obvious benefit would occur to farmers since
annual application of certain compounds could be adjusted
downward to take advantage of residue.
The strengthening of applicator laws is viewed as
another very desirable feature of some laws. Responsible
operators who perform valuable services should not suffer
from over-regulation. Irresponsible, thoughtless operators
will hopefully make their operations more efficient or
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suffer sufficient financial loss to make the venture unprofit-
able.
In any event, the restructuring of state laws along
the lines of the AAPCO in conjunction with the new Admin-
istration bill should go a long way in providing better
safety for all citizens as well as the environment as a
whole.
One additional case which should be commented upon is
that of Burk vs. Stauffer Chemical Co. in the Kansas City
United States District Court in November, 1970. This case
did not receive wide publicity. Judge William H. Becker
concluded on November 24, 1970, that "Donald C. Burk died as
a direct and proximate result of exposure to Dieldrin 1.5-E
formulated by the defendant Stauffer Chemical Co." The
judge indicated medical evidence showed that the exposure
caused overreaction of Burk's lymph system with the resulting
development of Hodgkin's disease, characterized by en-
largement of lymph glands, spleen and liver. Without
delving into any more of the case, it appears this decision
was made primarily to allow the deceased's widow and
children eligibility under workmen's compensation laws -
compensation which had previously been denied. The contractor
feels decisions of this kind, although obviously filling a
need to overcome some shortcomings in existing rules and
regulations (i.e., compensation for loss, injury or death
-------
in proper performance of the job), do make bad laws if
used for precedent. The contractor was unable to find a
medical doctor who would testify that the medical evidence
was sufficiently strong to suggest an intimate relationship
between dieldrin exposure and Hodgkin's disease.
Important Litigation
Court cases in the five states concerning pesticides
were reviewed to determine important points of law involved
in the decisions. Only those cases tried in a court of
record, i.e., State or Federal Court of Appeals, District
Court or Supreme Court, could be reviewed. Law digests
and indices of Court Reporters were used to research all
litigation involving pesticides from 1956 to mid-1971.
Cases adjudicated in appellate courts of the five
states during that period are summarized in Table3-H.
However, those cases undoubtedly represent a negligible
percentage of actual litigation; most suits are initiated
for recovery of damages in amounts which only warrant trial
in magistrate or district courts. For example, review of an
Iowa newspaper by the contractor revealed that a local
district court jury awarded $70,595 in damages to a rural
couple who claimed that the woman suffered physical and
mental impairment from an insect killer which was not
properly marked to indicate possible danger (1). There is,
however, no systematic means of retrieving records of such
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TABLE 3-H
LITIGATION INVOLVING PESTICIDES IN ILLINOIS, IOWA, KANSAS, MINNESOTA, AND MISSOURI, 1956-1971
Court
Year
Case
Summary
Court of Appeals,
Minnesota
1963 Land 0'Lakes Creameries
v. Hungerholt
Contamination of dairy products resulting
from use of defendant manufacturer's in-
secticide on dairy farm. Decision was that
label disclaiming liability does not relieve
manufacturer or compounder of his duty to
suitably convey notice of danger of product
containing deadly ingredients, so that proper
precautions may be taken to prevent wrongful
use and consequent injury.
01
Kansas Supreme Court
1964
Stertz v. Briscoe
Death of child after using bathtub in rented
premises following fumigation with an insecti-
cide containing parathion. Evidence establish-
ed that spraying of bathtub with parathion
was direct and proximate cause of death of
child.
District Court, Missouri 1965
Hunter v. E. I. duPont
and De Nemours and Co.
Personal injury sustained as a result of ex-
posure to the spray while applying a weed
killer to the lawn at his residence. Verdict
declared that caution statement on label of
manufacturer's product that contact with eyes,
skin, and clothing should be avoided, and
that solution might cause skin irritation was
an adequate warning of any hazard to life or
health which might result from use of product,
and that manufacturer was therefore not
negligent in failure to place an additional
warning on its label.
