EPA - 540/9-77-009
INCENTIVES FOR RESEARCH
AND
DEVELOPMENT IN PEST CONTROL
VOLUME II
APPENDICES
DECEMBER 1976
FINAL REPORT
ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF PESTICIDE PROGRAMS
WASHINGTON, D.C. 20460
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EPA REVIEW NOTICE
This EPA Report has been reviewed by the Office of
Pesticide Programs and has been approved for publi-
cation. Agency approval does not signify that the
contents necessarily reflect the views and policies
of the Environmental Protection Agency, nor does
mention of trade names or comercial products con-
stitute endorsement or recomendation for use.
For sale by the
National Technical Information Service
Springfield, Virginia 22151
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INCENTIVES FOR RESEARCH AND DEVELOPMENT IN PEST CONTROL
VOLUME II APPENDICES
DECEMBER 1976
Prepared by
Alfred E. Wechsler
Joan E. Harrison
Alan Burg
Donald Gibbons
Joanne Perwak
Robert Terry
for
Experimental Technology Incentive Program
National Bureau of Standards
and
Environmental Protection Agency
Office of Pesticide Programs
Strategic Studies Unit
Washington, D.C. 20460
Frederick W. Talcott
Project Officer
EPA- 540/9-77-009 Contract 68_01.3133
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ACKNOWLEDGMENTS
This program was conducted by Arthur D. Little, Inc., under EPA
Contract 68—01—3133. Dr. Alfred E. Wechsler was the project director,
Ms. Joan E. Harrison the assistant project director. Other key partici-
pants at Arthur D. Little, Inc., included Dr. Alan Burg, Ms. Paula
Didriksen, Dr. John Fu.nkhouser, Mr. Donald Gibbons, Mr. Robert Ludwig,
Dr. Hadi Madjid, Ms. Jane Metzger, Ms. Joanne Perwak, Mr. Michael
Michaelis, Mr. Donald Senechal, Mr. Robert Terry, and Ms. Judith Varone.
Dr. William Matthews (MIT) was a consultant to the program.
The work was performed under the guidance and with the assistaliCe
of Mr. Frederick W. Talcott (project officer) and Dr. Jay Turim of the
Office of Pesticide Programs, EPA; and Mr. Dan Fulmer and Mr. Phil Harter
(project officers) and Dr. Jordan Lewis of the Experimental Technology
Incentives. Program, National Bureau of Standards.
The ADL project staff gratefully acknowledges the contribution of
representatives of many U.S. pesticide companies whose cooperation and
valuable comments and critique made this work possible and meaningful.
Similarly, the extensive assistance and cooperation provided by the
staffs of EPA, USDA, and many other federal agencies, industry and farm
associations, and environmental groups was essential to the program.
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TABLE OF CONTENTS
Preface Page
Appendix A. History of Pesticides 1
1. Pre—1940 1
2. World War II 6
3. The Post—War Period 8
4. Summary 12
Appendix B. Factors of Importance in Pesticide Development 13
1. Factors Affecting Product Discovery 13
2. Factors Affecting Product Development 14
Appendix C. Concept and Framework for Incentives 19
1. The Incentive Concept 19
2. The Conceptual Framework 20
Appendix D. Preliminary Criteria for Screening of Potential
Incentives 29
Appendix E. Summary Listing of Original Incentive Actions 35
Appendix F. Results of Initial Screening of Incentives 45
Appendix G. Preliminary Working Papers 51
Government Insurance for Minor Crops 52
Government Insurance for Farmers Using Improved 54
Pest Control Methods
Government Support to Users of USDA 1PM Service 56
Reduced Registration Time for Safe Products 58
Reduced Registration Requirements for Biological
Controls 60
Government Funding of Environmental and Residue
Testing for Minor Crop and Specialty Pesticides 63
Government Generation of Environmental/Residue
Data for Minor Crop and Specialty Products 66
EPA Generation of Additional Registration Data 68
Government Funding of Research on Formulation 70
and Application Methods
Definition of Standards for “Safety” 72
Clearinghouse for Research Results 74
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TABLE OF CONTENTS (Continued)
Research Investment Credit 76
Repayment Loan Fund for Pesticide R&D 78
Low—Interest Government Loans 81
Proprietary Protection for Biological Pest Control
and 1PM 83
Commercialization of Pesticide Products Developed
by or for the Government 86
Aggregation of Public Sector Market Demand 88
Expansion of the Number and Role of Independent
Pest Management Consultants 90
Pesticide Development Award 92
Appendix H. Industrial, Government, and Association Contacts
in this Program 93
Appendix I. List of Comments on Proposed Preliminary Incentives
(by Incentive Category) 95
Appendix J. Comments on Preliminary Proposed Incentives 107
Appendix K. Relative Ranking of Incentives by Government
Agencies and Associations 199
Appendix L. Relative Ranking of Incentive by Industry 203
Appendix M. Average Ranking of Incentives 207
Appendix N. Incentive Suggestions From Industry, Government,
and Association Staff Contacted During Review
of “Interim Working Document” 209
Appendix 0. The Appropriateness of Incentives in Alternative
Futures 213
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PREFACE
This volume contains appendices which provide background Information
and additional details to support the results of the incentives program
given in Volume I. The Appendices cover four major areas as described
below:
Background Information——Pesticide History Appendices A & B
and Factors of Importance in R&D
A Conceptual and Evaluatory Framework for Appendices C & D
Incentives
The Process of Initial Development and Appendices E
Evaluation of Incentives——a Chronological through M
Presentation
• Listing and Initial Screening of Incentives Appendices E & P
• Preliminary Working Papers Appendix G
• Comments on Incentives Appendices I & J
• Ranking of Incentives Appendices K,
L &M
• Contacts in the Program and Additional Appendices H & N
Incentives Proposed
A Projection of the Future Impact and Acceptance Appendix 0
of Incentives
The reader is urged to examine Volume I and the Conference Report* prior to
reading these Appendices.
“Developing Incentives for Pest Control Methods.” Proceedings of a
Conference. National Bureau of Standards, Gaithersburg, Md., October
26 and 27, 1976, Under Contract No. 68—01—3133.
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APPENDIX A
HISTORY OF PESTICIDES
Attempts at pest control have been made since ancient times. Even
without knowledge of insect physiology or plant chemistry, farmers
utilized naturally occurring substances such as pyrethrum, which Marco
Polo brought to Europe from the Far East. Sabadilla preparations have
been used as louse powders by South American natives, and red squill has
been used as rodenticide since before recorded history. As early as 1763,
ground tobacco was used in France to control aphids.
In the past 100—150 years, however, vast changes have taken place
in control methods. Figure A—l shows some of the innovations which have
taken place along with some of the changes in regulations. The innova-
tions can be grouped into three major periods each with its own innova-
tions and use patterns: Pre—1940, WWII, Post—WWII.
1. PRE—1940
This era covers the period from about 1850 to 1939. It is character-
ized by very slow progress in the pesticide field, but important innovations
In basic research. Great progress was made in such fields as insect and
plant physiology, biochemistry, and organic chemistry. The pesticides
used during this time were largely inorganic compounds, or organic com-
pounds isolated from natural sources (pyrethrum, rotenone). During this
time the public was just becoming aware of the role that insects played
in agriculture and as disease carriers.
Most of the progress in pesticide development during this initial
period occurred with fungicides, perhaps because the grape industry, with
serious losses attributable to fungi, was one of the few organized agri-
cultural ventures. The first fungicide, called Bordeaux Mixture (copper
sulfate and hydrated lime) was used in French vineyards in 1885. About
1907, the prime sulfur solution and the self—boil prime sulfur mixture
were developed for use as fungicides. These three compounds were standard
from about 1907 to about 1930, and most of the research during that time
concentrated on finding the proper rates and timing of applications of
the three compounds.
Insecticides used during this period were primarily the arsenical
compounds. Paris green, the first and most widely applied arsenical
insecticide, was used in efforts to control the Colorado potato beetle
in 1865 and continued to be used in the early 1900’s for a wide variety
of pest problems. It was replaced to some degree by calcium arsenate,
which was less expensive and more effective against specific targets such
as the boll worm. Sodium arsenite is still used both as an insecticide
and a herbicide.
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The first petroleum product, kerosene, was used for insect control
in 1877. Soon after, crude petroleum was found to be phyto—
toxic to most plants, so various fractions of petroleum were investigated.
The first synthetic organic compound used to kill insects was carbon
disulfide, used as a fumigant in 1852. Hydrogen cyanide was introduced
in 1886 as an insecticide and was the first instance in which an insect
developed resistance. In 1911 the Germans used paradichlorobenzene, also
one of the first synthetic insecticides, against moths.
In 1922 the USDA conducted a systematic search for new synthetic
insecticides. Nicotine was proposed as the first compound to be
synthesized, and in 1928 a method for forming a nicotine—like compound
was discovered. The structure of pyrethrum, which had been used for
centuries, was described in 1924, but the compound was not successfully
synthesized until the 1950’s. The structure of another naturally occur-
ring insecticide, rotenone, was described in 1932, but was not synthesized
until 1961. In this same time span, the mode of action of physostigmine,
a naturally—occurring carbamate, as a cholinesterase inhibitor was
recognized, although this compound was not used as an insecticide. But
again, investigators were not able to synthesize the compound until later.
Biological control was used successfully in Missouri in 1870.
Parasites of the plum curculio were distributed for control purposes
from one part of Missouri to another. In 1873 a predatory mite from
abroad was introduced for control of the grape phylloxera in Missouri.
However, the success of these initial programs was not spectacular
enough to cause widespread Interest In biological control.
The Incident that did the most to promote the development of biolog-
ical controls occurred in California in 1889. Albert Koebele, from
California, was sent to Australia in 1888 to search for a predator or
parasite of cottony cushion scale, which was causing extensive damage to
citrus trees by feeding on leaves and twigs. The first shipment of the
vedalia, a predacious lady—bird beetle arrived, and within two years the
scale was under control and citrus production doubled.
By 1900, interest in biological control had increased considerably,
and in 1905 the Bureau of Entomology began a search for natural enemies
of the brown tail moth and gypsy moth. The explorations in this case
were more difficult and continued from 1905 to 1914, covering all of
Europe and Japan. The explorations were renewed and completed in 1922-
1927, and 13 species of parasites and predators were successfully
established in New England. However, their introduction did not completely
control these pests.
Other than the introduction of natural enemies, few types of biolog-
ical control were used during the pre—Worid War II period. Bacillus
thuringiensis was isolated in 1915 and a few attempts were made to use
this organism as a microbial pesticide; however, the results at that time
were not very encouraging. Some of the biological controls were
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incorporated into early integrated pest management (1PM) techniques. In
Germany in the 1930’s, government management of forestry practices used
several types of controls including the encouragement of natural pest
predators.
Herbicides were not commonly used before 1940. The earliest
herbicides included the Bordeaux mixture and other inorganic salts such
as ammonium sulfate and ferrous sulfate. The first organic chemical
used for weed control was DNOC in 1932. In general, research in herbi-
cides did not start until much later, when chemical agents structurally
related to the plant hormones (2,4,—D) were discovered.
2. WORLD WAR II
World War II was a major stimulus to the chemical industry, and a
great many chemicals were synthesized during this period. Many of the
chemicals were not originally developed as pesticides, but were recognized
as such a few years later. As a result of the high interest in synthetic
organic compounds from 1940-1950 and the questionable results from biolog-
ical controls, interest in this latter type of control declined.
The most important advance surrounding the World War II period was
the screening of synthetic organic chemicals as insecticides. The most
notable development during this period was the use of DDT as an insecti—
cide. Although this compound was first described in 1874, its insecticidal
value was not recognized until 1939. In that year, potato crops In
Switzerland were threatened by the Colorado beetle. Giegy provided Swiss
entomologists with a sample of DDT for testing, and its effectiveness
was confirmed. It was soon recognized that DDT could be used against
other pests, and its popularity grew rapidly. DDT was introduced into
the United States in 1942 under the trade name of Gerisol, and by 1943
was being manufactured in the United States. During the war it was used
only by the military, but afterwards became available for civilian use.
The success of DDT led to the testing of many analogs for insecticidal
value, such as TDE, methoxychlor, and the bromine and chlorine analogs.
DDT was followed in rapid succession by Bi-IC, toxaphene, heptachior, aldrin,
and dieldrin by 1950. The discovery of taxaphene was significant in that
it was one of the first pesticides developed by directed research. (A
chemist at Hercules Powder Co. hypthesized that insect toxicants would be
found in the highly chlorinated terpene products. Compounds of this type
were synthesized, and toxaphene was found in 1949.)
During the 1940’s, the chlorinated hydrocarbons were tested and found
to be effective on many pests. The high persistence of these compounds
was considered beneficial, and the environmental implications were not yet
realized. These compounds were so successful that other types of chemicals
which were also developed during this period, such as the organophosphates
and the carbamates, were not utilized.
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The organophosphates were developed in Germany with the expectation
of using them for warfare, although some were immediately recognized as
useful insecticides. In 1938, tetraethyl pyrophosphate (TEP?) was de-
scribed as a potent insecticide by Schrader (I.G. Farbenindustrie), and
in 1939 as a cholinesterase inhibitor. By the end of the war, Schrader
had prepared about 2,000 organophosphorus compounds, such as malathion,
parathion, schradan, etc. Some of these chemicals were found to be effec-
tive against pests that were not controlled by earlier compounds. The
organophosphates were marketed on a small scale after the war even though
special precautions had to be taken because of their acute toxicity.
These organophosphates, however, did not reduce significantly the overall
dependence on DDT for insect control during this period.
Carbamates were also developed in the World War II era. The first
were fluoro compounds prepared by Schrader as contact insecticides in
1936—1944. In 1947—1952, Gysin developed n, n—dimethylcarbamates such
as isolan, dinietan, pyrolan, dimetilan and pyramat. About 10 years later,
Sevin, one of the most commonly used carbamates, was described.
The scarcity and high cost of insecticides such as pyrethrum in 1938
led to the development of syriergists for this compounds. Sesame oil was
recognized as a synergist, because of the presence of sesamin. The knowl—
edge of this structure led to the synthesis of related compounds such as
piperonyl cyclonene and piperonyl butoxide. By 1948, pyrethrin type esters
(allethrins) were synthesized and available in large quanities. The
synergists are still used to make the synthetic pyrethrins economical.
An important innovation in application methods occurred in 1941 with
the development of aerosols. This type of carrier was effective and easy
to use. The need for mosquito control in the war zone was so great that
aerosol bombs were used the year after they were discovered. After the
war, they became available for civilian use, and the popularity of the
aerosol containers grew to a $33 million business in 1949.
Another war—related development for mosquito control was the repel—
lents. From 1901 to 1938, oil of citronella was the most widely used
insect repellent. During the war, however, when the need for repellents
under combat conditions was recognized, the Army tested about 7,000 organic
chemicals for insect repellency. Compounds that were developed from this
screening included Indalone, dimethyl phthalate, and Rutgers 612.
The use of herbicides grew rapidly immediately after WW II. The
first chemical widely used for weed control was 2,4—D, developed in 1944.
Within 5 years, 2,4-.D was used on more than 22 million acres of small
grains and corn in the United States. Another important herbicide,
2,4,5—T was registered for use in 1948, but this compound was not used
widely until the late 50’s and early 60’s.
The development of fungicides was slow between 1940 and 1950.
Bordeaux mixture and the sulfur compounds were replaced to a small extent
by newer, more effective materials, such as the copper compounds and the
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dithiocarbamate and quinone fungicides.
Few innovations in biological control occurred during the war period,
in part because of a decline in the USDA funding of biological control
investigations. The change in USDA policy was a result of the uncertainty
of biological control effectiveness, and the surge in the use of synthetic
organic insecticides.
In 1947 Vanderplank discovered that insect control could be achieved
by irradiation sterilization. However, this method was not used in the
field until almost ten years later. Chemosterilants were also recognized
as potentially effective in 1948.
3. THE POST-WAR PERIOD
After the war years, fewer innovations are evident although the
number of new compounds has increased steadily. The massive screening
programs of the 1940’s had identified many broad spectrum compounds that
could be used effectively against most recognized problems (except those
requiring fungicides). Many of the compounds discovered in the forties
were not widely used until the late 1950’s and early 1960’s because of
this market saturation. After this, the use patterns shifted toward less
persistent chemicals and, recently, more emphasis has again been placed
on biological control and integrated pest management.
The 1950’s was a time of rapid expansion in the use of the organo-
chlorines. By the 1960’s, however, public concern about the persistence
of organochlorine pesticides was growing. At the same time, insect re-
sistance to insecticides was becoming a problem. From 1908 to 1945, only
13 species of insects or ticks developed resistance. In 1964, about 137
species had developed resistance. These two factors, persistence and
insect resistance, helped the growth of organophosphates as substitutes
for the organochiorine insecticides In the 1960’s.
In the mid—l960’s, 65% of the insecticides used were still chlorin-
ated hydrocarbons and 22% of the total were organophosphates. In 1970,
many registrations for DDT were canceled, and by 1972 virtually all DDT
uses were banned. On the other hand, the production of methyl parathion
increased 24% per year between 1964 and 1969. Other relatively new
products such as Furadan and Bux Ten, have been replacing chlorinated
products. In 1972, chlorinated hydrocarbons, such as DDT, toxaphene,
chlordane, aidrin, and methoxychior still dominated the domestic market.
Recent cancellations of aidrin, dieldrin, heptachior, and chiordane will
affect the dominance of these chlorinated hydrocarbons.
A recent compound (1975) which shows encouraging results is NRDC—l43,
developed by Britain’s National Development Corporation. This compound
is a pyrethroid and appears to be 100 times as effective as DDT, but non—
toxic to mammals and birds. Previous synthetic pyrethroIds have had
stability problems, and they have been confined to indoor use. NRDC—143,
however, persists long enough to achieve effective killing, but not long
enough to accumulate.
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The use of herbicides, especially 2,4,5,—T and 2,4—D, has continued
to increase in recent years, and in 1962—1965, herbicides comprised 20%
of the total organic pesticide production in the United States. Military
use of 2,4,5—T as a defoliant in Vietnam rose sharply after 1962, and was
used even more extensively after 1967. Birth defects in Vietnam were
attributed to defoliants, and more studies were conducted on these chemi-
cals. Attempts were made to restrict the use of 2,4,5—T in the U.S. and
abroad in 1969.
In the early 1950’s, the discovery of 2,4,5—T led to large screening
programs. These screening programs, along with attempts to inhibit photo-
synthesis, resulted in the development of triazines.
By 1968, the triazines had become more important (in sales) than the
phenoxy compounds (2,4—D and MCP) and were widely used on corn. Triflur—
aim, a pre—emergent compound, became important in cotton and soybean
treatment. The use of benzoic acids (Amiben and Dicamba) has also increased.
In 1975, herbicides accounted for 62% of manufacturers’ pesticide sales,
insecticides accounted for 32% and fungicides for 6% (synthetic organic
pesticides).
The use of fungicides has changed little in recent years. The most
important compounds, as of 1972, were PCP, the dithiocarbamates, TCP, Captan,
PCNB, and Cyprex.
Interest in biological control has been renewed since World War II.
One of the most well—known tests of biological control took place in the
1950’s. The object of the campaign was the screwworm in the southern
United States. From 1935 to 1937, the USDA tested various chemicals on
this pest, but none was effective. In 1946, Knipling, a scientist at USDA,
suggested that male sterilants might be utilized. Organic compounds were
screened, but none were as successful as ionizing radiation in producing
male sterility. Tests were begun with x-ray and gamma radiation and both
were found to be effective. Extensive field tests were conducted and the
technique was found to be successful in controlling the screwworm.
This success led to the development of other types of sterilants,
such as chemosterilants. Goldsmith and co—workers, 1948—1955, found that
certain chemicals caused retardation and abnormal development in insects
that resulted in sterilization of the female. Since 1959, numerous com-
pounds have been screened as potential chemosterilants. The most widely
used compounds include apholate, tepa, and metepa.
The development of microbial pesticides has continued steadily since
the mid—l950’s, when the function of the toxin in Bacillus thuringiensis
was discovered. This discovery, and advances in the fermentation industry,
made mass production possible, and in 1958, the first commercial prepara-
tion became available. Several preparations have been commercialized since
then. Insect viruses such as polyhedrosis viruses are being tested and
one has been registered, but such areas as stability, application, and
consistency of results have been problems.
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Hormonal control of insects has also developed in recent years.
Two discoveries made this technique possible. First, Wigglesworth identi-
fied the gland responsible for differentiation of hormones. Second,
Carroll Williams of Harvard isolated a juvenile hormone from the adult
male cecropia silkworm. Work on the juvenile moulting hormone, ecdysone,
at the University of Wisconsin in 1962, isolated and identified the struc-
ture of this compound.
Zoecon Corporation, in California, is investigating hormonal control
of insects. Its product, Altosid SR—lO, a growth upsetting mosquito
larvicide, has been successful in the field, and has just recently been
registered.
Anti-juvenile hormones, capable of controlling insects in the larval
stage have recently been discovered in plant extracts. These anti—secretion
compounds show great promise for a variety of pests.
Since 1950 attractants have also been tested as an insect control
method. In Florida during 1956—1957, a hydrolysate—bait was applied with
malathion for control of the mediterranean fruit fly. The amount of
malathion required was only one—fourth that needed without the attractant.
The test was highly successful, and other combinations were developed.
The natural sex attractant was isolated from the female gypsy moth around
1960 in Germany. A similar sex lure called gyplure has been synthesized
and has been produced in quantity in the United States. Other sex attrac-
tants have been isolated since that time, but they are used mainly as bait
and survey material. Around 1967 and 1968, many more pheromones were
isolated through the use of improved microanalytic techniques, and their
function is now perceived as one of controlling insect problems rather
than surveying. Recently an experimental permit was acquired for the use
of pheromones as a control technique.
The two major innovations in application methods which have occurred
in the last 25 years were the development of aerogels and ULV. In 1959,
the silica aerogels were found to be effective against termites. (The
dust vehicle itself was found to be effective, and the mode of action was
dessication.) The development of ULV in 1964 reduced the costs associated
with transporting, mixing, and applying the carrier. The efficiency of the
Insecticide is sometimes increased in this type of application. To date,
however, few compounds have been registered for ULV use.
Encapsulation and other slow release techniques have been tested in
the last 10 years. Pennwalt Corporation developed a technique of encapsul-
ating methyl parathion which makes it less toxic to handle, and more
persistent in the field. Pennwalt is also testing an encapsulated synthetic
sex attractant against the gypsy moth in cooperation with USDA. Other
pesticide companies are also investigating the possibilities of encapsula-
tion, plastic laminates and polymeric capillary tubes for the slow release
of pheromones.
The importance of integrated pest management has increased
considerably in recent years. 1PM has had a sporadic history, with
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impetus coming mainly from lack of alternatives, i.e., after single
control methods have been tried and have failed.
An early example of a conscious attempt at integrated control took
place in California from 1955 to 1960. The spotted alfalfa aphid was
first detected in California In 1954. Within two years, it spread widely
over the state and was devastating the alfalfa industry. Natural preda-
tors were unsuccessful in controlling the aphid. Broad spectrum organo—
phosphates were then used, but these insecticides killed many of the
natural predators and parasites. However, the aphids were fairly well
controlled until resistance developed and the control costs increased.
The solution seemed to be to use natural predation with a selective chemi-
cal that would not interfere with the predatory population. Therefore,
Demeton was used, along with the biological control, and the aphids popul-
ation was greatly reduced within a year.
The availability of alternative methods of pest control has increased
greatly, as have the number of accepted control methods. The question is,
however, whether the use of these alternatives has increased with time.
As was described in the section on the history of pesticides, the
years before 1940 were characterized by the use of a limited number of in-
organic compounds, such as sulfur, copper, lead, and arsenic. These
materials were used for fungicides, herbicides, and insecticides. The
alternatives available at that time were also somewhat limited.
A few organic compounds were available before 1940, and these were
used sporadically as fumigants and moth—proofing agents. The most widely
used alternative method was biological control (the use of predators and
parasites). Actu-ally, interest was quite high in this type of control
since the inorganic compounds were not always effective.
The success of biological control was dampened with the advent of
DDT in the 1940’s and 50’s. At the same time, the organophosphates and
the carbamates were available. However, DDT supplanted almost all other
methods of control and few alternatives were utilized during this period.
With the unexpected development of resistance to DDT, and the coin—
plaints of DOT’s persistence in the environment, some of the other chemicals
were brought into use in the 1960’s and 1970’s. Today, the selection of
accepted chemicals is wide, as is the range of alternatives. Accepted
means of control today include the chlorinated hydrocarbons, organophosphates.
carbamates, and the phenoxy and triazine herbicide. The chlorinated hyro—
carbons and the phenoxy compounds are losing favor, however, they are still
widely used.
Many options besides the chemicals described above are available
today. Interest in the introduction of parasites and predators has been
revitalized, and bacteria and viruses are also used to control insects.
Sex attractants, juvenile hormones, and male sterilants may be utilized.
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The extent of use of these alternatives is not particularly high
at the present, except perhaps for the use of predators and parasites.
Acceptance of these new methods is slow, but increasing. They are used
in most cases when traditional methods of control fail or are not avail-
able.
One type of pest control which could be considered an alternative
is integrated pest management. This control method became more widely
used in the 1960’s and 1970’s almost out of necessity. A complete manage-
ment program is used when a single minded control attempt is not as
successful as it might be. Integrated control attempts to combat pests
using resistant crop strains, natural predators and parasites, and addi-
tional chemical or non—traditional methods when necessary.. The role of
this alternative should become increasingly important in the future,
since it has been successful in many cases.
4. SUMMARY
In general, pest control development has advanced steadily since its
slow start——early in the century and the burst of activity around WW II.
A current limit to innovative advancement is the lack of coordination be-
tween the basic research being conducted and efforts to develop and
commercialize products. If these and other barriers discussed earlier
were eliminated, it is likely that the late 1970’s and early 1980’s could
be a period of major advancement.
The identification of sources or funders of innovations is particularly
important to the development of incentives since they may be the most
appropriate recipients of incentive. An historical perspective is useful
in this consideration.
Non—traditional control methods have come from various sourcep, but
do not usually originate from pesticide companies. A large amount of work,
especially with predators and parasites, has been done by USDA. University
and individual researchers are much more important in providing innovations
in non—traditional control methods. The funds are provided by such sources
as USDA, NSF, the Rockefeller Foundation, and grower’s associations. Work
on pheromones, juvenile hormones, and viruses have been funded via these
channels.
In terms of actual pest control methods available to the user, how-
ever, pesticide companies are the major force in pesticide development at
this time. In the past, innovations such as DDT, the organophosphates,
and the carbamates were developed by European chemical companies. This
source of innovation continues to be important today, with the contribu-
tion of American companies becoming important. Systemic insecticides and
the triazine herbicides are examples of recent innovations coming from
chemical companies. Although incentives may apply elsewhere, with some
results, they will be most useful if they indirectly or directly influence
industry.
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APPENDIX B
FACTORS OF IMPORTANCE IN PESTICIDE DEVELOPMENT
Investigations into pesticide development in the past showed that a
historical perspective is not necessary to develop incentives for pesti-
cide development. As described in Volume I, we felt that the best way
to determine where incentives would be most effective was to Interview
various pesticide companies and determine what factors affected pesticide
development.
The following section details the results of our discussions with
industry. It describes the factors which affect or are considered in
pesticide development. Various factors or problem areas which may be
improved by incentives have been highlighted. The identification of
these problem areas led directly to the development of the 64 incentives
described in Appendix E.
1. FACTORS AFFECTING PRODUCT DISCOVERY
a. Serendipity
Serendipity——the gift of finding the unsought-for valuable——is an
undefinable commodity which sometimes operates in the development of pest
control methods, but is especially Important In the early stages. (In
one case, for example, a drug company was testing compounds using mice
and rats as laboratory animals. High rat mortality was reported for one
of the compounds, and the compound eventually was developed as a rodenti-
cide.) Serendipity is usually not pure chance, but requires a well—
qualified observer to capitalize on the circumstances. Because serendipity
is unpredictabie and uncontrollable, it is not very susceptible to in-
fluence by incentives.
b. Synthesis Operations
Companies vary widely in their synthesis and screening operations.
Many pesticide companies synthesize and screen large numbers of chemicals
by a variety of techniques. Some companies do no synthesis, and prefer
to license compounds from other companies or sell non—proprietary com-
pounds. Others synthesize all types of compounds, often for purposes
other than pesticide use, but screen everything for pesticidal activity.
Many International companies do all synthesis work in Europe, with
the American counterparts continuing the development. A few, however,
do both in the United States. The types and Innovativeness of the com-
pounds synthesized depend on the company, and the scientists involved,
and do not seem to be generalizable. Screening operations usually Include
only the major crops and pests. One company told us It screened potential
pesticides for effectiveness on corn, soybeans, wheat, rice, potatoes,
sorghum, and sugarbeets only.
13
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The screening also varies greatly from company to company——size,
thoroughness, time of observation, etc.
Although synthesis and screening operations are not major roadblocks
In the development of pest control methods, incentives can be applied
usefully at this stage of development when:
(1) The typical synthesis and screening operation excludes the
possibility of developing innovative products.
(2) Profitability considerations preclude a screening operation,
a common occurrence for minor crops.
2. FACTORS AFFECTING PRODUCT DEVELOPMENT
a. Return on Investment and Profitability
Gaining adequate return on their investments was the major concern
of all the companies we talked to; however, investments and returns
vary widely from company to company. First, investments In a product
depend on the type of product and the type of company. At one extreme,
a large basic producer would have to invest money into research, testing,
fulfilling registration requirements, production facilities, insurance,
and advertising and sales. At the other end Is the small company that
does not do its own research and thus has to invest only in a license f or
a product, production facilities, and marketing.
Company policies also bear directly on the question of profitability.
For example, some companies will consider only those products which have
the potential to grow at some minimum rate. One company we talked to ex-
pected a 12% annual growth rate. Moreover, some companies are interested
only in the short—term profitability of a product. These companies usually
obtain their products by licensing from other companies, and avoid spend-
ing time and money on research. Conversely, some companies conduct a
great deal of research and invest a great deal In a product and therefore
are interested in long—term profitability. Finally, some companies try
to achieve profitability with one big winner rather than with several
smaller products. Thus, while most of the companies we talked to were
concentrating their efforts on one product, one company preferred to look
for three $35—million products, for greater stability. These decisions
are very company—specific and cannot be correlated with company type.
Another variable is the amount of risk a company considers accept-
able. In the consideration of a compound, the risks or unknowns Include
such things as registration time and cost, the market size, and the possi-
bility of lawsuits. The risks are evaluated in different ways, with
different thresholds. Some companies have sophisticated models in which
they incorporate the estimated risks. The outcome is a prediction of
profit which is then rated as acceptable or unacceptable. Other companies
have less elaborate means of coming out with a similar type of prediction.
The thresholds of risk are company specific, and not always consistent.
14
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They also are not generalizable as to type of company.
In summary, the relationship of this factor to Incentives Is vague
because company policy largely determines the required R.0.I. and profit-
ability. There are other factors discussed below which are tied to this
factor, where problem areas are more easily Identified.
b. Size of Market
The size of the potential market is an essential consideration in
the evaluation of a product. Just about every company has some idea of
its minimum acceptable market size. This threshold ranges from $100,000
to $1 million to $10 million, depending on the type and size of the
company. A smaller licensing company with no particular marketing scheme,
and looking for short—term profitability, might consider a market as
small as $100,000. The smaller basic producers, or the larger licensers
or formulators might search out markets of $1 million or more. The
companies looking for the big markets ($10 million or more) are the larger
companies.
In specific cases the actual minimum will be determined in large
measure by the profit potential. As described previously, a high invest-
ment is required to develop a pesticide, and the market volume must be
sufficient to provide a return on the investment. Most minor crops cannot
provide this market volume, so a compound rarely is developed especially
for. minor crops. Companies who have done this say they would not attempt
it again.
Many minor crops are covered through extension of the registration
of a product developed for a larger market. Many companies, however, feel
this procedure is not economically feasible, since the cost of extending
a registration is usually around $25,000, and sometimes as high as $100,000
for a food crop. In many cases, this investment is considered too large.
Moreover, many compounds will not be reregistered for minor uses because
of the cost of the additional testing required.
Another important consideration in the determination of a threshold
market is liability. Many low—volume crops have a high cash value, and
one suit could wipe out a whole year’s sales. Companies reported to us
cases where growers requested a product and then sued the company when
the product proved Ineffective or phytotoxic. In several instances, prod-
ucts have been taken off the market because of suits. The home and garden
area is particularly sensitive, since liability centers around human
hazard. Several companies we talked to had gotten out of, or were hesitant
to go into the home and garden market, even though they felt it was
profitable. Companies also want to avoid suits because they give a prod-
uct a bad name and indirectly could have a significant economic Impact.
For example, a small suit involving a minor crop could have large effects
on the sale of a product to a larger market. Most companies feel that the
liability risks are too high in a minor crop.
15
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The IR—4 project, which has had some effect on companies’ considera-
tion of minor crops, is in effect, an incentive already in operation. This
project is part of the CSRS, and was set up in 1963 to compile required
information for obtaining pesticide tolerances and registered labels on
minor use crops. Initially, this organization gets recommendation from
state extension services and makes a list of priority problems. IR—4 then
goes to the company involved and assesses the chances for registration, and
obtains the company’s agreement to register it. The residue work is done
by the state experimental stations. This data, together with that from
the company, Is combined and sent in as a regular application. The only
difference is that the $10,000 application fee is waived for IR—4.
The effect of this program on companies is to decrease their invest-
ment costs greatly and thus make smaller markets more attractive. How-
ever, liability problems remain to be considered. In fact, they may be
more serious in the eyes of the company, since the data has been submitted
by another party, whose work is often unknown to them. For this reason,
many companies are still hesitant to register their products on minor
crops. In addition, the general opinion is that IR—4 needs to be expanded
or reorganized. Many companies feel that the project is bogged down with
formulations, and is not as effective as it might be.
The foregoing analysis of market size suggests several roadblocks
which may be amenable to incentives:
1. The high investment required for the low return of minor crops
is often a blockade.
2. Liability Is a barrier to the protection of high—value, low—
volume crops and to the home and garden market.
3. Company policy dictated by the need for a big winner neglects
the smaller markets.
4. The work of IR—4 is hampered by the unwillingness of many
companies to register products cooperatively, and by the large
volume of registrations requested each year.
c. Proprietary Position
A proprietary position on a product is considered essential by most
companies, and patents are the prime means of obtaining this position.
In rare cases, a company may have such a processing or marketing advantage
that it feels its position is safe, even without a patent.
The lack of patentability of non—traditional control methods has pre-
sented a problem to many pesticide companies. Naturally—occurring materials
such as Bacillus thuringiensis are not patentable; and several companies
suggested that they would not go into biological controls without a patent.
One company that has gone ahead with this type of product felt that its
advantage was in marketing.
16
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Other products, such as synthetic hormones or growth regulators, are
patentable, and several companies reported that they were doing research
in these areas.
