\
    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.

-------
     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

-------
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

-------
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.

-------
     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

-------
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.
                          10

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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.
                           16

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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:
                          17

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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

-------
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

-------
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

-------
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

-------
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

-------
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

-------
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

-------
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

-------
     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

-------
     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

-------
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

-------
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

-------
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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                                                                                                          —t.  r/ss* iiwT "i ^•••'JJ^KS-  L^ T i i wi
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                                                                                                   : .—T-^^rtr1^" t ~. \— .'w

                                                                                                   SafelliFtefcfflt
                   JT (;-""• Jj "^^i^V"i'':"'\"''iy^»^ll|wiii||i'1i^i||'p!^ws'^a|l'f "'I'1"                                           	^f"^v"^;'Sc/1^~^''

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-------
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

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     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

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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

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                  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

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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

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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

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                     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

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                               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

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                         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

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                                         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

-------
     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

-------
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

-------
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

-------
     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

-------
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

-------
     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

-------
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 ).
                          45-E

-------
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

-------
     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

-------
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

-------
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

-------
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

-------
     (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

-------
     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

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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

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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

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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

-------
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

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                       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

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                                              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

-------
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

-------
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

-------
                                           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.

-------
                       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

-------
                       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

-------
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
                           117-E

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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
                          118-E

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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.
                           119-E

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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
                         120-E

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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.








                       121-E

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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.
                           122-E

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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
                           123-E

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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,
                           124-E

-------
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.
                            125-E

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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.
                          126-E

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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







                          127-E

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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.
                          128-E

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                    LITERATURE REFERENCES
1     Bloom, S. C. and S. E. Degler.  Pesticides and
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3     Carson, R.  Silent Spring.  Houghton Mifflin Company,
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4     Robinson, J., A. Richardson, A. N. Crabtree, J. C.
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5     Kapoor, I., R. L. Metcalf, R. F. NyStrom and G.K.
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6     Harrison, H.L., 0. L. Loucks, J. W. Mitchell, D. F.
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7     Eberhardt, L.L., R. L. Meeks and T. J. Peterle.
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8     Morris, R. L. and L. G. Johnson.  Pesticide Levels in
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9     Morris, R. L. and L. G. Johnson.  Pesticide Levels in
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10    Morris, R. L. and L. G. Johnson.  Pesticide Levels in
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11    McDonald, P.  Personal communication.

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13    Detwyler, T. R.  Man's Impact on Environment.
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                            129-E

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14    Broughey, A. S.  Man and the Environment.  The
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15    Hartley, G. S. and T. F. West.  Chemicals for
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18    Burnett, R.  "DDT Residues: Distribution of
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19    Risebrough, R. W., D. B. Menzel, D.  J. Martin,
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20    Woodwell, G. M., C. F. Wurster, and P. A. Isaacson.
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21    Sprague, J. B. and J. R. Duffy.  "DDT Residues in
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22    Vance, B. Dwain and W. Brummond.  "Biological
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23    Hannon, M.R., Y. A. Greichus, R. L.  Amplegate
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24    Holden, A.  V. and K. M. Marsden.  "The examination
      of surface  water  and sewage effluents for
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25    Leshniowsky, W.O., P.R. Dugan, R. M. Pfister,
      J. I. Frea  and C. I. Rondles.  Adsorption of
      Chlorinated Hydrocarbon Pesticides by Microbiol
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      Duplications.  Inter. Assoc. of Great Lakes Res.
      Proc. 13th  Conference, 1970, pp. 611-618.
                              130-E

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26    deKoning, H. W. and D. C. Mortimer.  "DDT Uptake
      and Growth of Emydena gracilis", Bull, of
      Environmental Contam. and Toxicol. 6 (3):244-248,
      1971.

27    Yeh, H.H.  The Uptake and Persistance of Pesticides
      in an Algae-laden Environment. Ph.D. Dissertation,
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28    Johnson, B.J., C.R. Saunders, H.O. Sanders, and R.S.
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29    Macek, K., C.R. Rodgers, P.L. Stalling and Sidney
      Korm.  "The uptake, distribution and stimulation of
      dietary 14C-DDT and 14-C-Dieldrin in Rainbow Trout",
      Trans. Amer. Fish. Soc. 99 (4):689-695, 1970.