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TABLE
Continued
Court
Year
Case
Summary
District Court, Iowa
1966 Holladay v. Chicago,
B. and Q. Railroad Co.
The railroad's negligence with respect to
herbicides sprayed on right-of-way was
judged a proximate cause of plaintiff switch-
man's condition of acute and disabling
neuritis that existed after date of exposure.
Missouri Court o-f
Appeals
1966
Venie v. South Central
Enterprises, Inc.
Evidence established that a particular herbi-
cide, used by the plaintiff buyer at the
defendant seller's recommendation was cause
of loss of field of strawberry plants.
Iowa Supreme Court
1966
Niggi v. Laverty Sprayer,
Inc.
SB
In action for personal injuries and property
damage allegedly resulting from aerial in-
secticide spraying operations by the defemrr
dant the evidence of injuries was insuffi-
cient to establish a jury question on the issue
of liability. However, there was adequate
evidence on the issue of liability of the
defendant spraying company for loss of use
of the plaintiff's cattle pasture and pond
as the alleged result of aerial insecticide
spraying.
Court of Appeals,
Minnesota
1967
Skogen v. Dow Chemical Co.
Brain damage allegedly caused by exposure of
plaintiff to defendant's organo-phosphate
insecticide. Judicial review upheld jury
finding that brain damage was caused by
viral encephalitis rather than organo-phos-
phate poisoning from insecticide.
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TABLE
Continued
Court
Year
Case
Summary
Minnesota Supreme Court
1967
Bates v.
Mfg. Co.
Root-Lowell
Evidence that consumer held defective insecti-
cide sprayer tube in one hand and glass bot-
tle holding insecticide liquid in other while
attempting to assemble the apparatus created
question for jury on issue of whether con-
sumer was contributorily negligent or had
assumed the risk of the injury resulting
from breaking of the insecticide bottle.
Court of Appeals,
Illinois"
1969Federal Savings & Loan
Insurance Corp.
CO
i
Condemnation of shipment of spinach due to
excessive pesticide levels in the spinach
resulted in litigation alleging erroneous
determination of contamination. The defen-
dant, a U. S. government employee, claimed
sovereign immunity. The appellate court up-
held the lower court's decision that the
defense of sovereign immunity be waived.
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cases.
Analysis of cases presented in Table 3-H and of many
more cases from courts of record throughout the country
indicate litigation generally involves either negligence
of the manufacturer or distributor in conveying the danger
of his product, or negligence of the applicator in handling
or spreading the pesticide. A third area of negligence
involves misuse of pesticides in applications for which
they are not intended.
The above cases set several precedents regarding a
manufacturer's responsibility to properly warn users of
the danger of the product. First, it was determined that
a chemical company in compounding, distributing, or
applying pesticides is held to the skill of an expert and
consequently is charged with superior knowledge of the nature
and quality of its products, including their harmful effects
(Holladay v. Chicago, B., and Q. Railroad Co.). Further,
the manufacturer or compounder of such hazardous materials
owes a duty to users to suitably convey notice of this
danger, so that proper precautions may be taken to prevent
wrongful use and consequent injury. This responsibility is
fulfilled by naming and properly communicating the hazards
on the label of the package in which the articles are
marketed (Land O1Lakes Creameries v. Hungerholt). However,
in a case based upon negligence, the plaintiff cannot recover
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damages for usage of a product inherently dangerous to
human life or health when used as directed or as the
manufacturer could reasonably contemplate it would be used,
if the manufacturer has given adequate warning of such
danger (Hunter v. E. I. duPont & DeNemours & Co.).
Litigation in other states has considered additional
areas of the manufacturer's liability in labeling dangerous
pesticides. The fact that the manufacturer of a pesticide
had complied with the U. S. and Texas acts regulating
marketing of pesticides and that the label employed had
been approved by appropriate agencies did not preclude a
finding of the manufacturer's negligence for failure to warn
of the full extent of danger. The manufacturer was guilty
of negligence in the case of a child who allegedly died
as a result of ingesting a pesticide because the wording of
its label gave as an antidote a mere first aid to prevent
absorption of the poison by the bodily system but contained
no language to indicate that once the poison had been
absorbed there was nothing that could be given to counteract
its effect (Texas Civil Appeals, 1968, Rumsey v. Freeway
Manor Minimax). Even though a poison is known to the
ordinary person to be inherently dangerous, there is a
common-law duty to warn of the full extent of danger.