Any products developed with government financing are also not patent-
able. In some cases, potential products developed by USDA were not ex-
ploited by industry for this reason. For example, USDA developed a
repellent recently and offered it to several companies. However, no
company was willing to produce it without a patent. In another case, a
pheromone was developed by the government and picked up by a small company
which had the necessary chemistry to produce it. However, products trans-
ferred from government to industry are the exception, not the rule.
Government funds are also often provided to universities for research
on pest control methods. This makes any products they may come up with
non—patentable, and the transition from university to Industry also be-
comes very difficult.
The expiration of patents is of concern to some companies, especially
those that are in very competihve markets. However, all were concerned
about the loss of patent time due to registration requirements. Many
companies feel they lose the full benefit of their patent, and do not have
enough time to make a return on their investment. One product, which is
in the tenth year of its patent, has had only two successful sales years.
In summary, problems related to patents which may be amenable to the
development of incentives include:
(1) Protection of naturally occurring materials (considered essential
by many companies).
(2) Transferral of ideas or products developed by the government or
universities (very difficult now because of patent problems).
(3) The loss of patent time because of registration requirements for
all types of products, but especially innovative ones (a problem
for all pesticide developers).
d. Health and Environmental Considerations
At one time, pesticide producers and consumers primarily considered
only the efficacy of a compound in their evaluation. However, these
attitudes have changed somewhat In the last ten years, mostly as a result
of the environmental movement. Rachel Carson, in 1962, caused the public,
and especially government officials, to become more aware of the dangers
of pesticides. Residues of DDT began appearing in untreated areas, and
concentrating in organisms high in the food chain. At the same time,
regulations and registration policies became stricter, and environmental
considerations became very important in the registration of a compound.
17
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As a result, pesticide companies have begun to consider this factor
early in the screening of pest products, although opinions differ among
companies about the essentiality of health and environmental parameters in
determining whether to go ahead with a product. Two such parameters,
toxicity and persistence, have been the basis for stopping the development
of some compounds. Other environmental factors such as bioaccumulatlon or
mobility usually have not prevented a company from going ahead With a
product. Some companies have an absolute limit on an LD 50 of a compounds
which they will consider.
A few companies strive to provide safer products than their competitors.
This type of company feels the public is concerned, and hopes to answer
their demands for safer products. One problem with this strategy is that
the consumer cannot distinguish safe products from more toxic ones, since
no such statement can be made on the label.
Although the inherent characteristics of compounds or control methods
cannot be affected by incentives, they might be modified by changes in
formulation or application techniques. The consideration of health and
environmental aspects by pesticide companies and users is desirable to
EPA; therefore incentives should be directed at encouraging it.
18
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APPENDIX C
CONCEPT AND FRAMEWORK FOR INCENTIVES
1. THE INCENTIVE CONCEPT
The term “incentive” is familiar. It derives from two Latin words:
incentivus , meaning something that sets the tune, that provokes or in-
cites; and incinere , meaning to sing or sound. An incentive is thus
something inciting to action or effort, such as fear of punishment or
expectation of reward. A related term is “incantation,” meaning a formula
of words intended to produce a magical effect; from “incantation” come
“charm” and “chant.”
“Incentive” is so familiar that it can be used and understood in
various and confusing ways. Common usage tends to emphasize the charm
of money, for example incentive pay, as a method of inciting assembly
line workers to expend greater effort improving their productivity;
managers have sometimes employed chants and company songs to help motivate
salesmen to achieve higher targets and profits. Similarly, familiar
forms of federal governmental incentives are money grants, for example
to states to encourage building of roads, and chants, for example slogans
exhorting citizens to buy savings bonds.
The familiarity of these types of incentive tend, however, to obscure
two significant points. First, effective incentives can exist in many
different forms. Second, the interests of the incentive provider are no
more important than those of the incentive receiver; too often, In fact,
incentives seem to have been designed with much more attention given to
what is desired by the provider than what is desired by the receiver!
responder, which can lead to building too many highways and to relying
too long on overworked and empty slogans.
Thus, even though an incentive may be thought of as something which
is given to incite a certain action, it is more useful to think of it as
something which links two sides of an equation or two partners in a
deal. The incentive provider seeks to attract (or compel) an actor (an
individual or an organization) to change his behavior in specific ways
related to the provider’s general goal and specific objectives. In order
to obtain the desired actions, the incentive must somehow appeal to the
responder’s desires or fears, and thus to his goals and objectives. But
the goal structures of the provider and the responder are certainly not
alike. Indeed, EPA’s overall goal of protecting the environment may
conflict directly with the industry’s general goal of maximizing profits
by marketing pesticides. However, each partner to the deal has several
purposes or needs (often competing), which each organizes (perhaps
intuitively) into some order or hierarchy. For example, EPA cannot
afford to protect the environment at the obvious expense of lost agricultural
19
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production and scarcer or less nutritious food. Likewise, the industry
would also suffer from losses and weaker demand from agriculture. So,
despite differences between their general goals , the two partners share
some similar specific objectives . An incentive thus succeeds insofar
as it links objectives shared by its provider and its target actor. A
successful incentive is thus a type of bargain or deal in which each
party feels it gains more than it pays or gives up.
This concept results In several implications. In order to design
an effective incentive, the provider clearly must know several things,
either empirically or Intuitively, Including:
• The provider’s own general goals and specific objectives, for
example EPA’s Intention to encourage pest control methods which
are increasingly non—toxic to non—target organisms;
• The actors (incentive responder) to be motivated (ranked by
importance), for example pesticide manufacturers, formulators,
dealers, and applicators;
• The responders’ goals, objectives, and probable patterns of
behavior in reaction to various types of incentives; even though
the specific objectives of the several groups which comprise the
pesticide industry vary greatly, they share the common goal of
maintaining or improving their business operations; and
• Problems or barriers hindering responders from acting In ways
desired by the provider, for example, fragmentation of the market
for certain (minor use) pesticides.
2. THE CONCEPTUAL FRAMEWORK
The task of determining effective incentives for innovation in pest
control methods is complex, however, and a conceptual framework for
achieving this end was developed. This framework consists of four basic
parts——criteria, factors, incentives, and innovations.
Criteria are the major determinants of success, where success is
defined as the safe and effective use of a pest control method or product.
Prior to the 1960’s, the major criteria affecting success were effective-
ness, commercial potential, feasibility of production, and consumer
attractiveness. A fifth major criterion has been added: safety. This
criterion Is important both to the consumer and the producer.
All of these criteria must be met in order for a pest control product
to be a success; that is, it must be effective, it must be commercially
attractive, it must be safe, it must be produced economically, and It
must be used.
Many factors or conditions make up a criterion. For example, in
the assessment of commercial attractiveness, factors such as patentability,
20
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market size, competitive products, and the nature of the use should be
considered. If these conditions or factors are not met satisfactorily
(to the developer) then the criterion is not met and the product is not
a “success.” In this case, an “innovation” is needed to either change
the conditions or how they are met. If this innovation is not forthcoming,
an incentive may be needed.
Incentives can be described and categorized in various ways for
various purposes. The following four descriptions are general:
• Direct Directly associated with industrial R&D on new pest
control methods (for example, EPA grant to company
X to develop a new biological control agent for forest
products)
• Indirect Affects industry/others so that indirectly more
emphasis, funds, activities will be devoted to new
pest control R&D (for example, patent extension of
3 years which may lessen risks of some potential
products enhancing industry Investment)
• Positive The traditional incentive which rewards actions or
provides additional methods, approaches, funds to
accomplish a task or project (example, direct fund-
ing of R&D to universities on application methods)
• Negative An incentive (disincentive) which removes or restricts
(restric— a currently used action, approach, etc., to force a
tive) new mode of action (example, denial of registration
of potential Insecticide products on specific crops
except growth regulators, parasites, predators, virus
and bacteria)
As an example of this process, a product may be too costly to produce,
(factor) in which case the feasibility of production criterion is not
met. In this case a change may be needed in the technology, or In the
cost to the producer. An incentive may be needed to either make these
production costs acceptable by subsidy or tax benefits, or to reduce
the costs by technical innovations.
A conceptual outline of the process might include the following:
“Criteria” combine to define “success.”
“Factors” or “conditions” combine to define “criteria.”
“Innovations” can influence how “factors” or “conditions” are
met.
“Incentives” can influence whether “innovations” occur.
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Table C—i shows some of the various factors which make up the five
criteria. Table C—2 shows seven categories of incentives, defined by
the way in which they operate.
a. The Time Dimension
The order of meeting the various “conditions” and “factors” is of
utmost importance in assessing the relative importance of various innova-
tions and thus the emphasis that should be placed on any given incentive.
Consequently we analyzed the various action and decision steps in
the development and utilization of pest control methods on the basis of
the circumstances surrounding periods of high innovative activity and
the effect of potentially important factors. Our objective was to
Identify the major decision steps and the action steps (or “factors” and
“conditions”) that precede each step, and then to divide these “factors”
among the appropriate “criteria” on a time/decision framework.
b. Identification and Evaluation of Incentives
On the basis of the foregoing rationale, we established the follow-
ing procedure for the identification and initial evaluation of incentive
actions:
1. Develop a list of factors of importance in research, develop-
ment and marketing of new products.
2. Determine which factors are essential, which are helpful, and
which are Insignificant to:
• various type companies
• various persons within companies
• other interested parties
(Matrix 1)
3. Determine the actors who will make overriding decisions on
these factors. (Matrix 1)
4. Determine the components which contribute and are critical to
meeting these factors. (Matrix 2)
5. Among these components, establish which are most frequently
not met in practice (these should be most appropriate for
incentives).
6. Determine the types and nature of the barriers which prevent
these components from being met adequately.
7. DetermIne the facilitating actions (incentives) which can be
applied to eliminate these barriers.
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TABLE C-] -
Factors and Criteria of Pesticide Development
“ Efficacy ”
Commercial
Attractiveness
Safety
Considerations
Production
Feasibility
Consumer
Attractiveness
Initial Devel .
understanding of
pest physiology
cost of research
ability to synthesize
adequate analytical
techniques
ability to kill
target
Compound Effective-
ness
,., overall effect
on crop
effectiveness in
field
consistency of
results
residual effective-
ness
formulation and
application tech-
nique
margin of safety
consideration of
unforeseen con-
sequences
carry over effects
broad spectrum vs.
narrow spectrum
consideration of
compound combi-
nations
weather and meteoro-
logical consider-
ations
market survey (pre-
diction of factors
listed under con-
sumer attractiveness
patentability
patent time
competitive products
major vs. minor use
user (gov. vs. citi-
zen)
size of market
— no. users
— volume
duration of utili-
zation
nature of use (epi-
demic, military,
food, etc.)
profitability
broad spectrum vs.
narrow spectrum
suitability for
foreign markets
tests to determine
safety and to comply
with federal 1 , state
and local regulations
persistency
toxicity and other non-s
target effects
mobility
selectivity
metabolism
bio—accuniulation
residues in food
factors affecting deci’-
sions to get experi-
mental use permit and
registration
early specificity of
requirements
testing procedures
cost of tests
total time of tests
regulatory delays
prognosis for registra—
t ion
timing of permit
approval
possibility of unforeseen
consequences (econ.,
admin., and legal)
post—use monitoring
production technology
capital requirement
construction costs
and delays
product ion capability
process and operating
costs
distribution channels
effectiveness of sales
persons
availability of formu-
lation facilities
plant siting consider—
at ions
packaging
storage and product
lifetime
pollution control
needs
advertising
cost of product
distributor ‘s
influence
State Exp. Sta.
evaluations
market conditions
acceptability
nuisance factors
perception of
safety
application of
product
— cost
complexity
— frequency
— ease
— requirement
of certified
applicator
immediacy of
results
effect on crop
— marketability
— yield
carry—over effect
effectiveness of
sales persons
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TABLE C-2
yj es of Incentives (Operational )
o Administrative/Rulator rbyEPA: Incentives which change an
administrative procedure, regulatory requirement, document, or
guideline, so as to responders to act in certain ways; for
example, amending FIFPA to eliminate its present 3(c)(l)(D)
clause.
• Administrative/Regulatory by Other Agencies : For example,
amending the patent law so as to compensate patent holders
for forced shortening of patent life resulting from time
absorbed by government’s registration process.
• Funds : Direct funding, or credit, to subsidize and encourage
specific parts of the pesticide development process; familiar
examples from other programs include federal 90% funds offered
to states to provide the remaining 10% and to build interstate
highways and loan guarantees for low—cost housing.
o Service/Function/Facili : Resources in kind offered for
direct use in the pesticide development progress; parallel
examples include leasing of federal land for oil shale exploita—
tion, designing an intercontinental bomber which is given to
airframe manufacturers to adapt to civilian aviation, and the
TVA’s development of an improved fertilizer which is then given
over to commercial marketing.
o Manpower/Training : Providing personnel resources; prominent
examples include agricultural extension services to stimulate
modern agricultural practices, and training unemployable workers
to qualify for entry—level jobs.
• Information/Data : Providing, organizing, or evaluating informa-
tiorL needed by responders; familiar examples include government-
funded clearinghouses, the National Technical Information Service
(NTIS), and standard—setting services by the National Bureau of
Standards (which may also be related to regulatory actions).
o Consumer/Market : Indirect incentives which seek to create or
enlarge markets, and thus to motivate changes by industry; for
example, aggregating purchases by governmenr agencies to create
attractive markets and setting specifications which will also
improve products sold to non—government buyers.
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MATRIX 1
To Use in Rankin _ g Importance of Factors to Parties at Interest
LI ’
ACTORS
rACTORS
.
low
persistence
N
H*
H
N
H
N*
return on
investment
N*
Necessary
Helpful
= Necessary and overrides other factors
= Helpful and overrides
11=
11*
-------
MATRIX 2
For each factor, list component and determine critical component for each actor.
‘ - ACTORS
COMPONENTS
.
r .3
V
CU
..
c 1
;
—__—
.
-
—
-
—
—
-------
8. Determine the agents/persons who must apply the incentives,
respond to the incentives, or be intermediaries in the process
and their willingness to make this contribution (Matrix 3).
9. Trace back through the above steps to determine the potential
effects of these incentives.
However, by the time we had proceeded through the first several
steps, it became apparent that this procedure, while theoretically ideal,
was not sufficiently practical to be used throughout the program. Further-
more, the program goals and objectives changed somewhat to focus on in-
centives to reduce the problems resulting from regulation and to encourage
safety and biologically integrated pest control. Consequently, we adopted
a more empirical approach to the identification and evaluation of in-
centives. In retrospect, many of the steps indicated in the theoretical
approach were conducted, but in a less formal and detailed manner.
27
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MATRIX 3
Use in Assess Feasibility of Incentive
ACTORS
O .i
FACTOR -
COMPONENT
INCENTIVES
QW
‘
g
1) Factor
a) Component 1
—
—
NI
—
-
-
-
i) Incentive 1
7__
DI
—
Ii) Incentive 2
b) Component 2
i) Incentive 1
-p.--
)I
—
NI
#—
DI
.- —-
)I
—
—
ii) Incentive 2
2) Factor
DI Desires Incentive
Not desirous of incentive
Actor applies incentive
= Actor who responds to incentive
* Intermediary
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APPENDIX D
PRELIMINARY CRITERIA FOR SCREENING OF POTENTIAL INCENTIVES
CATEGORY A — SIGNIFICANCE AND APPLICABILITY
1. Is the incentive significant/applicable to the Important goals of
the incentive program as defined by EPA?
a. Improve environmental and human safety of pest control agents
and use practices——
• promote pest control methods that are increasingly
— non—toxic to non—target organisms
— non—mobile and non-bioaccujnulatjve
— narrow spectrum
— non—persistent
• promote biological control, integrated pest management
and other non-traditional chemical pest control approaches
b. Maintain or develop an adequate supply and variety of pest
control methods for all important pest problems
• increase variety and availability of pest control
methods by stimulating innovation
• encourage development of pest control methods for
minor crops and markets
• maintain viability of the pest control industry
and enhance R&D resources
• maintain diverse resources for pesticide research
and development
c. Increase the effectiveness of pest control methods——
• encourage R&D on new, effectiie pest control
methods
• promote inflovation in formulations, application
and use practices
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• encourage practiLcs and methods which minimize pest
resistance and maintain natural control mechanisms
d. Decrease economic costs of pest control——
• improve cost/effectiveness of pest control methods
• maintain resources for alternate pest control approaches
2. Is the incentive significant/applicable to the factors of importance
to industry in developing new products ?
a. Improve profitability/return on investment
b. Enhance individual product markets through:
• increasing total potential market size
• increasing access to market
• increasing market penetration
• providing competitive edge
c. Reduce registration time and costs
d. Enhance proprietary position
e. Encourage new corporate entries
f. Improve safety——
• human toxicity
• persistence in environment
g. Allow company freedom of choice
h. Assure compatibility/congruence with product line
i. Enhance product novelty or uniqueness in marketplace
j. Reduce liability or enhance ease of insurability
k. Enhance foreign market opportunities
1. Improve screening operations
in. Improve synthesis operations
30
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3. Is the incentive significant/applicable to the needs of
agriculture and other pesticide uscrs ?
a. Improve the “unit profitability” of agricultural production
b. Improve the availability and effectiveness of pest control
methods for minor crop and specialty applications——
• minor food crops . home and garden
• forest products • rangeland
• vector control • waterway
• right of way • industrial crops
• stored products • cultural practices
• resistant pests
c. Enhance the security of agricultural enterprises (e.g.,
through the improved predictability of crop harvest)
d. Improve the availability and cost/effectiveness of
fungicides, netnatocides, growth regulators, rodenticides, etc.
e. Enhance the development of innovative functional, effective
and inexpensive pest control methods
f. Reduce other agricultural input requirements through use of
effective pest control techniques
g. Improve the cost/effectiveness of methods for storage,
application and disposal of pesticides
h. Improve the diversity of opportunities f or agricultural
enterprises
i. Improve the availability and cost/effectiveness of integrated
pest management approaches
j. Improve the safety——environmental and human——of the use of
pest control methods
k. Enhance the “social acceptability” of agriculture and
agricultural practices
1. Enhance the effective lifetime of land for agricultural
activities
31
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CATEGORY B - FEASIBILITY
4. Is the incentive simple in concept and direction?
5. Is the incentive simple to implement?
a. Existing agency or institutional structure and mechanism
available
b. Resources available for implementation and conduct of
resultant efforts
c. Political posture/factors acceptable
d. Minimal interagency action
6. Does administration of the incentive require a low administrative
burden?
7. Is the overall feasibility of implementing the incentive action
promising?
8. Are the risks or uncertainties in achieving desired goal low?
9. Is the incentive compatible with current and likely future trends?
a. Environmental policy and regulations
b. Agricultural production and consumption
c. Pest control uses
d. Environmental concerns
e, Energy availability
f. Industry structure
g. Federal agency policies and actions
h. Consumer preferences
i. Social values
j. Inttrnational considerations
32
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CATEGORY C — ACCEPTABILITY/DESIRABILITY
10. Is the incentive acceptable to the various actors potentially
involved?
a. Established pest control industry—
• manufacturer
• formulator
• whole. ale distributor
• dealer
b. EPA——
• OPP
• Other
c. Other federal agencies
d. Congress
e. Agriculture industry/farmer
f. Other pesticide users
g. Public
h. “Public interest” groups/environmentalists
i. Universities
j. States
11. Does the incentive have real benefits to the parties listed above
(other than the pest control industry, agriculture and other
pesticide users)?
12. Are the costs to the parties listed sufficiently low to be
practical and acceptable?
13. Is the goal to which the incentive is directed acceptable and
desirable (significant) to these parties?
33
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CATEGORY D - TIMING AND INTERACTION
14. Can one expect a short response time until results are apparent?
15. Will the incentive demonstrate a long duration of effectiveness?
16. Does the incentive require implementation for only a short
time?
17. Can the incentive action sustain or pay for itself, without
continued and long-term commitment of resources by the
incentive provider?
18. Do many of the above criteria need to be met before the
incentive can be made effective (convergence)?
19. Does the incentive encourage the emergence of a champion!
advocate?
20. Is the incentive relatively independent of other incentives
and their implementation?
21. Duration and continuity——degree to which incentive
is available when desired.
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APPENDIX E
SUMMARY LISTING OF ORIGINAL INCENTIVE ACTIONS
INSURANCE/LIABILITy
1. Insurance for Minor Crops
In order to encourage pesticide companies to develop and register
products for minor crops, the federal government create an insurance
program to reduce the company’s liability for production—related
damage to these low total volume, often high value crops.
2. Government Insurance for Farmers Using Improved Pest Control Methods
Through a new USDA Insurance program, reimburse farmers for
crop losses resulting from use of innovative pesticides, formula-
tions, or application methods.
3. No—Fault Tolerance
USDA and State Experiment Stations would develop “guaranteed” residue
and phytotoxicity data which could be used for registration by
interested industrial organizations. Companies would not be liable
for any crop losses for a specified period after registration if these
data were used.
4. Insurance for Unsuccessful Product Development
To encourage the development of more pesticide products, the federal
government would provide Insurance to companies to reimburse development
costs of new products of proven efficacy If they are found to be un-
acceptable during the environmental and safety test and evaluation.
5. Product Failure Insurance
The federal government would participate In a pr ram to provide
insurance to protect companies against losses due to product failures
or product—related accidents. Insurance would not be restricted to
minor crops.
6. Reinsurance
To provide better insurance coverage for pesticide companies, a
federal reinsurance program for catastrophic losses would be
established.
35
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14. Reorganization of USDA Research on Biological Control
Reorganize USDA research on biological controls to include more
1PM testing, product or program development, and pest—targeted
efforts.
15. 1PM C pyright
Provide copyright or similar protection for 1PM systems in order
to provide royalties to system developers.
REGISTRATION CHANGES
16. Reduced Registration Time for Safe Products
Reward companies that develop safe pest control products by providing
a shorter and less expensive registration process.
17. Facilitate Registration Process f or Innovative Products
Through granting of priorities for, and changes in, administrative
procedures, facilitate review of experimental permit and registration
applications for innovative pest control products.
18. Reduced Registration Requirements for Biological Controls
Encourage the development of biological control methods by
administrative or substantive changes in the registration process
that reduce the requirements for these products.
19. Decreased IJncertaintiesof Re&istration Process for Applicants
Through changes in the staff and procedures at EPA, specify specific
time frames and establish stable and clear procedures for the
registration process in order to stimulate registration of more
products.
20. Reduced Time and Cost of the Registration Process
Streamline and/or reorganize both administrative and technical
requirements of registration in order to achieve more registered
products and more products registered for minor uses.
21. Registration of Only the Safest and Most Effective Product for Each Use
By extremely selective registration of only the most desirable
products, encourage continual new product development incorporating
ever increasing safety and effectiveness.
36
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IR- 4
7. Supplemental Funding for IR-4
Fund, through EPA, additional residue testing of chemicals and
biological controls through the IR—4 program.
8. Residue Journal
As part of IR—4, establish a journal to publish residue research
in order to recognize scientific work of an important but not
glamorous type.
9. Crop Groupings f or Minor Crops
By means of crop groupings, enable registration of one product
for several minor crops on the basis of one set of tests.
10. Insurance for IR—4
Through a fund available to IR—4 from USDA, reimburse farmers for
crop losses due to use of product registered through the IR—4 program
during the first two years after registration.
INTEGRATED PEST MANAGEMENT AND. BIOLOGICAL CONTROL
11. Government Support to Users of a USDA 1PM Service
At the initiative of EPA, set up an 1PM advisory service for
farmers, including among the advisors the USDA Extension Service
and representatives of companies whose products could be used In 1PM.
12. Subsidy for 1PM
Government support (by direct subsidy, tax credits, or returns)
to agricultural groups or farmers In a region who use 1PM techniques
rather than traditional pest control methods.
13. Rights to 1PM
Sell, through a federal mechanism, exclusive rights to biological
controls to private 1PM enterprises in order to increase the use
of 1PM.
37
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TESTING BY GOVERNNENT
22. EPA Screening/Testing of Innovative Pesticides
Arrange testing of promising innovative pesticides without compromising
the proprietary position of the developer in order to reduce testing
costs. (Modeled after the drug screening programs of the National
Cancer Institute.)
23. Government Funding of Environmental and Residue Testing for
Minor Crop (and Specialty) Pesticides
Fund environmental and residue testing of minor crop pesticides at
non—government organizations in order to reduce product development
costs to companies.
24. Government Generation of Environmental and Residue Data for
Minor Crop and Specialty Pesticides
After submittal by pesticide developer of efficacy and toxicity
data, USDA or EPA conduct environmental and residue testing
necessary for registration.
25. Efficacy Screening of Potential Pesticides
Conduct either primary or field efficacy screening of potential
pesticides at government laboratory (USDA) for a standard fee.
26. Government Testin of all Re istration Parameters
Provide a government service and facilities for testing of those
parameters required for registration. Charge fees consistent with
costs of in—house testing by pesticide industry.
27. Government Certification of Private Laboratories for Testing
of Pesticides
Certify private laboratories for pesticide testing in order to
guarantee acceptability of results for registration.
28. Government Large—Scale Field Studies of Generic Representatives
of Innovative Pesticide
Provide to industry the results of large—scale government testing
of generic pesticides; accept data as part of registration require-
ments for pesticides in the class.
29. EPA Generation of Additional Registration Data
Following completion by the applicant of all tests required for
registration, conduct additional testing in government laboratories
or under contract to EPA.
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GOVERNMENT-SPONSORED R&D
30. Government Sponsorship of Commercial R&D on Biological Controls
Federally sponsor R&D by commercial companies on biological controls
in order to develop more products, as well as to strengthen company
skills in this approach to pest control.
31. Increase EPA Funding of R&D
Substantially increase EPA funding of R&D, emphasizing innovative
pesticides and -potentiation of new and existing pest control methods.
32. Government. Funding of Basic Research
Fund a coordinated program of long—range basic research, under
government sponsorship, on new pest control methods.
33. Government Funding of Applied Research
Fund a coordinated program of applied research under government
sponsorship, on new pest control methods.
34. Government Funding of Research on Formulation and Application
Methods
Fund, by the government, research to increase the cost effectiveness
of pesticide applications, by means of safer formulations and better
application methods.
35. Definition of Standards for Safety
EPA clarify the concept of “safety” and its requirements for registered
pesticide products, both within EPA and through more EPA participation
in ASTM’s Pesticide Committee and ANSI’s new Environmental Council.
EDUCAT1O , TRAINING AND INFORMATION
36. Training of Farmers and Applicators
Promote new methods of safe and effective pesticide use by conducting
seminars and other training for farmers and applicators via their own
organizations or state extension services.
37. Independent Pesticide Research Foundation
Set up an independent, non—profit organization through collaboration
of government and industry to disseminate impartial information and
conduct a responsible public education program.
39
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38. Federal MarketinZ of Pest Control Approaches
Increase public knowledge and acceptance of innovative pesticides
by cooperative federal-industry programs of providing information,
advertising and marketing.
39. Improvement in EPA Contacts with Congressional Overseers
Increase and regularize information flow between EPA and Congress
in order to increase the understanding of the Congress and
judiciary of pest control and regulation problems.
FUNDING AND REIMBURSEMENT OF INDUSTRIAL DEVELOPMENT
40. Clearinghouse for Research Results
Encourage companies to disclose unsuccessful research efforts
through a research information clearinghouse by reimbursing
some portions of the research costs.
41. Research Investment Credit
Create a tax credit similar to the current investment credit,
allowing a company to offset directly its tax liability by 10 percent
of the capital investment in research during the year, providing that
the total does not exceed 50 percent of the pretax profit.
42. Direct Subsidy of Research
Government subsidize the entire cost of R&D and registration of pest
control methods that are innovative, aimed at minor crops, or otherwise
not commercially attractive. Sale of patent rights by EPA, with first
refusal granted to the developer.
43. Reimbursement of Registration Costs for Pesticides for Minor Crops
Increase the availability of pest control agents for minor crops by
reimbursing costs of registration of already proven agents (i.e.,
those registered or other crops/insects) on specific minor crops lacking
alternative methods.
44. Repayment Loan Fund for Pesticide R&D
Provide a continuing source of capital investment funds for R&D
of pest control methods by establishing federal loans to industry
for safety and environmental testing. Repayment of the loans is
based upon product success.
40
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45. Low—Interest Government Loans
Through low—interest loans from the government, provide funds for
safety and environmental testing on desirable pest control methods.
PENALT IES
46. Water Residue Tax
Assess pesticide manufacturers with a tax based on the amount of
pesticide residues found in monitoring of water bodies and rivers.
47. Safety Tax
Create a tax on pesticides paid by manufacturers, based on the toxicity
(e.g., LD 50 ) and/or persistence (e.g., half—life in aquatic muds).
48. Pesticide Use Tax
Charge pesticide users a use tax based on criteria such as toxicity,
environmental parameters, safety, etc., fund research with tax revenues.
PRODUCT PROTECTION/PROPRIETARY POS ITION
49. Modification of Patent Issue Date and/or Duration
Provide, through modification of the patent process, a specified period
of product protection, taking into account delays caused by the
government, and thereby encourage industry to develop new products.
50. Proprietary Protection f or Mological Pest Control and 1PM
Encourage commercial companies to develop biological control and
1PM methods by protecting (either through patents or the product
registration process) R&D efforts and resultant products in the
marketplace.
51. Commercialization of Pesticide Products Developed By or For the Government
Through more liberal policies for selling and exclusive licensing,
facilitate the commercialization by industry of potential products
(primarily biological controls) for which the original R&D was
accomplished by or under contract to the government.
41
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MARKET STIMULATION/PRODUCT DEMAND
52. Aggregation of Public Sector Market Demand
Use of the combined purchasing power of all federal agencies (plus
possibly state agencies) to encourage the development of new pest
control methods.
53. Aggregation of Government Markets for Pesticides
Variation of above. Stimulate the development of new pest
control methods by eliminating price from government procurement
performance specifications and by basing specifications solely
on criteria such as efficacy, toxicity, and safety.
54. Aggregation of Government Markets for Foodstuffs Grown with
Desirable Pest Control Methods
Stimulate pest control research and development through inclusion
of the pest control methods used during production in the performance
requirements for foodstuffs purchased by federal agencies.
55. Influence Pesticide Markets by Education and Food Product Labeling
Foodstuffs Grown with “Safe and Effective Pest Control Methods ”
Influence pesticide markets by increasing the civilian market demand
for foodstuffs grown with certain pest control methods through
education programs and mandatory labeling of foodstuffs.
56. Government Performance of Market Analyses
Reduce uncertainties concerning long—term markets for pesticide
products by government analysis of markets, competing products and
processes, and prospective public regulations.
57. Subsidies or Price Support for Crops Raised with Desired Pest
Control Products or Methods
Provide direct subsidies or crop price guarantees for private users
of integrated pest management and other innovative and safe pest
control methods.
58. Expansion of Extension Service Program
Stimulate user demand for effective and safe products and methods
by use of State Extension agents to assist with the informed
selection and use of pest control methods.
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59. Increase Foreign Markets for U.S. Pesticide Products and Processes
Initiated by EPA, explore foreign markets for safer and more
effective pest control methods developed in the U.S. Eventually
expand the market for these products.
60. Expansion of the Number and Role of Independent Pest Management
Consultants -
With USDA or EPA support, increase the number and role of pest
management consultants; also develop total performance pest
management service organizations in order to aid the farmer and
influence pest management practices.
61. Safety Index
Include safety index on pesticide labels to enable consumers to
compare relative safety characteristics of the available pesticides.
OTHER
62. Independent Pesticide Broker
Establish an independent organization to buy and sell information
and data on existing and potential pesticides; rights and licenses
to specific products; and other Information on products, uses, and
application.
63. Collaborative Industrial Efforts
In order to encourage collaborative R&D by companies on new, high—
risk innovative products, eliminate any regulatory or legal barriers
and, if necessary, provide economic incentives for such effort.
64. A Pesticide Development Award
Establish a prize/award to be given by EPA each year for the
outstanding innovative pesticide development.
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P PVE1 DIX
RESULTS OF INITIAL SCREENING OF INCENTIVES
Score
Incentive Title
INSURANCE/LIABILITY
1. Insurance for Minor Crops Questionable Good Good
2. Government Insurance for Farmers Using Questionable Good Good
Improved Pest Control Methods
3. No—Fault Tolerance Questionable Bad Bad
4. Insurance for Unsuccessful Product Bad Bad Bad
Development
5. Product Failure Insurance Bad Good Good
6. Reinsurance Questionable Good Good
IR-4
7. Supplemental Funding for IR—4 Questionable Good Good
8. Residue Journal Questionable Questionable Questionable
9. Crop Groupings for Minor Crops Good Good Good
10. Insurance for IR—4 Questionable (should be integrated with liability)
INTEGRATED PEST MANAGEMENT - BIOLOGICAL CONTROL
11. Government Support To Users of a USDA Questionable Good Questionable
1PM Service
12. Subsidy for 1PM Good Good Questionable
13. Rights to 1PM Good (concept of rights needs more investigation)
14. Reorganization of USDA Research on Bad Bad Bad
Biological Control
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Incentive Title
15. 1PM Copyright
REGISTRATION CHANGES
16. Reduce Registration Time for Safe
Products
17. Facilitate Registration Process for
Innovative Products
18. Reduced Registration Requirements
for Biological Controls
19. Decreased Uncertainties of Registration
Process for Applicants
20. Reduced Time and Cost of the
Registration Process
21. Registration of Only the Safest and Most
Effective Product for Each Use
22. EPA Screening/Testing of Innovative
Pesticides
23. Government Funding of Environmental
Testing for Minor Crop (and specialty)
Pesticides
24. Government Generation of Environmental
and Residue Data for Minor Crop and
Specialty Pesticides
2). Efficacy Screening of Potential
Pesticides
26. Government Testing of All Registration
Parameters
Score
ADL
EPA ETIP
Questionable
Bad Bad
Questionable
Good Good (given
good
criteria)
Questionable
Review in working paper
Good
Not Resolved Not Resolved
Good
Not Resolved Not Resolved
Good
(review in working paper)
Bad
Bad Bad
Questionable
Questionable/Bad Good
Questionable
Good
Good
Questionable
Bad
Bad
Questionable
Bad
Bad
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Score
Incentive Title ADL. EPA ETIP
27. Government Certification of Private Questionable Bad Bad
Laboratories for Testing of Pesticides
28. Government Large—scale Field Studies Bad Questionable Bad
on Generic Representatives of
Innovative Pesticides
29. EPA Generation of Additional Registra— Questionable Bad—Good Good
tion Data
30. Government Sponsorship of Commercial Good Not Resolved
R&D on Biological Controls
31. Increase Funding of R&D (not appropriate incentive) ——
32. Government Funding of Basic Research Good Bad Bad
33. Government Funding of Applied Research Bad Questionable —
34. Government Funding of Research on Good Review in working paper
Formulation and Application Methods
35. Definition of Standards for Safety Questionable Good Good
EDUCATION, TRAINING AND INFORMATION
36. Training of Farmers and Applicators Questionable (if not done, explore)
37. Independent Pesticide Research Bad Bad
Foundation
38. Federal Marketing of Pest Control Bad Bad
Approaches
39. Improvement in EPA Contacts with Questionable Questionable Bad
Congressional Overseers
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Score
Incentive Title ETIP
FUNDING AND REIMBURSEMENT OF INDUSTRIAL DEVELOPMENT
40. Clearinghouse for Research Results Questionable Questionable Good to idea; Bad to—me-chani m
41. Research Investment Credit Good Bad Questionable
42. Direct Subsidy of Research Questionable
43. Reimbursement of Registration Costs Good Good (if USDA) Good
for Pesticides for Minor Crops
44. Repayment Load Fund for Pesticide R&D Questionable
45. Low Interest Government Loans Good
PENALTIES
46. Water Residue Tax Bad Bad Bad
47. Safety Tax Questionable Bad Bad
48. Pesticide Use Tax Bad
PRODUCT PROTECTION/PROPRIETARY POSITION
49. Modification of Patent Issue Date and/or Good Good Good
Duration
50. Proprietary Protection for Biological Good Questionable Good
Pest Control and 1PM
51. Commercialization of Pesticide Products Good
Developed by or for the Government
MARKET STIMULATION/PRODUCT DEMAND
52. Aggregation of Public Sector Market Questionable Good Good
Demand
53. Aggregation of Government Markets Questionable Good Good
for Pesticides
54. Aggregation of Government Markets for Bad Questionable Questionable
Foodstuffs Grown With Desirable Pest
Control Methods
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Score
Incentive Title ADL EPA ETIP
55. Influence Pesticide Markets by Education Bad Bad Bad
and Food Product Labelling Foodstuffs
Grown with “Safe and Effective Pest
Control Methods”
56. Government Performance Market Analyses Bad Bad Bad
57. Subsidies or Price Support For Crops Questionable Questionable Questionable
Raised with Desired Pest Control
Products or Methods
58. Expansion of Extension Service Program Needs further development
59. Increase Foreign Markets for U.S. Bad Bad Bad
Pesticide Products and Processes
60. Expansion of the Number and Role of Questionable Good
Independent Pest Management Consultants
61. Safety Index Needs development
OTHER
62. Independent Pesticide Broker Questionable Questionable Questionable
63. Collaborative Industrial Efforts Good Questionable Bad
64. A Pesticide Development Award Good Questionable Bad
Notes : — Indicates no ranking given.