30    Fromm, P.O. and R. C. Hunter.  "Uptake of Dieldrin
      in isolated perfused gills of rainbow trout",
      J. Fish. Res. Bd. Canada 26:1939-1942, 1969.

31    Nacok, K.J. and S. Korm.  "Significance of the
      food chain in DDT accumulation by fish",
      J. Fish. Res. Bd. Canada 27: 1496-1498, 1970.

32    Menzel, D.N., J. Anderson and A. Randtke.
      "Marine plytoplankton vary in their response to
      chlorinated hydrocarbons", Science 167:1724-1726,
      1970.

33    Wurster, C.F., Jr.  "DDT Reduces Photosynthesis by
      Marine Plytoplankton", 'Science 159: 1474-1475, 1968.

33a   Stadnyk, L., R. S. Campbell and B.T. Johnson.
      "Pesticide Effect on Growth and 14C-Assimilation in
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      6(1):l-8, 1971.

34    Sanders, H.O. and O.B. Cope.  "The Relative Toxici-
      ties of Several Pesticides to Naiads of Three Species
      of Stoneflies", Limnol. & Oceanog. 13(1); 112-117,
      1968.

35    Sanders, H.O. and O.B. Cope.  "Toxicities of Several
      Pesticides to two Species of Cladocerans", Trans.
      Amer. Fish. Soc. 95(2); 165-169, 1966.
                            131-E

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36    Thompson, A.R.   Stonefly metabolism and the Effects
      of DDT ,  Ph.D.  Dissertation, University of Utah, 1971

37    Macek, K.J. and W.A.  McAllister.  "Insecticide
      Susceptability of Some Common Fish Family Represen-
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38    Macek, K.J. and H.O.  Sanders.  "Biological Varia-
      tion in the Susceptability of Fish and Aquatic
      Vertebrates to DDT",  Trans. Amer.  Fish. Soc. 99(1):
      89-90, 1970.

39    	 In Annual Progress Report; 1970, Fish-
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      Fisheries and Wildlife, Columbia,  Mo.

40    Rodgers,  C.A. and D.L. Stalling.  In  Annual
      Progress Report; 1970.  Fish-Pesticide Research
      Laboratory.  Bureau of Sport Fisheries and
      Wildlife, Columbia, Mo.

41    Mayer, F.L., Jr.  In Annual Progress Report: 1970.
      Fish-Pesticide Research Laboratory.  Bureau of
      Sport Fisheries and Wildlife, Columbia, Mo.

43    Rodgers,  C.A. "Uptake and Elimination of Simazine
      by Green Sunfish", Weed Science.  18(1): 134-
      136, 1970.

44    Murphy, P.G. and J.V. Murphy.  "Covalation Between
      Respiration and Direct Uptake of DDT in the Mosqui-
      to Fish", Bull. Environ. Contam. & Toxicol. 6(6):
      581-588,  197T:

45    Lee, E.L.  "Measurement of Pesticide Toxicity by
      Fish Respiration Rate.  Sc.D.  Dissertation,
      Washington University, 1969.

46    Greer, G.L. and U. Paim.  "Degradation of DDT in
      Atlantic Salmon", J.  Fish. Res. Bd. Canada, 25:
      2321-2326, 1968.

47    Bardide,  G.E.,  E.J. Harris, H.J. Dean, T.M. Wal-
      ker, J. Skea and D. Colby.  "The Accumulation of
      DDT in Lake Trout and the Effect on Reproduction",
      Trans. Amer. Fish. Soc. 93(2): 127-136, 1964.

47a   Smith, R.M. and C.F.  Cole. "Chlorinated Hydro-
      carbon Insecticide Residues in Winter Flounder",
      J. Fish.  Res. Bd. Canada.  27:2374-2380, 1970.
                             132-E

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48    Janicki, R.H. and W.B. Kinter.  "DDT: Disrupted
      Osmoregulatory Events in the Intestine of the
      Eel, Anguilla rostrata, Adapted to Seawater".
      Science.  173: 1146-1148, 1971.