In Massachusetts, an appellate court determined that
it was a jury question whether the manufacturer of a
-------
poisonous insecticide should have foreseen that its product
would be used by persons of limited education and reading
ability and that a warning, even if it were in the precise
form of a label submitted to the U. S. Department of Agri-
culture, would not be adequate, because of its lack of
skull and bones or other comparable symbols (Court of
Appeals, Massachusetts, 1965, Hubbard-Hall Chemical Co. v.
Silverman).
Cases involving pesticide misapplications are generally
jury questions of negligence. Horticulturists have the
right to use dusts and sprays to protect their growing crops
from insects and diseases, but they must exercise due care
in doing so, and may be held liable in damages for spreading
poison dusts and sprays negligently. Farmers may not
delegate the work of dusting or spraying a crop with
poisonous pesticides to an independent contractor and thus
avoid liability for negligently spreading poisonous dusts
and sprays (Mississippi Supreme Court, Lawler v. Skelton).
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Summary and Conclusions
The contractor has endeavored to examine and
present in concise form, the status of Federal and
state laws directly pertinent to the five-state study
area. By collecting and analyzing pertinent laws at
the state and Federal level, and through a series of
interviews with key people, a picture of good and bad
has been assembled; each will be presented with the
contractor's evaluation of areas of needed reform.
The Federal regulation of pesticides operates
under the Federal Insecticide, Fungicide and Rodenticide
Act (FIFRA), enacted in 1947 and amended in 1959, 1961
and 1964.
The act prohibits the interstate or international
shipment of economic poisons unless they: are registered
pursuant to provisions of Section 4 of the act, are in
unbroken immediate containers, and are labeled according
to the provisions of the act.
Should the Administrator find that an imminent hazard
to the public would exist, he may suspend the registration
of an economic poison immediately.
Any person who violates this law" may be found
quilty of a misdemeanor and on conviction can be fined
not more than $1,000.00.
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New Federal Legislation
During 1971, Congress has considered legislation
to amend or replace FIFRA. At least eight different
bills dealing with pesticides were introduced in the
House of Representatives. The primary one was H. R.
4152. In the Senate four bills have been under considera-
tion, two of which (S. 600 and S. 745) would - like
H. R. 4152 - replace the present FIFRA. The other
bills would either prohibit the sale of DDT or pro-
hibit the sale of aldrin, chlordane, DDD,TDE, dieldrin,
endrin, heptachlor, lindane, and toxaphene. The fate
of any legislation in the Congress is to be considered
uncertain until enacted by both Houses and sent to the
President. H. R. 10729, the Committee rewrite of H. R.
4152, was enacted by the House in the first session of
the 92nd Congress. There is strong expectation that
Senate action in the 1972 session will result in enact-
ment of a new FIFRA very similar to H. R. 10729.
H. R. 10729 incorporates many of the provisions of
the existing law (FIFRA), but goes well beyond it in the
Federal regulation of intrastate as well as interstate
activities, including registration of pesticides in
intrastate commerce. It provides for the classification
of pesticides as to: (a) "general use" or (b) "restricted
use." The original versions had a third category of
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"use by permit only." It also provides for the certi-
fication of pesticide applicators. It provides for
aid and guidance to states in developing training pro-
grams for pesticide applicators and for the certifica-
tion of individuals entitled to use restricted pesti-
cides.
The bill also substantially increases the enforce-
ment powers of the Federal agency. There are provisions
for criminal misdemeanor and for civil penalties. These
include not only the registrant, wholesaler, dealer,
retailer, or other distributor, the commercial pesticide
applicator, but the farmer who knowingly violates any
provision of the Act.
Impact of the Pending Federal Legislation
A sampling of views from Congressional offices in
the five-study states of Minnesota, Illinois, Iowa, Missouri
and Kansas showed: (1) the legislation was an integral part
of more effective pollution control, (2) improved control
of commercial and private applicators to prevent over-
doses and careless applications, (3) more effective hand-
ling of pesticides, (4) reduction in on-site storage of
pesticides, and (5) more effective control over retail
sales subject to recall on order of the Administrator.