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APPENDIX C
PRELIMINARY WORKING PAPERS*
*In this Appendix, selected preliminary working papers are presented.
These papers were circulated to representatives of industry, govern-
ment, and other groups as part of the incentive development and evalua-
tion process. Not all of the original. 64 incentives (Appendix E) were
developed into preliminary working papers. Only the working papers of
those incentives which were not developed further or incorporated in
the final incentives (Part Two of Volume I) are presented here.
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GOVERNMENT INSURANCE FOR MINOR CROPS
SUNMARY
Insurance companies are frequently reluctant to provide insurance for
entirely new pesticides for which little actuarial data is available and
which carry a risk of large claims. Small and new companies in the
pesticide industry are most likely to have difficulty in obtaining
coverage or to have to pay high premiums.
The aim of this incentive is to foster the development, registration,
and distribution of innovative pesticides that involve a lessened risk
to the environment and human health and safety.
The government would set up a reinsurance system to encourage insurance
companies to cover pesticide companies for major and catastrophic losses
due to product failure and product—related accidents from the introduction
of innovative pesticides. Further, the government would provide similar
coverage for minor crops through a no—fault insurance system.
OBJECTIVES
The purpose of this incentive is to encourage pesticide companies to
develop, register, and distribute innovative pesticides by providing
special insurance protection for major and catastrophic losses because of
large suits due to product failure and product—failure—related accidents.
The introduction of new and innovative pesticides that differ significantly
from prevailing products, such as, for example, biological controls,
involve unknown risks on which actuarial data has not been accumulated.
Insurance companies are reluctant to insure such products, and, if they
do, the insurance premium is apt to be high. This affects adversely
small companies, new companies, especially if they have been established
to manufacture an innovative product, and non—diversified companies. This
incentive would help EPA to achieve its goal of fostering the development
of innovative pesticides that serve to protect the environment and human
health and safety, as well as that of developing an adequate supply and variety of
pesticide control methods. The incentive would also contribute to the
profitability of pesticide companies of all sizes. This Incentive would
benefit also agriculture, especially because it would foster the development
of pesticides for minor crops.
EXPECTED OBSERVABLE RESULTS
An insurance program of the type envisaged here could probably be implemented
within one to two years, since it would build into the existing insurance
system. The results, would be long—term, bringing about new pesticides,
uses, and registrations after five years, although some short—term effects
may occur because some products that are now in the R&D stage may be
introduced faster.
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Government Insurance for Minor Crops, Cont’d
DESCRIPTION AND IMPLEMENTATION
The main thrust of this incentive is to protect pesticide companies against
major and catastrophic losses from product failure and product failure
associated accidents. This insurance would not cover losses due to
environmental damage since this risk is dealt with in the registration
process and since the aim is the development of pesticides that cause
less environmental and human health damage.
This incentive would be provided only to new products for which actuarial
data had not been accumulated for a period of perhaps three to five years.
However, natural market forces will remove ineffective or high risk
products during that time. Furthermore, insurance would not be used to
maintain a product that incurs large product failures.
A reinsurance system, to be administered and covered by the USDA or EPA,
would compensate Insurance companies for their Insurance coverage of
pesticide companies. The insurance coverage would be for new products,
for any or all crops or uses once registration had been achieved.
Reinsurance would encourage Insurance companies to offer the desired
insurance at premiums acceptable to pesticide companies.
The liability for product failure Is the same for pesticides developed
for minor crops as for major crops. Since the sales of pesticides in
the minor crop market are small, pesticide companies have a disincentive
to develop pesticides for these markets. An insurance program especially
designed to encourage companies to develop pesticides for this market
would be one that is based on a no—fault system. Such a system might
be administered and covered by Federal Crop Insurance Corporation (FCIC)
which already insures farmers. A no—fault system is one In which the
insuror covers the insuree for damage that the insuree sustains from
a third party. Thus, in a no—fault system Insurance is to be provided
the farmer for damage he sustains from the failure of a product of a
pesticide company. Such a system not only relieves the pesticide company
from the risk of product failure, but it also encourages the farmer to
use new pesticides because any damage will be recovered easily and quickly.
This coverage could be written for new products registered specifically
for minor crops or uses or for existing products that are newly registered
for these uses.
REQUIREMENTS FOR SUCCESS
The administrative costs of such an incentive would not be excessive. The
reinsurance system involves setting up administrative capability within the
government but most of the work would be carried out by the existing private
insurance industry. The no—fault system would be added on to the existing
FCIC. Although no-fault insurance would be an added burden, the settlement
procedures are simpler than under a regular insurance system. The chief
expense to the federal government for such an incentive would be the
expense of covering the insurance claims. The magnitude of possible
claims is unknown and needs further study.
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GOVERNMENT INSURANCE FOR FARMERS USING
IMPROVED PEST CONTROL METHODS
SUMMARY
This incentive is designed to reduce the economic risk to farmers using
improved pest control methods by a crop insurance program administered
by an existing USDA agency. The program would be relatively easily
evaluated, but require large cash reserves and stringent requirements
for success.
OBJECTIVES
The objective of this incentive is to hasten the adoption of improved pest
control techniques that represent significant departures from present
methods and thus substantial economic risk to the user because of lack
of familiarity with the technology and its effectiveness. With acceptance
of improved techniques by agriculture, the pesticide industry will have
an incentive to continue research and development of such techniques.
EXPECTED OBSERVABLE RESULTS
The results of this incentive are relatively easily defined and evaluated.
Within the first two years of use, it is expected that farmers’ acceptance
of the insurance program will be evident. Assuming sufficient farmer
acceptance, the relationships between insured farmers in an area and
subsequent general implementation of the new pest control technique can
then be measured quantitatively. The probability of success would be
enhanced by the fact that the likely users of this program would be the
successful, inr%ovative farmers who are leaders in technology adoption
within the crop coninodity that they raise.
DESCRIPTION AND IMPLEMENTATION
The design of this program is similar to that of two existing USDA programs:
the Federal Crop Insurance Corporation and the Diaster Payment Program
administered by the Agricultural Stabilization and Conservation Service.
Thus, an administrative structure will likely be in place in almost all
areas of use.
It should be noted that the purpose of this program is not to protect
industry from liability due to improper testing or formulation of its pest
control products, but rather to protect the farmers from economic risk
while trying out a new pest control method.
The major steps in implementation would be:
• definition of pest control methods Insured under this incentive
and period of insurance,
• an education program to acquaint farmers with the Incentive,
54
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Government Insurance for Farmers Using
Improved Pest Control Methods, Cont’d
• insurance (without cost) to participating farmers,
• field monitoring of factors unrelated to the pest control
method which affect crop yield,
• assessment of acceptance of the pest control method following
discontinuance of the insurance.
REQUIREMENTS FOR SUCCESS
The requirements for success of this incentive are stringent. Both
timely decisions on cause (pest control method or not) for loss and
magnitude of loss of insured crops and timely payment for losses are
essential. Potentially substantial loss because of misuse of the pest
control method by the farmers will also have to be covered and a large
reserve fund established for potential losses. An effective policy on
pest control methods to be insured and the period of insurance must be
developed. Further, the liability of the government and the organizations
which write the insurance policies must be differentiated.
55
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GOVERNMENT SUPPORT TO USERS OF USDA 1PM SERVICE
SUMMARY
This incentive would consist of the creation of local 1PM advisory services
using USDA extension service personnel and the development and implementation
of a mechanism for federal financial support to users of these services.
OBJECTIVES
Implementation of this incentive would encourage the use of 1PM practices,
which could be expected to:
• decrease the usage of traditional pesticides (especially excess
amounts applied due to over—reaction to a potential or perceived
pest problem),
• protect populations of beneficial insects which act as a
natural check on pest populations,
• decrease the build—up of resistance of pest populations to
traditional pesticides, and
• decrease the costs of pest control to the user, both financial
and in terms of unexpected, secondary effects, e.g. phytotoxicity
caused by traditional pest control practices.
Farmers wishing to use 1PM practices would find the necessary consultation
services readily available for a minimal cost, if any, and receive
financial benefits, both from reduced purchases of pesticides and from
government financial support.
An additional benefit would be a change in the status of 1PM from an
experimental one, to incorporation in good agricultural practices. This
would, in turn, signal to developers of pest control methods that suitability
of their products for use in 1PM programs will be a requirement for future
success of their products.
EXPECTED OBSERVABLE RESULTS
The actual increase in usage of 1PM would depend on the magnitude of the
government subsidy, as well as the success or applicability of 1PM for
particular crops. With a significant government subsidy, perhaps 50% of
the agricultural groups or individual farmers involved in crops that have
been shown through demonstration projects to be amenable to 1PM practices
might begin to use those practices. For crops that have not been the subject
of 1PM demonstration projects, only 20% of those farmers and agricultural
groups might be expected to begin 1PM practices. Overall, the reduction
in usage of traditional pesticides probably might be 10%. The decrease
in pest resistance, damage to natural predators, and overall environmental
impact would be difficult to quantify.
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Government Support to Users of USDA
1PM Service, Cont’d
DESCRIPTION AND IMPLEMENTATION
The current state extension services would be expanded to include two
or three additional field personnel specializing in pest control for
every current such person. These probably should be entomologists or
agronomists with special expertise in integrated pest management.
Additionally, these persons should be allowed to hire local field workers
for necessary monitoring activities of [ PM.
Since integrated pest management is an activity which requires week—by—
week monitoring and information gathering from individual fields, these
field persons responsible for 1PM would not be able to provide these
services for any and all who ask for them. Each of these 1PM field
persons, therefore, would have a case load of 20 to 25 farmers involving
a maximum of, e.g., 10 000 acres. Once a year there would be an opportunity
to sign up for this service on the first come, first served basis.
Another function of the 1PM personnel is coordinating pest control methods
on an area basis to assure that methods do not counteract each other.
The 1PM personnel could point out the problems to the user of the traditional
pest control method; actual stoppage of usage of that traditional pest
control would involve difficult legal implications. This coordination
activity is a recognized need in many parts of the country. Farmers would
sign up voluntarily to participate in the service, receiving federal
support either by direct subsidy, tax credits, or returns from 1PM
practices. This support can be a single predetermined amount guaranteed
to the farmer if he completes the 1PM program, with additional amounts
guaranteed if the 1PM practices don’t work (i.e., if the pest wipes out
the crop). These additional amounts would be given out only in the case
of massive failure rather than slightly decreased yields which may not
be traceable to pest problems.
Both extension service personnel and participating farmer would monitor
and record the purchases of traditional pest control methods and evaluate
the effectiveness of this program in reducing the amounts of traditional
pesticides used.
REQUIREMENTS FOR SUCCESS
The resistance of some USDA extension service personnel to 1PM must be
overcome. An exchange of information between the promoters of 1PM and the
field personnel who are experienced in the realistic limitations must be
established. Since the private 1PM services are an inherent part of the
future success of 1PM, their interests would have to be considered and
their participation in the program encouraged. This incentive must be
integrated and coordination with other incentives, specifically with
insurance Incentives that may provide financial guarantees to farmers
using non—traditional pest control methods.
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REDUCED REGISTRATION TINE FOR SAFE PRODUCTS
SUMMARY
This incentive is an attempt to reduce the duration of the EPA registration!
review process for selected new pesticide products that meet specific
safety criteria. Initially EPA would establish a system to classify
“safe” pesticides. An accelerated registration process for these products
could be high—priority consideration or “temporary” registration with
rapid (2—3 month) disposition of the application.
OBJECTIVES
The time consumed by data gathering, submission of application, and EPA
review is frequently mentioned by industry as an impediment to the research
and development of new pesticides. Even for pesticides that are considered
“safe” (in terms of mammalian toxicology and environmental effects) often
the EPA review and resubmittal of data take six to twelve months (or longer)
before registration is approved. This incentive would accelerate the
registration process for those pesticide products meeting rigorous standards
of safety and demonstrate EPA’S desire to accommodate the needs of the
pesticide industry.
EXPECTED OBSERVABLE RESULTS
This incentive could have both near— and long—term results. In the near
term, certain pesticide products now in the registration or reregistration
process could probably be approved more quickly. This might allow industry
to achieve registrations without loss of another “growing season” and
without the inevitable additional costs of delays. A longer term result
of this incentive might be the development of criteria defining “safe”
pesticides and representing a stable target for R&D efforts by the
pesticide industry.
DESCRIPTION AND IMPLEMENTATION
Implementation of this incentive would require first the development of
simple and practical criteria according to which both EPA and the potential
registrant could determine whether a given pesticide product would qualify
for accelerated registration. The criteria could be those used to
distinguish between general—use and restricted—use pesticides or some
subset of the general—use category defined by parameters such as oral,
dermal or inhalation toxicity, and persistence.
After establishment of these criteria, EPA could accelerate the registration
process by assigning a special registration staff to handle priority
applications. Alternatively a temporary or provisional registration
could be granted after cursory review, since the initial criteria for
accelerated registration should reduce much of the risk of toxicity to
humans or environmental damage; final registration could be effected at
a later time. EPA would be required to meet scheduled review dates and
report to the public the results of the accelerated registration process.
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Reduced Registration Time for Safe Products, Cont d
REQUIREMENTS FOR SUCCESS
The success of this incentive will depend on both industry and EPA.
Industry will have to accept the pretnise that some pest control products
are likely to be safer than others and that this is a valid reason for
accelerated registration. EPA, on the other hand, will have to “promote”
certain classes of pesticides in preference to others, (and maintain)
long—term standards for safe products, and establish an accelerated
review process even though a greater risk may be involved 0. course
the Incentive also requires that industry continue to develop potential
products that can be categorized as “safe.” This incentive might be
combined with others that give priority to biological control approaches
or otherwise to reduce the time and cost of the registration process.
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REDUCED REGISTRATION REQUIREMENTS
FOR BIOLOGICAL CONTROLS
SUMMARY
This incentive would reduce the requirements and time for registration
of biological control methods by modification of some current
procedures for application review, giving priority to those applica-
tions for registration of the desirable methods.
OBJECTIVES
Through this incentive, EPA would seek to increase the number of
biological pest controls currently on the market, since
• these controls are generally safer and more target specific
than chemical controls,
• they are generally considered to be innovative,
and
• FIFRA 1972 directs EPA to promote biologically integrated
pest control methods.
Companies wishing to register biocontrols would gain an opportunity
to decrease the time and cost of registering their products (decreasing
the total time and cost of developing the control method). With an
attitude of cooperation expressed by EPA, companies might be en-
couraged to proceed with biological controls, regardless of the actual
decrease in regulation time and cost.
EXPECTED OBSERVABLE RESULTS
Two major results would occur. The number of registered biocontrols
would increase, the exact numbers depending on the current state of
technical and commercial development of biological controls, as well as
the status of other limiting factors. The rate of registration might
increase from one year to two per year, with about three or four registra-
tions in the first year because of a small backlog of technically ready
methods. The time and cost of registering biological controls would
decrease. A rough estimate might be about a one—third reduction in time
and a 10—20% reduction in cost (from decreased test requirements).*
This latter estimate may be high considering the fact that EPA,
in trying to make the requirements more relevant to biological
controls, added about 10% more requirements in two Out of the
five types of biological controls reviewed.
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Reduced Registration Requirements for
Biological Controls Cont’d
The actual time and cost (estimated) should be monitored.
DESCRIPTION AND IMPLEMENTATION
This incentive would facilitate registration of biological controls by
several changes in the current registration process.
Currently biological control specialists are scattered throughout the
Registration Division. The only one, however, who is active in
biocontrol registrations on a regular basis is “Product Manager #17,”
located in the Insecticide Product Branch, who coordinates the review
of all biological control submissions. The technical review branches
(e.g., Ecological Effects, Toxicology, and Efficacy) do not now have
persons officially designated to review biological control petitions.
At least one person in each of the review branches should be familiar
with the full range of biological controls and take responsibility
for the review of these methods.
Currently all submissions are reviewed on a first come, first served
basis, according to the date stamped on the submission when it first
comes into the Registration Division from the mailrootn.
In order to speed up the review process for biological controls, the
technical review should begin as soon as the submission is received
by the technical review branches and continue uninterrupted until
completion. This would require that priority be given to the review
of submissions concerning biological control.
Questions that arise during registration sometimes stem from the
particular nature of the type of control. For instance, the concern
about the possible effects of juvenile hormones on other hormonal
systems (e.g., mammalian) has arisen often enough that EPA has funded
a study on the subject. OPP should review the test requirements for
each of the types of the biological controls during the initial imple-
mentation of this incentive and every few years thereafter, to determine
which tests, if any, can be done by EPA on a generic basis.
Currently EPA is going through the registration guidelines for each of
five types of biological controls (viruses, pheromones, fungi, bacteria,
and insect growth regulators), eliminating any that are not relevant.
At the same time, they are writing “guidance” (as opposed to “guidelines”
which must be published in the Federal Register ) outlining additional
tests relevant to each type of biological control. The resulting total
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Reduced Registration Requirements for
Biological Controls Cont’d
test requirements are expected to be slightly less than before for
viruses, bacteria, and fungi, and slightly more extensive than before
for pheromones and insect growth regulators.
No matter what the actual increase or decrease in test requirements,
the increased relevancy of the requirements will itself help the
registration process for biological controls. However, this incentive
should include significant decreases in the total testing, or costs
of testing,required, even if this increases the risk in EPA decision—
making.
Implementation of the incentive would require first a common agreement
within EPA on the definition of biological controls and a policy
position, e.g., promotional or non—promotional. Guidelines, and new
“guidance” would be reviewed in light of position in order to
determine whether requirements should or should not be reduced. Generic
tests for each type of biological control which could be funded by EPA
would be identified. Additional staff would be hired for the technical
review branches and trained in the full range of biological controls.
Finally, review of submissions for biological controls would have to
take priority over review of other submissions.
REQUIREMENTS FOR SUCCESS
The major requirement for the success of this incentive is the
assumption by EPA of a promotional position toward biological control
methods. Furthermore, this incentive is not independent of other
incentives in that its success (increased biological controls) requires
the elimination of possibly more important limiting factors (such as
the lack of proprietary protection).
It must be coordinated with other incentives that deal with the
registration process in general, particularly the one that seeks to
decrease the time and cost of registration for all products.
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GOVERNMENT FUNDING OF
ENVIRONMENTAL AND RESIDUE TESTING FOR
MINOR CROP AND SPECIALTY PESTICIDES
SUMMARY
The EPA or USDA would serve a management role responsible for
the environmental and residue testing of pesticides intended
for minor crops or minor uses. Actual testing would be carried
out, at government expense by non—governmental organizations using as
a structural model the drug screening activities of the National
Cancer Institute. Materials submitted would have previously been
shown by the submittor to be efficacious and of acceptable toxicity.
The program would not compromise the proprietary position of the
pesticide developer. This incentive can be projected to decrease
the relative cost of commercialization of pesticides for minor crops
and minor uses. It might also allow pesticide development by parties
outside of the existing agrochemical complex.
OBJECTIVES
The EPA and USDA would increase the availability of pesticides for
minor crops and minor uses by decreasing the relative cost of commercial-
ization of such pesticides. The pesticide developers and existing
manufacturers would gain from this incentive by receiving a means, at
government expense, for the environmental and residue testing of pesticides
intended for minor crops and minor uses. In addition, it is expected
that some pesticide developments would be stimulated by the availability
of such no cost testing. This latter goal would apply specifically to
materials of known toxicity but for which the venture capital might be
dependent upon adequate field testing.
EXPECTED OBSERVABLE RESULTS
The primary benefit to be expected would be the increased registration
of pesticides adequate for minor crop use. With an annual funding level
of $10 million, this program might allow the registration of at least
100 pesticide/minor use combinations per year. If priority were given to
the most important pesticide problems, a high proportion of these 100
potential registrations would result in the marketing of needed products.
Thus greater diversity and availability of products for minor crops and
minor uses could be envisioned, to the benefit of the agricultural
establishment, the environmental interests and, on a selective basis,
the agrochemical industry.
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Government Funding of Environmental
and Residue Testing for Minor Crop and
Specialty Pesticides, Cont’d
DESCRIPTION AND IMPLEMENTATION
Upon passage of enabling legislation or appropriate executive approval,
the EPA or USDA would serve as a conduit for environmental and residue
testing of selected pesticides. The field studies would be conducted
under contract and involve only minor crops (less than $200 million
commercial value annually) and minor uses (such as pesticides for
right—of—way clearance, structural use, and protection of stored
products). The criteria for selection of submitted pesticides for
inclusion in this program would be evidence of the compound’s efficacy,
and toxicity information equivalent to that required for registration.
The testing would be carried out by non—governmental organizations
under contract to the sponsoring executive agency (EPA or USDA).
Protocols would be established by the executive agency for the specific
tests to be conducted and RFP’s would be let.
The model for the relationship between individuals or companies submitting
compounds, the regulatory agency and the contract testing organization
would be the drug screening activities of the National Cancer Institute.
This model addresses such questions as the patent policy applicable to
industrial and research contracts, including an effective policy state-
ment on confidential compounds.
The NCI policy makes possible the evaluation of many thousands of
compounds that would not be readily available on an open basis for
screening of potential cancer chemotherapeutic agents,. An analogous
policy statement would hopefully allow equally successful results to
occur insofar as needed pesticides, addressing such questions as
confidentiality, publication of data, expert consultation and patent
policy. Thus, the supplier of compounds would suffer no los8 of rights
and privileges as a result of participation in the environmental and
residue testing program, and the government would seek no assignment of
rights from suppliers of materials.
The sole involvement of the executive agency would be as stated previously,
as a conduit. Materials submitted with the accompanying efficacy and
toxicity data would be assigned to a contractor for testing on a particular
minor crop or for a particular minor use. The resulting residue data
(and environmental data if the material or use so required it) would be
funnelled back through the executive agency to the submittor. The submittor
could make use of such data as he saw fit, either as part of a registra-
tion or even as a basis for the generation of investor interest.
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Government Funding of Environmental
and Residue Testing for Minor Crop and
Specialty Pesticides, Cont’d
The implementation of this incentive is expected to be straightforward.
Although the EPA would, on the one hand, be the most likely agency to
administer the program because of its knowledge of specific minor crops
and minor uses for which there were environmental concerns, it is
understandable that this agency might not be appropriate for the program
because of the possible conflict between its regulatory role with what
would appear to be a promotional role. In this case, the USDA might well
be responsible.
The USDA would have to develop protocols for the environmental and residue
testing of Important minor crops and minor uses. Upon completion of this
task, RFP’s would be issued and prospective contractors would propose to
conduct a specified level of testing. Once such contracts had been
issued (presumably on a cost—plus—fixed—fee basis dependent upon level
of testing activity) the •required inechanism.would exist. The sole remain-
ing task would be the creation of an executive committee to determine the
priority of specific minor crop and minor use problems and the potential
success (based upon efficacy and toxicity data) of submitted compounds
in solving such problems. The composition of the committee might be
similar to that of the existing federal pesticide working group.
UIREMENTS FOR SUCCESS
One prerequisite for success is a minimum annual budget of $10 million
and a program lifetime of at least five years. A further requirement,
of course, Is that the responsibility for directing and supporting such
a program could be resolved between EPA and USDA. Contractors would
probably be available from industry and academia to perform the testing.
The major concern, then, Is whether, In fact, companies would submit
compounds for testing. Many compounds now registered for major uses
would be expected to be funnelled through this program as a means of
helping the management of industrial organizations determine the advis-
ability of submitting applications for minor crops.
The extent to which compounds would be submitted for minor crops or
minor uses from existing agrochemical companies vs. small companies or
developers interested in entering the pesticide industry is unknown.
A mix between these two groups would tend to further the overall effective-
ness of the program.
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GOVERNMENT GENERATION OF ENVIRONMENTAL/RESIDUE
DATA FOR MINOR CROP AND SPECIALTY PRODUCTS
SUMMARY
After submittal and acceptance of efficacy and toxicity data for minor
use registrations, USDA (or EPA) will conduct residue and environmental
tests on potential products for minor and specialty uses. The incentive
will help pesticide developers market products for minor uses more
profitably and aid agriculture through increased availability of products
for minor crops and other specialty uses.
OBJECTIVES
Development of pest control products for minor markets——crops or specialty
applications——is generally regarded by industry as a high—risk, low—profit
venture. This is a result of the small potential market combined with the
high costs of development and registration testing, which are essentially
the same whether the potential market is large or small. This incentive
would reduce the development costs of pesticides for the minor markets
by requiring EPA or USDA to conduct residue and environmental tests on
potential products once efficacy and safety (toxicity) data had been
submitted by industry. Reduction of the cost of development, will
increase the funds available for synthesis, screening, and other portions
of the pesticide development process.
EXPECTED OBSERVABLE RESULTS
Within three to five years, this incentive should lead to more pesticides
registered for minor uses. Industry, will consider the minor use part
of the pesticide market more profitable, devote more of its efforts to
products for this market, and thus benefit agriculture. Reregistration,
currently in progress, is expected to remove from the market many products
that are now registered for minor crops; this incentive could help reinstate
many of those products. A longer term result would be the development of
additional pesticide products for other than minor uses, as funds now spent
on marginally profitable products were diverted to new product development.
DESCRIPTION
This incentive differs only slightly from other methods of subsidizing the
costs of safety or environmental testing required for registration. In
its present concept, the USDA (EPA) using its own facilities, laboratories
and staff or with the aid of the experiment station at state universities——
would conduct residue tests and any necessary environmental tests on
pesticides for which applications have been submitted for minor—use
registration. The pesticide developer would be required to submit
efficacy and toxicity test data acceptable for registration. (Presumably
much of the toxicity data will already have been submitted to EPA as part
of the registration of the product for a major use.) USDA (EPA) wuuld then
conduct residue and environmental tests within a specified time frame,
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Government Generation of Environmental/Residue
Data for Minor Crop and Specialty Products, Cont’d
providing these data to the developer for use in full registration
application.
The conduct of the tests by the government will neither guarantee results
acceptable for registration nor preclude an applicant from submitting
his own data. Further, a developer would not be required to complete
his application for registration for the minor use although a penalty
might be charged, (e.g., requested payment for 1/2 the testing cost) if
the test results provided by the government were not used. Proprietary
positions would not be compromised by use of government—generated data.
REQUIREMENTS FOR SUCCESS
To be successful, EPA must define (and industry accept) the range of
minor uses to which this incentive will apply. Dollar value of the crop
or value of the pesticide market might be criteria for this classification
or definition. A system and method for conduct of the residue and environ-
mental tests must be established, perhaps as an expansion or modification
of the IR—4 program or the USDA laboratories. The government agencies
must be willing to adhere to fixed schedules for conduct of the test
efforts. Industry must be willing to relinguish the control over the
tests to the government agency in return for the cost of tests. Finally,
other problems such as product liability will require consideration and
solution before industry may be willing to participate in this program,
even with the reduced cost of testing.
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EPA GENERATION OF ADDITIONAL REGISTRATION DATA
SUMMARY
This incentive will require that EPA delineate carefully all tests required
for registration of pesticides, maintaining the same requirements for a
specified time period. Any additional test data required, as a result
of the review of specific applications, would be generated by the EPA or
other federal agencies at EPA expense on a timely schedule if the applicant
did not desire to submit this additional data.
OBJECTIVES
The uncertainty in test requirements for registration, additional or serial
testing after submittal of initial application, and the resultant delays
in the registration process are mentioned frequently by industry as a
disincentive for more active R&D on new pesticide products.
EPA has attempted to reduce or eliminate this uncertainty through publication
of Section 3 regulations and guidelines that define to a much greater extent
than previously the required test program and the data needed for registration.
Nevertheless, based on past experience, industry anticipates that caution on
the part of EPA reviewers and their inherent aversion to risk will still
result in additional data requirements and delays in following submission
of a registration application. The objective of this incentive is to
ensure that EPA specifies its data requirements In entirety, Insofar as
possible, so that industry has a reasonable and stable target for its R&D
on new products for registration. Requiring EPA to conduct any additional
tests not specified in the registration guidelines would provide an incentive
for EPA to make its decisions (based upon data submitted by the applicant)
in a timely and straightforward manner, even though the risks may be
somewhat higher.
EXPECTED OBSERVABLE REStTLTS
This incentive is expected to reduce the costs and time of the registration
process to industry because industry should not have to conduct additional
work after the initial submission of data which meets existing, well—
established and stable registration requirements. The reputation of EPA
will benefit from timely registrations of new products and its increased
effectiveness as a decision maker. Indirect results would be less reliance
by EPA on additional data In evaluating the risks of the proposed pesticide
products, among EPA staff a greater awareness of and experience with the
data gathering portion of the pesticide development process, and ultimately,
the greater opportunity for industry to use Its available research funds
In the development of new innovative pesticide products.
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EPA Generation of Additional Registration Data, Cont’d
DESCRIPTION AND IMPLEMENTATION
EPA would first review the Section 3 regulations and guidelines and
resolve wherever possible any existing uncertainties concerning data
requirements for registration. Thereafter, Section 3 and the guidelines
would be republished with no changes to be made (except from minor
corrections of errors) for two years. Further changes could be made
every two years. Definitive data checklists would be developed as an
aid to the review of applications. In reviewing future applications for
registration, the EPA could still reject data because of its inadequacy
or because of errors but only to the extent that the data submitted fail
to meet the published requirements. Anytime EPA review staff felt the
need for additional, not—previously—specified data, EPA would have to
develop the data itself, at USDA or EPA facilities, at universities,
state extension services, or independent organizations, under grant or
contract. A reasonable time schedule for this data development would be
followed, with the industrial applicant kept informed of progress and
results as the work proceeded. On the other hand, the industrial applicant
could elect to provide the additional required data at his own cost.
Any data generated by the government would be in the public domain, not
to be used in support of other registration applications without approval
of the applicant and compensation to the government.
REQUIREMENTS FOR SUCCESS
The success of this incentive depends primarily on EPA’s attitude and
view of the registration and review process. Initially the incentive may
force EPA to be more cautious in establishing data and test requirements.
Ultimately there will be less opportunity or incentive for EPA to require
more data. It is important that this incentive not “backfire,” i.e., that
EPA not make the registration requirements so stringent that the time and
costs of registration to industry increase still further, so that EPA
may never be required to generate any additional data. Thus this incentive
attempts to strike a balance between reasonable requirements for registration,
whose costs are paid for by industry, and additional testing to lower the
risk involved in registration, with the costs borne by the public. Since
it will not be easy to determine in all cases whether additional tests
are required because of inadequacy of the initial submission or because
of new EPA demands, at best a spirit of cooperativeness will be developed.
At the other extreme, an organized process for arbitration could be
required to resolve conflicting views of industry and the EPA.
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GOVERNMENT FUNDING OF RESEARCH ON FORMULATION AND APPLICATION METHODS
SUMMARY
This incentive addresses the present fragmented industry patterns, which
leave the final consumer with the task of integrating pesticides and
equipment, and thus impede adoption of new improvements. It would
increase significantly the current level of research under the direction
of a joint EPA—USDA management committee, assisted by an industry—user
advisory committee. Research projects, conducted mainly by state research
and extension organizations, would emphasize close cooperation by
researchers with consumers, equipment manufacturers, and pesticide formu-
lators.
OBJECTIVES
Better formulations and techniques of application would presumably improve
the variety of acceptable pest control methods available to farmers,
reduce the economic damages caused by pests, and promote methods that are
increasingly non—persistent and non—toxic to non—target organisms.
Moreover, a program sponsored by EPA and successful in assisting farmers
and the pest control industry would help to dispel antagonism toward EPA.
EXPECTED OBSERVABLE RESULTS
Benefits of this program would be both direct and indirect. State research
stations and extension systems would probably receive the major share of
increased funding, although contract research by pesticide formulators and
equipment manufacturers would no doubt be useful as well. Both industries
might be fearful of changing traditional techniques, but they would also
welcome government—paid research that would strengthen the variety of their
product lines, reduce the uncertainties and costs of registering new formu-
lations, (and probably move them into the market more quickly), increase
their acceptability on environmental grounds, and, facilitate the intro-
duction of new products to farmers.
An example of a current innovation, which the program could help to develop
and validate, is encapsulation, the relatively new technique of releasing
small amounts of pesticides over long periods of time. I ncapsu1ation offers
the potential of using only the amounts of chemical needed to kill the pest,
thus avoiding the overdoses of persistent chemicals that characterize many
present application techniques.
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Government Funding of Research on Formulation
and Application Methods, Cont’d
DESCRIPTION AND IMPLEMENTATION
The research funding for pesticide formulation and application would
be increased significantly over the next five to ten years. Research
would emphasize the integration of improvements in formulation with
improvements in application techniques. Although government would
probably fund and conduct most of the reasearch, companies might be in-
duced to supplement the effort by absorbing some costs of research
contracts in return for strengthening their staff skills and competitive
positions. State agricultural research organizations, aided by extension
agents, would study and define consumer needs in light of changes in
agricultural practices and of pesticide acceptability criteria set by EPA.