49    Grant, B.F. and P.M. Mehrle.  "Chronic Endrin
      Poisoning in Goldfish". J. Fish. Res. Bd. Canada.
      27:2225-2232, 1970.

49a   Eisler, R. and P.H. Edmunds.  "Effects of Endrin
      on Blood and Tissue Chemistry of a Marine Fish".
      Trans. Amer. Fish. Soc.  95 (2):153-159, 1966.

50    Lane, C.E. and E.D. Scura.  "Effects of Dieldrin on
      Glutamic Oxaloacetic Transaminase in Poecilia
      latipinna".  J. Fish. Res. Bd. Canada.  27: 1869-
      1871, 1970.

51    Buhler, D-R. and W.E. Shanks.  "Influence of Body
      Weight on Chronic Oral DDT Toxicity in Coho Salmon".
      J. Fish. Res. Bd. Canada.  27:347-358, 1970.

52    Roelofs, T.D.  Effects of Dieldrin on the Intrin-
      sic Rate of Increase of the Guppy^Ph.D. Disser-
      tation, Oregon State University, 1971.

53    Anderson, R.B. and W.H. Everhart.  "Concentrations
      of DDT in Landbodied Salmon at Sebago Lake, Maine".
      Trans. Amer. Fish. Soc.  95(2): 160-164, 1966.

54    Poff, R.J. and P.E. Degurse.  "Survey of Pesticide
      Residues in Great Lakes Fish'.'.  Wisconsin Depart-
      ment of Natural Resources.  Mngt. Rpt. No. 34, 1970,

55    	f Annual Report of Progress; 1970.  Fish-
      Pesticide Research Laboratory.  Columbia, Mo.

56    Johnson, L.G-  Pesticides in the Edible Portion
      of Fish from Iowa Water.The State Hygienic Labora-
      tory.  # 70-33.  1970.  Ames, la.

58    Allison, D., B. Kallman, O.B. Cope, and C.C. Van
      Valin. "Insecticides: Effects on Cutthroat Trout
      of Repeated Exposure to DDT".  Science.
      142:958-961, 1963.

59    Atchison, G.J.  Lipid and DDT Dynamics in Develop-
      ing Brook Trout Eggs and Fry.  Ph.D. Dissertation.
      Michigan State University, East Lansing, 1970.
                             133-E

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60    Mazone, C.R. and B.C. Blaylock. "Toxicity of Insec-
      ticide Formulations to Carp Embryos Reared in
      vitro".  Jour. Wildlife Management.  34:460-463,
      1970.

61    Anderson, J.M. and M.R. Peterson.  "DDT: sub-
      lethal effects on brook trout nervous system".
      Science.  164:440-441, 1969.

62    Anderson, J.M.  "Effect of Sublethal DDT on the
      Lateral Line of Brook Trout".  J. Fish. Res. Bd.
      Canada.  25: 2677-2682, 1968.

62a   Anderson, J.M. and H.B. Prins.  "Effects of
      Sublethal DDT on a Simple Reflex in Brook Trout".
      J. Fish. Res. Bd. Canada.  27: 331-334, 1970.

63    Culley, D.D., Jr. and D.E. Ferguson.  "Patterns
      of Insecticide Resistance in the Mosguitofish,
      Gambusia affinis".  J. Fish. Res. Bd. Canada.
      26:2395-2401, 1969.

64    Yarbrough, J.D. and M.R. Wells.  "Vertebrate
      Insecticide Resistance: The in vitro Endrin
      Effect on Succinic Dehydrogenase Activity on
      Endrin Resistant and Susceptable Mosquitofish".
      Bull. Environ. Contam. & Toxicol. 6(2): 171-176,
      1971.

65    Cory, L., P. Fjeld, and W. Serat.  "Environmental
      DDT and the Genetics of Natural Populations".
      Nature.  229:128-130, 1971.

66    Cope, O. B.  "Contamination of the Freshwater
      Ecosystem by Pesticides".  J. Appl. Ecol.
      3(Supplement): 33-44, 1966.

67    Walker, C. R.  "Chemicals and Their Effect on
      the Aquatic Environment". Proc. Southern Weed Science
      Society.  24:  39-57, 197lT~~~'

68    Walker, C. R.   Problems in Clearance and Registration
      of Herbicides for Aquatic Areas.' U. S. Department of
      Interior, 1969.