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There seemed to be a general concurrence from
farm communities on the need for legislation of this
general nature. The contractor's own survey and Con-
gressional office mail strongly express approval for
passage of the legislation. The greatest opposition
came from some retailers who were also applicators and
some commercial applicators - both saw impending legis-
lation as entirely too restrictive.
With respect to the potential impact of the Federal
legislation and state programs, each Congressional office
and the farmers and county agents surveyed indicated the
State Departments of Agriculture and Agricultural Extension
Services would have major responsibility.
Section 20, Research and Monitoring, and Section 23,
of H. R. 10729, State Cooperation and Training, are parti-
cularly significant advances. The provisions which speci-
fically empower the Administrator to: (1) foster research
in biologically integrated alternatives for pest control,
(2) formulate a national plan for monitoring, (3) expand
public funds to encourage state programs in training of
certified pesticide applicators, are viewed by the con-
tractor as necessary and desirable.
Testing and Registration of New Pesticides
Section 3. Registration of pesticides appears to
provide for sufficient information to allow the Administra-
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Iowa
The Pesticide Act of Iowa is a combined registration
(use) and application law. Licensing provisions and en-
forcement need to be strengthened in Iowa. Financial
responsibility for violation is more stringent in Iowa
than in Illinois. The institution of a chemical technology
review board in Iowa will allow the Secretary of Agri-
culture to promulgate additional laws and regulations.
Kansas
Stringent financial responsibility marks the Kansas
Pesticide Use Law. Kansas is the only study state re-
quired to issue regulations regarding storage and safe
disposal of pesticides and used containers. Although
viewed as something of an intrusion on the state's own
pesticide law, when interviewed, all the Congressmen from
Kansas indicated support of H. R. 10729.
Minnesota
Minnesota's Spraying and Dusting Law was the first
law in the five-state study area to employ restricted use
pesticide classification. DDT and its metabolites and
the cyclodienes were severely restricted as of July, 1970.
Congressman Bergland did not feel that the farmers
of Minnesota have been at any disadvantage to farmers
from other states because of the restrictions on the use
of certain pesticides. He stated that the contacts he
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tor to make adequate judgments regarding new compounds.
The provisions which allow a full description of tests
performed, § 3(c) (1) (D), and the results thereof to the
Administrator as he desires and § 3(c) (1), wherein the
Administrator shall publish guidelines specifying the
kinds of information required in support of registration,
are regarded as particularly important. The further pro-
vision that the Administrator shall make public all
scientific information relating to the registration of
any particular compound is viewed as an absolute necessity
and long overdue (§ 23 (c) (2), p. 18, lines 4-9).
Illinois
The State of Illinois has sound laws on record which
are consistent with H. R. 10729. The provisions of the
existing law are rather weak in regard to licensing of
employees of pesticide applicators but compliance with
the Administration bill should insure training and safety
precautions. When asked about this issue, Congressman
Finley's office indicated: (1) response to this bill has
been favorable, (2) the bulk of the farmers and farm
cooperatives recognize the need to work within a regula-
tory framework in order to preclude more restrictive
limitations on their use of agricultural chemicals, (3)
farm cooperatives are gearing up to assist farmers through
education to qualify under proposed registration systems.
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has had with farmers and farm organizations have at no
time indicated such a disadvantage. The general tenor
of comments from his home district during the period when
the legislation was under consideration was favorable
to passage. The only comments he has received since he
voted for the bill have been from individuals who ex-
pressed the view that legislation along the lines of
H. R. 10729 has been long overdue.
In total view, Minnesota already has more stringent
control than most states and compares favorably with
the Administration bill. No difficulty is seen in field
implementation of that legislation.
It should be admitted that Minnesota does not have
the same degree of agricultural involvement, as, say,
Iowa or Illinois, as far as corn and soybeans are con-
cerned.
Missouri
Missouri has the weakest pesticide control law in
the five-state study area. Two bills introduced in 1971
were fought strenuously by dealers and manufacturers.