A joint EPA—USDA committee would be established to supervise the program
to set priorities, to control the allocation of budgeted funds, to monitor
progress, and recommend changes in program emphasis to the funding authorities.
A broadly—based advisory committee would also be created with representation
from the formulators, equipment designers, state—level researchers, and
final consumers. This committee would advise on identifying research
opportunities, problems, and resources.
Current pesticides and application practices would be surveyed in order to
identify, and rank current problems.
These problems would be assigned mainly to state agricultural stations and
their affiliated extension systems who would be charged to work closely with
the formulators, equipment manufacturers, and consumers. They would develop
accurate data on consumer needs, relay them to formulators and designers
as inputs to their development of improved pesticides and application equip-
ment, conduct limited tests of proposed improvements, report results to EPA,
and verify the accuracy of findings and acceptability of improvements to
all parties.
REQUIREMENTS FOR SUCCESS
significant new funding required for this program would total several
million dollars. EPA, USDA, and state agricultural research stations would
have to work in close cooperation. Protection of company proprietary in-
formation would also have to be ensured. Commercialization of techniques
developed under the program would require modified federal policies, allow-
ing licensing of private companies to use government—owned techniques,
possibly in return for payment of royalties to the government.
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DEFINITION OF STANDARDS FOR “SAFETY”
SUMMARY
This incentive tries to address industry’s complaint that EPA’s
operational concept or definition of “safety” often seems not clear
enough for the practical needs of business, and subject to unexpected
change or re—definition.
EPA would seek to encourage industry to improve acceptable pest control
methods, and both EPA and industry would seek to reduce the costs of
developing new pest controls considered “safe.” This incentive consists
of several .steps, mainly more use of ASTM, and ANSI, but also better
communication of guidelines to users.
OBJECTIVES
By improving its definition of “safety” and related terms, EPA would
seek to encourage industry to develop a more adequate supply and
variety of pest control methods and to decrease the human and
environmental hazards of pest control agents.
In addition, EPA would hope to establish interpretations of safety.
Industry’s interest in this incentive would be perhaps simpler. With
its concern for reducing costs and working in a more certain business
world, industry would welcome steps to clarify the ground-rules and
to stop (or at least slow) the “moving target” of how its products
are declared safe for commercial use. The reduction of uncertainties
and delays would likely reduce industry’s costs for developing and
registering new products.
EXPECTED OBSERVABLE RESULTS
Tha nature of the results would probably be less quantitative than
judgmental. Successful clarification of key terms such as “safety”
should lead to fewer complaints from outside critics resulting in
misunderstandings. (However, differences of opinion would certainly
continue based on differing values and judgments about what levels of
safety are appropriate for public policy. Indeed, one measure of success
for this incentive would be that policy questions under debate would
be posed more clearly.) Moreover, tools in the forms of better working
concepts should lead to fewer sticky registration cases delayed by
unexpected policy debates. Therefore, registrations should occur
somewhat faster and in greater numbers than is normal today.
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Definition of Standards for “Safety”, Cont’d
DESCRIPTION AND IMPLEMENTATION
The problem addressed by this incentive has already been reported often;
moreover, EPA has recently taken steps to improve its ground—rules by
issuing its Section 3 regulations (40 FR 28242 of July 3, 1975) and
Proposed Guidelines (40 FR 26802 of June 25, 1975). These will no
doubt alleviate some problems.
But other steps should also be considered. One would be to make more
vigorous and effective use of the voluntary standard—setting mechanisms
provided by the American Society for Testing and Materials (ASTM).
ASTM’s Standing Committee on Pesticides, one of its 125 Standing
Committees, Qffers a ready, established, and continuing forum with time—
tested procedures, where various parties—at—interest may meet to
exchange views and resolve differences of opinion. Its current chair-
man, A.J. Culver, Jr., is an EPA staff member from the Corvallis,
Oregon, laboratories, and other staff members serve on various sub-
committees.
Another step would be participation by top—level EPA representatives
in the new Environmental Council now being formed by the American
National Standards Institute (ANSI). Whereas, ASTM’s Pesticides Committee,
composed of about 200 scientists and technologists, concentrates on
technical standards relating to test methods, ANSI ’s Environmental
Council, limited to 12—20 policy—making administrators from industry,
government, and consumer groups, is being launched to focus needed
attention on complementary policy questions relating to regulatory
standards. To be effective, the Council should include, as EPA’s
representative, its Administrator or Deputy Administrator and officials
with similar decision—making powers from industry. Although relations
between government and industry have been relatively fruitful at the
ASTM technical level, these Standing Committees typically are not
alerted early enough to the pending need for developing new analytical
techniques, thus slowing down the standard—setting process when the
need becomes critical. An important policy role of ANSI’s Environmental
Council, therefore, should be to monitor the progress of ASTM’s Standing
Committees, to find ways to mesh timing with related federal time tables,
and to establish priorities reflecting public regulatory needs.
UIREMENTS FOR SUCCESS
Two stand out. First, EPA and OPP need to decide that clearer
definitions of their operating concepts and guidelines are necessarY
for achieving their own goals. Second, they must follow through with
determination and consistency, by appointing officials of sufficient
status to committees and by providing them with the funds and
organizational support needed to represent EPA well.
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CLEARINGHOUSE FOR RESEARCH RESULTS
SUMMARY
The government would compensate companies for a fraction of the cost
of the research effort involved when they voluntarily contributed
results of the research to a clearinghouse, where the information
would be accessible to other companies and the public. The informa-
tion in this clearinghouse would help reduce researchers’ duplication
of prior work and lead to more productive R&D.
Ultimately more productive R&D would help us achieve the EPA’s goals
of improved environmental and human safety of pest control agents,
develop a variety of pest control methods for important pest problems.
and probably increase the effectiveness of pest control methods.
OBJECTIVES
The object of this effort is to make available for public information
the results of screening of chemical compounds for various pesticidal
uses; in most cases this will be unpromising data, but in every instance
the freer interchange of information will make the research efforts of
other companies, the government, or universities more productive because
less duplication will occur. More productive research should lead to
less costly research and/or the development of more innovative compounds.
This will help achieve important goals of EPA, i.e., encourage new R&D
and the development of an adequate supply and variety of pest control
methods. It would be an important contribution to industries’ efforts
to improve profitability and screening operations. Lastly, to agriculture
and other users, it could be expected to accelerate the availability of
new pesticides.
EXPECTED OBSERVABLE RESULTS
Observable results would be relatively long term; their impact on research
effort would not be apparent for four to six years. However, the
benefit would be long lasting, since the, knowledge disclosed would be
of value for many years, in fact, indefinitely.
DESCRIPTION
Much unsuccessful research is undertaken in the search for new pest
control methods. Currently most of that information generated reposes,
unutilized, within the records of the research organization that originated
it, of limited value to that organization, and no value to researchers in
other organizations. If the information were generally available to
interested investigators, it could serve at least to prevent other research
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Clearinghouse for Research Results, Cont’d
workers from “rediscovering the wheel,” especially ones that don’t
work, and to provide for other workers a possible clue that would help
in the development of an innovative new pest control method or agent.
A clearinghouse for this research information would facilitate its
availability and dissemination. Nobody likes to air his failures, and
all organizations are apprehensive that the research results may ultimately
have some value to their competitors. Therefore, it is unlikely that
companies would release this information without some safeguards and
incentives to do so.
For these reasons, a financial reimbursement for a fraction of the cost
of the research (either as a percentage of the cost through screening
or a fixed amount per compound) required to develop the information
would be made by the government. This function could be supervised by
the Department of Commerce in its National Technical Information Service,
by a learned society, or Chemical Abstracts , with the sponsorship and
financial support of the EPA or other funding mechanism.
REQUIREMENTS FOR SUCCESS
Implementation would be reasonably simple; the administrative framework
is partly in place in the case of the NTIS or the Chemical Abstracts .
Funding is presumably within the EPA’s control, and costs should be
nominal. Once the procedures had been established, the administrative
burden would be modest, especially if a fixed fee per compound was set
as the incentive payment.
On the other hand, that incentive payment must be sufficient to overcome
industries’ reluctance to part with the information and to overcome fears
that it may be of use to their competitors. A mechanism must be developed
for patented compounds or uses, whereby the developer would receive a fair value
for the licensing of any compound found to be of commercial value. However,
with accceptance of the incentive, the owner must license the compound if
such license is sought. If the compound is not patented, it must become
public property.
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RESEARCH INVESTMENT CREDIT
SUMMARY
This incentive is to encourage companies to invest in pesticide R&D
activities. The incentive could be altered by changing the percent
tax credit or by defining the type of research that would be eligible
for credit.
On EPA’s recommendation, Congress would pass a tax abatement scheme
similar to the current investment credit, which allows a company to offset
directly its tax liability by 10% of the capital investment made iii the
tax year, providing the total did not exceed 50% of the pretax profits.
This incentive would allow companies to offset their income tax by a
certain percent (perhaps 10%) of their research expenditures on pesti-
cides during that tax year.
OBJECTIVES
From the point of view of the government, particularly the EPA and USDA,
the object of this incentive is to encourage more research on pest control
by private industry. Increased research, in turn, can be expected to lead
to more innovative means of pest control. Furthermore, the incentive
can be designed in such a way by the government that it channels the
research effort into whatever direction is of particular interest to
the government. Since this is a financial incentive to increase research,
the time horizon to initial results is likely to be relatively long, five
or more years, but the benefits will accrue for many years, even if or
after the incentive is withdrawn.
For the developer of basic pesticide control products or methods, the
incentive will reduce research costs, since some is recovered in reduced
taxes. This reduced cost leads to a higher return on the money invested
in research, development, and marketing of the product resulting from that
research. Furthermore, most of the benefits can be claimed via the
Internal Revenue System, in a manner similar to the present capital
investment tax credit system, with which industry is thoroughly familiar.
EXPECTED OBSERVABLE RESULTS
The government can expect to see an increase in research effort and the
resulting development of new products or methods for pest control within
about five years. As it costs about $6—8 million to develop each new
product and introduce it to the market, the cost in lost revenue to the
government will be a fraction of this figure, the exact level depending
on the percent of research expenses that can be offset against income
tax liabilities. This figure can be set at any level desired, and the
incentive will be directly proportional to that level.
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Research Investment Credit, Cont’d
DESCRIPTION AND IMPLEMENTATION
The research investment credit incentive is very similar to the current
Federal tax credit for investment in depreciable personal property
(Internal Revenue Code Sections 46—48 and 50) except that it applies to
the costs of research, rather than capital goods. The present law
allows individuals, partnerships, and corporations to offset directly
against their income tax liability 10% (in most cases) of capital invest-
ments (of most kinds) placed in service in that tax year up to $25,000
plus 50% of the tax liability over that amount. Furthermore, it allows
that credit to be carried back three years and forward seven years,
permitting the credit to be utilized even if there is a loss in one or
more years.
Currently, although research facilities are eligible for investment
credit, research expenses are not. The research investment credit would
work In a manner similar to the capital investment credit, except that
it would apply to clearly defined research efforts and the minimum credit
and percent levels could be altered upward or downward. For the purpose
of this example, they are assumed to remain the same as the present
investment credits. The research investment credit incentive could be
focused on specific areas of interest to EPA, e.g., biological control,
by restricting the type of research (or development) eligible for tax
credit.
The implementation of the incentive calls for an Act of Congress to alter
the Internal Revenue Code and the development of tax guidelines in that
new law. The further implementation then would be through the normal
Federal Income Tax Return Statements.
REQUIREMENTS FOR SUCCESS
Obviously the incentive should be substantial enough to be attractive to
the recipient; it should more than offset his additional clerical work
and the burden of government monitoring (possibly including disclosure
of R&D targets) required to be sure he is operating within the tax
guidelines. A 10% level should offer such an incentive. Assuming this
10% tax credit and a cost of $6—8 million to develop a new product,
the cost in lost tax money to the government should not exceed about
$100,000 per year per successful compound, assuming credit was given
for theentire expense of developing the pest control compound or
method, and a lesser cost if only parts of the expenditures were
eligible. An incentive such as this will only be effective, however, if
there is a reasonable confidence on the part of industry that this
incentive will be available over a fairly long period of time, say at
least ten years.
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REPAYMENT LOAN FUND FOR PESTICIDE R&D
SUMMARY
This incentive would provide loan funds for industry to conduct long—
term toxicity and other required development tests on potential
products. Funds provided by the federal government to pesticide
development or independent organizations would be repaid if and when
commercialization of the products had been achieved. An advisory group
and peer review system would oversee the selection of potential
products for funding and provide quality assurance.
OBJECTIVES
The process of discovery, development, and registration of new pesticide
products is lengthy and expensive, lasting an estimated 5 to 8 years and
costing $5 to $10 million per product. Many small companies lack the
available capital for the initial investments and cannot maintain such
a long—term investment, eien for the potential products. Larger
organizations facing similar financial constraints must rely upon the
profitability of existing products to support new product development.
This incentive provides loan capital to be used for long—term toxico-
logical or environmental testing, which is in the public interest mandated
by public regulatory agencies, or for other important steps in the
development process. Repayment of loans would depend upon the successful
commercialization of the resulting products; provisions would be made to
ensure that diligent efforts are expended on new pesticide developments.
Pesticide producers may have a means to support their more innovative,
but less certain, approaches to pest control. Although the initial
expenditures necessary to establish the loan fund might be high, the
effort could be self—sustaining if successful products are developed
and loans are repaid.
EXPECTED OBSERVABLE RESULTS
This Incentive will not yield significant results for at least five
years. After this time, several new pesticide products would be
registered and marketed each year; products that presumably would
have otherwise been unavailable. Another observable result would be
the establishment and growth of new pesticide development organizations,
as well as renewed interest in pesticides among existing companies. A
side benefit of this incentive would be the establishment by industry,
agriculture, government, and the public of criteria for desirable
pesticides.
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Repayment Loan Fund for Pesticide R&D, Cont’d
DESCRIPTION AND IMPLEMENTATION
This incentive, originally proposed by Djerassi*, was intended to reduce
the burden of long—term toxicological testing required by EPA. Djerassi
proposed that the developer of a potential pest control agent have the
option of applying to the appropriate federal agency for funding of long—
term toxicological tests in an independent laboratory. If the product
were commercialized, the developer would pay to the government a
royalty over the lifetime of the product of until the costs of the
original loan (with interest) had been repaid. Djerassi suggested
limits to the funding requests and a peer review system to aid in the
program Implementation.
The Incentive proposed herein builds upon Djerassi’s concept and
offers several other features for consideration.
1. An advisory group consisting of federal pest control and
health experts, industry representatives, and the public
to develop criteria and a methodology for selection of
potential pesticide products to be considered for funding
under this incentive and to oversee the Implementation of
the loan fund.
2. A loan fund of $10 to $20 million, with authorized
expenditures for at least a 5—year period to provide
for continuity of effort and stability of the incentive.
3. A loan schedule, with limits placed on the funds available
for different portions of the development/test process, and
a repayment plan (royalty on commercialized product or
other scheme).
4. Provision of funds to either an independent organization
(not a government entity) or the pesticide company seeking
support. Funds provided to an independent group may include
a “guarantee” that the data obtained in accordance with
approved protocols would be acceptable for registration.
Funds provided directly to the developing organization
may be subject to constraints such as periodic peer
review to prove diligence in pursuing tests, incremental
funding based upon results, etc.
5. The proprietary position of the industrial organization
requesting funds would not be compromised, except for the
royalty provisions made to the government.
*Djerassi, C., C. Shih—Coleman, and J. Dickman, 1974. Insect control
of the future: operational and policy aspects. Science 186:596—607.
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Repayment Loan Fund for Pesticide R&D, Cont’d
REQUIREMENTS FOR SUCCESS
The principal requirements for success of this incentive are the initial
establishment of a large enough fund to have an impact on the R&D process
and the development of an equitable process for selecting potential products
for funding and for loan repayment. The first will most likely require
congressional action or a separate funding of FIFRA. The second will
need cooperative action of EPA, USDA, HEW and pesticide developers. It
might be advisable for pesticide organizations to act through their trade
associations in developing this incentive. Since the funding will be
optional, companies can participate as they desire depending upon the
risks they envision in specific products. An additional requirement for
success, however, is the desire of several companies to share with the
government the risk of product development at the expense of some of
the potential profit.
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LOW-INTEREST GOVERNMENT LOANS
SUNMARY
A federal agency such as USDA or the Department of Commerce would offer
low—cost, long—term loans to pesticide development organizations to fund
specific toxicity and environmental tests required for registration of
new products. The developing organizations must demonstrate the efficacy
of the product for which a loan is requested, meet a test schedule, and
agree to repay the loan over a 10—year time period. The incentive will
increase the capital availability f or companies and hopefully will
increase the flow of new products through the registration process.
OBJECTIVES
Within the pesticide industry, there Is general belief that government
regulations have caused significant increased in the cost of research
and development of pesticides. These costs have resulted in a decrease
in the type and number of new pesticide products that enter the marketplace,
and ultimately In decrease in increases in the cost of maintaining
agricultural productivity. Since a portion of the increased cost of the
regulations is caused by increased public concern and action with regard
to human safety and environmental quality, the public might reasonably
be expected to bear some of these costs. One method is to pay the
increased cost of pesticide products, passed on from farmer or other
user to the consumer. Another approach is through federal support of
the pesticide industry, in part of their work.
The federal government has offered capital in the form of low—interest
loans to many groups, including farmers, veterans, Industries, municipalities,
to assist them in endeavors that they would otherwise not be able to undertake.
This incentive would provide similar low—interest, long—term government loans
to qualifying pesticide organizations. The loans would be used to finance
portions of the R&D program for new pesticide products, e.g., tests required
by the registration process, or at the discretion of the company, in meeting
other regulatory requirements. The intent of this incentive is to provide
law—interest capital to assist in the R&D required by regulations, and allow
pesticide companies to use their own capital for the higher risk or
enterpreneurial portions of the R&D process: synthesis, screening, production
research, etc.
EXPECTED OBSERVABLE RESULTS
The results of this incentive action can be both intermediate and long
term. Availability of funds to conduct the testing required by registration
will permit some organizations to bring n re potential products into the
registration process over the next three to five years. If company internal
funds are available for the more critical steps in the development process,
opportunity for innovation of new pesticide products may also increase over
the longer term. Although this incentive does not alleviate the increased
cost of registration and regulation, it provides a mechanism whereby
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Low—Interest Government Loans, Cont’d
organizations can meet corporate goals of appropriate use of capital
and achievement of profitability, while at the same time meeting a
national need.
DESCRIPT ION
An agency of the federal government, most likely the Department of
Agriculture (or perhaps the Department of Commerce and the Small
Business Administration) would establish a procedure for reviewing
applications and granting loans to pesticide companies. Low—interest,
long-term loans would be provided to organizations for the conduct of
the specific tests required by the registration regulations and guidelines
(e.g., long—term toxicology, environmental fate and significance, residue).
Efficacy would have to be demonstrated for each ,product and the results
of acute toxicity tests submitted in order to provide sufficient proof
that the product is a good candidate for registration.
A schedule of loan funds available for various tests would be developed,
with individual companies restricted to some maximum number of loan
applications per year. Loan funds would probably be restricted to tests
on new products, rather than new applications for already registered
products in an attempt to expedite the entrance of new products into
the marketplace. Loans might be restricted further to approaches or
products that are “innovative” or in a special category such as biological
controls. Funding, provided incrementally based on the results of the
prescribed tests, would not extend for more than three years for any one
product. Repayment would extend for a longer time, perhaps ten years.
4UIREMENTS FOR SUCCESS
Establishment of this loan program will most likely require Congressional
approval and recognition of the problem imposed by current regulations.
The major costs to the government will be for administration. Industry
would have to agree to a fixed schedule of tests, probably conducted in
a prescribed manner. Although the loans would not be large financial
benefits since they must be repaid, the availability of funds over a
short term may be a significant advantage to some pesticide companies.
Careful delineation of tests suitable for the loan program, as well as
simple means for demonstration of efficacy and low acute toxicity, will
be important in the implementation of the incentive. An agency other
than EPA should probably administer the loan system.
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PROPRIETARY PROTECTION FOR BIOLOGICAL PEST
CONTROL AND 1PM
SUMMARY
This incentive would attempt to eliminate a major barrier to extensive
industrial R&D of biological control methods by improving the proprietary
protection for bacterial, viral, and predator pesticides. The improved
protection would result from strengthened and enforced patents for
processes, formulations, or applications, “pseudo patents” for special
pesticides, or similar changes in the patent system. An alternative
mechanism would be granting of EPA by “proprietary registrations” for
a specified time in lieu of a patent.
OBJECTIVES
Industry generally acknowledges that the lack of adequate proprietary
protection for products is an important disincentive to R&D on new forms
of viral or bacterial approaches to pest control. In general, patents
cannot be obtained either for new species of bacteria or viruses or for
their use in 1PM programs, and processing patents usually apply only
to a single specific method , among many, of producing the bacterial
or viral strain. Without the security of a patent or other protection
mechanism, industry is often unwilling to devote the necessary sustained
R&D effort to develop and market biological pest control methods (assuming
that these methods would meet other goals of efficacy, safety, etc.).
This incentive would establish one or more mechanisms——in the form of
“pseudo patents,” strengthened peripheral patents, “proprietary rights,”
or a “proprietary registration”——which would provide a patent—like status
for selected biological control methods and/or their use in 1PM techniques.
As a result, industry could expect a greater return on its investments in
biological control R&D and products, and thus might be encouraged to
devote more of Its efforts In exploring these approaches. EPA would
receive the benefits of the availability of a greater range of alternative
techniques for pest management.
EXPECTED OBSERVABLE RESULTS
Observable results of this incentive would be long term. If greater
proprietary protection were available, major pesticide companies that have
devoted only limited efforts to biological control would presumably expand
their R&D efforts and reexamine some approaches that have been “on the
shelf.” The Incentive would benefit smaller pesticide companies as well,
since product protection could be assured and would represent an investment
strategy. In a four— to eight—year period, several new bacterial or viral
pesticides could be expected to reach the market. The incentive would be
self—sustaining and, combined with creative R&D efforts and other incentives
dealing with biological control, could provide a major stimulus to the
development of biological controls.
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Proprietary Protection for Biological Pest
Control and 1PM, Cont’d
DESCRIPTION AND IMPLEMENTATION
This incentive might be accomplished either through changes in the patent
and/or copyright system and for through changes in the EPA registration
process.
The exclusivity and applicability of process patents for bacterial or
viral pesticides could be strengthened. For example, patent for a basic
fermentation (or other culture approach) process awarded for a typical
bacterial pesticide could be sufficiently broad (instead of limited to
narrow, controlled conditions) to prohibit other organizations from
using the basic process to produce the pesticide. Similarly, broad
generic patents could be provided for the formulation process——both
ingredients and methods. Methods of storage and/or handling of the
agent from its production to end use could also be given strong patent
protection. Several of these suggested features might be incorporated
in the modification to the patent system currently being considered by
Congress.
A second possible approach would be strengthening of the provisions Of
copyrights and trademarks. For example, a particular biological species
might be used as a trademark or the use and application copyrighted.
Other companies could not use this designation or instructions (broadly
interpreted) in the registration, labeling, or promotion of the product.
Another approach might be “pseudo patents,” which would apply ,to a natural
product or bacterial or viral species. The pseudo patent would have the
intent and protection offered by a normal patent on a chemical product,
but be limited to the use of the product as a pesticide for specific uses.
Such a pseudo patent issued at time of registration might apply to use
on a specific crop or insect pest. The pseudo patent system could even
be used for predator or parasitic species. Any change in the patent
system must be accompanied by a speedy and equitable enforcement mechanism.
A second means of providing proprietary status for biological control
methods is through the registration process itself. EPA could register
a biological control approach after data requirements had been met (in
the order in which the applications are received) and provide a protection
period of ten years, for example. During this protection period, EPA
would not register the same biological control method (e.g., species,
culture, or insect) again to another company, except under a license
agreement with the company holding the original registration. Since all
products have to be registered, the license would serve as patent protection.
The 3(c)(i.)(D) section of FIFRA amended would not apply to these products.
After the specified period had passed, EPA would register the product to
all who applied with appropriate data.
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Proprietary Protection for Biological Pest
Control and 1PM, Cont’d
REQUIREMENTS FOR SUCCESS
ThIs incentive wo”ld require the approval and enthusiasm not only of
those who administer the patent system but most likely, also of Congress.
Success would also depend upon appropriate definitions, limits, or
standards for biological control approaches, so that the eligibility of
each product for this protection could be determined easily. Since
biological products are used in other industries, the process envisioned
here may have to be expanded to areas other than pesticides.
For EPA, FIFRA will probably have to be changed allowing “special
consideration” to be given to biological approaches and careful guidelines
provided. Whether or not the EPA can grant the “exclusive” registration,
probably will have to be determined by Congress or the courts. Another
most important requirement for success of this incentive is the acceptance
by EPA, industry, agriculture, and the public that biological control
warrants such special consideration.
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COMMERCIALIZATION OF PESTICIDE PRODUCTS
DEVELOPED BY OR FOR THE GOVERNMENT
SUMMARY
Federal agencies would encourage industry to exploit pesticide technology
that had been developed by or under contract to the government. Two
means of this encouragement would be exclusive licenses to government—
owned patents and facility—development contracts for the pilot production
of novel pesticides.
The program would emphasize biological control methods.
OBJECTIVES
The primary objective of this incentive is increased commercialization and
utilization of innovations developed at government expense, USDA or EPA
would obtain the societal benefits presumed to result from the exploitation
of innovative technology. Since the basic and applied research being
conducted at government expense is already directed toward meeting such
goals (as individually stated by these agencies), the exploitation of
the discoveries resulting from such a program should also be in the interest
of the agency and of the government. Previously the development of novel
technology by such agencies was believed to be followed by the rapid
absorption of such technology by the private sector. This, however, has
not always been the case. By the development of specific programs for
such exploitation, the benefits initially expected could, in fact, be
realized.
The companies receiving the licenses and contracts would have an opportunity
to develop new products with a decreased investment and risk. The facilities—
development contracts would allow companies to “learn” and test new production
methods, especially in the area of biological control. Such work could be
conducted by both large and small companies without the risks normally
associated with entering into a new product area. The licenses would allow
companies exclusive rights to technologies and products without the need
for initial internal R&D activities. While the benefits to industrial
organizations of acquiring pre—existing technology is oftentimes not
especially economically significant (in light of the pre—registration
testing that is still required), the fact that the royalties for such
technology would be drawn from profits acts as an additional stimulus
to exploit such technology.
EXPECTED OBSERVABLE RESULTS
With a reasonable level of support, this incentive should produce at least
ten exclusive licenses per year and half as many facilities—development
contracts for biological control products.
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Commercialization of Pesticide Products
Developed by or for the Government, Cont’d
DESCRIPTION
The USDA, EPA and other agencies would take specific steps to encourage
the utilization of pesticide products and technology developed and owned
by the government. Specific attention would be directed to biological
control developments, in which the work at government expense had not
resulted in a viable commercial pesticide product although the potential
for successful commercialization existed.
The specific encouragement would be twofold. Industrial organizations
would be provided, exclusive long—term licenses to government inventions.
Such licenses would last as long as the patent. The industrial organi—
zation receiving the license would be the one demonstrating the production
and distribution facilities most likely to allow the exploitation of the
technology. The specific royalty arrangement would be based on profits
rather than on sales so as to further encourage development.
The second means for encouraging utilization of government—developed
pesticide technology would be through the specific use of facilities—
development contracts. Government agencies would recognize as part of
their task in performing basic and applied research in pesticides the
goal of producing enough materials for satisfactory testing of efficacy.
The production of such materials (including biological control agents)
would be contracted to industrial organizations with the understanding
that such organizations would then be prime candidates for receiving
future license to the technology (since they would have acquired the
requisite production experience).
REQUIREMENTS FOR SUCCESS
The success of this incentive would depend upon the existance of signifi-
cant product ideas from government research suitable for commercial
exploitation. Interviews at the ARS indicate that such undeveloped
“inventions” do exist. Furthermore, industry and government would have
to perceive the same product ideas as commercially attractive.
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AGGREGATION OF PUBLIC SECTOR MARKET DEMAND
SUNMARY
This Incentive, to aggregate public sector market demand (at the federal
level at least, and possibly the state and local government levels as
well), is intended to apply the forces of market demand to encourage
innovative pest control products. This mode has already begun to be
explored by the General Services Administration for other civilian goods
and commodities.
OBJECTIVES
The primary objective of this incentive is to encourage development of
more effective pest control methods.
For the commercial pesticide producers it would reduce the risks in
introducing new pest control method(s) by assured, near— and long—term,
market demand of sufficient volume and similarity of performance require-
ments to warrant investment in product development.
EPA’s objective would be to stimulate aggregation of federal and/or state—
local purchasing to performance requirements agreed upon between EPA and
purchasers, in order to stimulate commercialization of desired pest control
method(s), by using aggregated public market demand as pump—priming for
potential private market demand.
EXPECTED OBSERVABLE RESULTS
Within two to three years, continuous improvements in pesticide control
methods would be expected such that public market needs are satisfied
(e.g., Forest Service) and potentially desirable methods are provided
for the private market as well. A longer term result (five to seven years)
could be requiring a large enough market to provide opportunities for
high—volume production, and/or with a cost—differential (over existing
methods) that must initially be borne by public sector.
These near— and long—term results would benefit both private and public
sectors, by providing improved and highly innovative pest control methods
that might otherwise be unavailable.
DESCRIPTION AND IMPLEMENTATION
Aggregation of public sector demands for improved or new pest control
methods is Intended to exert the pull of market demand on industry to
provide such methods. Federal, state, and local government markets appear
to be large enough to exert this effect if appropriately aggregated. EPA
would persuade GSA to become the lead agency in developing federal agency-
wide purchasing practices to common performance requirements.
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Aggregation of Public Sector Market Demand, Cont’d
Agreement on performance requirements (efficacy, toxicity, environmental
safety and health as well as price) would have to be achieved ameng
numerous agencies [ DOD, USDA, USD1, HEW, USDL (OSHA) and CPSC]. GSA (for
all of the civilian “consumer” agencies) and DOD would have to collaborate
to articulate prospective size of combined government market and continuity
of such market with stated performance specifications over 5—10 years (in
order for industry to obtain desired return on investment), and test industry
reaction in order to determine if “stimulus” would work.
If this proves to be successful at the federal level, state agencies should
be encourage.d (voluntarily or not) to join the “purchasing pooi.”
In setting performance requirements, federal purchasing agencies must bear
in mind prospective costs and risks of developing new pesticide control
methods implied by these requirements. This calls for frank and open
discussion between buyers and sellers. Also, discussions are needed
between government buyers and prospective civilian purchasers to determine
whether and how performance requirements satisfying government needs do,
or can be made to, meet prospective private user needs also.
REQUIREMENTS FOR SUCCESS
Technological innovation is most likely to be productive and viable over
both the short and the long term if a deliverate kind of continuing creative
tension is maintained between two different approaches to innovation:
increasing “technology push” and increasing “market pull.” EPA’s options
for action should, therefore, reflect the need to orchestrate the creative
tension between these push and pull modes.
EPA can influence the “pull” for innovative pest control in two major ways:
by mandating and enforcing increasingly stringent standards for safety;
and by helping to create the demand through aggregating public sector
markets.
The two actions are not contradictory or mutually exclusive. The second
can indeed help to demonstrate the validity of standards set in the first.
In fact, it is intended that the “performance” (rather than the design,
compound, or method of application) of the desired method be specified
(quantitatively) for a variety of criteria: e.g., efficacy of pest reduction,
toxicity, safety, environmental and social effects, cost, impact on industry,
etc.
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EXPANSION OF THE NUMBER AND ROLE OF INDEPENDENT PEST
MANAGEMENT CONSULTANTS
SUMMkRY
The USDA or EPA would support through training and subsidies an increase in
the number (and distribution) of independent pest management consultants
who provide advice to farmers and growers. Similarly the USDA would support
the development of total performance pest management service organizations
in order to aid the farmer and influence pest management practices.
OBJECTIVES
It has been denxrnstrated that effective use of 1PM approaches has the
potential for reduction of the environmental hazards of pesticides and
for maintenance or improvemnt of agricultural productivity. In the
western United States, there has been a growing use of independent pest
management consultants who offer advice to farmers and growers for a fee.
The advice frequently includes 1PM counseling, aids the user in selecting
the optimum types and timing of pest control approaches, and can result
in substantial savings to the farmer or grower. The objectives of this
incentive are to encourage• the increased use of independent pest management
consultants in other locations and to expand their operations to, include
a total pest management performance instead of only pest management
consulting. The pest management performance organization would select,
apply, and monitor, pest control techniques and guarantee a level of
pest control to the farmer or grower.
EXPECTED OBSERVABLE RESULTS
In the short term, this incentive will lead to a greater number of independent
pest management consultants working in several parts of the country. Their
efforts can lead to increased use of 1PM, acceptance of 1PM by farmers, and
reduction in the quantity of pesticides which enter the environment. Expanding
the role of the independent pest management consultant can lead to a
“centralization” of environmental accountability because a smaller number
of persons will be responsible for the use of pesticides. Agriculture
will benefit from less costly pest control and lower risks for farmers Or
growers. Unfortunately there are few, if any benefits to the pesticide
industry other than the potential ease of marketing for dealer or distributors.
A hoped for result will be the development by industry of pesticides that
are n re easily integrated into 1PM approaches.
DESCRIPTION AND IMPLEMENTATION
The first part of this incentive can be accomplished in several ways. Training
programs for independent pest management consultants can be supported by
USDA or EPA through the state universities. Existing pest management consultants
can be encouraged to add staff and expand their activities by direct subsidy,
low—cost loans or other measures. Subsidies should be based upon both
staffing and acreage covered to assure that quality is not compromised.
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Expansion of the Number and Role of Independent
Pest Management Consultants, Cont’d
Finally, farmers or growers could be subsidized for using the pest management
consultants. The subsidies and training would best be funded by USDA or
EPA and administered through the states, to ensure that local needs are
met and use of the consultants is justified and appropriate.
The second part of this incentive is more speculative in both method and
expected results. The federal government, perhaps through the Small
Business Administration or the USDA, would assist individuals desiring
to enter the total pest control performance business. This could be
accomplished through loans to provide initial working capital for equipment
and salaries. An insurance program would be considered to reduce early
financial difficulties resulting from crop failure when the organizations
are not well established, or alternatively an insurance program established
for the farmers who use the pest control performance business. In return
for this support, the pest control performance organization would be.
required to utilize 1PM approaches, pesticides which are most safe and
effective, etc.
REQUIREMENTS FOR SUCCESS
The greatest requirement for success is the acceptance of the farmer or
grower of these approaches. Provision of education and information on
pest management consultants through the state extension services could
help. The pest management consultant has been successful partly because
he provides advice and lets the farmer or grower choose methods or
pesticides to be used. If the consultant were to enter the “performance”
business, he would be considered “another vendor” and make the customer
(farmer) suspicious of his objectivity and adequacy. The role of the
pesticide industry and its relationship to the consultant or the
performance organization is uncertain; industry is not likely to benefit
greatly from either and not support them.