69    Sprague, J. B.  "Measurement of Pollutant Toxicity
      to Fish. I. Bioassay Methods for Acute Toxicity".
      Water Research.  3:  793-821, 1969.
                             134-E

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70    Sprague, J. B.  "Measurement of Pollutant Toxicity
      to Fish. II. Utilizing and Applying Bioassay Results"
      Water Research.  4(1):  3-32, 1970.

71    Sprague, J. B.  "Measurement of Pollutant Toxicity
      to Fish. III. Sublethal Effects and 'Safe1 Concentra-
      tions".  Water Research.  5(6):  245-266, 1971.

72    Post, George and T. R. Schroeder.  "The Toxicity of
      Four Insecticides to Four Salmonid Species".  Bull.
      Environ. Contain. & Toxicol.  6(2):  144-156, 1971.

73    Deichmann, W. B. and J. L. Radomski.  "Retention of
      Pesticides in Human Adipose Tissue - Preliminary
      Report".  Industr. Med. & Surg.  37:  218-219, 1968.

74    Radomski, J. L., W. B. Deichmann and E. E. Clizen.
      "Pesticide Concentrations in the Liver. Brain and
      Adipose Tissue of Terminal Hospital Patients".
      Fd. Cosmet. Toxicol.  6:  209-220, 1968.

75-89  References to be provided under separate cover.

90    Cecil, H. C., J. Bitman and S. J. Harris. "Estro-
      genicity of O,p'-DDT in Rats".  Agr. & Food Chem.
      19:  61-65, 1971.

91    Fahim, M. S., R. Bennett and D. G- Hall.  "Effect
      of DDT on the Nursing Neonate".  Nature.  228: 1222-
      1223, 1970.

92    O'Leary, J. A., J. E. Davies, W. F. Edmundson and
      M. Feldman.  "Correlation of Prematurity and DDE
      Levels in Fetal Whole Blood".  Amer. J. Obstet. &
      Gynecol.  106:  939, 1970.

93    O'Leary, J. A., J. E. Davies, W. F. Edmundson and
      G. A. Reich.  "Transplacental Passage of Pesticides".
      Amer. J. Obstet. & Gynecol.  107:  65-68, 1970.

94    Deichmann, W. B.  and W. E. MacDonald.  "Organo-
      chlorine Pesticides and Human Health".  Fd. Cosmet.
      Toxicol.  9:  91-103, 1971.
                             135 -E

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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,





                           1-F

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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-





                           2-F

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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

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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

-------
          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

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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

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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

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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

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     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

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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

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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

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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

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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

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                       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

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     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

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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

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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

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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,
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      Science, Vol. 170, 1970, pp. 1206-1207.

27    Water Quality Criteria, Report of the  National
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28    Wiersma, G. B., P. F.  Sand, and R.  L.  Schutzmann,
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      No. 2, 1971, pp.  223-227.

29    Henderson, C., A. Inglis, and  W. L. Johnson,
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      1971, pp.  1-11.

30    Lichtenberg, J. J., J. W. Eichelberger, R.  C.
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      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
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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

-------
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

-------
"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

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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





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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




                          18-H

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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.
                           19-H

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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.
                          20-H

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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.
                           21-H

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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





                          22-H

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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





                           25-H

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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

-------
       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

-------
•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)

-------
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

-------
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.

-------
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

-------
     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

-------
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

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              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

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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

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                      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

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"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

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"Environmental Protection Act"
[111. Ann. St. (1966), ch. Ill 1/2,
s 1001 to 1051]
  54-H

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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

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                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

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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

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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

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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

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                   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

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           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

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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

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                  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
                          63-H

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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
                         64-H

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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
                           67-H

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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.
                         69-H

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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.
                          70-H

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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.]
                         71-H

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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






                          75-H

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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.
                         76-H

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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]
                         78-H

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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."
                         79-H

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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

-------
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.

-------
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.

-------
     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.

-------
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

-------
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

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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

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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.





                         122-H

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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





                         123-H

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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.





                         124-H

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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-





                         125-H

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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






                         126-H

-------
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.






                          127-H

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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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