Public hearings were held and testimony received. Manu-
facturers and applicators reported they could live with
the House committee substitute for 315 and 571. Biologists
and environmentalists were also satisfied. However, when
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brought to a vote, the bill failed to pass and both sides
appeared to be surprised. At a special session (November
18, 1971) it was decided that proponents of the bill(s)
would wait and see what happened to the Administration
bill in the Senate (H. R. 10729).
Identity of Favorable Types of Laws
The results of the contractor's survey of farmers,
county agents, Congressional offices, pesticide appli-
cators and retailers, support the Administration bill
(H. R. 10729). Although some states presently have laws
which appear to control use and application, it is
seen that sufficient control is not observed in practice
at all times. Hopefully the provisions of the bill,
which would strengthen or reinforce Federal aid to edu-
cational programs designed to improve methods of appli-
cation and human safety, would have their impact in in-
creased environmental protection as well*
Some of the verbiage of the existing state laws is
rather loose in the interpretation of how to dispose of
containers and unused pesticide. Hopefully, this major
source of environmental contamination will be solved by
more useful state laws in the future. As indicated in
another section of this report, many farmers have ex-
pressed an earnest desire to dispose of their material
in a suitable way but do not know of a practical solution,
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Aid in this matter should come from all states as soon as
possible.
Assistance to farmers by way of increasing their
ability to implement soil erosional control techniques
would have the multiple advantage of increasing crop
yield, keeping soil loss to a minimum and, most import-
antly, keeping pesticides used on the land where they are
normally effective. An obvious benefit would occur to
farmers since annual application of certain compounds
could be adjusted downward to take advantage of residue.
The strengthening of applicator laws is viewed as
another very desirable feature of some laws. However,
responsible operators who perform valuable services
should not suffer from over-regulation.
Recommendations
As previously stated, the contractor, throughout
surveys and interviews, found general support for the
Administration Bill (H. R. 10729). Obvious areas of
concern are included in this bill but certain points
which will ultimately aid in the implementation of the
bill through administrative order should be identified.
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Licensing of Products
Licensing provisions of the bill appear adequate
provided sufficient valid support of claims is presented.
This would include updated standards, especially in the
area of chronic sub-lethal exposure, with due regard for
the degree of biomagnification identified for members of
each trophic level. Rising costs dictate that new
products should not be unduly restricted where no imminent
harm to humans or, more important, to the total ecosystem
is presented. To streamline the procedure, a temporary
license could be provided and at this time, or earlier,
support monies could be utilized to draw private
institutions or respected scientists and universities
into the entire process. Through these agencies,
sophisticated studies of kinetics of movement through
ecosystems and basic physiological responses at different
trophic levels could be used to augment the registration
procedure. Compounds could be identified by number to
protect corporate interests and workers placed under
some kind of confidential status. The important point
here is that specific items of information could be
identified by EPA and updated standards applied so
that needless duplication could be avoided and rigorous
adherence to standards employed.
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Compounds which are known to rapidly hydrolyze or
otherwise decompose in the environment should be given
considerably more latitude than compounds which are
specifically identified as persistent. Due regard for
human safety with less persistent, but more toxic
compounds is, of course, a requisite.
The contractor feels that the sooner the present
persistent compounds are removed, or sharply curtailed
in use, the better. It should be indicated here that
the present practice of permitting the overseas sale of
compounds such as DDT is a direct violation of the trust
placed in the hands of scientists and administrators in
the United States. The contractor feels very strongly
that if we have reason to believe that such persistent
pesticides are regarded as too dangerous for domestic
use, we have no right, especially in view of our position
of world leadership in science, to authorize their sale
and use overseas to further contaminate the global
environment.
The United States should, in fact, assume a leader-
ship posture of global concern and actively strive to
implement international regulation of such compounds.
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Prescription Dispensing and Sales
The contractor believes that there are some
applications of some persistent pesticides which may be
tolerated; structural pest users and other uses which
show none, or very little liklihood of environmental
contamination, may be considered. In any event, the
amounts used should be rigidly controlled and even these
uses should be phased out as soon as compounds with more
desirable characteristics are found.