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PESTICIDE DEVELOPMENT AWARD
SUMMARY
The incentive would be an award, granted each year by EPA for an outstanding
achievement in the development of innovative pest control methods.
OBJECTIVE
This incentive would represent an affirmative, rather than punitive, action
by EPA. At the present time EPA is viewed as a regulator, enforcer, or
at best a protector of the environment. EPA is not seen as an agency
that encourages and supports by the use of positive sympathetic and
friendly means. Therefore, creation of an award or prize for significant
efforts on behalf of the development of innovative pesticides would be
a very positive reinforcement for good achievements in the pesticide area.
In the short term, it is unlikely that this would have much direct impact.
In the long term, it could have significant impact on the public image of
the agency, as well as the view of industrial people who are trying to
work with it. Thus, rather than only a negative image of EPA, one would
be forced to admit that at least they are trying to be positive and that
a participant in pesticide development receives positive benefits.
EXPECTED OBSERVABLE RESULTS
The results sought are likely to be non—measurable because only attitude
and image are involved. Conceivably, someone’s behavior might change in
the basic research area, a new pesticide would be developed, and 10 years
from now the person would credit their behavior change to EPA. However,
in the next 5 years at least the EPA will not have the benefit of such
a blessing. Therefore, the results, at most, will be in terms of image
and public relations. It is difficult to visualize negative results from
the issuance of an award or prize other than the likely possibility that
some people will say that that’s a waste of EPA efforts and inappropriate
for a regulatory agency.
DESCRIPTION AND IMPLEMENTATION
In order to have any impact the award would have to be significant .
Therefore, the award should be the equivalent of: a $100,000 prize; a
six—month grant for a university sabbatical with full salary graduate
students; a two—month leave of absence from one’s employ at full salary;
or a year’s sabbatical in government service. The mechanics for the
institution of such an award should include a blue ribbon panel of
judgesdominated numerically by EPA staff members (but including others
as well), clear mechanisms and requirements for winning the award, and a
nominating or canvassing committee in order to get awards up to the judges
panel.
REQUIREMENTS FOR SUCCESS
EPA should seek.to reward achievements of the very highest caliber. The
only requirement for success is that it be done in a way that recognizes
these outstanding efforts in a public manner. Although such an award is
not likely to motivate large companies, it could motivate university
professors, individuals, or smaller groups to spend their efforts doing
further research in the pesticide area.
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APPENDIX H
INDUSTRIAL, GOVERNMENT, AND ASSOCIATION CONTACTS IN THIS PROGRAM
Industrial Participants
Abbott Laboratories
Amchem Products, Inc.
Cheinagro
Chevron Chemical Company
Ciba—Geigy Corporation
Dow Chemical U.S.A.
E. I. duPont de Nemours and Company
Elanco Products Company
FMC Corporation
*Helena Chemical Company
McLaughlin Gormley King (MGK)
3M Company
Monsanto Agricultural Products Company
S. B. Penick and Company
Shell Chemical Company
Stauffer Chemical Company
Story Chemical Company — Farchan Division
Thomson—Hayward Chemical Company
Zoecon Corporation
Government Agencies and AssociatIons Contacted
EPA
Office of Pesticide Programs
Criteria and Evaluation Division
Ecological Effects Branch
Operations Division
Registration Division
* Special Projects
Strategic Studies
Technical Services
* Office of Enforcement
Office of General Counsel
Office of Planning and Evaluation
Office of Research and Development
Agricultural Assistant to EPA Administrator
USDA
Assistant to Administrator
Cooperative Extension Service
Cooperative State Research Service
Economic Research Service
*Inter_Regio 1 Project Office (IR—4)
Pesticide Coordinator
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INDUSTRIAL, GOVERNMENT, AND ASSOCIATION CONTACTS IN THIS PROGRAM
Other Agencies and Associations
American Farm Bureau Federation
Department of Commerce — Office of Environmental Economics
Environmental Defense Fund
Federal Working Group on Pest Management
General Services Administration
National Agricultural Chemicals Association
Sierra Club
U. S. House of Representatives — Committee on Agriculture
U. S. Senate — Agricultural Committee
*
These organizations were contacted but did not receive copies of
the Interim Working Document
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APPENDIX I
LIST OF COMMENTS ON PROPOSED INCENTIVES (BY INCENTIVE CATEGORY )
Summary comments on the various categories of the 64 preliminary
incentives circulated to industry, government and associations in the
Interim Working Document are given in the following pages. Not all those
receiving the document commented on the incentives by category. EPA—Other
refers to divisions or branches of EPA other than the Office of Pesticide
Programs.
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CATEGORY: INSURANCE/LIABILITY
Industry :
• The federal bureaucracy should not be involved in insurance
because:
1) The potential for gross misuse in the form of false claims
of government funds is high.
2) Such involvement rewards and stimulates poor performance
by industry.
3) Liability is a “proper risk of doing business.”
4) Large companies would not consider this as an incentive
because they are assumed costs of business.
5) Any service, such as insurance, which is available in the
private sector should not be duplicated by government.
• These are incentives to the insurance companies, not the
pesticide companies.
Associations :
• Federal involvement in insurance would encourage poor quality
products in the private sector.
• Federal sponsorship of a reinsurance program for the insurance
industry in the area of minor crop pesticides may be a feasible
incentive.
EPA-OPP :
• All insurance incentivesimply registration of not very safe,
not very effective pesticides.
EPA-Other :
• There is potential for insurance incentives; they should be
investigated further. The approach should include replacement
of “chemical insurance” with “dollar insurance,” thus reducing
the amounts of pesticides needed.
Other Government :
• Insurance incentives undesirable because of (1) prospective high
expenditure of public funds; (2) encouragement of poor performance
by industry.
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CATEGORY: IR-4
Industry :
• IR—4 is a very useful program run by knowledgeable people.
More, similar services are needed and can best be accomplished
by expansion of IR-4 rather than initiation of a new program.
• IR—4 is a good program and can remain so as long as it is
funded through USDA, not EPA. Government support of minor
crops is needed, because industry will not do so. However, a
better vehicle for such support would be the trade associations
for particular crops; the government could provide funding
through the associations.
Associations :
• IR—4 funding should be increased, but should remain through
USDA, not EPA.
• IR—4 funding should not be used to direct the program more
heavily toward biological controls. IR—4 should remain free to
direct its efforts to those control methods it deems most
appropriate.
EPA:
• The IR—4 program needs to be extended, as it is unable to keep
up with current needs. Grower groups could aid this situation
through some mechanism where they can influence the program or
directly influence the registration of pesticides.
• Consideration should be given to a USDA—EPA agreement which
would allow USDA to register minor crop pesticides.
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CATEGORY: INTEGRATED PEST MANAGEMENT--BIOLOGICAL CONTROL
Industry :
• The federal government should not promote either 1PM or
biological control as their effectiveness has not been proven.
• Promotion of these methods at this time is not justified because:
1) The prospect of further improvement in 1PM is questionable.
2) Biological controls are not necessarily safer than chemicals.
3) Non—chemical controls likely are not viable or a possibility
for the near future.
• 1PM is currently promoted by EPA with the implication that no
chemicals are involved. All juseful 1PM programs use chemicals
and should be advertised as such. 1PM promoted from EPA will
never work; development and support of effective programs must
come from the users and extension service.
• 1PM likely will not reduce pesticide usage; pesticides are part
of successful 1PM programs, and such programs will not be so
widespread as to have a significant effect on amount of pesticides
used. Indeed, farmers are businessmen who would use as little
pesticides as possible for economic reasons.
• Current 1PM program development should include review of non—
chemical pest control methods used prior to 1945 when the shift
to chemical methods occurred. New 1PM programs should include
a balance of chemical and non—chemical methods. Also, 1PM methods
should encompass all pests and weeds, not just those above some
economic threshold.
• 1PM is a desirable goal, and 1ncentiv which move companies in
that direction would be good. Properly directed 1PM programs
will focus on specific pests without damaging non—target species.
EPA—Other :
• 1PM should be promoted through demonstration and user education.
Farmers will use 1PM if its effectiveness has been demonstrated
to them. Beyond this, incentives will have little effect on
growth of 1PM programs.
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CATEGORY: PRODUCT PROTECTION/PROPRIETARy POSITION
Industry :
• Favorable patent reform would allow a greater amount of time.
• Unfavorable; implementation would be difficult.
• Unfavorable, opposed to special treatment for 1PM or biological.
EPA:
• Not important, market changes sufficiently fast to reduce
significance of patents.
• Favorable, can be incentive to R&D. However, technical and
administrative difficulties seem insurmountable.
• Should be examined to fully evaluate feasibility and practicality.
Other Government Agencies :
• Feasibility of approaches other than patent extension is doubtful;
patent extension unlikely for pesticides alone.
• Uncertain of the real role of proprietary protection in
pesticide R&D.
• Of benefit to large companies only, not favorable.
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CATEGORY: REGISTRATION CHANGES
Industry :
• Favorable because:
1) The administrator has arbitrary powers; there is a lack of
objectivity in decisionmaking and a lack of procedural due
process.
2) Input from outside EPA is required on many decisions and
should be employed more.
3) EPA responsiveness needs improvement; EPA responses need to
occur more quickly and with a sense of timeliness relevant
to seasonality of crops. Stepwise approval on segments of
data submitted with definite time intervals and deadlines
for segment approval would be helpful, as well as a general
time limit for response from EPA.
4) EPA spends too much time on efficacy, which is time consuming.
Some of this time could be diverted to safety which might
reduce registration time.
Associations :
• This type of incentive shows the greatest promise. However,
certain suggested incentives contain problems, such as excessive
reduction of requirements for some products and not others.
EPA—OPP :
• Favorable; Increased efficiency in the registration process is
desirability.
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CATEGORY: TESTING BY GOVERNMENT
Industry :
• There is no need for federal government to do any more that it is
currently doing through the state extension services.
• Industry can perform testing more efficiently and less expensively.
• Regarding basic Information like toxicity and efficacy
1) companies would fear loss of proprietary data, and
2) government funds would be wasted because only marginal
compounds would be tested.
• Would not be an incentive to industry, as there would be major
problems with lack of control over research strategy and quality
and delays (as frequently experienced when industry contracts
with research organizations).
Environmental Associations :
• Government should not develop its own data because it would tend
to be defensive during evaluation of registration data.
Farm Associations :
• Favorable because the great bulk of additional registration require-
ments stem from environmental testing which is seen as “in the
public interest.” Reflecting these costs in EPA ’s budget would
be a means to find out how much “safety” the public is willing to
pay for.
EPA—Other :
Very unfavorable; no reasons given.
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CATEGORY: GOVERNMENT-SPONSORED R&D
Industry :
• Unfavorable because:
1) The federal government should not support any R&D that can’t
stand on its own in the pesticide industry.
2) This should not happen under any conditions, as government
research is inefficient. These incentives would lead to poor
quality research, loss of research strategy by industry, and
uncertainties due to lack of control over quality and delivery.
• This would be feasible only if the government gave exclusive
rights to a limited number of companies.
Farm Associations :
• Unfavorable because:
1) Private industry has been and continues to be responsive to
market demand. EPA feels no such responsibility to the public
and as such would not be able to direct research efforts in
directions most beneficial to users.
2) The R&D mechanisms and facilities are in place in private
industry and the generation of duplicate facilities by EPA
would be a terrible waste of funds. Furthermore, neither the
user nor the public would have great confidence in the research
abilities of EPA.
Environmental Associations :
Favorable; government sponsorship of R&D is essential.
Standards for safety and quality control for testing should be
more specific and of high quality. These incentives would insure
such measures.
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CATEGORY: EDUCATION, TRAINING, AND INFORMATION
Industry :
• These incentives would take a long time to be effective.
• There are no objections to training of farmers, but the mechanism
for doing so is unclear. Additionally, it may not be necessary
as farmers currently get good instructions from extension services
and agricultural field technical service personnel.
• EPA should be involved only to the extent of providing money.
The training should be done by USDA through universities and the
extension service.
EPA-OPP :
• These incentives are good in general, but as stated are too broad
and have been prepared without much knowledge of what the Operations
Division has been doing already. The main function of the Division
is to tell people how to use pesticides safely and how to protect
the environment.
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CATEGORY: FUNDING AND REIMBURSEMENT OF INDUSTRIAL DEVELOPMENT
Industry :
• Unfavorable; approach not consistent with free enterprise system.
• Unfavorable both In principle and for reasons of effectiveness;
government funding “inevitably” leads to government control of
research.
EPA—Other :
• Favorable to subsidies if they control research and lead to more
desirable products. A direct, controlled subsidy is preferable
to both repayment loans and investment credit, both of which can
be operationally confusing.
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CATEGORY: PENALTIES
Industry :
• Unfavorable; tax incentives should not be employed.
• Favorable, if implemented slowly and gradually.
• Unfavorable; pesticide manufacturers do not have sufficient
control over what happens to their products to require them to
pay for various forms of misuse, etc.
• Unfavorable, as industry already faces daily penalties inherent
to doing business——lawsuits, assessment of liability damages and
resulting loss of business.
• Unfavorable because they would require new legislation.
Farm Associations :
• Unfavorable because of the negative approach.
EPA—OPP :
o Unfavorable; cancellation would have a more noticeable and
immediate effect. Further, unsafe products should not be
registered. Assessment of equitable penalties would be extremely
difficult.
• Unfavorable; difficult to assess tax and administer.
EPA—Others :
• Unfavorable; no reasons given.
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CATEGORY: MARKET STIMULATION/PRODUCT DEMAND
Industry :
• Interesting but largely impractical.
• Unfavorable; no reasons given.
• Favorable; no reasons given.
Farm Associations :
• Favorable; aggregation of public sector market demand would
exert considerable pressure on various pesticide control markets.
However, public sector demand may already consider factors
addressed in this section; hence little change might results.
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APPENDIX J
COMMENTS ON PRELIMINARY PROPOSED INCENTIVES
Comments on the incentives presented in the Interim Working Document
are summarized below on an incentive—by—incentive basis. EPA—Other refers
to divisions or branches of EPA other than OPP. Additionally, selected
ADL—ETIP—EPA project staff comments are included in order to provide a
more complete response to the proposed incentives.
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1. Insurance for Minor Crops
In order to encourage pesticide companies to develop and register
products for minor crops, the federal government create an insurance
program to reduce the company’s liability for production—related
damage to these low total volume, often high value crops.
Goals : Encourage pesticide companies to register and produce products
for minor crops.
Action Agent : EPA, other federal agency
Industry :
• A feasible Incentive.
• Insurance coverage should only be sufficient to provide some
reasonable return of the investment.
• Liability isn’t a problem; liability is a proper risk of business.
• Not really an incentive, because companies still will not spend
sufficient money to obtain registration for low volume uses.
• Impractical; likely to encourage false claims.
EPA—OPP :
• Would benefit manufacturers, farmer/users.
• Worthy of future study.
• Program may be cost prohibitive due to administration of claims.
• Production—related liability Is not a problem.
EPA—Other :
• Implementation would be too complex and expensive.
ETIP :
• This form of insurance is undesirable because as the Incentive
is written it includes third party coverage.
Other Government Agencies :
• Favorable, if production—related liability is a problem.
ADL Project Staff :
• It is not. clear whether insurance is a major factor in the lack of
registrations for minor crops. Implementation of a federal
insurance program would be difficult.
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2. Government Insurance for Farmers Using Improved Pest Control Methods
Through a new USDA insurance program, reimburse farmers for crop
losses resulting from use of innovative pesticides, formulations,
or application methods.
Goals : 1) Provide the farmer necessary security to try a new product.
2) Reduce liability for companies producing innovative products.
Action Agent : USDA
Industry:
• A feasible incentive.
• A good concept is inherent in this incentive, that is awarding
of government bonuses to persons using certain methods.
• Difficult to implement and administer.
• Difficult to verify cause of losses; hence, false claims could
be encouraged.
• Not an incentive; farmers are willing to try new products on
their own.
EPA-OPP :
• Favorable, but large cash reserves and funding would be required
for training, paperwork, claims adjustors, etc.
• A strong incentive for users due to its fail—safe nature.
• Could be incorporated into the Federal Crop Insurance Program.
• Favorable, because USDA programs exist as implementation
mechanisms.
• Program could be costly, as innovative pesticides are not
always safe.
• Could have administrative problems with claims.
• Not a sufficient incentive for farmers to use a new pesticide.
ETIP :
• Favorablebecauseit works on demand.
• Difficult to implement due to problems related to determining
cause of losses.
Other Government Agencies :
• An attractive incentive because it properly emphasizes the farmer/user;
however, the large cash reserve required means it likely Is not feasible.
• Program should be structured to encourage innovation of useful
pesticides for problem areas, not just innovation for Its own sake.
ADL Project Staff :
• Such a program could induce farmers to take risks they would not other-
wise take; however, implementation could be difficult as neither
resources nor mechanisms are available.
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3. No—Fault Tolerance
USDA and State Experiment Stations would develop “guaranteed”
residue and phytotoxicity data which could be used for registra-
tion by interested industrial organizations. Companies would not
be liable for any crop losses for a specified period after regis-
tration if these data were used.
Goals : To encourage pesticide companies to register innovative formula-
tions or products with safer application methods.
Action Agent : USDA, State Experiment Stations
Industry :
• Favorable, but it is doubtful that USDA and State Experiment
Station personnel would want to assume risks involved.
• Most useful incentive of all, provided government insurance for
unsuccessful product efforts be administered so as to protect
the proprietary data and interests of the company.
USDA and State Experiment Station data is frequently “poorer”
than that developed by private companies; their data flow is
very slow.
• A disadvantage is that such data would be non—proprietary.
EPA—OPP :
• Incentive value high; would reduce testing coats.
• Difficulty in determining cause of loss (could be from misuse).
• Wrong emphasis; subsidizes the producer.
• Could lead to dangerous residues in food supplies.
• Would be difficult to implement; legal problems.
ETIP :
• Reinforces carelessness in development process.
ADL Project Staff :
• Improper role for Federal government; private industry should
develop tolerance data to protect itself.
• Difficult to implement; will not affect research on innovative
pesticides.
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4. Insurance for Unsuccessful Product Development
To encourage the development of more pesticide products, the Federal
government would provide insurance to companies to reimburse develop-
ment costs of new products of proven efficacy if they are found to be
unacceptable during the environmental and safety test and evaluation.
Goals : Encourage pesticide companies to carry innovative product develop-
ment further than they would normally.
Action Agent : EPA
Industry:
• A good idea; would be supported by industry.
• Favorable, provided the mechanism retains the proprietary interests
of the companies.
• Not an incentive——would not increase the number of new pesticides;
will not make any difference since companies will pursue products
as long as they are effective.
• Difficult to implement.
EPA-OPP :
• This incentive has merit if the minimal amount of environmental
and safety data required to get the insurance is defined. Also the
amount of data provided on these factors (beyond efficacy data)
would have to be sufficient to predict some favorable probability
of success.
• Would reduce the risks of product development.
• Would require close monitoring of producers’ activities in order
to define point at which development and evaluation should be
stopped.
• Such a concept would be better implemented through use of tax write-
off incentives.
• Would be very costly; difficult to implement.
EPA-Other :
• The general idea is satisfactory, but it does not address the
problem of reduced use of pesticides.
ETIP :
• Federal government should not insure failure of private enterprise.
Other Government Agencies :
• Federal role should never insure risks of private sector in doing
business; this is contradictory to the free enterprise system.
ADL Project Staff :
• Encourages ineptness and inefficiency and poor decision—making;
companies will pursue research on any products they see are
promising. Not an appropriate role for federal government.
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5. Product Failure Insurance
The Federal government would participate In a program to provide
Insurance to protect companies against losses due to product
failures or product—related accidents. Insurance would not be
restricted to minor crops.
Coals : Encourage pesticide companies to register and produce products
in general.
Action agent : EPA
Industry :
• Feasible from Industry perspective; may not be feasible from
government perspective.
• Although liability a problem, government should not be Involved
In insurance.
Farm Associations :
• Undesirable as It would negate the current competitive effort to
produce and market quality products. Additionally, reputable
companies have too much at stake to market non—safe, Ineffective
products; hence, would not use the incentive.
EPA-OPP :
• Should be combined with Incentive number 1; payment of claims may
be cost prohibitive; organization and administration of program
may be complicated.
• Insuring efficacy not a proper role for EPA; could encourage less
careful efficacy and safety testing.
• Not an incentive because production—related costs are assumed as
part of operating expenses by industry.
EPA-Other :
• This incentive will not reduce pesticide use.
ADL Project Staff :
• Federal role should not include Insurance of the private sector.
If the government’s desire is to foster the development of quality
products, It should do so by positive actions, not by protection
against failures.
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6. Reinsurance
To provide better insurance coverage for pesticide companies, a
Federal reinsurance program for catastrophic losses would be
established.
Goals : To allow pesticide companies more freedom to develop products
due to increased availability of adequate Insurance.
Action Agent : EPA or other Federal Agency
Industry :
• Feasible, but Federal role should not Include involvement In
insurance; further, government involvement would add overhead
to current reinsurance system.
• Catastrophic losses are not a big problem.
EPA—OPP :
• Favorable, but needs further evaluation.
• Payment of claims may be cost prohibitive; organization and
administration may be difficult and complex.
• May not be an incentive, as liability may not be a major factor
in research and development decisions and directions.
• Implies an expectation of catastrophic losses and hence,
acceptance of them.
EPA-Other :
• Not feasible to Implement. The logical administrative mechanism
Is the existing Federal Crop Insurance Program, but cost and
time required for such integration would be prohibitive.
Other Government Agencies :
• Should be considered as part of a comprehensive insurance program
including incentives 1, 2 and 3.
ADL Project Staff :
• Should be explored further. It could be helpful In promoting
wide—scale testing of some innovative pesticides which are not
being adequately tested. Similar approaches have been used by
the Federal government In other areas.
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7. Supplemental Funding for IR—4
Fund, through EPA, additional residue testing of chemicals and
biological controls through the IR—4 program.
Goals : Provide coverage for minor crops; encourage development of
safer chemicals and biological controls.
Action Agent : EPA, USDA
Industry :
• Not feasible or desirable. This would give EPA even more power
than it has now; EPA does not understand pesticide onomics.
• IR—4 should receive increased funds but funding should occur
through USDA, not EPA.
• Emphasis on biological controls and integrated pest management
is already excessive and should not be increased.
• Additional testing will be useful only if done at an early stage
in development of a pesticide taking into account seasonality.
Such testing could help In getting a new product or idea on the
market.
• A favorable idea, especially 8ince the major limitation on minor
crops is market potential and return on investment. However,
coordination with IR—4 needs improvement; IR—4 sometimes does not
get enough data and companies must provide more. Companies should
be able to go to IR—4 with, and Initiate tests on, specific products
rather than IR—4 come to companies with requests for registration.
EPA—OPP :
• Worthy of further study; this could be a good cooperative arrange-
ment with no great risk or expenditure of funds.
• IR—4 funding should be increased, but through USDA, not EPA.
• An incentive for industry as it reduces development costs.
Other Government Agencies :
• A favorable Incentive because of its emphasis on minor crops.
• IR—4 funding should be increased; however, there is some doubt if
it will use the funds effectively.
• The incentive could be unmanageable for several reasons: safeguards
would be needed to limit the amount of testing done, the number of
compounds tested, the number of compounds per submitter. Addi-
tionally, the program could be used to test questionable compounds
about w 4ch a great deal was already known; hence a “free ride”
for users.
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8. Residue Journal
As part of IR—4, establish a journal to publish residue research In
order to recognize scientific work of an important but not
glamorous type.
Goals : To increase the number of products registered for minor crops by
encouraging residue studies by researcher.
Action Agent : USDA, other agency
Industry :
• Favorable, but not feasible unless EPA accepts the research without
criticism.
• Favorable, but journal should include efficacy as well as residue
data.
• Not useful, but if adopted government should maximize use of its
dollars and have private industry do work rather than universities
or other institutions.
• Harmless, but useless. Not an incentive; unimportant.
Associations :
• Favorable; would encourage more residue work.
EPA-OPP :
• Not useful; too many similar journals already.
• Favorable, but has questionable incentive value.
• Favorable, but implementation should occur through expansion
of present journals combined with increased communication of
its value to users.
Other Government Agencies :
• Unfavorable; no reason for government to sponsor such a journal.
ADL Project Staff :
• This is not an area for EPA or USDA to be involved with, but
rather is more appropriate for industry or technical, professional
groups. Such a government—sponsored journal likely would be of
mediocre quality, and thus not be respected. Hence, incentive
value would be low as the opportunity for a government or industry
researcher to publish in such a journal would not be very attractive.
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9. Crop Groupings for Minor Crops
By means of crop groupings, enable registration of one product for
several minor crops on the basis of one set of tests.
Goals i) Improve the efficiency of IR—4.
2) Provide more products for minor crops.
Action Agent : EPA, IR—4
Industry :
• Favorable because:
1) it would reduce the workload on small volume pesticide
clearance; also reduce required time and fees for registration;
2) system was once operable which was effective; more recently a
new, feasible system has been developed which could be adopted;
3) is feasible as demonstrated by registration of Enstar on a
variety of ornamentals;
4) the minor crop market could become a major crop market, thus
providing an incentive to industry for more research.
• Could be effectively combined with Incentive number 3 — No Fault
Tolerance.
• Marginally helpful, if administered properly and In conjunction
with a reasonable and consistent registration and regulatory
attitude.
• Groupings useful, but company would not market products it had not
tested itself.
EPA—OPP :
• Favorable, because:
1) would accelerate registration process;
2) is a definite incentive for minor crop research;
3) is not costly;
4) Is a good USDA—EPA-industry cooperative venture;
5) spreads development costs over several markets.
• Favorable, but more workable in the non—food uses.
• Favorable, although may not contribute to Innovation.
EPA—Other :
• Favorable, would be cost effective; save money.
ETIP :
• Favorable, some questions regarding technological feasibility of
Implementation.
Other Government Agencies :
• Favorable, because of emphasis on minor crops.
• Unfavorable because of environmental risk; validation needed that
it could be done safely
ADL Project Staff :
• Generally good idea but requires sound scientific basis
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10. Insurance for IR—4
Through a fund available to IR—4 from USDA, reimburse farmers for
crop losses due to use of product registered through the IR—4 pro-
gram during the first two years after registration.
Goals : Encourage pesticide companies to register a product through IR—4.
Action Agent : USDA
Industry :
• Favorable, although it will not have much effect on the specialty
field.
• Such a program would be misused in the claims area, both by
farmers and the pesticide industry.
• Would be too costly in claims; question remains regarding pay-
ment of premiums——industry or government? Likely not feasible
in either case.
EPA—OPP :
• Deserves further study.
• Favorable; should be combined with Incentive number 2 — Govern-
ment Insurance for Farmers Using Improved Pest Control Methods.
• Not useful, because:
1) insufficient incentive for farmers to use a new pesticide;
2) efficacy and performance are not problems; rather, environ-
mental risk is key problem and the focus of IR—4 should
remain here.
ADL Project Staff :
• Implementation of this incentive could be complicated and
unpredictable, particularly because EPA would have to initiate
the funding in USDA or provide the funds themselves.
• Incentive value is questionable, as pesticide companies may
still believe the risks are too great. Companies evaluate not
only financial, but also public image risks.
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II. Government Support to Users of a USDA 1PM Service
At the initiative of EPA, set up an 1PM advisory service for farmers,
including among the advisors the USDA Extension Service and repre-
sentatives of companies whose products could be used in 1PM.
Goals: 1) Encourage companies to get their products into an 1PM program.
2) Inform farmers of 1PM and encourage them to use these methods.
Action Agent : EPA, USDA; pesticide companies
Industry :
• Unfavorable; would be very expensive with little return.
• Unfavorable; coordination and required mechanism too complicated
to work; against hiring of more government employees.
• Unfavorable; a new 1PM advisory service is not needed as 1PM
has been practiced for years by good entomologists, plant
pathologists and extension agents; effective services are used
without additional incentives.
• EPA should not be involved here; rather USDA and the pesticide
companies.
• Current program could be improved through increased involvement
of pesticide companies. Program structure should center on USDA
service to extension personnel, with advice of pesticide companies.
EPA should not be involved.
Associations :
• Favorable; government support for 1PM users is necessary. (Sierra
Club and EDF)
• Undesirable; a federally funded 1PM advisory service would be in
direct competition with the private sector. (American Farm
Bureau Federation)
EPA-OPP :
• Worthy of further study, but implementation could be complicated
and encourage bureaucratic red-tape; preservation of USDA and
industry roles necessary.
• Very favorable; one of the best incentives——assuming USDA heartily
endorses the program. It would be costly, but would achieve
success if properly run, publicized and evaluated.
• Favorable, if made available free to users.
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EPA—Other :
• Unfavorable; expansion of 1PM supportable only if cost/benefit
analysis justifies additional personnel.
• Favorable, if extension service added additional personnel.
Other Government Agencies :
• Favorable; first, demonstration could be conducted with the
Extension Service involved to monitor demonstrations and transfer
knowledge and practices to farmers.
ADL Project Staff :
• EPA and USDA should not be involved in this, particularly since
their involvement greatly Increases the number of actors that
would need to agree in order for the advisory service to be
effective. Rather, industry or trade associations should initiate
such a service on their own.
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12. Subsidy for 1PM
Government support (by direct subsidy, tax credits, or returns) to
agricultural groups or farmers in a region who use 1PM techniqueá
rather than traditional pest control methods.
Goals : Encourage farmers to use 1PM rather than traditional chemical
controls.
Action Agent : USDA, EPA
Industry :
• Unfavorable; incentive as written implies that 1PM does not
include use of chemical pesticides.
• Unfavorable; farmers should try new programs at own risk.
• Unfavorable; farmers will use any effective 1PM program; a
subsidy is not needed.
• Unfavorable; very costly and questions remain as to who would
finance the program.
EPA—OPP :
• Favorable, if implemented in conjunction with incentive number 11,
Government Support to Users of a USDA 1PM Service . The subsidy
could be broadened to include 1PM private organizations——to
provide low cost service and advice to farmers.
• Favorable; payment for trying new methods will be an incentive
to farmers.
Other Government Agencies :
• Unfavorable; government subsidy for 1PM is inappropriate as it
charges public twice for the same thing——once by government tax—
subsidy, once by product purchase; opposed to subsidies in general.
EPA Project Staff :
• Feasible if self—supporting 1PM programs can be identified.
ETIP Project Staff :
• Not supportable until commercial and educational methods of
promoting 1PM are explored.
ADL Project Staff :
• Federal money may be needed to overcome farmers’ hesitation to
use innovative pest control methods, but In the long term, these
methods must support themselves.
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13. Rights to 1PM
Sell, through a federal mechanism, exclusive rights to biological
controls to private 1PM enterprises in order to increase the use
of 1PM.
Goals : Increase the use of 1PM.
Action Agent : Federal government
Industry :
• Favorable; this approach has appropriate emphasis, that is,
private 1PM concern can sell the program, provide necessary
monitoring personnel, and guarantee the results.
• Unfavorable; selling “rights” for biological control to private
enterprise is selling programs that don’t exist.
• Unfavorable; is another layer of bureaucracy; also Dept. of
Justice would oppose this as anticompetitive.
EPA-OPP :
• Unfavorable; administrative difficulties likely.
• Not feasible; biological controls are not patentable.
Other Government Agencies :
• Not feasible from legal standpoint.
EPA Project Staff :
• Further definition of rights required.
ETIP Project Staff :
• Further definition of rights required.
ADL Project Staff :
Probably not feasible in view of copyright and proprietary
protection laws.
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14. Reorganization of USDA Research in Biological Control
Reorganize USDA research on biological controls to include more
1PM testing, product or program development, and pest-targeted
efforts.
Goals : Provide mre biological control and 1PM programs.
Action Agent : USDA
Industry :
• Favorable, but information should flow freely to farmers to
do with as they want and to private enterprise to exploit as
it sees fit.
• Unfavorable; the only reorganization needed is to return to the
old Entomology Research Service (ERS) and to put more emphasis
(and money) into practical research to solve the immediate
pest problems of the farmer.
• Impractical; USDA is already doing considerable research in this
area and results, as measured by useful products, have been
generally poor.
• Possibly useful; although USDA biocontrol research and promotion
has not been very effective.
Associations :
• Very favorable; however getting the reorganization through
Congress would be difficult. (Sierra Club)
EPA—OPP :
• Favorable; reorganization is needed but USDA must take initiative
with EPA playing a support role.
EPA—Other :
• Favorable; more effort on biological control would be good.
Other Government Agencies :
• Favorable and feasible; it requires no money, no outside agents
and no regulatory actions.
EPA Project Staff : Not feasible.
ADL Project Staff :
• USDA is doing considerable research in this area. EPA could
provide selective funding for additional research. However, they
may not be in a position to do so administratively.
• Reorganization of biological control across agencies is probably
valuable.
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15. 1PM Coyprig ,
Provide copyright or similar protection for 1PM systems in order to
provide royalties to system developers.
Goals : Stimulate development of 1PM systems.
Action Agent : Federal Government
Industry :
• Favorable, if a practical system develops.
• Not feasible now as such systems do not exist.
EPA-OPP :
• Not feasible.
• Not the type of activity that should be placed under copyright.
• Organization, development and administration all would be
difficult.
Other Government Agencies :
• Not feasible; likely that 1PM cannot be copyrighted.
EPA Project Staff :
• Not an incentive (no reasons discussed).
ETIP Project Staff :
• 1PM could be promoted better through protection via other
mechanisms (unspecified).
ADL Project Staff :
• This could be an effective incentive in that it would provide
exclusivity to the 1PM system creator. However, in many cases,
it is doubtful that the royalties involved will be sufficient
to have much incentive value. In addition, the implementation
would be difficult, as would enforcement.
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16. Reduced Registration Time for Safe Products
Reward companies that develop safe pest control products by
providing a shorter and less expensive registration process.
Goals : Encourage the development of safer products.
Action Agent : EPA (OPP)
Industry :
• Favorable because:
1) There is currently little incentive to develop “safe”
pesticides largely because it takes just as long for these,
as for the more toxic ones, to reach the market. Despite
problems defining safety, the key point is to reduce
registration time.
Unfavorable because:
1) Definition of “safe” is not possible, particularly prior
to registration.
2) Registration should not be prioritized; prejudice and
favoritism implied.
Environmental Associations :
• Unfavorable on the grounds that all products registered are
supposed to be safe if used according to directions.
• Feasible, if criteria can be defined for safe products.
EPA—OPP :
• Unfavorable because:
1) Safety is jeopardized.
2) Registration Division could not handle it administratively.
3) Difficult or impossible to identify a priori a safe product.
In fact, unfamiliar types of products may take longer to
approve.
4) Difficult to reconcile “safe” with “less expensive,”
data gathering is expensive.
• This should be done but it has been tried before, but shortening
registration time was unsuccessful.
• This should be expanded to include safe and effective products.
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EPA—Other :
• Prioritizing should not occur in the registration process.
• Favorable, if feasible.
• This already occurs; safer products move through the process
more quickly.
Other Government Agencies :
• Unfavorable. Although in favor of reduci ng registration time,
in general, cannot be done for safe products. Difficult to
define safe and set priorities.
EPA Project Staff :
• Favorable, if combined with incentive number 20, Reduced Time
and Cost of the Registration Process.
ADL Project Staff :
• Unfavorable; incentive value is low because:
1.) It is impossible to adequately define safe.
2) Decreasing cost and time of registration is not as significant
an influence in pesticide R&D decisions as anticipated
market and competitive edge.
3) Manufacturers will object to preferential treatment for
“safe” products.
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17. Facilitate Registration Process for Innovative Products
Through granting of priorities for, and changes in, administrative
procedures, facilitate review of experimental permit and registra-
tion applications for innovative pest control products.
Goals: Promote innovative R&D by providing a reward for innovative
products. (This action would help eliminate a current dis-
incentive, i.e., innovative products frequently experience
registration difficulties because registration guidelines are
not structured to accommodate their innovative features and
approaches.)
Action Agent : EPA (OPP)
Industry :
• Favorable, although: innovative pesticides are not necessarily
safer for the user, environment, or consumer of food; innovative
needs to be defined. Innovative has different meanings to
farmer, public, environmentalist.
• Favorable because:
1) Frequently current practices are disincentives to new or
innovative products (as discussed above under Goals) .
• Unfavorable because:
1) “Innovation” cannot be defined.
2) Registration should not be prioritized.
3) Innovation alone is not sufficient basis on which to reach
a judgment.
Environmental Associations :
• Agreement with incentive.
EPA-OPP :
• This should occur to everyone.
• Not feasible in that identification of innovative products
isn’t possible. Registration may take longer because of
innovative nature of certain products.
• Has little incentive value, but is an easily solved managerial
problem.
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EPA—Other :
• Favorable, if feasible, although questionable whether prioritiz-
ing should occur in registration.
• Difficult to define innovative and safe.
Other Government Agencies :
• Unfavorable; difficult to define innovative.
ADL Project Staff :
• Impractical because:
1) “Innovative” cannot be adequately defined.
2) Implementation and administration would necessarily be
very complex and likely not decrease registration time
sufficiently enough to provide an incentive for R D.
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18. Reduced Registration Requirements for Biological Controls
Encourage the development of biological control methods by administra-
tive or substantive changes in the registration process that reduce
the requirements for these products.
Goals : Encourage development of biological controls.
Action Agent : EPA (OPP)
Industry :
• Unfavorable because:
1) There is no justification to giving one type of “low hazard”
control advantage over another type of “low hazard” control,
registration should not be prioritized.
2) Discriminatory. This is against the law and would be
litigated. Con resg did not give EPA such statutory
authority.
3) Biological controls are not necessarily safer than chemical
methods of control.
4) This implies a ‘checklist’ approach rather than application
of reason to each case.
• Biological controls must be defined to clarify whether they
are limited to only bacteria and viruses.
Farm Associations :
• Reduction in requirements for registration for biological controls
would be a blatant admission of current over—regulation.
Environmental Associations :
• Not favorable; preferential treatment in any area, including
biological controls, is not justified.
EPA—OPP :
• Unsafe to reduce requirements; in fact a longer review time
may be needed due to their relative newness to the registration
process.
• Not feasible until the entire area of biological control methods
has evolved considerably.
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EPA-Other :
• There should be a better way to handle biological controls in
the registration process, but it should not include a reduction
in requirements. Biological controls are not “a priori” safe.
Other Government Agencies :
• Unfavorable; biologicals may require more rather than less
testing due to their unfamiliar nature.
• Feasibility and practicality of further streamlining registra-
tion requirements questioned.
ADL Project Staff :
• The requirements for registration should not necessarily be
reduced, but should be made more relevant to biological controls.
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19.* Decreased Uncertainties of Registration Process for Applicants
Through changes in the staff and procedures at EPA, specify specific
time frames and establish stable and clear procedures for the
registration process in order to stimulate registration of more
products.
Goals : 1) Promote more pesticide R&D by increased communication and
understanding between industry and EPA and hence, decreased
uncertainty for industry.
2) Encourage in industry “go—ahead” decisions on borderline
major—minor use production.
Action Agent : EPA, USDA, others
Industry :
• Favorable because:
1) Registration process needs clarification and addition of
specific time frames for procedures.
2) Currently Section 3 guidelines have become for many bureaucrats
minimum legal checklists. However, more data can be requested
which leads to more delays and uncertainties, and little
predictability.
• This is an extension of current stated practice. Rather,
empower EPA to hire advocates to expedite attractive materials
through existing registration process.
Environmental Associations :
• Favorable; no reasons discussed.
EPA—OPP :
• Feasible, but incentive value is questionable.
• Is already being done; additional effort not necessary.
EPA—Other :
• Strongly disagree; the registration process must be uncertain
if EPA is to do its job effectively.
*
Incentives 19 and 20 were viewed, by far, as the most favorable by
industry.
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Other Government Agencies :
• Favorable; would help reduce uncertainty and allow better
investment decisions by companies.
• Favorable; suggests a provisional registration whereby a
manufacturer signs an affidavit that his product fits stated
specifications. Risk of future rejection by EPA remains.
However, public health risks may be too high.
ADL Project Staff :
Recommend implementation, but the effects on innovation are
long term.
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20.* Reduced Time and Cost of the Registration Process
Streamline and/or reorganize both administrative and technical
requirements of registration in order to achieve more registered
products and more products registered for minor uses.
Goals : 1) Increase products registered by reducing time and cost of
the registration process.
2) Encourage industry to develop minor use products.
Action Agent : EPA (OPP)
Industry :
• Favorable because:
1) We (industry) would welcome opportunity to periodically
review with EPA the progress of the development of a chemical
to final registration. Also, would save us time and money.
2) Both managerial and data evaluation need improvement.
Product Manager (PM) system is one step in right direction;
many others needed as implied under this incentive. Suggestions
include:
a) one reviewer per application
b) improve “estimated time to answer”
c) staff for peak loads
d) allow application to retain place in review order when
more information requested
e) institute reviews of initial EPA work
f) create arbitration rules to resolve disputes between
applicant and reviewers.
• Unfavorable because:
1) Introduced alone this would not induce change. Time to
process applications is small compared to amount of time
spent collecting data and doing field trials.
Environmental Associations :
• Favorable, as long as effectiveness of review process is not
decreased.
*
Incentives 19 and 20 were viewed, by far, as the most favorable by
industry.
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EPA—OPP :
• Favorable if done for all pesticides.
• Feasible, but value as incentive is questionable.
• Review of minor use pesticides should be expedited but minor
use registrations as such should not be encouraged. Also,
minor uses should be more the concern of USDA.
EPA—Other :
• This will occur naturally and should not be artificially induced.
• Favorable, provided emphasis remains on making registration
process easier, but not less stringent.
Other Government Agencies :
• Favorable, although favoring of certain products seen as
questionable.
ADL Project Staff :
• Although current efforts to meet this objective are underway,
they should be broadened and expedited without compromising
the intent of FIFRA.
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21. Registration of Only the Safest and Most Effective Product for
Each Use
By extremely selective registration of only the most desirable
products, encourage continual new product development incorporating
ever increasing safety and effectiveness.
Goals : Encourage continual new product development incorporating
safety and effectiveness
Action Agent : EPA (OPP)
Industry :
• Unfavorable because:
1) Approach is wrong. Rather, set a minimum safety requirement
and let competition in the marketplace decide which pesticides
will be used.
2) Comparative toxicity should never be a criteria for registration.
3) This is illegal under FEPCA, Section 3.c.5. EPA would be
exceeding their mandate.
4) Impossible to determine prospectively which products will
be safest or most effective.
5) This is actually a disincentive to development.
6) Safety cannot be defined.
Environmental Associations :
• Unfavorable, no reasons discussed.
EPA—OPP :
• Unfavorable because:
1) is a disincentive
2) is illegal
3) is already being done; additional effort not necessary
EPA—Other :
• Unfavorable; is anti—competitive.
Other Government Agencies :
• Unfavorable; illegal, risky.
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EPA Project Staff :
• Impossible to do; illegal.
ADL Project Staff :
• Implementation likely would be impossible because:
1) such selective registration counters legislative history and
probably would require new legislation.
2) a definition of “safe and effective” backed with criteria and
standards would be almost impossible.
• Incentive value would be negligible because in efforts to define
“safe and effective” EPA would be forced to seek the lowest
common criteria or denominator. Thus, if any effect occurred,
it would be to foster sameness rather than innovation.
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22. EPA Screening/Testing of Innovative Pesticides
Arrange testing of promising innovative pesticides without compromis-
ing the proprietary position of the developer in order to reduce
testing costs. (Modeled after the drug screening programs of the
National Cancer Institute.)
Goals : 1) Decrease the relative cost of development of innovative
versus non—innovative pesticides.
2) Allow pesticide development by parties possessing limited
capital.
Action Agent. : EPA
Industry :
• Favorable; although if a pesticide fails in EPA tests, industry
should still be allowed to present counter data with a fair
chance for evaluation.
• Favorable, if done by USDA, not EPA.
• Unfavorable because:
1) EPA should not be involved and USDA should not assume any
additional testing role.
2) It would be very time consuming.
3) Question of keeping data proprietary.
Environmental Associations :
• Unfavorable; no reasons given.
EPA—OPP :
• Favorable because would reduce costs to industry. However,
current EPA pesticide budget would not permit the program; thus,
Congress would need to agree and produce a special appropriation.
• Favorable, if done by USDA or other agencies, not EPA.
• Unfavorable, because government testing more expensive than
indus trial testing.
ADL Project Staff :
• Unfavorable; too complicated and difficult to implement in that
it involves defining “innovative” products, establishing a testing
system, and developing a system to protect proprietary information.
Further, the testing system would be costly to taxpayers with
virtually no cost to industry.
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23. Government Funding of Environmental and Residue Testing for
Minor Crop (and Specialty) Pesticides
Fund environmental and residue testing of minor crop pesticides at
non—government organizations in order to reduce product development
Costs to companies.
Goals : 1) Decrease the relative cost of commercialization of pesticides
for minor crops.
2) Allow pesticide development by parties possessing limited
capital.
Action Agent : federal government
Industry :
• Favorable only if USDA, not EPA is agency involved. EPA could
not be sufficiently objective due to the conflict between its
promotional and regulatory roles.
• Favorable for USDA, but it likely would lengthen registration
time.
• IR—4 already has assumed this role.
• Favorable if long—term toxicity included.
• Favorable only if the definition of minor crops is based on the
sales of pesticides for the crop rather than of the crop’s value.
Additional careful definition would be needed to prevent inclusion
of groups such as orange growers whose crop acreage is small but
value high.
Environmental Associations :
• Unfavorable because of the difficulty in defining minor vs. major
crops.
EPA-OPP :
• Favorable only if limited to cases where the government has
a broader interest and there is no additional cost to the govern-
ment.
• Favorable if done through USDA or a quasi public corporation;
also such a program should involve more than one agency given
the complexity anticipated.
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• Unfavorable, because:
1) More expensive than private sector testing.
2) EPA should not pay for testing of this sort.
EPA—Other :
• Favorable, but change and limit emphasis from minor crops to
those situations in which there is a real unmet need; careful
screening of pesticides for inclusion would be required.
• Favorable, but Congress would likely not appropriate the needed
capital ($10 million estimated), nor the giving of a five—year
mandate to EPA (a regulatory agency with a controversial track
record).
ADL Project Staff :
• Industry development costs would not be greatly reduced in that
residue data for minor crops already can be obtained through IR—4
and environmental data usually is not required for minor crop
registration, if the product has been registered for other crops.
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24. Government Generation of Environmental and Residue Data for Minor
Crop and Specialty Pesticides
After submittal by pesticide developer of efficacy and toxicity
data, USDA or EPA conduct environmental and residue testing
necessary for registration.
Goals : 1) Focus research and development on minor crop and specialty
pesticides.
2) Decrease the relative cost of development of such pesticides.
3) Have the public pay for the maintenance of public concern
with environment and residue.
Action Agent : EPA or USDA
Industry :
• Favorable if USDA, not EPA, is the sponsoring agency. However,
chances of success are questionable due to limitation of USDA
staff and experiment stations; testing time likely would be
lengthened.
• IR—4 already has assumed this function. Also, environmental
data are already available when a material has been registered
on another crop.
• Favorable if toxicity data required by industry is limited
to the acute data with government conducting the rest of the
tests.
• Although government should fund, actual testing should be
done by non—government laboratories for reasons of efficiency
and speed.
• Unfavorable because this sets up registration functions in a
sequence, thus increasing the registration time. Industry
usually conducts tests in parallel.
• Unfavorable because industry feels its business is based on
its ability to do chemistry and residue work; hence there is
no interest in encouragement of this work in the public sector.
Environmental Associations :
• Unfavorable; would involve too much government time and money.
EPA-OPP :
• Favorable only if limited to cases where the government has an
interest in the product. There should be no additional cost
to the government.
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• Favorable if USDA does environmental testing and HEW conducts
residue tests.
• Favorable if not limited to minor uses but includes all
products.
EPA—Other :
• Unfavorable; government funded, rather than government performed
tests preferred because of effectiveness and cost.
Other Government Agencies :
• Favorable in that this incentive parallels an ETIP project
on paints. Indications to date are that such government
services can provide assistance in commercializing new paint
formulations.
ADL Project Staff :
• Testing by government might decrease the cost to industry,
but may cause unnecessary delays.
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25. Efficacy Screening of Potential Pesticides
Conduct either primary or field efficacy screening of potential
pesticides at government laboratory (USDA) for a standard fee.
Goals : 1) Decrease initial investment required for new pesticide
development.
2) Focus on identification of pesticides for neglected “important
pest problems.”
Action Agent : USDA
Industry :
• Favorable if limited to secondary screening of industry—
sponsored pesticides; should not apply to primary screening.
• Unfavorable because:
1) This is a proper role for industry; not government.
Auxilliary testing by federal facilities for a fee is
acceptable, provided government and industry data given
equal consideration in the registration process.
2) Private rather than government labs would be more efficient
and here a company would have some control over quality and
scheduling through payments.
Environmental Associations :
• Favorable, but the Department of the Interior and the USDA
already do this.
EPA—OPP :
• Favorable because:
1) This could be an incentive to small business, depending
on the fee. The laboratory should be USDA—EPA sponsored,
not just USDA.
2) Consistency in the registration process would be improved.
• Unfavorable because:
1) This should be done by industry.
2) Government testing would be more expensive than industry
testing.
3) It is industry’s responsibility to develop effective
products.
• Already being done by state and federal facilities at no fee.
ADL Project Staff :
• A large screening program could be very efficient and
effective, helpful particularly for small companies. Setting
up such a large program would be difficult and complicated,
but could be done.
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26. Government Testing of all Registration Parameters
Provide a government service and facilities for testing of those
parameters required for registration. Charge fees consistent with
costs of in—house testing by pesticide industry.
Goals : Insure that data generated meets the requirements of registration,
thus providing regulatory consistency and predictability and
reduction in delays and costs to industry.
Action Agent : EPA and USDA.
Industry :
• Unfavorable because:
1) Government would be almost completely in control of the
registration process, except for financing.
2) Such facilities would be huge and hence slow, resulting
in even more delays in the registration process.
3) This would double an already enormous cost.
4) This is of no advantage to anyone.
5) Would allow companies without expertise to get into the
business and thus decrease the overall integrity of the
industry.
Environmental Associations :
• Favorable; no reasons given.
• Unfavorable; no reasons given.
EPA—OPP :
• Unfavorable because:
1) This amounts to socializing the R&D process.
2) Would be very costly for taxpayers.
3) Industry responsibility and control eliminated. Industry
would not accept this.
4) Would put many small business out of business due to fees.
ADL Project Staff :
• Unfavorable; likely both time and cost of registration would
be increased.
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27. Government Certification of Private Laboratories for Testing of
Pesticides
Certify private laboratories for pesticide testing in order to
guarantee acceptability of results for registration.
Goals : Reduce industry time and costs for registration by eliminating
the necessity of repeating tests.
Action Agent : EPA or USDA
Industry :
• Favorable because:
1) Current pattern shows that registration personnel favor
data from certain laboratories over data from others.
2) There is great variability in the quality of data coming
from different laboratories.
• Unfavorable because:
1) This implies that data from labs other than government
and universities are inferior.
2) There are better ways to solve the problem of misinformation,
such as stronger penalties.
Environmental Associations :
• Favorable; would like to see certified safety laboratories
forming independent quasi—public, quasi—private analysis
as a third part in the registration reviews.
EPA—OPP :
• Favorable because:
1) It would promote dependable data.
2) Would assure better data production.
3) But certification may be very costly to taxpayers or to
pesticide purchasers.
• Unfavorable because:
1) Certification cannot be done effectively or efficiently;
it is too political in nature.
ADL Project Staff :
• This does not address the major registration problem related
to testing——that is the requirements of additional tests
following data submittal. Required repetition of tests due to
invalid methods Is not presently a problem.
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28. Government Large—Scale Field Studies of Generic Representatives
of Innovative Pesticide
Provide to industry the results of large—scale government testing
of generic pesticides; accept data as part of registration require-
ments for pesticides in the class.
Goals : Decrease the uncertainties associated with innovative, novel
pesticides regarding field efficacy, environmental disposition,
etc.
Action Agent : EPA or USDA.
Industry :
• Unfavorable because:
1) There are large problems with what constitutes any given
class; approach would necessarily be unscientific.
2) It Is not feasible. Analogs are very different in their
response.
Environmental Associations :
• Favorable; no reasons given.
EPA—OPP :
• Favorable; costs would be reduced.
• Favorable, but certain government agencies already do this.
• Unfavorable; working with generics is dangerous due to the
the generalization required.
ADL Project Staff :
• The relationship between results of testing generic classes of
pesticides and individual applications for registration is
not clear.
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29. EPA Generation of Additional Registration Data
Following completion by the applicant of all tests required for
registration, conduct additional testing in government laboratories
or under contract to EPA.
Goals : Decrease the costs (to industry) and delays as a result of
requests for additional tests.
Action Agent : USDA or EPA.
Industry :
• Favorable; this would speed up the process. However, clear
procedures would need to be established.
• Unfavorable because:
1) Tests additional to those required for registration should
not be required.
2) EPA could use this as a procedural device for stalling
unless strict safeguards were employed.
3) Companies consider time far more important than additional
cost. This arrangement would slow down testing considerably.
Modification to this incentive is for EPA to notify applicant
of all data deficiencies simultaneously, thus allowing
prompt completion of the additional requirements.
4) Industry should maintain responsibility for control of
obtaining data on their compounds.
Environmental Associations :
• Favorable, although may not be feasible as Industry would
probably object to the provision that government would be
able to retain the information (leading to 3(c)l(D) problems).
EPA—OPP :
• Unfavorable because:
1) This Implies EPA is penalizing itself for taking
precautions.
2) Not feasible; no reasons given.
3) EPA should define all data required for registrants.
(This Is currently in progress.)
EPA—Other :
• Favorable, but costly.
ADL Project Staff :
• Although this would place the financial burden on government,
and reduce cost to industry, the delays caused would be
unacceptable to Industry.
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30. Government Sponsorship o Commercial R&D on iologic l Controls
Federally sponsor R&D by commercial companies on biolgical
controls in order to develop more products, as well as to
strengthen company skills in this approach to pest control.
Goals : 1) Increase variety of pest control methods and choice
available to farmers.
2) Promote methods non-toxic to non—target organisms.
Action Agent : USDA primarily; also EPA and FDA
Industry :
• Favorable; but only if the research is funded at the
commercial companies due to the slowness of government
operations.
• Unfavorable because:
1) EPA and USDA already too involved in a promotion
of biological controls.
2) If the company sponsored will be the eventual
developer of the product, they would have an
unfair advantage.
Environmental Associations :
• Favorable; such sponsorship is required if biological
controlé are to become successful.
EPA—OPP :
• Favorable because:
1) Would reduce industry costs, but should not be sponsored
by EPA.
2) Would be a strong incentive. However, Congressional approval
and funding would be difficult to obtain.
• Unfavorable because: very costly to the government and industry
may reject It as interference.
• This Is already being done, usually by USDA, but results are
not made available to the public.
EPA Other :
• Favorable because: it will bring needed skills to industry.
ADL Project Staff :
• A costly program, which Is not desirable to many companies due
to the risk to subsequent proprietary protection.
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31. Increase EPA Funding of R&D
Substantially increase EPA funding of R&D, emphasizing innovative
pesticides and potentiation of new and existing pest control methods.
Goals : 1) Increase variety of methods available for pest control
2) Reduce development costs for industry.
Action Agent : EPA/OPP
Industry :
• Favorable; but only if safeguards for proprietary data could
be employed and the patent situation improved.
• Unfavorable because:
1) EPA should not be promoting these methods; role
should be limited to regulation.
EPA—aPP :
• Favorable because: would reduce Industry costs, but should not
be sponsored by EPA.
• Favorable; but should be financed by USDA through universities.
ADL Project Staff :
• Increased EPA funding alone could not be sufficiently large to
impact the R&D process. Therefore, implementation of this in—
centive should be explored as a cooperative program with other
agencies such as USDA and NSF which could provide both additional
funds and appropriately trained staff.
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32. Government Funding of Basic Research
Fund a coordinated program of long. ’range basic research, under
government sponsorship to promote new pest control methods.
Gn 1s : 1) Create a research base to promote increased variety
and supply of pest control methods.
2) Reduce industry costs of basic research.
Action Agent : Federal Government (EPA, USDA, FDA), States,
private laboratories (under contract).
Industry :
• Favorable; if sponsored by USDA, not EPA.
• Favorable; if most or all of the funding goes to industry.
• Favorable; if funded through universities, particularly land—
grant colleges where it could serve to train advanced
personnel in a manner similar to research sponsored by the
National Institute of Health.
EPA-OPP :
• Favorable; because it would reduce industry costs.
EPA Project Staff :
• EPA has already been attempting to clarify many aspects
of their R&D program.
ETIP Project Staff :
• This might be facilitated by a tie between OPP and NSF.
ADL Project Staff :
• Deserves further consideration.
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33. Government Funding of Applied Research
Fund a coordinated program of applied research under government
sponsorship, on new pest control methods,
Goals : 1) Increase the variety of commercially available pest
control methods.
2) Decrease industry costs of applied R&D,
Action Agent : Federal (EPA, USDA, FDA), states, private laboratories
(under contract).
Industry :
• Unfavorable because:
1) This would be subject to great misuse if limited to
new pest control methods.
2) Government should not be involved in applied research.
EPA—OPP :
• Favorable; because it would reduce industry costs.
• Unfavorable because: not necessary; no reasons given.
EPA—Other :
• USDA support should be increased, but only to the extent
that EPA funds alternative pest control measures,
ETIP Project Staff :
• Giving money to industry with little government control
would not be acceptable to EPA.
EPA Project Staff :
• Government funding is not available for this,
ADL Project Staff ;
• Except in limited areas, industrial groups are most likely
to fund research because it is closest to the marketplace.
Therefore, having the government do what industry, agricultural
field stations, and trade associations naturally do now is a
wasteful duplication of effort.
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34. Government Funding of Research on ormu1ation and Applicatton
Methods
Fund, by the government, research to increase the cost effective.-
ness of pesticide applications, by means of safer formulations
and better application methods.
Goals : 1) Increase effectiveness and reduce environmental hazards
of formulations and applications.
2) Reduce industry R&D costs.
Industry :
• Favorable if sponsored by USDA and limited to application
methods. Formulation research should be done by industry.
• Unfavorable because: industry is best equipped to do research
in both of these areas.
• Not necessary; already done to some extent by the states and USDA.
EPA-OPP :
• Unfavorable because:
1) Would likely act as a disincentive; no reasons given.
2) Should occur as a joint industry—government—project rather
than as a full subsidy to industry.
EPA—Other :
• Unfavorable because this is too far into t he market sector
for government interference; it could interfere with market
competition.
• Favorable; no reasons given.
Other Government Agencies :
• Need in this area is not for more government fundinft of
research but more coordination of funding emanating from
a variety of agencies. A 1976 House Bill, H.R. 11743, calls
for establishment of a National Aaricultural Research Policy
Committee which might serve such a functioa
ADL Project Staff :
• USDA and the pesticide industry have been doing significant
and useful R&D for 30 years or more. Creation of a new
separate agency to perform similar functions would be
wasteful and unlikely to lead to any innovation.
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35. Definition of Standards for Safety
EPA clarify the concept of “safety” and its requirements for
registered pesticide products, both within EPA and through
more EPA participation in ASTM’s Pesticide Committee and ANSI ’s
new Environmental Council.
Goals : 1) Encourage stable and responsible industry participation
in pesticide work.
2) Reduce industry uncertainties and costs by working
within predictable standards and regulations.
Industry :
• Favorable because:
1) Such a definition is necessary. However, the ASTM
and ANSI work too slowly for needed conclusions. Also,
in many cases they lack the proper expertise.
2) Such a definition is necessary since standards
can be described as sliding. However, definition
should be formulated without using the term safety
since it has no statutory significance.
• Unfavorable because:
1) Could lead to even more of a “checklist mentality”
by reviewers; thus further removing judgment from
the registration process.
2) If definition were of the checklist nattire, it would
be a disincentive to innovation and flexibility.
EPA-OPP :
• This is already being handled by promulgation of regulations
guidelines.
• Favorable if sufficiently flexible to recognize that the
concept of safety will change with time and progress.
EPA—Other :
• Favorable; the government should be clear in its objectives
and is already working on setting standards for safety,
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• Favorable; EPA has needed this for a long time.
Other Government Agencies :
• “Safety” needs further definition, but this is a difficult
task.
ADL Project Staff :
• Any work that the government can do to fill in the gaps in
the data base for pesticides and their impact on the
environment is useful. Therefore, helping to develop data
to define how safe is safe and increasing basic knowledge
is useful, and is an area that only the government can take
ultimate responsibility for.
• Stabilizing safety standards is complex and perhaps impossible.
Funding of research to define safety would be difficult.
Further, standards must be continually revised to incorporate
new information Hence, more research could lead to less
stability.
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36. Training of Farmers and Applicators
Promote new methods of safe and effective pesticide use by
conducting seminars and other training for farmers and applicators
via their own organizations or state extension services.
Goals: 1) Introduce new methods to user.
2) Reduce user’s confusion, irritation and costs of
selecting and applying new chemicals.
Action Agent : USDA and EPA
Industry :
• Favorable because:
1) These organizations and services are respected by
farmers.
2) Although it has no incentive value for companies, it
is a good idea for education of users. Education
should, in the long run, reduce the amount of regulation
required.
• Unfavorable because:
1) Farmers are not likely to attend meetings; futher,
they already know much about safe and effective pesticide
use.
Environmental Associations :
• Favorable; especially if implemented through the extension
services
• Favorable; however, it should be expanded to include 1PM.
EPA—OPP :
• Favorable; but USDA, not EPA, should assume responsibility.
• Favorable; but already being done by the Operations Division.
Information manuals for users of ten categorical types are
currently being developed through contracts with universities
and state extension services. Promotional efforts could be
increased.
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• Already being done, but is not an incentive.
EPA—Other :
• Favorable; particularly if implemented through establi8he.d
agricultural channels, extension services, county agents etc
Other Government Agencies :
• Favorable; but not directly related to the impact of FIFRA;
not an incentive.
ADL Project Staff :
• Incentive value Is questionable. Education alone will not
convince users to change methods and products. Products
and methods advocated must be more effective and less
costly.
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37. Independent Pesticide Research Foundation
Set up an independent, non.-prof it organization through collaboration
of government and industry to disseminate impartial information and
conduct a responsible public education program.
Goals : 1) Improve the quality of technical and policy debates.
2) Reduce uncertainties and costs resulting from criticisms
by ill—informed observers.
Action Agent : A new institution, backed by industry and government.
Industry :
• Favorably; but not likely to occur.
• Unfavorable because:
1) This would be just one more organization superimposed
on the many that farmers have to deal with flows
2) Not needed, and if established, such a foundation would
become too powerful. Government should not be involved
in this type of venture.
3) No benefits to anyone; the extension services already
do this.
Environmental Associations :
• Favorable idea, but the structure and implementation would
need much classification and development.
EPA-OP P :
• Favorable; public and EPA need to know what each other are
doing.
• Unfavorable; rather set up a National Pesticide Training Center
to provide overall coordination in training of applicators,
farmers and users. Initial work on such a center is underway
in the Operations Division.
• A good idea, but is not an incentive.
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Other Government Agencies :
• Favorable; but not directly related to the impact of FIFRA;
not an incentive.
EPA Project Staff :
• Unfavorable; no reasons given,
ETIP Project Staff :
• Unfavorable; no reasons given,
ADL Project Staff :
• Difficult to coordinate with existing regulatory mechanisms
and private research.
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38. Federal Marketing of Pest Control Approaches
Increase public knowledge and acceptance of innovative pesticides
by cooperative federal—industry programs of providing information,
advertising and marketing.
Goals : 1) Reduce industry marketing costs.
2) Increase consumer confidence in products through government
approval.
Action Agent : EPA, USDA
Industry :
• Unfavorable because: this is likely to be federally dominated
and slanted. Furthermore, this is an area they know nothing about.
Farm Associations :
• Unfavorable; the federal government should not be in the business
of advertising and marketing pesticides.
Environmental Associations :
• Unfavorable; federal involvement in marketing creates a conflict
of interest.
EPA—OPP :
• Favorable; but USDA, not EPA should assume responsibility.
• Favorable; Operations Division is already somewhat involved
by promoting certain measures by providing information. The
Division is not involved directly in marketing.
• Unfavorable; would discriminate against older, established,
safe pesticides.
• Already being done; efforts should continue.
• Unfavorable; EPA should not be involved in advertising and
marketing pesticides.
EPA—Other :
• Favorable; even though it establishes EPA in a promotional role.
Other Government Agencies :
• Unfavorable; mandated role of EPA is not marketing.
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EPA Project Staff :
• Unfavorable; no reasons given.
ETIP Project Staff :
• Unfavorable; no reasons given.
ADL Project Staff :
• Unfavorable; the federal government should not be involved
In marketing activities.
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39. Improvement in EPA Contacts with Congressional Overseers
Increase and regularize information flow between EPA and Congress
in order to increase the understanding of the Congress and
judiciary of pest control and regulation problems.
Goals : 1) For EPA, increase and regularize the information
flow with Congressional committee staffs in order to
facilitate realistic laws.
2) For Congress, promote a better understanding and
implementation of laws.
Action Agent : EPA
Industry :
• Favorable because:
1) Could prevent crisis confrontations.
2) Could improve EPA ’s contact with Congress which
needs to be more centralized. EPA currently reports
to approximately 30 Congressional committees.
• Unfavorable because: EPA has too many friends in Congress
already. EPA needs to listen more to farmers and industry
rather than advocacy groups.
• There should be a permanent Congressional committee to oversee
EPA.
Farm Associations :
• Unfavorable; neither the pesticide industry nor the users will
benefit from increasing EPA’s ability to lobby Congress.
Environmental Assocaitions :
• Favorable, but difficult or impossible to achieve.
EPA—OPP :
• Favorable; but likely that industry will not cooperate.
• Favorable;and already occurring to the extent time and
resources allow; efforts should continue.
• Favorable; but incentive value is questionable.
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EPA—Other :
• Impossible and probably unconstitutional as EPA is an
executive agency.
Other Governmental Agencies :
• Favorable; but needs development and clarification,
EPA Project Staff :
• Unfavorable; not an incentive,
ETIP Project Staff :
• Unfavorable; not an incentive.
ADL Project Staff :
• Good idea, but may be naive
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40. clearinghouse for Research Results
Encourage companies to disclose unsuccessful research efforts
through a research information clearinghouse by reimbursing
some portions of the research costs.
Goal : Encourage more efficient R&D work through encouraging
companies to disclose negative R&D results.
Action Agent : EPA, NTIS, or professional society.
Industry :
• Unfavorable; nonsense
• Favorable; particularly if it includes formulators.
• Unfavorable; disclosure of failures to competition is
unacceptable in that it indicates areas of research con-
centration. Prevention of competition for more negative
than prevention of cost of fruitless research.
• Unfavorable; unrealistic. Companies could not participate.
This would require revealing areas of research, and
jeopardize research results which appear valueless in an
immediate time frame but become valuable later in a different
context.
• Unfavorable; disclosed information could become useful to corn-
petitors.
Environmental Associations :
• Favors the idea of public disclosure of unsuccessful research,
but not at government expense.
EPA—OPP :
• Favorable, if information availability could be limited only
to participating companies.
• Favorable, but not feasible. Producers will only release what
they want released.
• Likely to be costly; difficult to sell to Congress without
predictable cost limits.
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EDA—Other :
• Favorable; if there are adequate safeguards for proprietary
data.
ETIP :
• Unfavorable; although a good idea, difficult to implement;
costly to exchange information in such a manner.
ADL Project Staff :
• Unfavorable because:
1) Data of any value, either immediately or perceived
as possible in the future, would be held back. Hence,
a public file of non—usable information would be
created.
2) ImplementatIon would be difficult, particularly in
securing industry cooperation and in establishing
acceptable methods of disclosure, payments and/or
royalties.
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41. Research Investment Credit
Create a tax credit similar to the current investment credit,
allowing a company to offset directly its tax liability by 10
percent of the capital Investment In research during the years
providing that the total does not exceed 50 percent of the
pretax profit.
Goal : Encourage companies to Invest in pesticide R&D activities.
Action Agent: . Congress, EPA, Treasury Department, IRS.
Industry :
• Favorable, but implementation doubtful due to both Congressional
and public reluctance during economic recession,
• Favorable if directed at research on safer pesticides.
• Favorable in concept, but implementation not feasible;
problems focus on defining research.
• Favorable, particularly during a recession when R&D tends
to be reduced. Also, such a credit would be one way for the
public to pay for certain environmental safety measures they
are insisting upon, currently at the expense of industry.
• Unfavorable; government should not be in any position to
control industry research.
• Favorable; but criteria needed to define specifically what
credit would be provided for.
• Favorable; but doubtful that EPA would cooperate.
Farm Associations :
• Favorable; has real potential as a mechanism for permitting
the public to fund those things they are demanding through
environmental research.
Environmental Associations :
• Unfavorable; industry already has too many tax loopholes
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EPA—OPP :
• Favorable; particularly if the research qualified for inclusion
could be specified.
• Favorable; use a sliding scale investment credit to direct
development to needed areas.
• Favorable; an effective Incentive providing industry with
substantial cost reductions.
EPA—Other :
• Favorable; but must be structured to give investment credit
only for needed research, not all research.
Other Government Agencies :
• Unfavorable, as it appears to be compounding one credit upon
another. Likely, the House Ways and Means Committee would
be against it, considering Its efforts to simplify the
tax structure.
• Unfavorable due to potential cost to government. Further,
Congress should not act before knowing the structure of the
Industry and its needs for such a credit; hence a considerable
educational effort would be needed before any Congressional
action occurs.
EPA Project Staff :
• Unfavorable; would be difficult to administer; makes tax laws
more complex.
ADL Project Staff :
• Should be explored further due to the general desirability
by industry, but implementation may be difficult.