Prescription use connotes a cumbersome machinery
generally. Hopefully this will not be necessary as state
cooperation and implementation of educational plans comes
into being. It has been demonstrated that far too many
people who use the mere toxic compounds do so in a
careless fashion — apparently unaware of their poisonous
nature.
We should strive to achieve integrated methods and
control which would specifically identify the need for
use of these compounds only when needed and in the
amounts needed.
Additional control is obviously required in the use
of heavy metal compounds.
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Application
These points have been covered elsewhere in this
report. It is clear that some kind of licensing is re-
quired, if for no other reason, so that each state knows
who is doing the application. Federal and state
sponsorship of training requisite to licensing is
encouraged. These items by themselves still do not insure
that proper application techniques will be followed.
The threat of license revocation after repeated instances
of careless application and the possible forefeiture of
bond, or the inability to secure adequate bonding in the
future, are seen as necessary and desirable implementation
features. Many commercial applicators have a demonstrated
record of careful use of pesticide materials. They should
find it easy to comply with regulations. Others, less
careful, and ignorant of the consequences of their acts,
are a potential threat to all and especially the
environment. Their services are no longer required or
desired.
Safe Disposal
Catalytic thermal decomposition is not possible by
the average farm user. Clearly, state or Federal
implementation is required to dispose of unused or surplus
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pesticides. The biggest single complaint from farmers
was that nobody had provided sufficient information
for safe disposal. Regional and area wide collection
points may be required. Dumping or burying are clearly
inadequate at present. Directions such as those on
manufacturers' packages, which call for the user washing
out the container before incineration, fail to tell him
what to do with the washings.
Control and Treatment Techniques
Decontamination from persistent organo-chlorides
appears to pose little threat to human health. The same
cannot be said for more highly toxic compounds. State-
wide implementation, such as that in Kansas and Iowa,
which alerts medical doctors to the possibility of
harm, is a possible helpful measure. Prescribed safety
methods, including the wearing of plastic garments and
gloves or respirators, appear to be largely ignored,
with the exigencies of planting time. The contractor
thus recommends that additional steps be taken by
manufacturers to produce formulations which are more
dust-free, covered with a protective coating which
could disolve when wetted, or such other plans which would
reduce the liklihood of human exposure.
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It is recommended that considerably more effort
be expended in the area of controlled degradation and
self-destruct methodology. Some steps have already
been taken but the unfortunate thing is that many of the
compounds used to catalyze the destruction may, themselves,
reach toxic concentrations with prolonged use. One
incentive here could be a premium placed on compounds
with demonstrated self-destruct or auto-degradation
capabilities at the time of application for registration.
Pesticide Containers
Standardization of leak-proof, safe containers
is absolutely called for. The manufacturer who packages
in a desirable container arid then tells the farmer to
destroy it is obviously unaware of the inherent thrift
of most farmers. Self-punching boxes and cans which
do not require additional handling by the operator have
been suggested. The payment of demurrage or a premium
on returned containers is also offered.
Additional research is badly needed in methods of
adequate disposal of used pesticide containers.
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Effluent from Manufacturers and Formulators
This is seen as an area of considerable abuse. It
is recommended that stringent effluent requirements be
instituted and enforced against manufacturers and
formulators. Every day that goes by with kilogram
quantities of pesticides entering the aquatic ecosystem
is another black day in our history. Whether activated
carbon columns are used to treat all effluent water or
whether lagoons which utilize biomagnification or
accumulation with subsequent expected incineration of the
biotic concentrator or whether some other method is used,
one fact remains: we have passed the point where we can
allow pesticide-laden effluent water to enter our public
waterways through municipal sewers and other discharge
pipes.
Information Collection and Dissemmination
The contractor has stated elsewhere the need and
desirability of a more complete information exchange
between manufacturers and the rest of the scientific
community. Due regard to the interests and degree of
financial involvement of the pesticide companies must
always be considered. We recommend such integrated
research programs (see above) as will streamline the
registration procedure, enhance cooperation between
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scientists and generally insure that adequate information
is gathered openly to assure maximum environmental
protection.
ft U. S. GOVERNMENT PRINTING OFFICE : 1972 O - 468-256
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