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42. Direct Subsidy of Research
Government subsidize the entire cost of R&D and registration of
pest control methods that are innovative, aimed at minor crops,
or otherwise not commercially attractive. Sale of patent rights
by EPA, with first refusal granted to the developer.
Goal : Accelerate development of innovative pest control methods.
Action Agent : EPA, USDA
Industry :
• Unfavorable; any participation by government leads to control
and patent problems.
• Unfavorable; industry should not be indemnified for its
products; it should assume its own risks.
• Unfavorable; absolutely not. Government subsidy leads to
government control; futher, government’s record of subsidizing
research in terms of actual product production has been poor.
• Favorable with modification. To avoid concerns and doubts
associated with direct subsidies, establish royalty rates at
which a company would repay loans from government if the
product proves successful.
• Favorable, depending on price char.ged by EPA for patent rights.
• Unfavorable; “innovative” cannot be defined.
Farm Associations :
• Unfavorable; the problem of non—attractive commercial production
should not be dealt with through subsidies. Rather, registration
costs should be reduced through reduction in registration
requirements.
Environmental Associations :
• Questionable; government should not be so involved in private
enterprise.
EPA-OPP :
• Favorable, if subsidy is less than total cost.
• Favorable, but doubtful industry will cooperate as EPA is
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given too much control.
EPA—Other :
• Unfavorable; all research should not be funded, but defining
innovative and setting criteria for other research to receive
funds would be too difficult.
EPA Project Staff :
• As written, is not specific enough to serve as an incentive.
ETIP Project Staff :
• This is not a role for EPA.
ADL Project Staff :
• Incentive would be too complex to implement, particularly
in the areas of determining the amount of research done by a
company and establishing a procedure for buying and selling
data.
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43. Reimbursement of Registration Costs for Pesticides for Minor Crops
Increase the availability of pest control agents for minor crops by
reimbursing costs of registration of already proven agents (i.e.,
those registered or other crops/insects) on specific minor crops
lacking alternative methods.
Goal : Encourage development and commercial availability of pest control
agents for minor crops
Action Agent : EPA, USDA
Industry :
• Unfavorable; should be incorporated as regular part of
IR—4 program.
• Favorable only if further developed by better defining minor
crops, registration costs and other variables.
• Favorable, as a company would not lose control of its product.
Farm Associations :
• Unfavorable in that direct subsidy of registration costs is
not a suitable solution; rather registration costs should be
reduced by reducing registration requirements.
Environmental Associations :
• Unfavorable; no reason given.
EPA—OP P :
• Favorable; implementation could be through removing the
tolerance charges (up to $10,000 per application).
• Favorable; should be a very effective incentive.
EPA—Other :
• Favorable, but the magnitude of the minor crop problem
needs further definition.
EPA Project Staff :
• Favorable, although USDA would be a more appropriate agency
for implementation.
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ETIP Project Staff :
• Favorable, although both the costs and the acceptable products
need definition prior to implementation.
ADL Project Staff :
• Subsidizing registration costs for minor uses is an indirect
approach. Instead, regulatory requirements should be examined
for applicability for minor uses.
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44. Repayment Loan Fund for Pesticide R&D
Provide a continuing source of capital investment funds for R&D
of pest control methods by establishing federal loans to industry
for safety and environmental testing. Repayment of the loans is
based upon product success.
Goals : Promote development of innovative pest control approaches through
provision of a continuing source of capital investment funds.
Action Agent : EPA
Industry :
• •Unfavorable; socialistic.
• Favorable, but costs of implementation should be examined.
Also, a mechanism for distributing loan money effectively needs
to be developed; perhaps the loan amount should be related to
companies’ R&D efforts or sales.
• Favorable, particularly for small and new businesses; could
attract new companies into the pesticide business.
• Unfavorable; not an Incentive and is costly to the taxpayer.
Environmental Associations :
• Favorable, especially for small businesses.
EPA—OPP :
• Unfavorable; too risky; tax incentives would be preferable.
• Worth further evaluation.
EPA—Other :
• Favorable, if focus of program is better defined. Prefer
this incentive to Low—Interest Government Loans (Incentive
#45), however, believe the low—interest loan is preferable
for industry.
Other Government Agencies :
• Likely too complicated to conduct as a workable incentive.
ADL Project Staff :
• This provides Incentive for research by providing capital for
initial Investments. However, it does not specifically address
innovative product development. Furthermore, most product
development risks should be assumed by industry.
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45. Low—Interest Government Loans
Through low—interest loans from the government, provide funds for
safety and environmental testing on desirable pest control methods.
Goals : Provide a source of low—cost investment funds for biological/
1PM pest control R&D.
Action Agent : EPA, or other federal agency.
Industry :
• Unfavorable; interference with free enterprise system.
• Favorable, although companies’ own capital should be. used for
more innovative research and development efforts.
• Unfavorable; this appears to be another way to promote 1PM
as definition of “desirable pest control method” is required.
• Favorable; would benefit small companies.
Environmental Associations :
• Favorable; small business administration loans could serve
as part of the implementation mechanism.
EPA—OPP :
• Worth further evaluation.
• Favorable, if criteria for granting of loans can be defined.
• Unfavorable; tax incentives would be preferable.
Other Government Agencies :
• This appears to be addressed to small formulators, as large
ones would not need such loans.
ADL Project Staff :
• Impossible to define desirable pest control methods.
171
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46. Water Residue Tax
Assess pesticide manufacturers with a tax based on the amount of
pesticide residues found in monitoring of water bodies and rivers.
Goals: Reduce the amount of persistent pesticides in use in the country.
Action Agent : EPA
Industry :
• Unfavorable; this does not account for misuse.
• Unfavorable; this is like a continuing “fire,” could be
abused by a large pesticide producer.
Environmental Associations :
• Favorable, but Congress not likely to be receptive.
EPA-OPP :
• Unfavorable; would function as a disincentive.
• Unfavorable; would result in expensive court cases.
EPA-Other :
Unfavorable; unconstitutional. Further, not feasible technically.
ADL Project Staff :
• A water residue tax is politically unacceptable at this time.
• Implementation would be complicated particularly in that
frequently it would be difficult to determine which manufacturer
was responsible for high—level water residues.
172
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47. Safety Tax
Create a tax on pesticides paid by manufacturers, based on the
toxicity (e.g., LD 50 ) and/or persistence (e.g., half—life in aquatic
muds).
Goals : Reduce the number of pesticide products on the market which
create a high risk to human health and/or the environment.
Action Agent : EPA
Industry :
• Unfavorable, but if implemented, criteria for such taxes
should include usefulness of the product as well as safety,
toxicity, etc.
• Unfavorable; registration requirements already constitute
a form of safety tax.
• Unfavorable and unfeasible; difficult to establish conditions
and criteria for safety. Taxes on a use basis more acceptable
than this.
• Unfavorable; pesticide qualities should not be the basis for
taxes.
Farm Associations :
• Unfavorable, neither toxicity nor persistence is a viable
measure of safety.
Environmental Associations :
• Favorable, but Congress not likely to be receptive.
EPA—OPP :
• Unfavorable; not practical to enforce.
• Possible, If based on poundage of pesticides sold.
EPA—Other :
• Favorable; when fees (taxes) are levied, society is being
repaid. Favors taxing manufacturers over users.
ADL Project Staff :
• Selecting indicators upon which to base the tax would be
difficult.
173
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48. Pesticide Use Tax
Charge pesticide users a use tax based on criteria such as toxicity,
environmental parameters, safety, etc., fund research with tax
revenues.
Goals : 1) provide incentive for industry to manufacture and sell “less
harmful pesticides;”
2) provide an incentive for users to purchase “less harmful
pesticides;” and
3) provide a source of revenue which can be returned to manufacturers
and others to support R&D efforts on “safer pesticides.”
Action Agent : EPA and other federal agencies.
Industry :
• Unfavorable, but if implemented, criteria for such taxes should
include usefulness of the product as well as safety, toxicity,
etc.
• Unfavorable; approved levels of toxicity are already written
into registration procedure.
• Of dubious value; it would be difficult to set criteria for
such a tax.
Farm Associations :
• Unfavorable; a use tax would become an additional negative
incentive to consumption and use and would thereby compound
the minor crop problem.
Environmental Associations :
• Unfavorable; criteria would be too difficult to define and
enforcement would also be problematic.
EPA-OPP :
• Unfavorable, would function as a disincentive.
EPA—Other :
• Favorable; when fees (taxes) are levied society is being
repaid. Favors taxing manufacturers over users.
ADL Project Staff :
• EPA cannot adequately define the necessary criteria for a
use tax to be implemented successfully.
174
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49. Modification of Patent Issue Date and/or Duration
Provide, through modification of the patent process, a specified
period of product protection, taking into account delays caused
by the government, and thereby encourage Industry to develop new
products.
Goals : Encourage industry to develop new products by improving the
changes of obtaining a return on their Investment.
Action Agent : Department of Commerce
Industry :
• Favorable, but not feasible. Ideally, patent should become
effective with registration since company has nothing it can
sell until that time.
• Favorable, if approach is to obtain full 17 years from
registration. However, 25 years would be excessive and
monopolistic. Further, patent life of less than 10 years
would cause companies to delay registering new products in
order to be sure they have “winners” capable of returning
their investment within that period.
• Favorable, if patent period begins on the date of first
registration for each specific use pattern . Patent life should
be less than 17 years, perhaps 10 years from registration for
each case.
• Favorable, but doubt that Congress will be receptive.
Environmental Associations :
• Favorable, but would never receive Congressional approval.
EPA—OPP :
• Unfavorable; may be barrier to innovation.
• Favorable; but feasibility of changing patent laws is doubtful.
Other Government Agencies :
• Favorable, but not likely to be received well by Congress.
• Favorable, but not feasible to change patent process.
175
-------
EPA Project Staff :
• Favorable; but impact on innovation questioned.
ETIP Project Staff :
• Favorable.
ADL Project Staff :
• Feasibility should be examined further.
176
-------
50. Proprietary Protection for Biological Pest Control and 1PM
Encourage commercial companies to develop biological control and
1PM methods by protecting (either through patents or the product
registration process) R&D efforts and resultant products in the
marketplace.
Goals : Encourage companies to devote R&D efforts to biological controls
by providing assurance that their efforts and resultant products
will be protected in the marketplace.
Action Agents : EPA, Patent Office
Industry :
• Could be favorable; however, this could encourage careless
work as companies would rush to get the first application.
Also, if one company has control for 17 years, innovative
improvements and modifications are discouraged.
• Unfavorable; unpractical; what would be done if another
company developed a more effective member of the same strain
of biological control?
• Unfavorable; biological controls likely will not be success-
ful; if successful, proprietary positions would be difficult
to develop.
• Not feasible. If 1PM patents could be developed, they could
not be enforced and would be useless.
• Unfavorable, because of favoritism to biological controls
and methods over others which are equally safe to people and
the environment.
Environmental Associations :
• Favorable; no reasons given.
EPA-OPP :
• Favorable; although legislative barriers likely to be substantial.
EPA-Other
• There is no real incentive to use (or develop) biocontrols
unless they are effective. In area of agricultural products,
product quality is a major deterrent to use of biological
controls.
• Favorable, but problematic. EPA would have to deal with
licensing, royalty and patent problems.
177
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• Unfavorable; large companies would take advantage of this while
small companies would not. Comparatively small companies
would lose out.
EPA Project Staff :
• Favorable, but Congressional approval unlikely.
ADL Pr j ct Staff :
• The proprietary protection for biological controls should be
further investigated, but 1PM does not lend itself to this
type of protection.
178
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51. Commercialization of Pesticide Products Developed by or For the
Government
Through more liberal policies for selling and exclusive licensing,
facilitate the commercialization by industry of potential products
(primarily biological controls) for which the original R&D was
accomplished by or under contract to the government.
Goals : Encourage industry to pursue potential products, for which the
initial R&D was accomplished by the government.
Action Agents : USDA, EPA, Others
Industry :
• Unfavorable; there is too much dependence on government.
• Favorable and skeptical...”if the government can develop a
product, notify them because they will try to sell it.”
• Favorable, if it does not focus primarily on biological controls.
• Not a significant incentive because it tends to put government
into competition with industry, an unequal and unnatural
relationship in many ways.
• Unfavorable; biological control research that could be patentable,
should not be developed by EPA or other government agencies.
• Favorable, if products sold to the highest bidder.
Environmental Associations :
• Favorable; no reasons given.
EPA—OPP :
• Favorable; removes risk of development from industry.
• Favorable, but effectiveness questionable due to the scarcity
of “significant product ideas.”
• Favorable; this is already done for promising products.
EPA-Other :
• Probably not useful for major pesticides, but good for minor
pesticides.
• This needs further investigation to determine whether there
are enough products developed by the government to warrant
major considerations.
179
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Other Government Agencies :
• Possible, although government likely would be seen as subsidizing
functions traditionally assigned to industry.
• Favorable, but problematic. Government work should remain in
the public domain.
• Unfavorable; would be advantageous to large, but not to small
companies.
EPA Project Staff :
• Incentive value is questionable.
ETIP Project Staff :
• May be impractical. This incentive addresses marginal areas
which are difficult to assess. The status of rights depends
on the product involved.
ADL Project Staff :
• Most of the products developed by the government are not
patentable, and thus would not be affected by this incentive.
180
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52. Aggregation of Public Sector Market Demand
Use of the combined purchasing power of all federal agencies (plus
possibly state agencies) to encourage the development of new pest
control methods.
Goals : Stimulate industry to take risks they would otherwise not take
in development of new pest control methods, through use of the
government market as a guarantee.
Action Agent : Various government agencies.
Industry :
• Unfavorable; could lead to price control.
• Unfavorable, if “new pest control methods” means “biological
contro1s ”
• Acceptable, but will be difficult to implement fairly. EPA
would have power to judge what should be encouraged and
discouraged.
Environmental Associations :
• Favorable; no reasons given.
EPA—OPP :
• Not an incentive. Public agencies do not use the same type
of pesticides used by agriculture.
• Favorable and having Incentive value if the use of pesticides
is great enough.
EPA-Other :
• Favorable; no reasons given.
• Questionable; such market aggregation can encourage graft and
corruption.
Other Government Agencies :
• Potentially workable through GSA, although currently it does
not purchase pesticides for government—wide use. Similar in
concept to purchasing programs used by GSA for other commodities.
• Unfavorable; each pesticide application Is somewhat unique
and the type used should be determined on a case—by—case basis.
181
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ADL Project Staff :
• Feasibility of implementation is questionable because:
1) Coordination of the federal agencies involved would be
difficult;
2) Interaction between the federal and private markets
and supplies would require careful monitoring.
182
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53. Aggregation of Government Markets for Pesticides
Variation of above. Stimulate the development of new pest control
methods by eliminating price from government procurement performance
specifications and by basing specifications solely on criteria such
as efficacy, toxicity, and safety.
Goals : Same as for Incentive #52.
Action Agent : Various government agencies.
Industry :
• Not an incentive as the government does not have enough Impact
in the pesticide market to make any basic difference in pesticide
R&D activity.
• Unfavorable; EPA would like to control the pest control practices
of all government agencies, particularly promoting 1PM. The
needs of the agencies vary considerably.
• Unfavorable; elimination of price from government procedure
leaves the door open for manipulation and arbitrary judgment
regarding efficacy, toxicity and safety.
Environmental Associations :
• Favorable.
EPA—OPP :
• Not an incentive. Public agencies do not use the same type of
pesticides used by agriculture.
• Could be an incentive if combined with Incentive #52.
EPA—Other :
• Favorable; no reasons given.
• Questionable; price should be de—emphasized but not eliminated.
Other Government Agencies :
• Potentially workable through GSA, although currently it does
not purchase pesticides for government—wide use. Similar in
concept to purchasing programs used by GSA for other commodities.
• Unfavorable; price should not be eliminated but only de—
emphasized.
183
-------
ADL Project Staff :
• Incentive value is questionable unless standards and criteria
are not oriented to lowest common denominator, as has been the
tendency when ASTM and similar bodies have set standards for
operation within an industrial sector. Such an orientation
will act to minimize and hinder, rather than promote, innovation.
184
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54. Aggregation of Government Markets for Foodstuffs Grown with
Desirable Pest Control Methods
Stimulate pest control research and development through inclusion
of the pest control methods used during production in the performance
requirements for foodstuffs purchased by federal agencies.
Goals : Stimulate development of new pest control products and methods
through creation of public consumer demand.
Action Agent : EPA, ETIP, DOD, HEW, V.A., AID, other agencies.
Industry :
• Unfavorable; ridiculous and impractical. This is a promotion
f or 1PM which is not sufficiently developed to deliver quality
food to the consumer.
Farm Associations :
• Incentive raises question: should government purchase of
foodstuffs be directed toward those food products using pest
control methods which produce high quality, lower priced foods,
or towards food products suffering greater pest damage, costing
more, and yet having caused less environmental damage?
Environmental Associations :
• Would be difficult to implement
EPA—OPP :
• Unenforceable; almost impossible to assure conformity to
requirements set.
• Unfavorable; complex and unduly discriminatory against
satisfactory chemical pesticides.
EPA—Oth r :
• Favorable but not feasible; too complicated for government
procurement to handle.
Other Government Agencies :
• Not an incentive; government purchases are not sufficiently
large to have significant influence on pesticide R&D activities.
185
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ADL Project Staff :
• Government would not be able to define performance standards
for safe and effective pest control methods. Any definitions
sufficiently agreeable to all agencies concerned would be so
Innocuous as to have little impact on research and development
activities.
186
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55. Influence Pesticide Markets by Education and Food Product Labeling
Foodstuffs Grown with “Safe and Effective Pest Control Methods ”
Influence pesticide markets by increasing the civilian market demand
for foodstuffs grown with certain pest control methods through
education programs and mandatory labeling of foodstuffs.
Goals : Stimulate development of new, safe pest control methods through
creation of demand in private markets, particularly institutional
buyers.
Action Agent : EPA
Industry :
• Unfavorable; the beneficial influence of education cannot be
determined.
• Unfavorable; ridiculous and Impractical.
• Favorable; but conflicts with current EPA philosophy of not
allowing safety claims on labels. Industry has been unsuccess-
ful In the past In gaining USDA and EPA favor for this.
Environmental Associations :
• Favorable; particularly with currently established trend of
public paying more for organic foods.
EPA—OPP :
• Unenforceable; too complex.
• Unfavorable, frequently not practical to isolate foods
produced under certain conditions.
• Favorable; could have tremendous impact as an incentive...
particularly given current public awareness of the possible
effects of residues in foods. However, food itself would have
to be cost competitive.
EPA-Other :
• Favorable, but likely too complicated unless good criteria
established for labeling.
• Not practical; requires too much consumer education.
ADL Project Staff :
• Difficult to define safe and effective; also, would increase
cost of food.
187
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56. Government Performance of Market Analyses
Reduce uncertainties concerning long—term markets for pesticide
products by government analysis of markets, competing products and
processes, and prospective public regulations.
Coals : Reduce market uncertainties for pesticide producers through
market analyses performed by the government.
Action Agent : EPA, USDA, private contractors.
Industry :
• Unfavorable; industry can analyze markets much faster and more
efficiently than can government.
• Unfavorable; government could not do a good job as shown by
EPA ’s economic impact analyses on cancellations, suspensions
and regulations.
• Favorable, depending on implementing agency. USDA or the
Department of Commerce would be acceptable; EPA would not
be acceptable.
Environmental Associations :
• Favorable; particularly would help small companies with market
analysis.
EPA—OPP :
• Not an incentive. Government analysis would be no more accurate
than private Industry analysis of markets...would not help
reduce uncertainties.
• There is a need for EPA to release to the public aggregated
data obtained under Section 7, particularly since the tariff
commission data no longer will be published.
EPA—Other :
• Unfavorable; private sector can do this better than public
sector.
Other Government Agencies :
• Unfavorable; no need for government to do this.
ADL Project Staff :
• Government should not be involved in marketing activities.
188
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57. Subsidies or Price Support for Crops Raised with Desired Pest
Control Products or Methods
Provide direct subsidies or crop price guarantees for private
users of integrated pest management and other innovative and safe
pest control methods.
Goals : Stimulate private users to utilize 1PM and other innovative,
efficacious and safe pest control method.
Action Agent : EPA, USDA
Industry :
• Unfavorable; this amounts to trying to pay farmers to use
less effective pest control methods.
• Unfavorable and impractical; safe cannot be adequately
defined.
Farm Associations :
• Unfavorable; this does not allow for regional variations of
agricultural production of any given crop. Further, “safe
pest control methods” needs further definition.
EPA—OPP :
• Unfavorable; difficult to implement. Criteria, proof,
enforcement systems needed to prevent fraud.
• Favorable; has strong value as an incentive.
EPA—Other :
• Unfavorable; insurance is a better mechanism than subsidy.
• Favorable; would promote non—chemical pest control methods.
Other Government Agencies :
• Unfavorable; subsidies are not practical.
ADL Project Staff :
• The following areas need definition:
1) a system to preva t misuse of subsidies for profit from
farmers,
2) boundaries for selecting pesticides and crops eligible
for subsidies,
3) an appropriate level of subsidy which will be lower in cost
than other control methods used by farmers.
189
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58. Expansion of Extension Service Program
Stimulate user demand for effective and safe products and methods
by use of State Extension agents to assist with the informed
selection and use of pest control methods.
Goals : Stimulate private users to utilize 1PM and other innovative,
efficacious and safe pesticides.
Action Agent : EPA, USDA
Industry :
• Interesting, but impractical.
• Not necessary. Farmers are quite satisfied with services
they are getting now.
• Favorable, if done through USDA with purpose of providing more
and better information to county agents. Incentive influence
would be minor.
• Favorable because this invelves strengthening an existing
organization that has already proven its effectiveness
and usefulness.
Environmental Associations :
• Reform of Extension Service is needed more than expansion.
(No reforms suggested.)
EPA—OPP :
Favorable; should already be in operation via USDA.
EPA—Other :
• Favorable provided such an effort is not too costly. Further,
extension service is already quite effective; hence specific
changes needed should be determined. One suggested change is
an environmental staff person in the service offices.
Other Government Agencies :
• Favorable; using existing mechanism of the Extension Service
is a good idea. Further, current effectiveness of the Service
is in question. Its role and capabilities should be further
defined and augmented.
ADL Project Staff :
• Favorable, if implemented in coordination with current USDA
programs.
190
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59. Increase Foreign Markets for U.S. Pesticide Products and Processes
Initiated by EPA, explore foreign markets for safer and more
effective pest control methods developed in the U.S. Eventually
expand the market for these products.
Goals : Stimulate foreign markets for U.S. pesticide products and processes.
Action Agent : EPA, USDA.
Industry :
• Impractical; foreign governments increasingly have and favor
their own regulations. Further, USDA is already exploring
foreign markets fairly effectively.
• Unfavorable, impractical; 1PM is not competitive here, nor
will it be abroad.
• Favorable, but EPA should not be the administering agency.
Environmental Associations :
• Favorable; should be implemented in conjunction with the
State Department, USAID, the Peace Corps, etc.
EPA—OPP :
• Favorable, but should not be administered by EPA.
• Unfavorable; current industry efforts are sufficient. Further,
EPA should not be involved in marketing.
EPA—Other :
• Unfavorable; 1PM has problems here and these will remain
in exporting.
• Favorable; needs further exploration.
Other Government Agencies :
• Unfavorable; not an incentive for pesticide R&D development.
ADL Project Staff :
• Favorable, if implemented in coordination with current U.S.
programs In foreign countries.
• Unfavorable; EPA should not be involved with marketing activities.
191
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60. Expansion of the Number and Role of Independent Pest Management
Consultants
With USDA or EPA support, increase the number and role of pest
management consultants; also develop total performance pest
management service organizations In order to aid the farmer and
influence pest management practices.
Goals : Aid creation of a new “business,” designed to promote sale of
pest management.
Action Agent : Private industry, EPA.
Industry :
• Favorable, if 1PM is not a required part of the program, and
expense to taxpayers should be minimized.
• Unfavorable, with government agencies such as EPA or USDA
Involved. The private sector will develop the needed quantity
and quality of services. Government support threatens the
independence and Integrity of pesticide salesmen.
• Favorable, if USDA or small business administration, not EPA,
Is administering agency.
Environmental Associations :
• Favorable; no reasons given.
EPA—OPP :
• Favorable, if run by USDA, not EPA.
EPA—Other :
• Favorable if administered by the Small Business Administration,
not EPA or USDA.
• Favorable; role of independent pest management consultants
can be very effective in giving farmers useful information.
Other Government Agencies :
• Unfavorable; the private sector will generate need for pest
management consultants and services. USDA/EPA role should be
one of information transfer, that is letting people know what
Is available.
192
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ADL Project Staff :
Unfavorable because:
1) the independent consultants would be in direct competition
with Extension Service agents and would be more expensive
than Extension Services. it is doubtful that they could
provide sufficiently superior service to convince farmers
to pay the increase.
2) the number of potential products involved is small and
existing industrial marketing and distribution chains are
adequate for current demand.
193
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61. Safety Index
Include safety index on pesticide labels to enable consumers to
compare relative safety characteristics of the available pesticides.
Goals : Allow consumer to determine the relative safety of products.
Action Agent : EPA
Industry :
• Favorable, particularly for household products.
• Unfavorable; there are too many variables, particularly the
difficulty in defining safety. The hierarchy of safety—
related terms which already exists is not recognized or under-
stood by most customers.
• Favorable, only to the extent of supporting use of restricted
and unrestricted on the label as an indication of safety.
• Unfavorable; there is already sufficient information regarding
human and environmental effects on the label.
• Favorable but will be difficult to implement. USDA and EPA
have rejected similar attempts in the past.
Environmental Associations :
• Favorable; labels should be organized around a color scheme
based on toxicity.
EPA—OPP :
• Favorable, even if it does not encourage new products. Although
it may be difficult to agree on criteria, it Is useful to make
the consumer more aware of pesticide problems.
• Favorable; a safety index would be more useful than an
environmental index.
• Unfavorable; criteria for indices are very difficult to define.
Environmental groups likely would present many challenges.
Other Government Agencies :
• Favorable, but difficult to implement.
194
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EPA Project Staff :
• Favorable, if differences between EPA and Industry can be
worked out.
ADL Project Staff :
• Goal is desirable, but implementation mechanism needs to
be examined further.
195
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62. Independent Pesticide Broker
Establish an independent organization to buy and sell information
and data on existing and potential pesticides; rights and licenses
to specific products; and other information on products, uses, and
application.
Goals : Aid individuals and companies in obtaining information (for
use in further development and/or registration) on possible
pesticide products that are of little interest to the original
developer but which may be of significant interest to others.
Action Agent : An independent federally chartered organization.
Industry :
• Favorable; would be useful to formulators. Could be difficult
to implement.
• Unfavorable; not needed.
EPA-OPP :
• Has little incentive value; difficult to implement.
EPA—Other :
Impractical; if implemented, EPA should not be involved.
EPA Project Staff:
• Favorable if mechanism can be developed and if there is enough
demand for a product dropped by companies.
ADL Project Staff :
• Such an organization or service should be initiated by the
private, not the public, sector. Government sponsorship
would have little chance of success because there would be
great reluctance by industry to transmit valuable Information.
196
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63. Collaborative Industrial Efforts
In order to encourage collaborative R&D by companies on new, high—
risk innovative products, eliminate any regulatory or legal barriers
and, if necessary, provide economic incentives for such effort.
oa : Enable industrial organizations to undertake, on a collaborative
basis, R&D on new high—risk innovative products that no single
organization could or would be willing to finance or conduct.
Action Agent : Federal government.
Industry :
• Unfavorable; impractical. Collaborative efforts will occur if
commercial interest exists, whether Incentives are there or
not. Philosophy is against our free—enterprise, competitive
system.
Environmental Associations :
• Favorable; small companies may need this and benefit from it.
EPA—OPP :
• Impractical; companies collaborate to the extent they desire;
going further likely will result in collusion.
VA—Other :
• Ineffective; contrary to free enterprise.
Other Government Agencies :
• Impractical; industry not likely to be interested. This
amounts to splitting profits.
EPA Project Staff :
• Interesting, but has little incentive value.
ETIP Project Staff :
• The more product—related the research, the less acceptable
the Ideal. Has little incentive value.
ADL Project Staff :
• Impractical, unlikely that industry desires to cooperate.
197
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64. A Pesticide Development Award
Establish a prize/award to be given by EPA each year for the
outstanding innovative pesticide development.
Goals : Encourage innovative development by industry.
Action Agent : EPA
Industry :
• Favorable, but unrealistic. Will not help the pesticide
industry as such, but might help people in academia.
• Unfavorable; companies do not need such awards. Their
award Is profit and company freedom. Further, it is likely
to be politically motivated, particularly if EPA selects
the recipient of the award.
Environmental Associations :
• Has little Incentive value for industry.
EPA—OPP :
• Has little incentive value for industry; could provide an
Incentive for individuals. Should not be administered by
EPA.
• Favorable; there should be an award for each major area of
pesticides.
EPA—Other :
• Has little incentive value.
Other Government Agencies :
• Unfeasible; EPA cannot define criteria for such an award.
EPA Project Staff :
• Has little incentive value.
ETIP Project Staff :
• Has little incentive value.
ADL Project Staff :
• Can recognize individual effort, but has little incentive
value for new product development.
198
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CODE : 0 Can’t abide or Nlive with” incentive
1 Unfavorable toward incentive
2 Neutral (or not necessary) toward incentive
3 Agreed with , but not optimistic about, incentive
4 Strongly support incentive
blank No opinion or comment obtained
AGENCY
APPENDIX K
RELATIVE RANKING OF INCENTIVES BY GOVERNMENT AGENCIES AND ASSOCIATIONS
. 2 3 4 5 Ii ce 9 ive 8 Nuin er
10 11 12 13
14 15 16 17
18 19
1.
EPA—OPP —
4
—
—
—
—
—
—
—
2.
EPA —OPP —
—
-
—
—
—
-
—
—
-
-
-
—
—
-
1
1
1
-
3.
EPA—OPP —
—
1
—
1
-
3
—
4
-
4
2
-
—
-
—
-
—
3
4.
EPA—OPP -
—
—
—
—
—
-
—
—
-
—
—
—
—
-
0
0
1
3
5.
EPA—ORB 3
3
3
3
3
3
—
—
4
—
—
3
—
3
—
2
1
1
0
6.
EPA—OfficeofPlan.&Eval. 1
3
—
—
—
1
—
—
3
—
3
—
—
—
—
4
—
4
—
7.
EPA—Agric.Asst.toEPAAdmin. 2
2
—
—
—
2
3
3
4
3
3
1
—
—
8.
Dept. ofCoimnerce 3
3
—
0
0
3
4
0
0
0
0
0
0
4
0
0
0
0
4
l-
9.
U.S. Senate Agric. Comm.—Senate Rvw.—
—
—
—
—
—
-
—
—
-
—
-
—
—
-
2
2
2
2
10.
U.S. House—Agric.Comm. 0
3
—
—
—
0
4
—
4
-
3
—
—
—
-
2
-
1
-
11.
GeneralServicesAdmin. —
—
—
—
—
—
-
—
—
-
—
—
—
-
-
—
-
-
-
12.
OGC —
—
—
—
—
—
1
—
—
—
—
—
—
—
—
—
1
3
3
13.
Amer. FarmfiureauFed. 3
—
—
—
0
3
3
—
—
-
—
1
1
—
—
—
0
—
1
14.
EDF 1
1
1
1
1
2
2
4
0
1
3
—
3
3
3
3
3
1
3
-------
RELATIVE RANKING OF INCENTIVES BY GOVERNMENT AGENCIES AND ASSOCIATIONS
— — — 3
— — 3 —
1 3 — 1
1 1 1 1
— 1 1 —
1 1 3 3
— 3 — —
— — 3 —
3 2 — — — —
— 3 11 0 3
— — 4
3 — — —
1 — — —
3 — 2 2
— 1 3 —
— 3 2 3
o 2 4 3
— — 2 —
— 2 — —
— — 1 —
3 3 3—
AGENCY
Incentive Number
20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36
1. EPA-OPP - -
2. EPA-OPP —
3. EPA-OPP 4 0
4. EPA—OPP 3 0
5. EPA—ORD 2 0
6. EPA—Office of Plan. & Eval. 3 —
7. EPA—Agric. Asst. to EPA Adinin. 4 0
8. Dept. of Counnerce 3 0
9. U.S. Senate Agric. Coimn.—Senate Rvw. 2 —
10. U.S. House—Agric. Comm. 1 —
11. General Services Admin. - —
0
0
0
4
-
—
-
—
4
1
1
—
0
—
—
3
1
1
1
1
4
3
3
—
—
—
4
—
—
—
0
1
2
4
1
0
1
—
4
—
—
—
—
—
—
0
3
0
—
—
—
—
—
—
—
0
—
—
12. OGC
13. Amer. Farm Bureau Fed.
14. EDF
-------
RELATIVE MNKING OF INCENTIVES BY GOVERNMENT AGENCIES AND ASSOCIATIONS
Incentive Number
AGENCY 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51
1. EPA—OPP 3 4 4
2. EPA—OPP
3.EPA—OPP 3— — — — 1 — — — 0 — 0 4 4 3
4.EPA—OPP — - — — — — 0 3 3 —
5.EPA—ORD —3 04 3 3 333 0 330 - 1
6. EPA—OfficeofPlan.&Eval. — 1 4 4 3 0 3 3 1 0 — — 3 3 3
7. EPA—Agrlc. Asst. to EPA Admin. — — — 0 0 0 — — 2
8. Dept.ofCommerce 3 0 4 0 1 2 2 2 0 0 0 0 0 3 3
9. U.S. Senate Agric. Comm.—Senate Rvw. — 1 — — 2 2 2
10. U.S. House—Agric. Comm. 2 1 1 — — 2 0 0
11. General Services Admin. — — — - — — 1 1 1
12.0CC — — — — — — 4 3 3 2
13. Amer. Farm Bureau Fed. — C) C) — 4 1 — — — 0 0 0
14.EDF 4 11 1 1 1 3 3 3 4 3 1 4 4 4
-------
AGENCY
RELATIVE RANKING OF INCENTIVES BY GOVERNMENT AGENCIES AND ASSOCIATIONS
Incentive Number
52 53 54 55 56 57 58 59 60 61 62 63 64
1. EPA-OPP -
2. EPA—OPP — -
3. EPA—OPP — -
4. EPA-OPP - -
5. EPA—ORD 4 4
6. EPA—Office of Plan. & Eval. 1 1
7. EPA—Agric. Asst. to EPA Admin. 1 -
8. Dept. of Commerce 0 1
9. U.S. Senate Agric. Comin.—Senate Rvw. — —
10. U.S. Rouse—Agric. Comm. 4 —
11. General Services Admin. 3 3
12. 0CC
1 1 2 2 3 2 — — 2
3 4 0 1 3 0 3 0 3 02
00—0 4 3 3 4 —40
— — — — 3 — 4 3 — — 3
0 0 0 1 4 0 3 4 013
— — — — 4 — — — — — —
13. Amer. Farm Bureau Fed.
0
t’.)
— — — — — 1 — — — — — ——
— 4 3 3 4 — 3 2 — 4 1 33
14. EDF
-------
APPENDIX L
RELATIVE RANKING OF INCENTIVES BY INDUSTRY
Incentive Number
COMPANY 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19
1 — — — — — — 0— 4 0 0 0 00 0 0 0 0 4
2 0 0 00 00 3 04 0 2 2 2 2 2 3 0 2 3
3 3 3 — 4 — — 32 3— — — — — — 4 4 1 4
4 00 3001 324 10— 02 00004
5 — — — — — — — — 0 — 1 3— — — — — — 4
6 11 1 111 3—42 1 1—4 3 32 33
7 11 1102 24 41 1 012 1 3114
8 — — — — — — — — — — — — — — — 1 1 14
9 11 4111 3— 2— — — — — 1 1 32
10 1 1 3 4 2 1 0 3 4 3 0 0 3 3 4 4 3 0 4
11 —————4 14 4 3 2111 3—— 4
CODE :
O Can’t abide or “live with” incentive
1 Unfavorable toward incentive
2 Neutral (or not necessary) toward incentive
3 Agreed with , but not optimistic about, incentive
4 Strongly support incentive
blank No opinion or comment obtained
-------
RELATIVE RANKING OF INCENTIVES BY INDUSTRY
Incentive Number
COMPANY
1
2
3
4
5
6
7
r’-)
0 8
9
10
11
20 21 22 23 24 25 26 27 28 29 30 31 32
4.0 1 0 1 1 1 1 1 1 1 1 1
4 0 0 0 0 0 00 0 2 0 0 0
4 0 0 3 3 1 00 0 0 3 3 3
4 0 2 2 2 001 0 0 1 0 3
4 0 1 1 1 1 1 1 1 1 1 1 3
4 1 — 3 — — — — — 3 — — —
402 3 3 302 31000
4 1 — — 1 — — — — — — —
3332 2 20—01 31—
40 3 3 3 004 2 4 0 0 2
44—— 0 ————0000
33 34 35 36 37 38 39 40 41 42
1 1 32 2 2 2 0 3 1
003 2 2—— 000
— 1 3 1 — — — 3 3 3
023 2 2 0—0 30
1 1— 2 — — 3 0 1 1
—43 1 2—— 4 40
0 3 3 3 00 10 33
0 1 1 — — — - — 2 —
0 3 3 4 0 0 40 30
0 0 3 — — — — — 3 —
-------
RELATIVE RANKING OF INCENTIVES BY INDUSTRY
Incentive Number
COMPANY 43 44 45 46 47 48 49 50 51 52 3 54 55 56 57 58 59 60 61 62 63 64
1
1
1
1
0
0
—
3
—
—
—
0
0
0
0
—
2
—
—
—
—
—
—
2
1
0
o
o
0
0
4
2
2
2
2
2
2
2
2
3
—
0
2
0
0
2
3
—
4
3
—
0
1
3
—
3
1
—
—
—
—
—
—
—
—
—
—
—
4
4
1
0
0
0
0
0
4
2
3
0
0
0
2
0
0
2
2
2
2
0
0
0
5
—
—
—
o
o
o
4
1
—
o
—
—
—
—
—
3
2
0
—
0
0
6
0
0
0
2
2
2
3
2
1
—
—
—
—
—
—
—
—
2
3
—
3
—
7
3
3
1
0
0
0
4
1
0
1
0
1
0
0
0
1
0
1
0
1
1
0
8
—
—
—
—
—
—
3
1
-
—
—
—
—
—
—
—
—
-
—
-
—
-
9
—
—
2
—
—
—
—
3
—
—
—
—
0
—
—
—
—
—
—
—
—
—
10
3
4
4
0
0
0
4
0
2
2
0
0
3
3
0
3
3
3
4
—
0
3
11
—
—
—
0
0
0
4
3
4
1
1
—
—
—
—
—
—
3
1
—
—
—
0
,Jl
-------
APPENDIX M
AVERAGE RANKINGS OF INCENTIVES*
Incentive No. Industry Government and
Associations
1 1.0 1.9
2 1.0 2.6
3 2.0 1.7
4 1.6 1.3
5 0.7 1.0
6 1.0 2.0
7 2.3 2.9
8 2.0 2.3
9 3.3 2,9
10 1.6 1.3
11 1.0 2.4
12 0.8 1.3
13 1.4 1.7
14 2.0 3.3
15 1.6 1.5
16 2.2 1.6
17 1.3 1.1
18 1.2 1.5
19 3.6 2.7
20 3.9 2.9
21 0.8 0.7
22 1.4 1.0
23 1.9 1.7
24 1.7 1.8
25 1.9 2.2
26 0.3 1.0
27 1.3 2.0
28 0.9 2.3
29 1.3 2.0
30 1.9 2.0
31 0.7 2.0
32 1.3 2.8
33 0.3 2.0
34 1.5 2.2
35 2.8 2.4
36 2.1 3.0
37 1.3 3.3
38 0.5 1.5
39 2.5 2.2
40 0.9 2.2
*
Obtained by dividing the sum of relative rankings by the number of
responses in each category.
207
-------
Incentive No. Industry Government and
Associations
41 2.5 2.0
42 1.0 1.3
43 1.5 2.8
44 1.7 2.8
45 1.4 1.8
46 0.3 0.9
47 0.2 1.6
48 0.4 1.2
49 3.6 2.1
50 1.8 2.7
51 2.1 2.3
52 1.0 2.2
53 0.5 2.6
54 0.6 1.4
55 1.2 1.6
56 1.0 1.5
57 0.5 1.0
58 2.3 3.4
59 1.8 1.4
60 2.0 3.3
61 1.7 3.0
62 0.3 1.5
63 0.7 2.0
64 1.5 2.2
208
-------
APPENDIX N
INCENTIVE SUGGESTIONS FROM INDUSTRY, GOVERNMENT,
AND ASSOCIATION STAFF CONTACTED DURING REVIEW OF
“ INTERIM WORKING DOCUMENT ”
Incentives
1. Facilitate better communication between industry and EPA, through
a vehicle such as the Research Directors Committee of the National
Agricultural Chemical Association
2. Decrease power of the office of General Counsel to override
scientific rationale
3. Implement a statutory time limit for EPA’s response concerning
the temporary registration
4. Create a new registration category for materials that present
no threat to human safety and may be used on minor crops at the
risk of the applicator
5. Waive the liability, including listing on the label, for minor
crops listed under IR—4
6. Allow companies to advertise safety by creating a “safe” category
and/or by removing the caution from category 4 products
7. Apply USDA or EPA research resources to safer, innovative pesticides,
not restricted to minor crops and including efficacy testing
8. Implement “self registration” whereby the manufacturer certifies
that the product complies with stated specifications
9. Legislate time limits for decision making by EPA
10. Eliminate government involvement in the search for and development
and marketing of pest control products
11. EPA publicize need for benefits and advantages of chemical pest
control rather than maintain a consistently critical and negative
view of pesticides
12. EPA develop guidelines, establishing reasonable parameters for
pesticide development
13. Institute crop grouping for purpose of establishing residue
tolerances
14. Expedite issuance of experimental use permits
209
-------
15. Allow inclusion of IR—4 crops in registration requiring minimal
corporate investment
16. Establish negligible (rather than finite) residue tolerances
17. EPA allow for greater use of data waiver in registration
procedures
18. Shorten EPA time for product data review, through data waiver,
for example
19. Extend patent protection, by beginning it at time of use
approval
20. Develop different review protocols for “safer” chemicals
21. Increase manpower for and competency of EPA staff engaged in
review
22. EPA provide accurate estimate of time of review completion
23. Involve panel of reviewers in specific section of review, e.g.,
toxicology
24. Enable informal discussion between company and reviewer concerning
disputed conclusions
25. Complete application as additional requested data becomes available,
rather than dropping application to bottom of review list
26. Sell or license product to USDA for minor crop registration
27. Create a National Pesticide Training Center
28. Expedite use permits for critical areas of need
29. Government support work on protocols and test methods for
registration
30. Implement provisional registration or changes in the experimental
permit system to facilitate data collection
31. Eliminate tolerance fee
210
-------
Suggestions :
1. Reasonable and well thought out regulations taking into account
industry’s data, views, and experience
2. Development of an honest, objective risk—benefit approach
reflecting more than the views of EPA
3. Abolish concept of 100% safety
4. In designing incentives, find a balance between short—range
benefits and short—range costs as a strategy for gaining
Congressional approval.
5. Extend risk protection to the end user but not the pesticide
producer.
6. Develop a prac tica1 rather than academic approach to data review
by EPA
7. Provide motivation for lower—level EPA staff to work toward “real
progress.”
8. Inform EPA staff of the “realities” of the pesticide business
211
-------
APPENDIX 0
THE APPROPRIATENESS OF INCENTIVES IN ALTERNATIVE FUTURES
1. BASIS FOR ANALYSIS
En 1974, the Center for the Study of Social Policy of Stanford
Research Institute (SRI) was awarded a contract by EPA to develop a
series of scenarios of alternative futures and recommendations for the
use of the alternative futures method in the EPA planning process.’
Ten scenarios were developed, each representing a plausible alternative
future for the coming 25 years. The scenarios were developed not in an
attempt to predict the future, but to use as a basis for contingency
planning by EPA and to place some bounds of the uncertainty in the
future. The scenarios are described by several “driving trends” and
their variation over time——energy and its growth rate, climate, personal
and social values, and food price and availability. The scenarios
cover variations on three major themes:
• Industrial success with no major value or institutional
changes from the present
• Industrial distress resulting in social, economic and
political anxiety and instability
• Industrial transformation exemplified by the adoption
of “frugal” values, involvement of more people in self—
sustaining activities, and development of new social
and economic institutions.
After developing these scenarios and exploring their basis and
variations, SRI staff presented and tested a methodology that could
be used to systematically explore the policy implications of these
future scenarios for EPA. The method consisted of presenting policy
issues in such a way that they could be answered by a “more/less” or
“increase/decrease” response. The acceptance or effect of the policy
issues at some time in the future considered with respect to any
scenario could then be compared to the understanding of present
attitudes or perceptions of effect. Following this approach, a cross
scenario analysis could be made for each issue, or all issues could be
examined with relation to specific scenarios. The method allows
examination of a number of issues over time in a variety of plausible
future scenarios.
‘ Alternative Futures for Environmental Policy Planning: 1975—2000 ,
Stanford Research Institute, D.S. Elgin, D.C. MacMichael, P. Schwartz,
EPA—540/9—75—027, October 1975.
213
-------
With the guidance of the EPA project officer (who had also been
project officer for the SRI work) we experimented with the use of the
SRI developed methodology to examine the potential acceptance and
impact of five incentive actions——lengthen patent life, fund basic
research, advertise safety, encourage 1PM, and improve the registration
process——and the EPA/ETIP project over the time frame 1980—2000,
considering the prevailing conditions and three scenarios taken from
the SRI work. The questions were posed: “Will acceptability of the
incentive within the subset of society that includes pesticide R&D
and production industries, EPA, Congress and the user community be
greater or less than at present?” “Would the EPA/ETIP project on
incentives and its objectives have more/less acceptance (or impact )
than at present?” The three scenarios we considered are described
briefly in Figures 0—1, 0—2, and 0-3. These three most clearly
exemplify the themes mentioned above. Other scenarios display these
themes in a less extreme fashion and could have been chosen. However,
we felt the clarity of these three was useful for our experiment.
Although these figures are self—explanatory, we have presented the
definitions of these driving values taken from the SRI report in
Table 0—1 to assist in their interpretation.
In an all—day meeting, six ADL and one EPA staff member considered
these Incentives and developed a consensus on the acceptance and impact.
(In preparation for the meeting, each participant had read the incentive
actions, the SRI report, the scenarios, and the methodology.) There
was only modest disagreement during the discussion, and a consensus was
reached on most issues. Table 0—2 summarizes the process.
The group assigned a symbol to represent its judgment on each of
the questions. The symbols used and arbitrary scoring numbers assigned,
were:
Substantial increase ++ + 2
Moderate increase + + 1
No change from present 0
Moderate decrease + — 1
Substantial decrease — 2
Split with society +1+ 0
Reversal between time
periods *
B. RESULTS
Table 0-3 displays the results of this process when the accept-
ability of the incentives was examined. Table 0—4 does the same for
the impact of the incentives, and Table 0-5 shows the results for
the program objectives. An asterisk was used to denote when a
214
-------
FIGURE 0—1
“ SUCCESS” SCENARIO
SCENARIO 1
“HITTING THE JACKPOT’
Summary
Basically, this is the Kahnian future. Science produced the answers; nature was kind; wise corporate business leadership
acted responsibly; government stayed out of the way. The present time of troubles was merely a temporary aberration
on the long term multi—fold trend line. The general, increasing, end more widely extended level of prosperity during the
25-year period placed no excessive strain on the environment: the prosperity of th. period enabled the repair of whatever
minor damage was done. By 2000 the highly complex and interdependent world economic system demanded a form
of world government, and this same system increasingly demanded and established world rules for regulation of
the environment.
100
z
2 Achievement IN0I (lDUAL VALUES
AND
— — Survival
0 LIFE STYLE
Frugal
‘.. ‘ ,- ———.
CS •,
.S••I •.• .. sI•• •C• . .S• S • • • • •• S S • • • . •‘‘ • S 5
0 I
1975 1980 1990 2000
ENERGY
1980
1990
2000
continued
high growth
continued
high growth
continued
high growth
CLI MATE
favorable
favorable
favorable
FOOD
moderate price,
no shortage
moderat. price,
no shortage
moderate price,
no shortage
‘Th. values/life style graph Is not meant to be a precise description of popUI•tiofl in each hf. style/values group;
rather It Is only Intended to be Illustrative of the changing pattern of life-styli. and values.
215
-------
FIGURE 0-2
“ TRANSFOR1 tATION” SCENARIO
SCENARIO 4
“JOURNEY TO TRANSCENDENCE”
This scenario is the story of evolution and transformation. The old, growth-dependent order slowly eroded as it faced the
limitations of a finite earth. From the late 1970’s to the early 1990’s the leadership doggedly persisted in trying to make
the “American Dream” work but with diminishing success. A new order, guided by a more humane image of men, slowly
emerged in the midst of the decay of the old. With ever increasing success its adherents learned how to translate its aspira-
tions into practical realities. At the turn of the century the visible success of this new frugal sector had drawn most of the
remnants of the old order to its side.
ENERGY
1980
1990
2000
controlled
growth
controlled
growth
zero or
declining
growth
CLIMATE
variable
variable
variable
F OOD
high price,
no shortage
high price,
shortage
high price,
no shortage
Summary
100
z
0
QL
w
o>
I-
9w
I —u-
0 -
ow
-J
w
0
1975
1980 1990 2000
216
-------
FIGURE 0—3
“ DISTRESS” SCENARIO
SCENARIO 8
“THE DARK AT THE TOP OF THE STAIRS”
In the late 1970’s, efforts to control the demand for energy brought on a decade-long recession. By 1990, people
learned to live with reduced levels of energy consumption. However, this was accomplished through the gradual withering
of the industrial state and the slow, grudging acceptance of more frugal life styles. In the 90’s the climate turned for
the worse, pushing energy consumption up and the standard of living even lower. The end of the century marked the
free market industrial world with near exhaustion, economic stasis and pessimism but with social peace, enforced by
authoritarian regimes. Socialist industrial countries, better prepared by experience for these conditions, were little better
off, but did not share the sense of trauma and defeat. Third world Countries were left to their own resources and displayed
a variety of social and economic conditions. Some were materially better off. Others, especially Latin American and
African dependencies of the industrial nations, simply relapsed into primitive conditions in which cities became
Calcuttas and the countryside reverted to primitive agriculture.
ENERGY
1980
1990
2000
controlled
growth
controlled
growth
continued
high growth
CLIMATE
variable
variable
- worsening
FOOD
high price,
no shortage
high price,
shortage
high price,
shortage
Summary
100
0
—e
I-. a.
-Jo
Q-uJ
u -- i
o
°uJ
o.
uJ
Lu>
>z
-J
Lu
0
1975
1980 1990 2000
217
-------
TABLE 0-].
DEFINITIONS OF DRIVING TRENDS
Energy (E)
Continued high growth : the historical trend of high growth
(rate = 4%) in energy consumption is continued.
Controlled growth : the growth rate in energy consumption is
controlled by design and slowed (rate . 1—3%).
Unsuccessful high growth : the continued high growth in energy
consumption is disrupted by severe supply problems and a
rapid net decline is experienced.
Zero or declining growth : the growth rate in energy consumption
is leveled out (rate . 0— —1%).
Climate (C)
Variable climate : from year to year the climate is relatively
unpredictable, swinging from good to bad. In some years
the weather conditions for agriculture are generally favor-
able. In others drought, untimely rain, or shortened grow-
ing seasons are experienced.
Favorable climate : the trend from 1890—1960 of generally constant,
good, and predictable weather Is resumed. From year to year
the weather pattern aids expanding agricultural production.
Worsening : the trend from 1960—1970 of cooler weather and shifting
hence unpredictable weather, is continued. In most years
droughts, untimely rain, shortened growing season, or other
weather—related calamity is common.
Values (V)
Achievement values : this sector of the population emphasizes
material things——status, fame, affluence, and outward achieve-
ment——on the personal level; and growth, bigness, competition
on the system level. Other descriptions of values congruent
with this sector include: mechanistic, materialistic,
individualistic, secular, centralized, scientific, empirical.
Survival values : this sector embraces the values of the achieve-
ment sector as described above; however, the material circum-
stances are such that these values cannot be readily realized.
The consequences are frustration, dogged endurance, emphasis
upon security and survival aspects of achievement values, etc.
218
-------
TABLE 0-1 Continued
Frugal values : emphasis in this group is upon voluntary simpli-
fication of the exterior aspects of life in order to attain
greater richness of inner aspects. Coupled with the fore-
going are two other dominant values: a self—realization
ethic which asserts that each person’s proper goal is the
evolutionary development of his fullest human potential;
and an ecological ethic which asserts that the Earth is
limited, recognizes the underlying unity of the human race,
and perceives man as an integral part of the natural environ-
ment.
Survival/frugal split : this is a values pattern which emerges
when the dominant achievement sector is substantially
reduced to a small minority by adverse economic circumstances
and leaves two divergent modes of responding; importantly,
the nature of the response of these two groups is often
nearly identical but the motivation (premised upon values)
is often quite different; e.g., survival folks would consume
less gasoline because they were forced to by high prices;
frugal folks would consume less because they were forced to
and because they wanted to consume less, given their values
orientation.
Trimodal split (achievement, survival, frugal) : this values
grouping assumes that there is no single dominant values
sector in society; rather, the values are split among the
three groups.
Achievement/frugal split : the values are split predominantly
among the two groups along the values dimensions as character-
ized for each above.
Achievement/survival split : the values are split predominantly
between these two groupings along the dimensions described
for them above.
Food (F)
High prices for food/no food shortage : a number of forces can
combine to create a “high” price without a food shortage;
e.g., higher energy prices, a moderate degree of adverse
climatological change, export of food to enhance balance of
payments, more food demanded due to population growth
domestically and/or abroad, greater proportion of indirect
consumption of protein, greater proportion of food consumed
with technological input——so—called “convenience foods,”
and so on.
219
-------
Table 0—1 Continued
Moderate food price/no shortage : this condition assumes that the
supply and demand factors discussed above do not Individually
or collectively “conspire” to create high prices and/or shortages.
High food price/food shortage : this assumes that some combination
of adverse circumstances——domestic and/or International——creates
a condition where there is both high food prices and chronic
food shortages.
220
-------
TABLE 0—2
SCENARIO! INCENTIVE EVALUATION PROCESS
Incentives
• Fund Basic Research
• Advertise Safety (on label)
• Improve the Registration Process
• Encourage Integrated Peat Management (1PM)
• Extended Patent Life
Examine via these questions:
• Will the acceptability of the incentive within the subset
of society that includes the pesticide R&D and production
industries, EPA and USDA, Congress and the user community
be greater or less than at present?
• Will the impact of the incentive be greater or less than
at present?
Overall Objective:
• Operate a program of incentives to promote innovation in
pest control
Sub—Objectives:
• Alleviate barriers to innovation caused by regulatory
problems, and
• Promote safer biologically integrated pest controls
Examine via this question:
• Will the objectives be seen to be more or less appropriate
and acceptable by society as a whole than at present?
221
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TABLE 0-3
ACCEPTABILITY OF INCENTIVE. ACTIONS IN ALTERNATIVE
FUTURE SCENARIOS, RELATIVE TO PRESENT
ALTERNATIVE FUTURES:
SUCCESS TRANSFORNATION DISTRESS
INCENTIVES: Direction Scores Sum _ Direction Scores Sum Direction Scores Sum
Fund Basic Research 1980 + +1 + —l —1
1990 + +1 +4 + —l —2 4’ —1 —3
2000 ++ +2 0 4’ —l
Advertise Safety 1980
on Label
1990
2000
0
4’ —l —2
+ —l
±± 0
0 +1
+ +1
0
‘ 0 0
0
Improve Registration 1980
Process
1990
2000
+ +1
+ +1 +3
+ +1
÷-“ 0
.
+ +1 +3
‘r ” F +2
+ +1
*+ +1 —1
+ —1
Encourage 1PM 1980
1990
2000
-- -b - 0
0 +1
+1 ,
+
+ —l
*
‘F +1 —2
++ +2
‘ ‘ -1
+ —l -3
4’ —1
Lengthen Patent Life 1980
1990
2000
‘F +1
+ +1 +3
‘F +1
- - - - U
, —1 —2
4, —1
+ —1 —2
4, —1
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TAELE 0 -4
IMPACT OF INCENTIVE ACTIONS IN ALTERNATIVE
FUTURE SCEI’ ARIOS, RELATIVE TO PRESENT
ALTERNATIVE FUTURES:
SUCCESS TRANSFORNATION DISTRESS
Direction Scores Sum Direction Scores Sum Direction Scores Sum
Fund Basic Research 1980
1990
2000
0
- 0 0
0
—1
—1 —2
0
+ —l
—1 —4
—2
Advertise Safety 1980
on Label
1990
2000
0
0 0
0
0
+ +1 +2
+1
—1
—l —3
—1
Improve Registration 1980
Process
1990
2000
+ +1
+ +1 +3
+ +1
- - - +1
+ +1 +4
+ +1
—
—1
—1 —4
+4 —2
Encourage 1PM 1980
1990
2000
0
- --÷ 0 0
0
0
+ +1
+1
—-——
o
o o
+-÷ o
+ -i
4 —1 —3
—1
).
Lengthen Patent Life 1980
1990
2000
o
+-÷ o o
- -- - o
÷-÷ o
0 0
- --* o
INCENTIVES:
c )
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TABLE 0—5
ACCEPTABILITY AND APPROPRIATENESS OF OBJECTIVES IN
ALTERNATIVE FUTURE SCENARIOS, RELATIVE TO PRESENT
ALTERNATIVE FUTURES:
SUCCESS
Direction Scores
TRANSFORMATION
Sum Direction Scores
DISTRESS
Sum Direction Scores Sum
OBJECTIVES:
Overall 1980
1990
2000
—l
—l —4
—2
+1
—1 —1
—l
+ +1
*
-— - 0 —1
—2
Alleviate Regulatory 1980
Problems
1990
2000
0
+2 +4
++ +2
+ +1
* 0 0
—l
+ +1
*
÷ 4 - 0 0
4- —l
Safer Biologically 1980
Integrated Controls
1990
2000
0
0 0
0
0
+ +1
++ +2
+ —l
* 0 0
+ +1
-------
reversal between two time periods was indicated. The patterns shown
in these tables were examined for insights into the viability of the
incentives program and the incentive actions in these alternative
futures. To supplement this information we included the results of
SRI’s analysis of some of the policy issues examined in this work.
See Table 0—6.
The acceptability of incentives between scenarios and in different
time periods was examined. It was found that in none of the three
scenarios does any incentive move in a consistent direction in all
periods. Only in two cases (Safety on the Label, 1980; Improve Regis-
tration, 1990) were trends of acceptability consistent. This lack of
consistency indicates that it is not possible to find a policy of in-
centive actions that is appropriate for all eventualities. Thus there
is some risk no matter what course EPA chooses, although this risk can
be reduced somewhat by watching carefully for signs that society is
taking one path to the future or another. The findings for each of
the five incentives examined and the EPA/ETIP program are as follows:
( 1) Provide Funds for Basic Research :
Basic research is not well accepted except in an industrialized
and technologically successful society. This incentive has the longest
lead time before results are evident. It has conflicting acceptability
among scenarios in each of the time periods (the only incentive having
that extreme form of conflict). Furthermore, in the transformation and
distress scenarios, the probable impacts are weaker than at present.
Thus, an investment by society in basic research for pest controls is
somewhat fragile, if there 18 some possibility that the future will
have elements of the distress or transformation scenarios. If the
investment is not made soon, it may not be made at all, and the longer
the delay, the less promising the payoff from the research.
( 2) Advertise Safety :
Advertising of safety is more or less acceptable across all sce-
narios, that is, enough of the population apparently desires it in
almost any scenario to make it worthwhile. The impact under the trans-
formation scenarios is equal to or greater than now, possibly because
individual styles and decisions are more important. The impact in a
distress scenario is low since the incentive does not lead to solution
of a major problem.
( 3) Improve the Regulatory Process :
This incentive shows greater acceptability In the future than now
across all scenarios, but for different reasons. In the success
scenario, the desire (and demand) is to help industry and technology
play its part more effectively. In a transformation scenario,
assuming federal regulations exist in the year 2000, improving the
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TABLE 0-6
POLICY ISSUES FROM SRI ANALYSIS
ALTERNATIVE FUTURES:
POLICY ISSUES:
SUCCESS
Direction Score Sum
TRANSFORMATION
Direction Si-ore Sum
DISTRESS
Direction Score-Stun
4. Conditions Provide 1980
Incentives for Innovation
1990
2000
t +1
+ +1 +3
+ +1
4. —1
* 0 0
+ +1
+ +1
—1 —l
4. —1
5. Demand EnvIronmentally 1980
Sound Pest Control
1990
2000
0
0 0
-f--’ - 0
4 - —l
4. * —l 0
++ +2
+ +1
f/f* 0
+ —1
7. Environmental Quality 1980
Over Economic Ends
1990
2000
+ —1
+ —1 —3
+ —1
—l
+/4- * 0 0
+1
+1
+/4 .* 0 0
—l
13. Acceptance of Flexible 1980
Policy Stance 1990
2000
4- +1
+ +1 +3
+ +1
+ +1
+ +1 +3
+ +1
+1
. +1 +3
+ +1
-------
registration process will serve small industry and agriculture more
than others. In a distress scenario, improvements in the registration
process are intended to help solve some of the existing problems, but
as the social and political climate degrades, and faith is lost in
existing institutions, there may be no need to pursue regulations.
There is a reversal in the attitudes toward acceptance of the incentive
over time. The impact of this incentive is at least as good as at
present in the success or transformation scenarios, but there is little
hope for success in the distress scenario.
( 4) Encourage 1PM :
In both a highly successful industrial scenario, and a scenario
of industrial, political and social distress, 1PM most likely will
not be received enthusiastically. Similarly, the impacts will not be
great. Industry might perceive 1PM as a new field in pest control, or
a portion of the market. not yet under control and thus devote efforts
to its pursuit. On the other hand, new technology may make 1PM less
necessary. The greater promise of acceptance and impact of 1PM is in
the more individualistic society, where the individuals who were trans-
formed to exhibit the frugal nature of man can see the advantages of
1PM.
( 5) Lengthen Patent Life :
Only in a highly industrialized society will lengthening the patent
be accepted to a greater degree than now. The effectiveness is expected
to be small, In any case.
( 6) EPA/ETIP Program on Incentives
We find that the acceptance of such a program is probably greatest
now, under the conditions which presently exist. We attribute this to
the assumption that more of society believes we still have time and
methods available to solve problems of pest control cost/benefits. The
split of values today is such that achievers, frugals and survivors,
can see the benefits from an incentive program, and thus can support it
even though their goals may differ considerably. In the absence of
great food, energy, political or social crises, the public will support
government programs to Improve the efficiency of government, help
industry meet some of its needs, and solve some public problems.
If a highly successful technical/industrial society evolves,
either the problems of pest control will be solved or those who are
not part of the mainstream society will have neither the desire nor
power to change the system via an incentives program.
In a society which involves transition to frugal values, there
will be less of a demand for a program which seeks to continue
industrial development of new pest control approaches. In early
227
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years of this transition, a program of incentives aimed at meeting
needs of individuals might be accepted, but as these needs change and
as society changes with them, both the government structure which can
create incentives as veil as the benefits to be gained from such
incentives will be of little importance and usefulness.
Incentive programs might be useful in scenarios in which
institutional degradation and social distress are evident and could
help overcome such trends. However, if external variables are strong
enough to drive the society further toward the brink of social and
economic disaster, incentive programs can be of no value——much more
important survival and political issues will consume the energies
of the public.
The individual objectives of the EPA/ETIP program may have some-
what different public acceptance than the concept of the incentive
program itself. For example, alleviating the problems of regulation
will be highly acceptable in a technological/industrial society, but
it is doubtful that in such a society pesticide regulations which pose
significant problems for industry would exist. Assistance in the
development of safer, biologically integrated products can have
greater acceptance and impact in the transformation scenario than
in other scenarios.
In general, an incentive program will have less importance, less
acceptance and less impact if technology is readily available to meet
the problems of pesticide use. Where major societal changes take place
rapidly, long—term programs——e.g., incentives for R&D of new pesticides
which cannot be expected to give results for at least ten years——will
have less acceptance than at present.
( 7) General Results and Conclusiotis
In addition to analyzing’ the impact of an individual incentive
under different scenarios, we also examined the effect of all the
incentives in a particular scenario. The success scenario showed no
reversals of acceptability or impact of incentives, and the program
objectives and related SRI issues also displayed no reversals. The
transformation and distress scenarios, however, which reflect substantial
shifts in economic and social conditions and public attitudes, indicate
reversals in the acceptability of the program objectives and in some
public attitudes important to pest control innovation. This indicates
that in a success scenario any initial movement in the acceptability
of an incentive action will be a good predictor of its acceptability in
the long term (to the year 2000). However, the context of public
attitudes that affect environmental and innovation issues could shift
severely over the next 24 years if prevailing conditions are significantly
different from the industrial success scenario. That would make future
decisions about particular incentives more difficult and less certain.
228
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A subjective ranking of the acceptability of the five incentives
examined places them in the following order at present: changes to
the registration process, advertising of safety on the label, funding
basic research, promotion of 1PM, and lengthening patent life. Likely
shifts in that ordering were examined in the three time periods in the
three scenarios. It was found that no substantial changes in the
ordering could be expected; that no incentive would be likely to shift
in this ordering by more than one place up or down. Further, the
incentive with the most acceptability now (changes in the registration
process) would never be moved out of its position of primacy.
The 1PM incentive, the program objective dealing with the promotion
of biologically—integrated controls, and the policy issue dealing
with the demand for environmentally sound pest control move in comple-
mentary and parallel ways in the success and transformation futures.
In the distress scenario, however, the public attitudes toward the
program objective and the policy issue shift in opposite directions,
and are at odds with the consistent diminished acceptability of the
1PM incentive action.
Some light is shed on this apparent anomaly when the issue dealing
with conditions providing incentives for innovation is compared with
the acceptability of the overall program objective. In the success
and transformation scenarios, these move in appropriately complementary
directions. That is, when conditions are conducive to innovation,
the public’s perceived need for the incentive program is less, and
vice versa. But in the distress scenario, with all its confusion and
breakdown of social and economic systems, society’s needs, capabilities
and resolves tould be seriously out of synchronization. Thus, in this
scenario, conditions become less and less conducive to innovation in
pest control, and the same conditions cause society to become less
willing or able to undertake incentive actions to compensate. So, if
the future resembles the disarray of the distress scenario, rationality
and order in government planning decisions may be subordinated to
the exigencies of the moment.
229
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TECHNICAL REPORT DATA
(Please read Isstructions on the reverse before completing)
1. REPORT NO. 12.
EPA—540/9177/0O9
3. RECIPIENT’S ACCESSIOI*NO.
4. TITLE AND SUBTITLE
IN NTIVES FOR RESEARCH AND DEVELOPMENT IN PEST
CONTROL VOLUME II APPENDIcES
5. REPORT DATE
DECEMEER 1976
6. PERFORMING ORGANIZATION CODE
7.AUTHOR(S)WECHSLER, HARRISON, BURG, GIBBONS, PE1 PiX,
TERI .,
8.PERFORMINGORGANIZATIONREPORTNO.
78167
9. PERFORMING ORGANIZATION NAME AND ADDRESS
ARTHUR D. LITTLE, INC.
Cambridge, Massachusetts 02140
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
68—01—3133
12. SPONSORING AGENCY NAME AND ADDRESS
Office of Pesticide Programs
Strategic Studies Unit
u.s. Environmental Protection Agency
Washington, D.C. 20460
13. TYPE OF REPORT AND PERIOD COVERED
Final
14. SPONSORING AGENCY CODE
EPA/500/01
16. SUPPLEMENTARY NOTES
Project Officer: Frederick Talcott, Phone 202-755—0958;
16. ABSTRACT This program identified, developed, and evaluated incentives
(externally applied influences) that the federal government can offer
to reduce barr ers to innovation and thereby encourage the continued
development of pest control methods by industry. The history of pest
control innovation was analyze, end influencea on current decision—
making concerninq industrial pesticide R&D were studied to provide
background for the development of incentives. Then, 64 preliminary
incentive ideas were devised and evaluated in accordance with a
conceptual framework. These incentives were screened and ranked
according to their feasibility, the acceptance by parties involved
in their implementation, and their potential contrThution to
realizing tne objectives of this program. Nine particularly
promising incentive areas were developed further and evaluated i r a
several possible future scenarios. Recoanended incentives included
specific actions designed to dectease regulatory hindrances to R&D,
reduce the risk of product development by industry, increase the
availability of minor use pesticides, lengthen patent life,
advertise safety on the product label, increase utilization of
Integrated Pest Management, and increase information and training
for pesticide users. The insights and cosaents of representatives of
the pesticide industry and government staff concerned with pesticide
development and regulation were sought at several stages in the
development of incentives.
17. KEY WORDS AND DOCUMENT ANALYSIS
a. DESCRIPTORS
b.IDENTIFIERS/OPEN ENDED TERMS
— Crop groupings
Minor Use pesticides
integrated pest management
na,gulatory hindrances
Alternative futures
Enterpreneuxial risk
Preduct tasting
information and training
product labeling
R&D incentives
19. SECURITY CLASS (ThisReport ,j
Unclassified
C. COSATI FieLd/Group
Regulation
iviroxunent
Pesticides
Research
Patents
Toxicology
06/F 06/J
14/F 05/C
07/A 02/B
18. DISTRIBUTION STATEMENT
Release Unlimited
21. NO. OF PAGES
235
20. SECURITY CLASS (This page)
Unclassified
22. PRICE
EPA Form 2220.1 (9.73)
230
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